S. R-RG. 100-598
RESTART OF THE PILGRIM I
NUCLEAR POWERPLANT
HEARING
BEFORE THE
COMMITTEE ON
LABOR AND HUMAN RESOURCES
UNITED STATES SENATE
ONE HUNDREDTH CONGRESS
SECOND SESSION
ON
EXAMINING THE PROPOSED RESTART OF THE PLYMOUTH, MA, NUCLE-
AR POWERPLANT, AND THE POTENTIAL IMPLICATIONS FOR THE
PUBLIC HEALTH AND SAFETY IN THE SURROUNDING COMMUNITIES
JANUARY 7, 1988— PLYMOUTH, MA
Printed for the use of the Committee on Labor and Human Resources
S. Hrg. 100-598
RESTART OF THE PILGRIM I
' NUCLEAR POWERPLANT
HEARING
BEFORE THE
COMMITTEE ON
LABOK AND HUMAN EESOUKCES
UNITED STATES SENATE
ONE HUNDREDTH CONGRESS
SECOND SESSION
ON
EXAMINING THE PROPOSED RESTART OF THE PLYMOUTH, MA, NUCLE-
AR POWERPLANT, AND THE POTENTIAL IMPLICATIONS FOR THE
PUBLIC HEALTH AND SAFETY IN THE SURROUNDING COMMUNITIES
JANUARY 7, 1988— PLYMOUTH, MA
Printed for the use of the Committee on Labor and Human Resources
U.S. GOVERNMENT PRINTING OFFICE
83-478 WASHINGTON : 1988
For sale by the Superintendent of Documents, Congressional Sales Office
U.S. Government Printing Office, Washington, DC 20402
COMMITTEE ON LABOR AND HUMAN RESOURCES
EDWARD M. KENNEDY, Massachusetts, Chairman
CLAIBORNE PELL, Rhode Island ORRIN G. HATCH, Utah
HOWARD M. METZENBAUM, Ohio ROBERT T. STAFFORD, Vermont
SPARK M. MATSUNAGA, Hawaii DAN QUAYLE, Indiana
CHRISTOPHER J. DODD, Connecticut STROM THURMOND, South Carolina
PAUL SIMON, Illinois LOWELL P. WEICKER, Jr., Connecticut
TOM HARKIN, Iowa THAD COCHRAN, Mississippi
BROCK ADAMS, Washington GORDON J. HUMPHREY, New Hampshire
BARBARA A. MIKULSKI, Maryland
Thomas M. Roluns, Staff Director and Chief Counsel
Kevin S. McGuiness, Minority Staff Director and Chief Counsel
(n)
CONTENTS
STATEMENTS
Thursday, January 7, 1988, Plymouth, MA
Page
Agnes, Peter, Assistant Secretary of Public Safety; Sharon Pollard, Secretary
of State of Energy; and Deborah Prothrow-Stith, Health Commissioner 434
Prepared statements of:
Mr. Agnes 437
Dr. Prothrow-Stith 447
Alexander, Lawrence, State Representative; Peter Forman, State Representa-
tive; David Malaguti, chairman of the Pljmiouth Board of Selectmen; and
Rachel Shimshak, Massachusetts Public Interest Research Group 97
Prepared statements of:
Mr. Alexander 100
Mr. Forman 10*7
Ms. Shimshak 123
Bosen, Theodore, Anti-Nuclear Board member, prepared statement 861
Boston Edison Co., prepared statement 780
Cobb, Dr. Sidney, prepared statement (with attachments) 827
Golden, William, State Senator, Norfolk, Plymouth District; Grace Healy,
chairperson of Plymouth Committee on Nuclear Matters; Mary Ott, co-
chairperson of Citizens Urging Responsible Energy; Neil Johnson, chairper-
son of the Duxbury Citizens Committee on Nuclear Matters; Ann Waitkus-
Amold, chairperson of the Disabled Persons Advisory Group on Nuclear
Evacuation for the State Office on Handicap Affairs, and William Abbott,
president of the Plymouth County Nuclear Information Committee, Inc 3
Prepared statements of:
Mr. Golden 4
Mr. Abbott 16
Ms. Waitkus-Arnold 25
Mr. Johnson 33
Ms. Ott (with attachments) 40
Dr. Healy (with attachments) 55
Kerry, Hon. John F., prepared statement (with an attachment) 458
Kirby, Hon. Edward P., State Senator, Second Plymouth District, Common-
wealth of Massachusetts, prepared statement 855
Krimm, Richard, Assistant Associate Director of FEMA; Dr. Thomas Murley,
Director of the NCR's Office of Nuclear Reactor Regulations; William Rus-
sell, NCR's Regional Administrator, Region I; and Jack Doland, FEMA
Region 1 531
Prepared statements of:
Mr. Krimm (with an attachment) 533
Mr. Murley 600
Kugelmann, Eileen, director, Mass Safe Energy Alliance (SEA): Cape Cod,
prepared statement 853
Murphy, Lt. Gov. Eveljm 322
Prepared statement 325
Shannon, Attorney General James 332
Prepared statement 335
Studds, Hon. Gerry E., prepared statement 456
Theriault, Judy, prepared statement 854
(HI)
Articles, publications, etc.:
The Pilgrim Generating Facility at Plymouth, Report of the Joint Special
Committee established for the purpose of making an investigation and Page
study, excerpts from, July 1987 128
MASSPRIG— Blueprint for Chaos II: Pilgrim Disaster Plans Still a Disas-
ter 162
No Exit— The MASSPIRG Survey of Pilgrim Evacuation Planning, Sep-
tember 1987 244
Nuclear Lemon — Rateplayer Savings from Retiring the Pilgrim Nuclear
Powerplant, November 1987 281
Petition of Michael S. Dukakis, Governor and James S. Shannon, Attor-
ney General for the institution of proceeding pursuant to 10 C.F.R. Sec.
2.202 to modify, suspend, or revoke the operating license held by the
Boston Edison Co. for the Pilgrim Nuclear Station, dated: October 15,
1987 341
Review of the status of the Mark I BWR Liner Melt-Through Issue, by
G.A. Greene, Brookhaven National Laboratory Experimental Modeling
Group, Upton, NY 552
The Potential Adverse Health Effects of the Plymouth Nuclear Power
Facility, by Belton Burrows, M.D., and Donald Muirheadm, Jr., M.D 846
Communications to:
Wyngaarden, Dr. James B., Director, National Institutes of Hegdth, from
Senator Edward M. Kennedy, January 7, 1987 92
Kennedy, Hon. Edward M., U.S. Senate, from James B. Wyngaarden,
M.D., Director, National Institutes of Health, January 28, 1987 94
Zech, Hon. Lando, Chedrman, Nuclear Regulatory Commission, from
David P. Malaguiti, chairman, Board of Selectmen, September 2, 1987 ... 116
Hurley, Thomas S., Director, Office of Nuclear Reactor Regulation, Wash-
ington, DC, from David F. Malaguti, chairman. Board of Selectmen,
November 6, 1987 118
Questions and answers:
Response of Mr. Krimm to questions submitted by Senator Kennedy 777
Response of Mr. Murley to questions submitted by Senator Kennedy 617
RESTART OF THE PILGRIM I NUCLEAR POWER-
PLANT
THURSDAY, JANUARY 7, 1988
U.S. Senate,
Committee on Labor and Human Resources,
Plymouth, MA.
The committee met at 7 p.m., at the Carver Regional High
School, Plymouth, MA, Senator Edward M. Kennedy (chairman of
the committee) presiding.
OPENING STATEMENT OF SENATOR KENNEDY
The Chairman. We'll come to order. We have a very full pro-
gram this evening and this is an extremely important hearing.
We're going to insist on order. We very much appreciate all the
courtesies that have been provided by the townspeople here in
Plymouth. We want to thank Mr. Simon, the superintendent of
schools, for making the facility possible.
As I mentioned, we have a full agenda, a number of panels. We
want to make sure that the views of all of our witnesses are given
adequate consideration, so we're going to insist that the hearing
move along. In a situation like this, we are always caught in a
time-bind between giving people an opportunity to speak and re-
ducing the amount of time that people have, but that is the nature
of many of these hearings, particularly those hearings that we
have out in the field.
We will ask all of the witnesses on the panels to limit their state-
ments to three minutes. If they have additional comments, they
can make those statements a part of the record.
I would expect in a hearing like this that anyone who is going to
appear before this committee ought to be able to summarize their
views since we are looking at expert testimony.
We will try and conclude this hearing around 9:30 or quarter of
10. If it looks like we're going later then that, we'll take a brief
break part way into the hearing, in a couple of hours.
I'll make a brief opening statement, and then we'll move on to
the first panel of witnesses.
We're going to insist that all of our witnesses be sworn in during
the course of these hearings. We are going to insist on order and
we're going to desist from any exclamations of approval or disap-
proval. We're going to maintain the decorum of a committee of the
United States Senate.
The Committee on Labor and Human Resources is here to look
into the proposed restart of the Plymouth Nuclear Power Plant,
(1)
and its potential implications for the public health and safety in
the surrounding communities. This committee has had a long in-
volvement in oversight of nuclear powerplant safety and its effects
on public health. In 1979, the committee held hearings on the acci-
dent at Three Mile Island, and a year ago, we investigated the acci-
dent at Chernobyl in the Soviet Union.
Since the dawn of nuclear power, we have learned a great deal
about its potential — and about its awesome possibilities for destruc-
tion. We know more today about the health effects of radiation ex-
posure, but many unanswered questions remain. And there is one
fact of which we are certain, radiation if unleashed can cause un-
paralleled injury and devastation. The world learned that lesson
again from the tragedy at Chernobyl where 31 people lost their
lives and thousands more will die of leukemia and other radiation
related diseases.
We know that nuclear plant accidents not only can happen, but
do happen. In fact, the Nuclear Regulatory Commission estimates
that in the next 20 years, there is a substantial chance for a core
meltdown in a U.S. powerplant.
In view of these serious implications, the NRC should be evaluat-
ing more effective ways to improve public safety. Regrettably, the
opposite has been true. In recent years, the Commission has weak-
ened its efforts to protect the public. And the experience of Plym-
outh is a case in point.
Plymouth's history is replete with cases of mismanagement,
equipment failure and regulatory violations. In May 1986, NRC of-
ficials identified it as one of the least safe plants in the country. It
has been involved in a number of enforcement actions, and in Jan-
uary 1982, it was subjected to one of the largest NRC tines in histo-
ry, totaling $550,000.
Plymouth has also received excessive "minimum satisfactory"
ratings by the NRC in its periodic assessment reports. The plant
relies on a containment structure that many experts agree is likely
to rupture in the event of high pressure buildup.
Finally, and perhaps more important, both the Commonwealth of
Massachusetts and the Federal Emergency Management Agency
have concluded that residents living near the plant do not have an
adequate evacuation plan in the event of a radiation emergency.
Yet despite these serious ongoing problems, the Commission is con-
tinuing with the process for restarting the plant.
Residents and State officials have repeatedly called on the
Agency for meaningful participation in the restart decisions. Their
petitions have fallen on deaf ears. The NRC has consistently reject-
ed requests to hold a hearing. To some extent this hearing is in-
tended to fill that gap.
Our concerns are not limited to people residing within the 10
mile emergency planning zone, but for residents of Cape Cod and
in the South Shore area as a whole. Residents fear that they will
not be safely evacuated in the case of a nuclear accident, and their
fear is compounded because the plant's record is unsatisfactory.
Through this hearing, the committee will obtain a better under-
standing of how the Commission makes its restart decision and
how it evaluates recommendations for the public, from the State
and from FEMA. I look forward to hearing from the witnesses.
Our first panel of witnesses this evening is comprised of resi-
dents of this area, Plymouth and Duxbury, which could be most di-
rectly affected by a restart of the Pilgrim plant. They have done a
tremendous amount of work on the subject, and they are the most
vivid proof of the democratic process in action. So I welcome them
here tonight. I would like them to come to the witness table and
we'll all hear their presentations.
They will be introduced to us by State Senator William Golden,
who will also be testifying before us later this evening.
STATEMENTS OF WILLIAM GOLDEN, STATE SENATOR, NORFOLK,
PLYMOUTH DISTRICT; GRACE HEALY, CHAIRPERSON OF PLYM-
OUTH COMMITTEE ON NUCLEAR MATTERS; MARY OTT, CO-
CHAIRPERSON OF CITIZENS URGING RESPONSIBLE ENERGY;
NEIL JOHNSON, CHAIRPERSON OF THE DUXBURY CITIZENS
COMMITTEE ON NUCLEAR MATTERS; ANN WAITKUS-ARNOLD,
CHAIRPERSON OF THE DISABLED PERSONS ADVISORY GROUP
ON NUCLEAR EVACUATION FOR THE STATE OFFICE ON HANDI-
CAP AFFAIRS, AND WILLIAM ABBOTT, PRESIDENT OF THE
PLYMOUTH COUNTY NUCLEAR INFORMATION COMMITTEE,
INC.
Mr. Golden. Good evening, Mr. Chairman. For the record, my
name is State Senator William Golden from the Norfolk, Plymouth
District.
It is my pleasure tonight to welcome you and to thank you for
beginning tonight a process which the Nuclear Regulatory Commis-
sion of the United States has denied the people of America and the
citizens of America's hometown, Plymouth, and that is the opportu-
nity to participate in the process of determining the future of the
nuclear power plant here in Plymouth.
The witnesses on this panel before you this evening, Mr. Chair-
man, will be Grace Healy, the chairperson of Plymouth Committee
on Nuclear Matters; Mary Ott, cochairperson of Citizens Urging
Responsible Energy; Neil Johnson, chairperson of the Duxbury
Citizens Committee on Nuclear Matters; Ann Waitkus-Arnold,
chairperson of the Disabled Persons Advisory Group on Nuclear
Evacuations for the State Office on Handicap Affairs, and William
Abbott, president of the Plymouth County Nuclear Information
Committee, Inc.
[The prepared statement of Mr. Golden follows:]
TESTIMGtJY OF MASSACHUSETTS STATE SENATOR WILLIAM B. GOLDEN
BEFORE THE SENATE COMMITTEE ON LABOR AND HUMAN RESOURCES,
JANUARY 6, 1988.
Mr. Chairman,
I want to thank you and the members of this committee for
the opportunity to testify before you this evening. I believe
that the Piglrim Nuclear Power Station should be closed for
reasons of safety, reliability and economics. There is
overwhelming evidence that it is one of the worst-managed
nuclear plants in the country. Its containment vessel has been
proven to be defective. No emergency plans exist to adequately
protect the public in the event of a serious accident at the
plant. Evidence also has been mounting of serious security and
radiological control problems at the plant and a recent study
has demonstrated that it would be less expensive to shut the
plant down than to allow it start up again.
Yet, no level of government has acted decisively to shut
this plant down. Under the Atomic Energy Act, states have
almost no power regarding the safety of nuclear power plants.
Federal authority - which is embodied in the Nuclear Regulatory
Commission - has a virtual monopoly regarding the operation of
nuclear plants. Unfortunately, the Nuclear Regulatory
Commission has failed to distinguish between plants that are
safe and those that are not. Rather than providing a fair and
open forum for resolution o"f nuclear safety concerns, as well
Page 2
TESTIMONY
as a mechanism for closing unsafe plants, the NRC has chosen to
be an advocate for the nuclear industry. Despite all of the
well-documented problems at Pilgrim, the NRC has chosen to keep
the plant licensed.
In July of 1986 I filed a petition with the NRC
requesting a formal hearing on the suspension or revocation of
Pilgrim's license to operate. Both the governor and the
attorney general have since filed similar show-cause petitions
with the NRC requesting hearings on the Pilgrim license. The
NRC's failure to consider fully and fairly these petitions has
convinced us that we cannot rely on the NRC to protect the
public from the dangers presented by the Pilgrim nuclear power
plant .
We urgently and respectfully request that you join our
efforts by using the power of this committee to demand that the
NRC hold formal hearings so that Boston Edison may demonstrate
why It should be allowed to operate a plant that is unsafe,
unrealiable and uneconomical.
A year and a half ago, I testified at length before the
Congressional Sub-Committee on Energy, Conservation and Power
in Washington, D.C., on the problems at Pilgrim.
Unfortunately, very little has changed since that hearing, and
the problems that I discussed in that testimony have not been
resolved. Accordingly, I would like to submit that testimony
again to your committee. A copy of it is attached.
/
6
T«.8timonv of Maaaachuaetta State Senator Willlaa fl. Golden befoyi*
the Conaresaional Sub-Comaittee on Energy. Conaervatlon and
Power. July 16. 1986,
Mr. Chairauin:
I vajit to thank you ajid the membera of the conunlttee for
giving me the opportunity to appear before you today. Shortly
alter World Nar II. the federal government Initiated a bold
national policy to develop the peaceful use of nuclear energy.
Today, many aspects of this policy have failed. These failures
imperil the health, safety and welfare of milliona of Americana
and steund in the way ot the development of a safe amd secure
energy luture. it 13 critical that we appreciate what these
policy failures have meant.
The nuclear industry has not achieved uniform standards of
excellence. :iome plants have state-of-the-art technology. Some
are well -managed. Some are appropriately located in areas away
from population centers. Some are etficient, coat-effective
producers of electricity. A few — those run by the military- -have
adequate security.
However, many others were poorly designed and now have
outdated equipment. They are located in areas that are densely
populated or are vulnerable because of their geography. Some
plants are poorly managed. Some no longer make economic sense.
Nearly all civiliam reactors have inadequate protection from new
and more sophisticated security threats.
The federal government, which has the central responsibility
lor nuclear safety, has tailed to understand local conditions and
concerns. It has not made suilicient distinction between good
and bad nuclear plants.
Boston Edison s Pilgrim Nuclear Power Station--located in
America' s home town, Plymouth, Massachusetts--ha3 come to
symbolize the failure of this policy. The problems of this plant
fall in five broad categories: management, technology, emergency
planning, security and economics.
Pilgrim has long suffered from poor management. In 1982,
the Nuclear Regulatory Commission levied what was then the
largest civil penalty in the agency's history against Boston
Edison for management and safety problems. The NRC's SALP
reports, or overall performance reviews, for 1981, 1982 and 1985
gave Boston Edison the lowest possible rating for plcunt
operations. The most recent ;5ALP report, issued this February,
cited the company ror poor starting, supervision, procedures and
self -assessment. A special NRC inspection report issued on April
2, again pointed out stalling and organizational deficiencies.
In May, the NRC commissioners told this committee that Pilgrim is
one of the worst-run and least-safe plants in the country. In
June, the Massachusetts Department of Public Utilities issued a
sweeping criticism of Boston Edison' s overall management,
concluding that the company had all but abdicated its
responsibility for planning.
These reports and disclosures have destroyed public
confidence in Boston Edison s aUility to manage Pilgrim safely.
They are sufficient cause for the NRC to hold public hearings on
8
whether this utility should be allowed to continue to run the
plant. The NRC has refused to take this step, and because or
this refusal, the public is rapidly losing confidence in the
NRCs ability to regulate Pilgrim.
1 urge this committee to use its influence to persuade the
NRC to hold hearings on the possible suspension, revocation or
transfer of Boston Edison s license to operate Pilgrim.
The adequacy of Pilgrim s containment structure is another
matter of serious concern. Pilgrim is a 19603 model General
Electric boiling water reactor with a Marie 1 containment vessel.
The NRCs chief safety official, Harold Denton, recently stated
that there is a 90 percent probaiJillty of failure of a Mark I
vessel in the event of a core meltdown. This level of risk is
intolerable. The NRC should demand that Pilgrim's containment be
upgraded to the highest standards the industry can provide.
The NRC can no longer persist in ignoring important design
distinctions among nuclear plants. It is time to determine
whether it is more economical to upgrade the Mark I system or to
close plants with Mark I containment permanently.
No issue so plainly illustrates the failure ot national
nuclear policy as emergency preparedness. ITie public might be
more inclined to accept the pronouncements or the experts on the
highly technical issues surrounding nuclear power if the
emergency plans for nuclear plants were not so patently
inadequate.
The 10-mile emergency preparedness zone, which the NRC
requires of all nuclear facilities, may make sense tor a plant
located m the middle oi a western desert. But it is clearly
inappropriate for densely populated urban and suburban areas of
the Northeast.
A serious accident at Pilgrim would have effects far beyond
the 10-mile zone. Flans should be developed to deal with an
emergency at Pilgrim that would affect Boston, which is 40 miles
away, or Cape Cod, which is only 12 miles from the plant.
Boston Edison, the NRC, and the Federal Emergency Management
Agency have assigned a low priority to emergency planning. The
Pilgrim plan has never received formal approval from FEMA or the
NRC. FEMA did not even receive a copy of the most recent Pilgrim
plan until ten months after it was prepared.
Neither the utility nor the federal government has dealt
with the cost or adequate emergency planning. In an actual
emergency, the crucial links in tne chain or command are unpaid,
minimally trained local civil defense directors. For any plan to
work, professional civil defense departments with adequate staffs
and equipment must be in place.
In this age of global terrorism, political extremism and
individual fanaticism, it is imperative that security be upgraded
at Pilgrim and all other nuclear plants. Official NRC
regulations call for strict security at nuclear plants. However,
this official policy has not been effectively implemented by the
nuclear industry or the NRC.
In an attempt to lull the public into a comfortable feeling
about nuclear power, the Atomic Industrial Forum- -a nuclear
industry organization- -suggested last week that nuclear power
10
plants are ideal summer tourist attractions. ITiis attitude is
irresponsible and dangerous. :3ecurlty interests require that the
public be kept as rar away as possible from nuclear plants.
The NRC has tailed to realize that the eif ectiveness of its
elcLborate security regulations is no better than the individuals
who carry them out. At Pilgrim this taslc falls to individuals
who are recruited through classified ads in the local weekly
newspaper stating, "We are looking for those individuals with a
career as a nuclear security officer in mind and would like to
earn $11,000 to $18,000. .. You must be at least 19 years old and
must bring with you copies oi birth certificate, drivers license,
high school diploma or G.E.D. certificate." Security at nuclear
plants demands higher standards.
At Pilgrim, security problems are compounded by reports or
alcohol and drug abuse, horseplay m sensitive parts of the plant
and continuing labor -management strife.
This committee should seriously consider having the United
;itates military or the Department of Defense police provide
direct security for Pilgrim and all other nuclear plants.
Nuclear facilities are not tourist attractions. They are
sensitive installations which in the wrong hands could expose
civillem populations to catastrophic dsmgers.
Finally, national nuclear policy has failed because the
federal government has lost sight of the policy's prime
objective — cheap energy. A chairman of the Atomic Energy
Commission once stated that nuclear power would give us
electricity "too cheap to meter." This clearly has proven false.
11
Today, we need to re-examine ail of the old assumptions
surrounding the economics ol nuclear power.
A cost-benefit analysis of Pilgrim has not been conducted
since the plant went on line 15 years ago. Pilgrim and other
existing plants are becoming increasingly expensive to run, as
the costs or maintenance and safety improvements escalate. The
public IS demanding better security, management and safety at
nuclear plants. These measures will cost money. The economics
of all nuclear plants should be subjected to thorough reviews.
These reviews also should talce into account items that are
undervalued on company balance sheets or may not show up at all.
The public has subsidized nuclear power by limiting utility
liability for accidents through the Price Anderson Act. Civil
defense planning and government regulation are other costs to the
public of nuclear power. The future costs of decommissioning and
waste disposal are still unlcnown.
_I urge this committee to press for the suspension of
Pilgrim 3 license until the following actions are tatcen;
1) The NRC holds public hearings on whether Boston Edison is
qualiiied to manage the plant.
2) The reconstruction or replacement of the existing
containment vessel so that Pilgrim has a state-of-the-art
containment system.
3) The creation of a 4u-mile emergency planning zone and the
development of a new civil defense program, which would be funded
by Boston Edison and would be capable of responding to a serious
accident at Pilgrim.
12
4) Ttie lOfmatlOn of a military or Deiense Department police
security iorce I'or Pilgrim and all other nuclear racilities.
5) The completion ot an economic C03t/benetit analysis ot
Pilgrim.
Three Mile island and Chernobyl have changed forever the way
Americans think about nuclear power. The test of our national
nuclear energy policy no longer lies in a comlortable consensus
between the utility industry and the NRC. To survive, nuclear
power must prove itself not just in the nation' s capital but in
Plymouth, Massachusetts, and other home towns throughout America.
It is time for the rederal government to stop listening only to
experts and technocrats and to start listening to the American
people. No policy will succeed until public coniidence is
restored in the technology and in the ability of governemnt to
manage it in the public interest.
13
The Chairman. Well, thank you very much, Senator Golden. We
will ask all of you if you would be kind enough to stand.
[Witnesses sworn.]
The Chairman. We'll start with Mr. Abbott.
Mr. Abbott. Mr. Chairman, thank you for the opportunity to tes-
tify before your committee. You have asked here tonight what will
be the impact upon the health and safety of the communities sur-
rounding the Pilgrim I plant should it be allowed to start up in the
next few months.
Others here tonight will address the issue of protection against a
catastrophic accident and emergency planning. I would like to
focus my brief comments and recommendations on the subject of
radiation emissions for Pilgrim I and their control and their moni-
toring, or as is usually the case, the lack thereof by the NRC.
Over a year ago, I testified before two Massachusetts legislative
committees advocating the funding of an effective monitoring
system by the State of Massachusetts to do what the NRC does not
perform. Legislation was introduced, but it died a few days ago in
the final hours of the 1987 legislative session; thus we must still
rely on the NRC to police the operations of Pilgrim I; a reliance,
which based on past experience, certainly gives me and the resi-
dents of this area little comfort.
Pilgrim I has had a history of continued unplanned radiation re-
leases, which are among the highest in the nation. Again and
again, we see reports of radiation releases in the files; we must dili-
gently dig through unpublicized NRC reports to see that there is
this recurrent public health menace.
Now, Senator, given the reports of substantially higher than av-
erage incidents of cancer in Plymouth and towns downwind of the
plant, the do-nothing approach by the State of Massachusetts and
by the NRC can no longer be tolerated. To date, our efforts have
been singularly unsuccessful in getting the NRC to do anything
about this. They have failed miserably over the years, both in dis-
charging their public protection function, and equally as impor-
tant, in giving the public any comforting perception that it is ful-
filling this function.
Operating from a distance, whether it be King of Prussia, PA, or
Washington, the NRC's typical involvement is to become activated
after receiving a report from Edison; dispatch a team to the site;
listen to Edison's explanation, and then generally endorse and
ratify Edison's report with the usual conclusion, without any fur-
ther investigation, that the public health was not, in fact, impacted
by the incident.
Massachusetts, likewise, has effectively failed to monitor the
plant. We, through a Federal court suit years ago, got the Depart-
ment of Public Health to install dosimeters in Plymouth and sur-
rounding towns to monitor the release of radiation.
Unfortunately, the carrying out of this function has been proven
nearly worthless since the devices are only read quarterly; results
are hidden from public view, and even worse, Mr. Chairman, no at-
tempt is made to correlate the reading of these devices with known
accidents at the plant which could lead to off-site releases, despite
Edison's predictable, self-serving statements that all releases are
contained within the site perimeter.
14
Let me illustrate this fundamental failure with one example to
show you that the responsible authorities are not protecting the
citizens of the South Shore. We researched this ourselves.
In June 1982, Edison sent a detailed report to the NRC regional
office explaining that highly radioactive resin beads and particu-
late matter, which had accumulated over an extended period of
time, were found to have been accidently injected into the ventila-
tion system and from there to the outside of the building. This ma-
terial was discovered on the roofs of several of the buildings and on
the grounds of the Pilgrim I plant site.
The Region I NRC office dispatched a team to the site and found
that this material had been probably released through the vent
duct which exhausts to the atmosphere at an elevation of about 100
feet. Ten cubic feet of this highly radioactive resin was found in
the standby gas treatment system inlet plenum. This is the source
of releases of radioactive materials to the atmosphere.
Now, despite the very serious potential of this accident for off-
site contamination and the carrying away of radioactive dust by
the winds, no effort was made to read the off-site TLDS — there are
three separate sets of these maintained by the NRC, Boston Edison
and the State of Massachusetts — no efforts were made to correlate
those readings with this observed accident. Nobody bothered to
read them to see if Edison's statement made at the time — that no
radiation escaped off-site — was, in fact, true.
Now, this failure was probably due to the fact that the readings
did not become available — they are only read quarterly — until sev-
eral weeks after the particular release.
We did check the readings, and the results were highly signifi-
cant. For instance, in the summer of 1982, all TLD locations as
measured by Edison, the NRC and the State showed a large rise
and then declined by the same percentage, indicating a consistent
pattern. Likewise, the dose-rate decreased with distance away from
the plant as one would expect from a point source. The zone closest
to the plant showing the largest dose-rate.
The Chairman. What do those kinds of increases mean in practi-
cal terms, in terms of the health hazard for the population?
Mr. Abbott. Senator, they are substantially in excess of back-
ground radiation, and I think that anytime you add to the back-
ground radiation more radiation from the Pilgrim nuclear plant,
you are adding to the health hazard of the people of the area.
We have asked the State of Massachusetts to hold hearings to set
new levels of radiation standards, emission standards. This is one
of the problems we have with the NRC, that the standards that
they have are not consistent with current scientific evidence. But
the key here is that although the statement was made that nothing
escaped, clearly radiation did escape. Out as far as 20 miles toward
the northwest, all locations showed an increase of radiation. The
existing background dose-rates were nearly tripled in the third
quarter of 1982.
About a year ago, I discussed this at a meeting with NRC at a
public forum. They told me that they had not read the — the gentle-
man that was there was on the NRC team that inspected the plant
after that accident — had not read the TLD data. He said some four
years after the incident he thought the TLD data was "worth
15
checking." The State Department of Public Health did not do much
better.
The Chairman. I'll give you another minute.
Mr. Abbott. The remedy to this failure is starkly obvious. Either
the NRC or the State or both should gear up with the necessary
manpower and equipment to monitor the day-to-day operations at
Pilgrim I, including all planned and unplanned releases of radi-
ation on a regular, continuous basis, not this haphazard hit-or-miss
system that we have now. Monitoring equipment should be read on
a real-time, continuous basis up to at least 20 miles from the plant,
and the results made public so we don't have to search for them.
Until that is in place. Senator, I say the plant should not be al-
lowed to re-open.
The people of the South Shore deserve to know what they are
being exposed to. It is of fundamental importance to our mental
well-being and physical health that this system be in place. We ask
the support of your committee to insure that the NRC not give its
approval to Pilgrim restart, unless and until an effective real-time,
continuous radiation monitoring system has been fully implement-
ed. Thank you.
[The prepared statement of Mr. Abbott follows:]
16
statement of William S. Abbott
President, Plymouth County Nuclear Information Committee,
before Senate Committee on Labor and Human Resources,
on January 7, 1988
Thank you for the opportunity to testify before your Committee,
You have asked here today what would be the impact upon the health
and safety of the surrounding communities from the operation of
Pilgrim I should it be allowed to start up by the NRC in the next
few months. Others here today have addressed or will address the
issues of protection against a catastrophic accident and emergency
planning. I would like to focus my comments and recommendations
on the subject of radiation emissions from Pilgrim I and their
control and their monitoring (or as is more usually the case, the
lack thereof) by the NRC. Over a year ago I testified before two
separate Massachusetts legislative committees advocating the
instituting and funding of an effective monitoring system by the
State of Massachusetts to be sure the citizenry is protected from
the operations of Pilgrim I. Legislation was introduced, but this
week it died in the final hours of the 1987 legislative session.
Thus, until such legislation is once again introduced and enacted,
we must rely on the NRC to police the operations of Pilgrim I - a
reliance which based upon past experience certainly gives me,
and I presume many others, little comfort-
Pilgrim I has had a history of continued unplanned
radiation releases which are among the highest in the nation.
Again and again we see reports (such as the 1986 SALP report) of
unplanned radiation releases; only with diligent digging in the
morass of NRC unpubliciSed reports do we see the true extent of
17
this recurrent publ ic health menace. Now, given the reports
of substantially higher than avera<3e incidences of cancer in
Plymouth and towns downwind of the plant, the do-nothing approach
by the State of Massachusetts and by the NRC can no longer be
tolerated.
This history of Pilgrim I for the past 15 years has been
one of citizen groups digging through the voluminous microfilm and
technical reports, most usually in the Public Document Room in the
Plymouth Public Library, to find the obscure reports of the releases
of radiation by Pilgrim I into the Plymouth environs — and then
trying to get the NRC and the State Department of Public Health
to do something about it. To date our efforts have been singularly
unsuccessful. The NRC has failed miserably over the years — both
in discharging its public protection function, at least as regards
Pilgrim I, and in giving the public any comforting perception that
it is fulfilling this function. Operating from a distance, whether
it be King of Prussia, Pennsylvania or Washington, D.C., the NRC's
typical involvement is to become activated after receiving a report
from Boston Edison, then to dispatch a team to the site, listen to
Edison's explanation, and then generally endorse and ratify Edison's
report — with the usual conclusion, without any further investigation,
that the public health was not adversely impacted by the incident.
The State of Massachusetts likewise has failed over the
years to effectively monitor the plant's operations. And it is
not for lack of trying on our part that the State is not performing
this function. Several years ago as a result of federal court
litigation involving Pilgrim I brought by Plymouth County
Nuclear Infromation Committee, the State Department of Public
18
Health installed several thermoluminescent dosimeters ("TLD'S") in
Plymouth and surrounding towns, supposedly to monitor the release
of gamma radiation from Pilgrim I. Unfortunately, the carrying
out of this function has proven to be nearly worthless since the
devices are only read on a quarterly basis and the results are
virtually hidden from public view — and even worse, no attempt is
made to correlate the readings of these devices with known abnormal
occurrences at the plant which could lead to offsite releases
despite Edison's predictable self-serving statements that all
radiation releases are contained within the site perimeter.
Let me illustrate this fundamental failure of the
responsible authorities to protect the citizens of the South Shore
by a case in point which I researched myself. In June 1982, Edison
sent a detailed report to the NRC Region I office explaining that
highly radioactive resin beads and particulate matter, that had
accumulated over an extended period of time, was found t'o have
been accidently injected into the duct-work of the ventillation
system, and from there to the outside of the building. This
radioactive material was discovered on the roofs of several of the
Pilgrim I buildings and on the ground. The NRC Region I office
dispatched a team to the site which found that the resin had been
probably released through the reactor building vent-duct which
exhausts to the atmosphere at an elevation of approximately 100
feet. Ten cubic feet of this highly radioactive resin was found
in the Standby Gas Treatment System inlet plenum (the source of
releases to the atmosphere). Despite the very serious nature
19
of this accident and the potential for oCEsite contamination and
the carrying away of radioactive dust by the winds, no effort was
made to read the off site TLD's (separate sets of TLD's are
maintained by the NRC and Boston Edison, in addition to the TLD's
maintained by the State), and correlate such readings with the
observed accident at the plant. Neither the NRC nor the State
ever bothered to read their TLD's to see if Edison's typically
pollyannish statement that no radiation escapted off site was in
fact true. This failure was no doubt partly due to the fact that
^he TLD readings do not become available, given the current
practice of reading them quarterly, until several weeks after any
particular release. I did check the readings and the results are
highly significant. For instance, in the summer of 1982, all TLD
locations, as measured by Edison, the NRC, and the State, showed a
large rise and then declined by about the same percentage,
indicating a consistent pattern. Likewise, the dose-rate
decreased with distance away from the plant, as one would expect
from a point-source, the zone closest to the plant (0-0.16 miles)
showing the largest dose-rate, thereby confirming that the accidental
escape of highly radioactive wastes reported to the NRC did in
fact lead to offsite contamination. At all locations as far away
as 21 miles to the northwest, the existing background radiation
dose-rates were nearly tripled in the third quarter of 1982.
Despite the potential health effects of this release of radiation,
a member of the NRC inspection team who had visited the plant
after this release told me in the summer of 1986 that his team
had not road the TLD data, and that then, some four years after
the incident, he thought that these readings might be "worth
20
checking". And as for the State Department of Public Health,
suffice it to say that it took me many long hours of digging
and prodding to even get the State data out of the offices of
the State employee who collected it -- just as with the NRC no
attempt whatsoever had been made by the Department of Public
Health to correlate this data with the accident.
This incident and the lack of follow-up by the responsible
monitoring authorities illustrates the failure of the system
as it exists today to protect adequately the public health of
the citizenry from the operation of Pilgrim I in what has become
the fastest growing area of our State. The remedy for this failure
is starkly obvious: Either the NRC or the State, or both should
gear up, with the necessary manpower and equipment, to monitor
the day-to-day operations of Pilgrim I, including all planned
and unplanned releases of radiation off-site, on a regular continuous
basis -- a complete system of radiation detection devices should
be installed off-site at various distances from the Plant, and
read constantly and continuously -- and the results made public.
Such a system, if properly designed and implemented, could add
measurably to the public's confidence that its safety and health
were being duly considered and protected.
And there is even more that the State can do -- the
State of Massachusetts has the legal power to set its own level
of maximum permissible airborne radioactive emissions from Pilgrim
I. Under Section 122 of the Clean Air Act Amendments of 1977,
Congress specifically provided that the States have the legal
authority to set emission standards at levels which are more
21
stringent than standards imposed by the NRC or the EPA. And
tho NRC itself has recognized that the setting of such standards
by a State might even prevent the construction of nuclear plants
or halt the operation of existing facilities.
Meanwhile, the NRC continues to rely upon standards
of permissible radiation releases which are obsolete and understate
by many times the actual health risks posed by such emissions
of radiation. Obviously these permissible radiation standards
should be updated by the NRC, but having seen the way the NRC
operates for the past 15 years, I have little hope that the NRC will
do so. In the absence of NRC action it is imperative that
the State of Massachusetts act in this critical area, to design
and set standards of radiation releases which must be met by
nuclear plants operating within the State -- standards that will
take into account the latest of scientific evidence on the health
effects of low-level radiation, and then to engineer and implement
a monitoring system to ensure that Pilgrim I does not exceed
such standards, and if it does, to shut it down. It is of fundamental
importance to the mental wellbeing and physical health of the
citizens of the South Shore that such a system be in place before
the plant is allowed to restart. Ke ask the support of your
Committee to ensure that the NRC not give its approval to Pilgrim
restart unless and until an effective realtime continuous monitoring
system, run either by the NRC or the State of Massachusetts (not
Boston Edison) has been fully implemented.
22
The Chairman. I'm going to come back to some questions for Mr.
Abbott. I would like to try and go down the panel first, and then
come back with some questions. I'll ask that Ann Waitkus-Arnold
testify next, and then we'll proceed to the others, she is the Chair-
woman of the Plymouth Commission on the Handicapped.
Ms. Waitkus-Arnold. Thank you, Senator.
The Chairman. Put that mike a little closer.
Ms. Waitkus-Arnold. Thank you for the opportunity to testify
before your committee. My name is Ann Waitkus-Arnold and I rep-
resent the Massachusetts Office on Handicap Affairs, and chair-
woman for the Disabled Persons for the Disabled Advisory Group
on Nuclear Evacuations.
I'm also the chairperson for the Public Commission on Handicap
Affairs, Resource Coordinator for We the People and
The Chairman. Slow down just a little, Ann, so we can all
Ms. Waitkus-Arnold. OK. I'm also a member of the Massachu-
setts Advisory Council on Handicap Affairs.
The purpose of the advisory group is to make recommendations
to be used by the Massachusetts Civil Defense Agency and the util-
ities. This is a crucial first step in a statewide effort to insure that
all people are included in planning, not only for Pilgrim I, but for
Massachusetts residents affected by Yankee Atomic and for
Yankee Rowe nuclear power plants.
In my official capacity for the State, I have had the opportunity
to talk with representatives from Civil Defense, Department of
Public Safety, Boston Edison, Yankee Atomic, and I've addressed
FEMA and the NRC on several occasions. However, I have seen
little evidence of any real efforts to insure the health and safety of
the special needs of populations by these agencies. They may give
the appearance of concern, but I have found this to be mostly lip-
service. Government assurances to protect the public in the event
of an accident at Pilgrim I have been deceptive and grossly irre-
sponsible.
The NRC has licensed nuclear facilities that have not included
people with disabilities and pain. And only recently has FEMA con-
cluded that plans for Pilgrim I plant are not adequate for people
with special needs.
The State's newest revised draft of October 1987, developed with
the assistance of Boston Edison, now states that potassium iodine
will be stockpiled for use for those who will be left behind, instead
of including all citizens in actual evacuations
The Chairman. Would you like to expand on that point?
Ms. Waitkus-Arnold. OK.
The Chairman. On the significance of storing that particular
chemical.
Ms. Waitkus-Arnold. They will be storing that chemical — the
chemical protects the thyroid gland against radioactive iodine. The
problem that we have with this is that it is only to be given out to
people in nursing homes, hospitals and
The Chairman. Let's get a little more complete picture. You are
talking about there being included in an evacuation plan the sug-
gestion that some people might leave, but might leave those who
have physical disabilities behind?
Ms. Waitkus-Arnold. Right.
23
The Chairman. People in nursing homes or who have other
physical disabilities. They are going to be inoculated with this, or
they take a pill. They take a pill, and they take whatever radiation
there is. The other people have effectively left, and they leave the
handicapped or physically disabled — or physically challenged, as
my son would say — behind, to take their pills and hope for the
best?
Ms. Waitkus-Arnold. Right. This is a drug that can cause severe
allergic reactions, hemorrhaging, and even death.
Mr. Chairman. Do you have any instant reaction to that type of
an evacuation plan? I can't let that quite slide by so quickly.
Ms. Waitkus-Arnold. My instant reaction is anger, discrimina-
tion, and I think it is a very inhuman way to treat people, especial-
ly elders and disabled. Those are the only people targeted out for
this particular type of treatment.
The Chairman. The elderly and the disabled?
Ms. Waitkus-Arnold. Elderly and disabled. That means that we
have a discriminatory system in our country today.
In my opinion and the opinion of the advisory group, Edison has
spent a great deal of time lulling people into a false sense of securi-
ty, and h£is consistently been misleading and deceptive on the
issues of special needs.
One example is a special needs survey done by Edison at the in-
sistence of our disability group. The purpose of the survey was to
identify people who will need assistance during evacuation; unfor-
tunately, they ignored our suggestions and offers of assistance. The
resulting survey was designed in such a way as to exclude most of
the people with disabilities.
Consequently, there is a stunning discrepancy between the 1986
Disability Census figure, which shows 4,000 people in Plymouth
alone with severe limitations and the utilities' figures showing only
474. Edison then incorporated these erroneous figures into their
new evacuation time estimates of special needs population.
The Chairman. As I understand, partially because many of those
who have physical disabilities don't report them; is that right?
Ms. Waitkus-Arnold. No. It's because the survey was kind of a
bogus survey. It wasn't sent out to people — it wasn't sent out to
any handicapped or elderly house. They refused to send it out to
every household in the town of Plymouth. It wasn't understandable
by many disabled people; elders who had no idea that the service
pertained to them because it spoke about severe disabilities, and it
did not include a lot of questions about many disabilities. Obvious-
ly, if one is blind, one would not be able to fill out the survey.
In addition, we have advocated for 2 years that Edison comply
with NRC's regulations to notify and alert all segment of the com-
munity in case of an accident of Pilgrim I. This includes people
who are deaf and hard of hearing.
I have testified before the NEC several times on this issue; how-
ever, proper action has not been taken to obtain and distribute spe-
cial equipment to the 420 residents who have requested it from
Boston Edison. I feel that the NRC is complicit in its violations of
federal law because they have been aware of this violation, but
have taken no action to make Boston Edison comply.
24
With few exceptions, there appears to be an attitude from the
Federal Government on down that some elderly and disabled
people are not worth consideration because exclusion is permitted.
The quality of our Government is reflected by the way the Govern-
ment deals with its citizens that are in need of assistance, and
until this attitude changes, disabled people will be continued to be
treated as second-class citizens. I'm talking about people who we
love and care about, our children, parents, grandparents who may
have hearing, vision or physical disabilities, the thousands of elder-
ly who will need assistance in an evacuation; our disabled veterans
in homes and hospitals and the many retarded persons in group
homes, who may not even recognize that an emergency exists.
What will happen to them during an emergency?
We are not asking for special treatment, only equal treatment.
Failure to include elderly and disabled in planning is deprivation
under the equal treatment under the 4th and 14th amendments.
We are not sajdng we ought to come first. We just want the same
chance to escape as everyone else has. Basic civil rights are the
birthright of all Americans and second class citizenship should no
longer be allowed. Realistic and humane emergency plans must be
developed for all people and every town and village from Cape Cod
to the borders of New Hampshire affected by this plant. Unless a
workable plan can be designed for everybody, and until such a plan
can be tested and implemented. Pilgrim I should remain closed.
There have been serious incidents which reveal the GE contain-
ment systems, like the Pilgrim I containment, had an unsafe
design, making it very unlikely to withstand a major accident. This
report was kept secret by GE and the NRC for 12 years. In addi-
tion, the report stated that radioactive and chemical waste in
Pl5anouth by Boston Edison was duly reported to State and Federal
authorities and has yet to be investigated after 7 years. We feel
that waiting 7 years is 7 years too long to find out whether our soil
and water have been contaminated.
In light of the above examples, there must be an immediate mor-
atorium on the operation of all nuclear plants which affect Massa-
chusetts residents, and Congress must hold a full investigation into
why the NRC has failed to protect the health and safety of elderly
and disabled people as well as the rest of the general public. Thank
you very much for inviting me to speak.
The Chairman. We'll come back to you. Do you know of your
own knowledge whether other evacuation plans treat the handi-
capped like this?
Ms. Waitkus-Arnold. Jerome Plant.
The Chairman. Where they have similar kinds of
Ms. Waitkus-Arnold. Exactly.
[The prepared statement of Ms. Waitkus-Arnold follows:]
^&*
25
The Disabled Persons' Advisory Group
on
Nuclear Evacuation
Ann Waitkus-Arnold Post Office Box 3803 617-747-4574
Chair Plymouth, MA 02361 Voice &TDD
Honorable Edward M. Kennedy
2400 J.F.K. Federal Building
Boston^ Ma. 02108
Mr Chairman;
My name is Ann Waitkus-Arnold, and I represent the Massachusetts
Office on Handicapped Affairs as the Chairwoman of the Disabled Persons'
Advisory Group on Nuclear Evacuation. I am also the Chairperson of the
Plymouth Commission on Handicapped Affairs, Special Needs Co-ordinator
for We the People, Inc. of the United States, and a member of the Plymouth
Nuclear Affairs Committee and the Massachusetts Advisory Council on
Handicapped Affairs. The purpose of the Advisory Group is to make re-
commendations to be utilized by the Massachusetts Civil Defense Agency
and the Utilities. This is a crucial first step in a statewide effort
to insure that ail people are included in planning, not only for Pilgrim
I, but for Massachusetts residents affected by Yankee Atomic in Rowe, and
the Vermont Yankee Nuclear Power Plant. In my official capacity for the
State, I have had the opportunity to work with representatives from
M.C.D.A., the Departmentof Public Safety, the Boston Edison Company,
Yankee Atomic, and I have addressed the Federal Emergency Management Ag-
ency and the Nuclear Regulatory Commission on several occassions.
However, I have seen little evidence of any real efforts to insure
the health and safety of the Special Needs Populations by these agencies.
They may give the appearance of concern, but I have found this to be
mostly Up service. Government assurances to protect the public in the
26
(2)
event of an accident at Pilgrim I have been deceptive and grossly irr-
esponsible. The NRC has licensed Nuclear facilities that have not in-
cluded people with disabilities in Planning, and. only recently has
FEMA concluded that plans for the Pilgrim I Plant are not adequate for
people with Special Needs although I realize the NRC is not obliged
to take advice from FEMA. The States newest revised Plan, of October.
1987. developed with the assistance of Boston Edison, now states that
Potassium Iodide will be stockpiled for use by those who will be left
behind, instead of including all citizens in actual Evacuations. Who
are these people who will be left behind? - People in Hospitals. Nurs-
ing Homes and Detention Centers, including the Plymouth County Farm.
This proposed use of a drug which can cause severe allergic reactions,
hemmorrhaging. and even death, is inhumane and totally unacceptable.
In my opinion, and in the opinion of the Advisory Group. BECo
has spent a great deal of time and money lulling people into a false
sense of security, and has been consistently misleading and deceptive
on these issues. One example is the Special Needs Survey, done by BECo.
at the insistance of the Disabiltiy Group. This group included people
with disabilities, representatives from Independent Living Centers,
and State Agencies. The purpose of that Survey was to identify people
who will need assistance during Evacuation. Unfortunately, they refused
our input andParticipation in developing a workable document. and. instead.
the Survey was not done in good faith, and did not collect the needed
information. Consequently, there was a stunning discrepancy between the
1986 Disability Census Figures showing 4.000 people with severe limit-
ations in Plymouth alone, and the Utilities' figures showing only ^7^.
BECo then incorporated their erroneous figures into their new Evacuation
Time Estimates for Special Needs Populations, thereby calling into
question the validity of this document.
27
(3)
In addition, we have been advocating for two years that BECo comply
With NRC Regulation to "notify and Alert all segments of the community"
in case of an accident at Pilgrim I. This includes people who are deaf
and hard-of-hearing. I have testified before the NRC several times on
this issue, however, proper action has not been taken to obtain and
distribute special equipment to the 421 residents who have requested
It from BECo. I feel the NRC is complicit in this violation of Federal
Law because they have been made aware of this violation, but have taken
no action to make BECo comply.
With few exceptions, there appears to be an attitude from the Fed-
eral Government on down that elderly and disabled people are not worth
consideration, because exclusion is pisrmitted. This is defacto
discrimination. The quality of our Government is reflected by the way
the Government deals with it's citizens who are in need of assistance,
and, until this discriminatory attitude changes, disabled people will
continue to be treated as second class citizens. I'm talking about people
whom we love and care about - our children, parents and grandparents
who may have hearing, vision, or physical disabilities, the thousands
of elderly who will need special assistance, our disabled veterans in
homes and hospitals, and the many retarded persons in Group Homes, who
may not even recognize that an emergency exists. What will happen to
them during an Emergency? These people are human beings who are impor-
tant to our communities. We are not asking for special treatment, only
equal treatment. Failure to include elders and disabled citizens in Ev-
acuation Planning is depravation of Equal Treatment under the Fifth and
Fourteenth Amendments, we're not saying we want to be first - we just
want the same chance to escape as everyone else, however small that
may be. Basic Civil Rights are the birthright of all Americans, and
second class citizenship must not be allowed. Realistic and humane
28
(4)
Emergency Plans must be developed for all people in every town and
village from Cape Cod to the borders of New Hampshire! Unless s work-
able plan can be designed for everyone, and until such a plan can be
tested and implemented. Pilgrim I must remain closed.
There have been serious incidents, including the Reed Report,
which revealed that GE containments, like the Pilgrim I vessel,
have an unsafe design making it very unlikely to withstand a major
accident. This report was kept secret by GE and the NRC for 12 years!
In addition, the reported dumping of radioactive and chemical waste in
Plymouth by BECo. duly reported to State and Federal Authorities, has
yet to be investigated after seven years. We feel that waiting seven
years is seven years too long to find out whether our soil and ground
water have been contaminated.
In light of the above examples, there must be an immediate
Moratorium on the operation of all Nuclear Plants which affect Mass^
residents, and Congress must hold a Full Investigation into why the
NRC has failed to protect the health and safety of Elderly and Disabled
people, as well as the rest of the general public.
Thank you. Mr. Chairman, for inviting me to speak on these issues,
and 1 would be happy to answer any questions you might have.
Ann Waitkus-Arnold
Chairwoman
29
^/le J^dX/u/'/on ^/ace 3^om /SOS
^oi/o/i 0^06'
MICHAEL S. DUKAKIS
Governor
727-7440
JIM GLEICH Vccc i TDD
Director 1-8O0.322.2O20
Voice & TDD
FOR IMMEDIATE RELEASE CONTACT: LORRAINE GREIFF
DECEMBER 4, 1987 617-727-7400
PRESS RELEASE
ANN WAITKUS-ARNOLD APPOINTED CHAIRWOMAN OF DISABLED PERSONS
ADVISORY GROUP ON NUCLEAR EVACUATION
AWN WAITKUS-ARNOLD OF PLYMOUTH WAS RECENTLY APPOINTED BY THE
MASSACHUSETTS OFFICE OF HANDICAPPED AFFAIRS TO BE CHAIRWOMAN
OF THE DISABLED PERSONS ADVISORY GROUP ON NUCLEAR EVALUATION.
THE PURPOSE OF THE ADVISORY COMMITTEE IS TO MAKE RECOMMENDATIONS
TO THE STATE-WIDE TASK FORCE ON CIVIL DEFENSE TO INSURE
INCLUSION IN EVACUATION PLANNING FOR PEOPLE WHO ARE ELDERLY
AND /OR DISABLED IN ALL AREAS OF THE STATE NEAR NUCLEAR POWER
STATIONS.
THE ADVISORY GROUP CONSISTS OF ADVOCATES WHO ARE DISABLED
FROM THROUGHOUT THE STATE. IT HAS MET WITH BOSTON EDISON,
YANKEE ATOMIC, AND THE MASSACHUSETTS CIVIL DEFENSE AGENCY.
IT IS EXPECTED TO RECOMMEND THE HIRING OF A PROFESSIONAL
CONSULTANT TO RESEARCH THE DEMOGRAPHICS OF PEOPLE WITH
DISABILITIES NEAR NUCLEAR POWER PLANTS; TO DETERMINE THEIR
NEEDS IN THE EVENT OF AN EMERGENCY; TO DETERMINE WHICH PEOPLE
IF ANY, CANNOT BE EVACUATED; AND TO DETERMINE THE ATTENDENT
RISKS IN REMAINING WHERE THEY ARE.
"THIS ADVISORY GROUP IS A CRITICAL FIRST STEP IN THE STATEWIDE
EFFORT TO DEAL WITH EMERGENCY EVACUATION PROCEDURES FOR ALL
PEOPLE," ACCORDING TO JIM GLEICH, DIRECTOR OF THE MASSACHUSETTS
OFFICE OF HANDICAPPED AFFAIRS.
30
The Chairman. Mr. Johnson.
Mr. Johnson. Thank you, Senator for this opportunity to testify
before the committee.
My name is Neil Johnson. I'm the chairman of the Duxbury Citi-
zens Committee on Nuclear Matters, and a member of the Duxbury
Emergency Response Committee also. I am a registered profession-
al engineer and have design experience working on nuclear power
plants as a licensing, environmental and structural engineer.
I would like to address three areas: switchyard and emergency
diesel generators, overpressurization failure and direct torus vent-
ing and stress corrosion cracking.
First, the switchyard and emergency diesel generators. On No-
vember 12, 1987, at approximately 2:10 a.m., the Pilgrim nuclear
power station experienced a complete loss of offsite power, LOOP,
during adverse Weather conditions. This resulted in a start-up of
two emergency diesel generators. Prior to the restoration of offsite
power at 11:15 p.m. on the same day, one of the diesel generators
had to be shut down, leaving only one diesel generator operating.
The event was not given a licensee emergency classification by the
NRC, as the plant was in cold shutdown.
It was reported that the loss of offsite power was associated with
icing in the switchyard. I'm concerned that similar problems with
the plant operating could occur in the future that could result in
more serious consequences.
Since June of 1972, there have been 20 instances of loss of the
345 kv offsite system and four instances of loss of both the 345 kv
and the 23 kv offsite system. This would be considered four LOOP
events, L-O-O-P.
I believe that prior to restart, the NRC should review the switch-
yard and emergency diesel generators as a system and assure the
public that the integrity of this system can be maintained under
adverse conditions.
Based on the recent diesel generators and switchyard problems, I
believe that the NRC should require completion of the installation
of the new 2,000 kw blackout diesel prior to the restart.
The conclusion of the NRC Augmented Inspection Team review
of the November 12 incident, the loss of the offsite power was that
the inoperability of the B emergency diesel generator resulted from
the performance of maintenance using inadequate or incomplete
maintenance procedures.
1 believe that the NRC should assure the public that BECO will
more aggressively pursue courses of action to mitigate mechanical
problems such as those experienced on the B emergency diesel gen-
erator.
The next topic is on overpressurization failure and direct torus
venting.
The Chairman. Let me just briefly ask you what would have
been the effect if you had a diesel generator fail, if the plant had
been on-line?
Mr. Johnson. Had the last diesel generator failed and the plant
been on-line, it would have been a station blackout. There is — there
are some emergency batteries that would keep things going for a
short time. But without offsite power and without the two diesel
generators, you have a station blackout.
31
The Chairman. What does that mean, station blackout?
Mr. Johnson. That means you don't have power to run the serv-
ice water system and your systems required for safe shutdown.
The Chairman. So the systems for safety would have been effec-
tively shut down; is that what you are saying?
Mr. Johnson. Yes. There are some batteries that would keep
things going for a period of time. OK, overpressurization failure
and direct torus venting. I understand that severe accidents in the
extreme can generate pressures of more than twice the design pres-
sure of a Mark I containment structure similar to the one at Pil-
grim and could cause containment rupture. One core damage pre-
vention strategy utilized is containment venting of excess pressure
gradually. I have a sketch attached for those who would like to see.
This is achieved by bubbling the release from the gas treatment
system — excuse me, from the reactor dry well through the wet well
on through the standby gas treatment system, the SBGT, where re-
maining radioactive iodine and particulates are removed, finally
venting out through the main plant stack. Incidently, the standby
gas treatment system remained out of service from 1984 through at
least 1986 at Pilgrim.
It is also my understanding that the existing vent duct work as-
sociated with the standby gas treatment system is of fairly light
gauge and may be broached in accident venting. Therefore, the in-
stallation of the direct torus vent system, which provides a direct
vent path, with heavier gauge pipe around the standby gas treat-
ment system was proposed at Pilgrim. Installation of this system
was begun, but not completed due to a lack of approval by the
NRC.
I believe that the NRC should be concerned about the effects of
secondary release of radioactive gas into the reactor building in the
event of duct work failure. Also, if in the future, the NRC approves
the direct torus venting system, I believe that they should review
the operation of the manual override, which would allow the opera-
tor to manually override switches to allow venting to continue even
with high radiation in the torus vapor space. I know that's fairly
technical, but
The Chairman. That is very technical. [Laughter.]
I'll give you 30 seconds to translate it for everyone. Let's just
take a minute and give us the essence of it, if you would.
Mr. Johnson. OK. With a station blackout, there are spray sys-~^
tems that would cool the reactor. However, if those fail due to no
power or some other problem, then there is direct torus venting or
a venting out of the dry well portion of the containment through
the wet well.
The Chairman. As I understand it, they don't have torus vent-
ing; they want to have torus venting?
Mr. Johnson. Yes. They have started installation of torus vent-
ing which would bypass the standby gas treatment system. That
has not been given approval by the NRC.
The Chairman. Edison desired to design a standby system, but
NRC has not approved that?
Mr. Johnson. They felt it was conflicting — I forget the exact ter-
minology. Conflicting safety issues, I think is the terminology.
32
The Chairman. Some translate that as possibly the fact that if
Boston Edison is prepared to put it in, that might suggest that
others should put it in their plants, and others might not be willing
to do it. I don't know if that's fair.
Mr. Johnson. I'm also a bit concerned in that there is a manual
override in the event of high pressure and high radiation that
would allow an operator to open a valve to bypass the SBGT and to
go right out to the atmosphere via the main plant stack.
[The prepared statement of Mr. Johnson follows:]
33
STATEMENT OF NEIL JOHNSON
Good evening. My name is Neil Johnson, and I,m the Chairman of
the Duxbury Citizens Committee on Nuclear Matters and a mem.ber ;f
the Duxbury Emergency Response Comm.ittee. I am a registered
Professional Engineer and have 13 years of design experience
working on nuclear power plants as a Licensing, Environmental and
Structural Engineer. I,d like to address 3 areas - Switchyard
and Emergency Diesel Generators, Overpressurizat ion Failure and
Direct Torus Venting and Stress Corrosion Cracking.
Swit :hyard and Emergency Diesel Generators
On November 12,1987 at approximately 2:10 AM, the Pilgrir. Nuclear
Power Station experienced a complete loss of offsite power (LOOP,
during adverse weather conditions. This resulted in startup of
the two emergency diesel generators. Prior to the restoration of
offsite power at 11:15 P.M. on the same day, one of the diesel
generators had to be shut down leaving only one diesel generator
operating. The event was not given a licensee Emergency Class-
ification by the NRC as the plant was in cold shutdown.
It was reported that the loss of offsite power was associated
with icing in the switchyard. I am concerned that sir-.ilar
problems with the plant operating could occur in the future that
could result in more serious consequences.
Since June jf 19''2 there have been 20 instances of loss of the
345 kV offsite system and 4 instances of loss of both the 345 >V
and the 23 kV offsite systems ( 4 LOOP events ) .
I believe, that prior to restart, the NRC should review the swit-
chyard and emergency diesel generators as a system, and assure
the public that the integrity of this system can be maintained
under adverse conditions.
Based on the recent diesel generator and switchyard problems 1
believe that the NRC should require completion of the installa-
tion of the new 2000 KW blackout diesel prior to the restart.
The conclusion of the Augmented Inspection Tea.m review of tr.e
November 12, 1987 loss of offsite power was that the ir.-
operability of the "B" emergency diesel generator resulted frorr.
the performance of maintenance using inadequate or incomplete
maintenance procedures.
I believe that the NRC should assure the public that BECO will
m^ore aggressively pursue courses of action to mitigate mechanical
problems such as those experienced on the "B" e.mergency diesel
generator?
34
Overpressure Failure and Direct Torus Venting
I understand that severe accidents in the extreme can generate
pressures of T.ore than twice the design pressure of a Mark I con-
tainment structure similar to the one at Pilgrim and could cause
containment rupture. One core damage prevention strategy util-
ized IS containm.ent venting of excess pressure gradually. (see
attached sketch) . This is achieved by bubbling the release from
the reactor drywell , through the wet well, on through the Standby
Gas Treatment System (SBGT) where remaining radioactive iodine
and particulates are removed, finally venting out through the
main plant stack. Incidentally, the Standby Gas Treat.-p.ent System
remained out of service from 1984 through at least 1985 at
Pilgrim.
It is also my understanding that the existing vent ductwork as-
sociated with the Standby Gas Treatment System is of fairly light
gague and may be broached in accident venting. Therefore the
installation of a Direct Torus Vent System which provides a
direct vent path, with heavier gauge pipe, around the Standby Gas
Treatment System, was proposed at Pilgrim. Installation of this
system, was begun but not completed due to a lack of approval by
the NRC.
I believe that the MRC should be concerned about the effects of
secondary release of radioactive gas into the reactor building in
the event of a ductwork failure. Also, if in the future the MRC
approves the Direct Torus Venting System, I believe that they
should review the operation of the raanual overide which would al-
low the operator to manually overide switches to allow venting to
continue even with high radiation in the Torus vapor space.
35
36
stress Corrosion Cracking
The 1987 update of the summary of findings and recommondations in
the Reed Report - 19''5 - General Electric Corporation states that
stress corrosion cracking ( SCC ) is a complex, industry-wide
problem affecting both BWR ' s and PWR ' s , and relates fundamentally
to the harsh environment in which components and piping must
operate in nuclear power plants.
In December of 1983, the NRC ordered the lisensee to shut down
and inspect the recirculating system piping for mtegranular
stress corrosion cracking. The licensee replaced the recirculat-
ing system piping and was authorized to restart in December 1984.
I recommend that the NRC make sure that all recommendations by
General Electric to upgrade BWR reliability as i.mpacted by stress
corrosion cracking have been implemented at Pilgrim so that this
condition does not reoccur in the future.
37
Questions
In The restart plan reference is made to the fact that 4 shifts
of operators will be available during startup and power ascension
and that 6 shifts will be available in the longer term. Since 4
shifts are not able to cover the work week of 21 shifts without
regular use of overtime ( 50 % overtime ) , how soon will Edison
have 6 shifts available?
Would the NRC please obtain and make available to the public the
records of hours worked by the operators on duty on November 12,
1987. A two week period prior to and including November 12, 1987
would be appropriate.
The restart plan states that "It is not intended as a go/no go
acceptance criteria. They may proceed if their performance falls
reasonably within a goal?" Who determines if their performance
falls within a goal and what criteria is used?
V/e would like the NRC to discuss decommissioning costs and
methods. How can we be assured that deccmmissioning will be
adequately funded for Pilgrim I when it has outlived its
usefulness? What lessons has the NRC learned from the Ship-
pingport Pa. decommissioning?
What will the NRC do to insure that groundwater ingress both
through the seams in the Process Building wall and through the
conduit penetration for the switchyard sump pump is corrected?
38
The Chairman. OK. We'll go to Mary Ott. We're trying to open
up the back here so that we can have some of our other guests go
up on the stage. It might be somewhat uncomfortable, but at least
they'll be able to observe.
I'm informed that there is another room here where they are
covering this through a TV monitor, I'm informed the back is
loaded with equipment. I don't know where the fire marshall is,
but we'll check. Anyway, we'll move on.
Mary Ott, we'll hear from you.
Ms. Ott. Good evening. Senator Kennedy. We commend you for
calling this important meeting and are very grateful for the oppor-
tunity to express our deepening concern about the health and
safety impact with the restart of Pilgrim, and further at the failure
of the Nuclear Regulatory Commission to perform its sanctioned
duty to regulate this utility.
Our concerns encompass Pilgrims flawed GE Mark I contain-
ment, its poor management history, the lack of evacuation plans
for area residents, the threat posed by the continued stockpiling of
tons of nuclear waste on site, the alarming increase in cancer in
the five towns downwind, and finally, the credibility of the Boston
Edison Co. and its regulator, the NRC.
Although a conclusive link has not been found. Pilgrim's history
has heightened suspicion of the connection between the plant and
increased cancer incidents in surrounding communities. The State
Department of Public Health confirmed this increase in 1986.
Because the report was criticized for omitting crucial data, a new
study was promised, which was to include more recent data, causal
factors, occupational risks and study of cancer incidence in commu-
nities near nuclear powerplants in New England. This study should
be completed before Pilgrim is allowed to restart.
Pilgrim's poor management has been a serious concern since the
plant was licensed in 1972. Edison's decision to use known defective
fuel resulted in widespread contamination of the plant and contrib-
uted to their inability to control iodine releases during the early
1970's. They subsequently applied to the NRC for a revision of spec-
ifications to provide for, quote, "operational flexibility", end quote.
It was granted.
Following Edison study findings in 1982, the NRC assigned spe-
cial priorities to monitoring the management of Pilgrim. By 1986,
16,000 hours of inspection time had been spent at Pilgrim, and a
third resident inspector assigned. This is 50 percent more inspec-
tion hours than spent in similar plants in the northeast, a peculiar
commitment of resources to oversee a plant that the NRC keeps as-
suring us has always been operated in a safe manner.
Following Edison — oh, excuse me. Still the problems persist.
Since 1984, about 100 mishaps have occurred at Pilgrim; 12 acci-
dents have occurred since 1982, causing Edison to notify state offi-
cials and police. Despite the objections of State Secretary of Public
Safety, 22 legislators and concerned residents, Edison refueled the
reactor with no evacuation plan in place and without notifying the
appropriate authorities.
They also commenced the refueling on the very day they assured
the press that the procedure would be done a week later. When
questioned about the contradiction, the NRC responded, quote, "if
39
the utility lied to the public or to reporters, there is no authority
under the Atomic Energy Act for the NRC to do anything about it.
There is no law that says they have to tell reporters the truth,"
end quote.
In November of 1987, a series of spills and leaks resulted in the
contamination of several workers. Edison's vice president was in
Florida at the time. There was no NRC resident inspector on site.
Plant spokesmen originally denied any leaks, and then later ac-
knowledged them. Later a single generator was the only source of
electricity to provide cooling for the loaded reactor. If the plant
had been operating and that generator failed, we would have had
to implement the evacuation plan that we do not have.
Something is wrong here. Senator. Boston Edison has withheld
documents from the public document room with the permission of
the NRC. Many missing have been obtained through the Freedom
of Information Act and chronicle a history of unmonitored releases
to our environment. Edison continues to tell us that there has been
no releases in excess of technical specifications. The NRC has not
made any attempt to contradict the known misinformation.
During the last 18 months, we have been assured by the NRC
and the industry that nuclear power has defense in depth, and
we're often reminded that there are inherent risks associated with
all forms of energy. The risks we are being asked to bear are unac-
ceptable.
Since local and State officials are powerless to resolve our dilem-
ma and the NRC refuses to hear our requests for a legal hearing,
we appeal to your committee to initiate an independent, congres-
sionally sponsored investigation into the health and safety impact
of the operation of Pilgrim, and further into the conduct of the Nu-
clear Regulatory Commission. Only a legal inquiry can provide the
truth about Pilgrim's troubled history. Such a hearing is needed if
public confidence in our system and in the NRC is to be restored.
Thank you, Senator.
[The prepared statement of Ms. Ott (with attachments), follows:]
40
TESTIMONY OF MARY C. OTT, CO-CHAIRMAN, DUXBURY
CITIZENS URGING RESPONSIBLE ENERGY (CURE) BE-
FORE THE U.S. SENATE COMMITTEE ON LABOR AND
HUMAN RESOURCES, JANUARY 7, 1988.
Senator Kennedy, members of the Senate committee, my name is Mary Ott and 1 am the Co-
Chairman of Duxbury Citizens Urging Responsible Energy. We commend you for calling this
important meeting, and are grateful for the opportunity to express our deepening concern
about the health and safety impact of the restart of the Pilgrim Nuclear Power Station and fur-
ther, at the failure of the U.S. Nuclear Regulatory Commission (NRC) to perform its sanction-
ed duty to regulate this utility.
Our concerns encompass Pilgrim's flawed GE Mark I containment; its poor management
history; the lack of evacuation plans for area residents; the threat posed by the continued stock-
piling of tons of nuclear waste on site; the alarming increase of cancer in the five towns down-
wind; and finally the credibility of the Boston Edison Company and its regulator, the NRC.
Although a conclusive link has not been found. Pilgrim's history has heightened suspicion of
the connection between the plant and increased cancer incidence in surrounding communities.
The State Department of Public Health confirmed this increase in 1986. Because the report
was criticized for omitting crucial data, a new study was promised which is to include more re-
cent data, causal factors, occupational risks, and a study of cancer incidence in communities
near nuclear power plants in New England. This study should be completed before Pilgrim is
allowed to restart.
Pilgrim's poor management has been a serious concern since the plant was licensed in 1972.
Edison's decision to use known defective fuel resulted in widespread contamination of the
plant, and contributed to their inability to control Iodine releases during the early '70's. They
subsequently applied to the NRC for a revision of technical specifications* to provide for
"operational flexibility." It was granted.
Following Edison's precedent-setting $550,000 fine in 1982, the NRC assigned special priori-
ty to monitoring the management of Pilgrim. By 1986, 16,000 hours of inspection time had
been spent at Pilgrim and a third resident inspector assigned. This is SO'yo more inspection hours
than spent at similar plants in the Northeast. A peculiar commitment of resources to oversee a
plant that the NRC keeps assuring us has always operated in a safe manner.
Still, the problems persist. Since 1984, about /oo mishaps have occurred at Pilgrim.*
Twelve accidents have occurred since 1982, causing Edison to notify state officials and police.
Despite the objections of the State Secretary of Public Safety, 22 legislators and concerned
residents, Edison refueled the reactor with no evacuation plan in place and without notifying
appropriate authorities. They also commenced the refueling on the very day that they assured
the press that the procedure would be done a week later. When questioned about the contradic-
tion, the NRC responded, "If the utility lies to the public or to reporters, there is no authority
under the Atomic Energy Act for the NRC to do anything about it. There is no law that says
they have to tell reporters the truth."*
In November a series of spills and leaks resulted in the contamination of several workers.
Edison's Vice President was in Florida at the time. There was no NRC resident inspector on
site. Plant spokesmen originally denied any leaks, then later acknowledged them.
•BECO letter to NRC dated May 22. 1975
•South Look, Karl Abraham, Region I, NRC, Oct. 6-8. 1987
41
The plant experienced a complete lost of offsite power for 21 hours. A single generator was
the only source of electricity to provide cooling to the loaded reactor. If the plant had been
operating, and that generator failed, we would have had to implement the evacuation plan thai
we do not have.
Something is wrong here. Boston Edison has withheld documents from the public document
room with the permission of the NRC. Many missing have been obtained through the Freedom
of Information Act and chronicle a history of unmonitored releases to our environment.
Edison continues to tell us that there have been no releases in excess of technical specifications.
The NRC has not made any attempt to contradict the known misinformation.
During the last 18 months, we have been assured by the NRC and the industry that nuclear
power has "defense in depth," and are often reminded that there are inherent risks associated
with all forms of energy. The risk we are being asked to bear is unacceptable.
Since local and state officials are powerless to resolve our dilemma, and the NRC refuses to
grant our request for a legal hearing, we appeal to your committee to initiate an independent,
Congressionally-sponsored investigation into the health and safety impact of the operation of
Pilgrim; and further, into the conduct of the Nuclear Regulatory Commission.
Only a legal inquiry can provide the truth about Pilgrim's troubled history. Such a hearing is
needed if public confidence in our system, and the NRC, is to be restored.
Thank you.
Postscript: CURE Co-Chairman, Dr. Donald M. Muirhead Jr. and his associate Dr. Belton
Burrows have submitted additional written testimony regarding the health effects of radiation.
42
/.;( CA
y^r^.5-^.2/j.- y^J't/
dOBTON CotsoN Company
r««Cu»"*f 0'r-Ct«
aOO BovLflTOH S*aCCT
aoaTOM. H^cVACMuirrra 02I99
•^0
Qt%.
Director
Division of Reactor LI' —<"!•.
Office of Nuclear Ren '"r Regulation
U.S. Nuclear RoRulat Coimlssloi
U.ishlnpton, D.C. 20555
Mjy 22, 1975 ,^ ',h
Di., et No. 50-293
License DPR-35
Subject: Proposed Revision to Airborne Effluents
Technical Specification for PilRrlni Unit CI
Dr.Tr Sir:
iipcr.itlon of PilRrin N'uclear Power- Scat ion In accordance with the present
Technical Specifications has revealed that section 3.8. B. 2 of the speclflca-
ilons should be revised to more accurately describe the Intent of the
specification ind provide operational flexibility. Accordingly, Bi ton
Ccison Conpany hereby requests that the attached proposed revlslor to
r^nlinic.il Specif Ic.nlon pages 179. 179A, 179B, 191A and 191B be lued Co
provide the necessary r larlf Icaclor. and definition.
This submittal has been approved by the Onslte Review Committee but has not
been reviewed by the Nuclear Safecy— Review tnd Audit Conmlrtee (NSRAC).
SSRAC review is underway and will be compleced during the week bep.lnnlng
May 27, 1975.
This proposed Technical Specification muse be considered Cemporary since It
does not reflect the requirements contained In Che new Appendix I Co 10 CFR 50
Issued by the Connlsslon on April 30, 1975 (and published In Che Federal
Reglscer, Voluoe 40, No. 87, May 5, 1975). Boston Edison will propose further
revisions to the Technical Specifications on effluent releases In accordance
with the new Appendix I not later than June 4, 1976.
Conronucilth of Massachusetts)
County of Suffolk ;
VeiO crul;
your
w^suR
rhen personally appeared before me Francis M. Staszesky, who, being duly sworn,
did state Chat he Is Executive Vice President of Boscon Edison Company, Che
applicant herein, and that he is duly authorized to execute and file Che
proposed Technical Specification revisions described herein in Che name and
on behalf of Boston Edison Company and Chac the staternentfl In nald proposed
revisions are true to the best of his knowledge and belief. ^ .yY
My Ccmimiaslon expires:
Notary Publ'c
DMC n SI.-vii r-v
y
43
59
TABLE 2
LER SYNOPSIS (11/01/85 - 01/31/87)
PILGRIM NUCLEAR POWER STATION
LER
NUMBER
EVENT
DATE
CAUSE
CODE
85-028-00
10/10/85
X
85-029-00
10/18/85
X
85-030-00
10/30/85
X
85-031-00
10/29/85
X
85-032-00
11/25/85
B
85-033-00
11/27/85
X
85-034-00
12/31/85
B
86-001-00
01/06/86
A
86-002-00
01/16/86
X
86-003-00
02/11/86
E
86-004-00
02/20/86
X
86-005-00
03/07/86
B
86-006-00
03/16/86
B
SUMMARY DESCRIPTION
INADEQUATE SURVEILLANCE PROCEDURE
FOR STANDBY GAS TREATMENT SYSTEM
HIGH PRESSURE COOLANT INJECTION
SYSTEM AND ANTICIPATED TRANSIENT
WITHOUT SCRAM SYSTEM INVERTERS
INOPERABLE
INADEQUATE RECIRCULATION PUMP
START PROCEDURE
FAILURE TO MEET MINIMUM SHIFT
CREW COMPOSITION
MAIN STEAM LINE HIGH FLOW SWITCH
SETPOINT DRIFT
MAIN STACK AND RBV MISSED
SURVEILLANCE TEST
TECHNICAL SPECIFICATION REQUIRED
FIRE DAMPERS FOUND DEGRADED
UNPLANNED REACTOR SCRAM ON LOW
WATER LEVEL DUE TO OPERATOR ERROR
REACTOR SCRAM DUE TO PRESSURE
SWITCH SENSITIVITY
480 V SAFETY BUS INADVERTENTLY
DEENERGIZED DURING MAINTENANCE
STANDBY LIQUID CONTROL SYSTEM
DECLARED INOPERABLE WHEN ^
SQUIB VALVES NOT TESTED INSITU
HEAD SPRAY PIPING LEAK IN TORUS
ROOM
WELD LEAK ON REACTOR WATER LEVEL
INSTRUMENT LINE
44
60
LER
NUMBER
EVENT
DATE
CAUSE
CODE
86-007-00
03/22/86
X
86-008-00 .
04/04/86
m
X
86-009-00
04/11/86
X
86-010-00
04/15/86
X
86-011-00
04/19/86
X
86-012-00
05/16/86
X
86-013-00
05/30/86
B
86-014-00
06/10/86
X
86-015-00
06/13/86
X
86-016-00
06/21/86
E
86-017-00
07/01/86
X
86-018-00
06/29/86
X
86-019-00
07/15/86
X
86-020-00
08/20/86
D
SUMMARY DESCRIPTION
MAIN STEAM LINE ISOLATION WHILE
REACTOR SHUTDOWN
REACTOR SCRAM AND MAIN STEAM
ISOLATION VALVE (MSIV) RESET
PROBLEMS
IN SERIES PRIMARY CONTAINMENT
ISOLATION VALVES M0-1001-28B
AND 29B INDICATING LEAKAGE PAST
SEATS
MAIN STEAM LINE ISOLATION WHILE
REACTOR SHUTDOWN
LEAKAGE PAST MSIV'S IN EXCESS
OF LLRT CRITERIA
INSUFFICIENT ONCE/CYCLE HPCI
SURVEILLANCE PROCEDURE
USE OF NON-SEISMIC GENERAL
ELECTRIC TYPE CFO RELAYS
INSUFFICIENT ONCE/CYCLE RCIC
SURVEILUNCE PROCEDURE
PRIMARY CONTAINMENT LOCAL LEAK
RATE TESTS OVERDUE
BUS A5, BUS A6 AND STARTUP
TRANSFORMER DEGRADED VOLTAGE
RELAY CALIBRATIONS OVERDUE
CONTAINMENT ISOLATION VALVE
LOCAL LEAK RATE TEST FAILURES
GENERAL ELECTRIC AKF FIELD
BREAKER FAILED TO TRIP
AUTOMATICALLY
INSUFFICIENT MONTHLY ATWS
SURVEILLANCE PROCEDURE
UNIDENTIFIED FIRE BARRIER WALLS
AND PENETRATIONS
45
61
LER EVENT CAUSE
NUMBER DATE CODE SUMMARY DESCRIPTION
86-021-00 08/27/86 B STANDBY GAS TREATMENT SYSTEM /^
DELUGE SYSTEM SINGLE FAILURE ^
MODE
E MISSED TECHNICAL SPECIFICATION
SOURCE LEAK CHECK SURVEILLANCE
A MISSED FIRE WATCH AND FIRE
WATCH PATROLS
X NON FIRE RESISTANT COATED
STRUCTURAL STEEL
B MISALIGNMENT OF THE FIRE
SUPPRESSION WATER SYSTEM
D FAILURE TO PERFORM RADIO-
ACTIVE MATERIAL SURVEILLANCE /^
TEST OF STANDBY GAS TREATMENT
SYSTEM AND LIQUID RAD. EFFLUENT
MONITOR
C LOSS OF OFFSITE POWER DUE TO
SEVERE WINTER STORM
86-028-00 12/23/86 X FAILURE TO RECOGNIZE THE EFFECTS
OF ELECTRICAL ISOLATION RESULTING
IN ESF ACTUATION
86-029-00 12/23/86 X LOSS OF OFFSITE POWER WHILE WASHING
SALT FROM YARD INSULATORS
86-022-00 08/29/86
86-023-00 09/12/86
86-024-00 10/07/86
86-025-00 11/11/86
86-026-00 10/29/86
86-027-00 11/19/86
NOTE:
There is no published synopsis of Licensee Event Reports
for 1987 at this time. Per the Librarian, Grace Karbot,
in the Plymouth Public Document Room, 19 such events
did occur in 1987.
1984
20
1985
34
1986
29
1987
19
TOTAL
102
46
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47
Page 1
QUESTIONS FOR INCLUSION IN CONGRESSIONAL RECORD OF JAN.
7, 1988 hearing on the restart of the Pilgrim Nuclear
Power Plant
submitted by Citizens Urging Responsible Energy
HEALTH ISSUE:
1. What is the reason for the State's failure to investigate
Boston Edison's alleged dumping of radioactive materials
on their property^in Plymouth? (promised in Aug., 1987)
2. Boston Edison has admitted to dumping radioactive
.material at the Plymouth town dump site. Do state and
|federal regulations permit such action? Are not Plymouth
■residents exposed to radiation when using the dump?
3. Massachusetts is the nation's fifth largest producer
of low-level nuclear waste. (100,000 cubic feet) What
portion of that waste is generated by Pilgrim? How does
that compare with similar size plants of the same design?
4. After the radioactive leaks in Nov., 1987, CURE requested
that air sampling and soil testing be done by the Mass. Dept.
of Public Health. The state agreed to the undertaking, but did
not do it. Who decided that this was not necessary?
5. Almost 2 years have elapsed since the State promised to
redo and upgrade the health study of high cancer incidence
in the 5 towns downwind of Pilgrim. What is the current
status of the study? Does the state feel that the issue of a
possible conclusive link between adverse health effects and
Pilgrim should be resolved before the plant's restart?
6. Boston Edison undertook a study of their employees' and
former employees' health status. Is this study completed?
Does it have preliminary findings? Will it be shared with
the MDPH?
7. What were the NRC and state radiation monitoring readings
in June, 1982 when highly radioactive resin was blown out
a 100 ft. duct and deposited on roof tops and paved areas at
Pilgrim? (all readings: onsite, stack, offsite)
Was data retrieved from dosimeters at all locations?
8. CURE reported allegations to the NRC last summer regarding
the removal of shrubbery onsite at Pilgrim which was said to be
radioactive. The NRC said that the licensee stated the bushes
were removed for security reasons. They later admitted that
there was some amount of radioactivity and would investigate
the matter. How do bushes at Pilgrim become radioactive?
Where were they taken? Were appropriate surveys conducted?
48
QUESTIONS ON HEALTH ISSUE, CONT'D Page 2
9. NRC: Please interpret, based on the Sandla report,
the expected number of deaths and casualities, long and
short-term, which would result from an accident at Pilgrim,
(in laymen's terms)
10. NRC: Can you provide figures on the increase of
background radiation over the last 15 years? (in laymen's terms)
What percentage of the increase is attributed to man-made
radioactive nuclfdes (i.e. cesium 137, I 131, strontium 90,
etc.)? Are figures available locally and nationally?
What are the present figures for natural background radiation
(i.e. solar rays, etc.)?
11. NRC: Has Boston Edison ever exceeded technical speci-
fications on radioactive releases from Pilgrim?
On what dates, and in what amounts over specification?
Are there fines or violations associated with such releases?
49
Page 3
QUESTIONS FOR INCLUSION IN CONGRESSIONAL RECORD OF JAN.
7, 1988 hearing on the restart of the Pilgrim Nuclear
Power Plant
submitted by Citizens Urging Responsible Energy
FIRE PROTECTION:
1. Is BECO now in full compliance with Appendix R require-
ments in fire protection? Have they applied for any waivers?
2. Are all barriers, fire doors and penetration seals
repaired and capable of passing required testing?
3. In Feb., 1986 72 locations at Pilgrim were being observed by
fire watches because of unfinished maintenance in the area of fire
protection. How many were being observed on Jan. 1, 1988?
4. Is the water pressure from the town of Plymouth adequate
to fight a fire on the second floor of Pilgrim Station?
5. The Standby Gas Treatment deluge system has been reported
to be inoperative since 1984 because it requires an outage
to test it. Has this matter been resolved during the current
outage? If not, why not?
6. The Halon system in the computer room is reported to have
been inoperable since March, 1985 because there is no pro-
cedure to test it. Why isn't there a procedure? When will
there be one?
7. What procedures are in place to suppress a fire in the
computer room since the halon system in inoperative?
8. The smoke detectors over the spent fuel pool have been
inaccessible to test since May, 1984. BECO is said to be
investigating acquiring a compact scissors lift to test to
test these and other inaccessible detectors in April, 1986.
Has it been acquired? Have they been tested since that time?
9. BECO documents reveal that some outstanding maintenance
requests (mrs) in the area of fire protection which were
established several years ago have been assigned 1987 m.r.
numbers giving the impression that they represent newly
identified problems. Please list outstanding mr . in this area,
and the dates each m.r. was established.
10. CURE received a report that Pilgrim's onsite fire
brigade was activated to investigate the sound of a small
explosion and the smell of "something burning" on Nov. 12th
at the time of the power loss. Evidence has been shown to
Department of Public Safety and the Senate Committee.
The NRC and BECO continue to deny these reports. What pro-
cedures were used by the NRC to investigate this allegation?
Did onsite NRC inspectors question employees who would have
been assigned to the brigade at that tinie?
50
Page 4
QUESTIONS FOR INCLUSION IN CONGRESSIONAL RECORD OF JAN.
7, 1988 hearing on the restart of the Pilgrim Nuclear
Power Plant
submitted by Citizens Urging Responsible Energy
GENERAL SAFETY:
1. Did BECO shut Pilgrim down voluntarily on April 11, 1986,
or did the NRC shut them down?
2. Is the Confirmatory Action Letter (CAL) still in effect?
3. Was -unusual event" the proper declaration for the emergency
at Pilgrim which began on April 10, 1986? NUREG-0654, page 1-9,
item 4. classifies a Main Steam Isolation valve malfunction
causing leakage as an "alert declaration."
4. Was the emergency in April caused by a recurring GE design
problem with the Main Steam Isolation Valves?
5. On Oct. 29, 1987 at the Duxbury forum, BECO claimed to
have resolved the main steam isolation valve problems which
have been identified by GE in the Reed report as unresolved
generic issues. Has this resolution been shared with the NRC or GE.
Is there documentation of this resolution in published form?
6 On April 4, 1986, the Residual Heat Removal (RHR) A Loop was
shut down for repairs. Was the RHR A Loop repaired and operable
on April 10, 1986?
7. We have noted no emergency event declarations since the
shutdown in April, 1986. The NRC says that declaration require-
ments do not apply to plants that are not operating. ^hy then
were three inspectors dispatched to New Hampshire and Seabrook
cited for a violation in procedure for not notifying the state
of Massachusetts within 15 minutes of the declaration of an
"unusual event"?
8. How many scrams (manual and automatic) have occurred at
Pilgrim since it began operation in 1972? Do scrams con-
tribute to core embrittlement? What is the industry average?
9. What tests have been performed to assess any potential
weakening or embrittlement of the Pilgrim reactor? Who did
them? What were the results? When were they done?
10. BECO has spent 30 million dollars on enhancements to
their GE Mark I containment. Ten million of that amount is
said to have been spent on a risk assessment study. Does the
NRC have a copy of this document? Will they share it with
state officials?
51
QUESTIONS ON GENERAL SAFETY, CONT' Page 5
11. How many "substantial safety hazard" reports (or their
equivalent) have been generated by Pilgrim since 1972?
Please define report and list the dates and reasons for such.
How does Pilgrim's average compare to similar size plants of
the same design?
12. How many violations of NRC requirements have taken place
at Pilgrim since 1972? How does the total compare to similar
size plants of the same design?
13. On August 15, 1986, BECO notified the NRC that contrary
to technical specification requirements, monitoring of the
primary containment inerting system makeup flow rates had
not been conducted. (said to detect any large increase in
containment leakage) They further stated that instrumentation
used to perform such monitoring had been out of service since
January, 1985. Did the NRC cite or fine BECO for this vio-
lation of procedure? Is this instrumentation now functional?
14. Is the Standby Gas Treatment System activated by a power loss?
15. If direct torus venting were to be used, what is the
range of dose rates at the exclusion zone boundary in the event
of venting? At what pressure would venting take place?
16. If Pilgrim had been operating on Nov. 12, 1987, and the
single operating generator had failed, did the potential
exist for a core-melt accident sequence? (please answer
yes or no)
In November, 1987,-
17. During the power loss CURE received a report that two
pumper trucks were called onsite at Pilgrim to remove
excess water from drains. The volume of water was said to be
be such that it posed back up problems in the plant which
would activate automatic sump pumps; thereby drawing ad-
ditional electricity from the single operating generator.
If the system had not been pumped out before the pumps
engaged, would an emergency evacuation have occurred?
Was the NRC informed of this incident? Was the waste water
contaminated? Was it tested? Where was it taken?
52
Page
QUESTIONS FOR INCLUSION IN CONGRESSIONAL RECORD OF JAN.
7, 1988 hearing on the restart of the Pilgrim Nuclear
Power Plant
submitted by Citizens Urging Responsible Energy
EMERGENCY PLANNING: NRC, FEMA and State Officials
1. What agency is liable for damages incurred as a result of
an improperly implemented evacuation plan?
2. If a radioactive plume can travel 10 miles per hour, how
can people evacuate to a proper shelter under adverse weather
conditions?
3. Is it true that the planning for the health and safety of
residents in the EPZ is not based on a worst case scenario event?
4. Does Duxbury need a 3rd reception center to decontaminate
evacuees?
5. BECO'S KLD time estimate study indicates that during a
major snowstorm, 50% of all driveways will be plowed within
30 minutes. Vfhat is the basis for that judgement?
6. NRC: define explicitly the role FEMA'S judgement will
play in determining the "adequacy" they claim will be required
in emergency planning before they will grant permission for restart.
7. FEMA announced withdrawal of approval of Pilgrim's
evacuation plan on August 6, 1987. The NRC has now exceeded the
120-day period to make a decision regarding FEMA'S negative
findings. When will that decision be made?
8. Why has BECO'S Bus Shelter Survey not been made available
to communities in the EPZ?
9. FEMA declined to participate in a forum sponsored by the
the Duxbury Board of Selectmen on Oct. 29, 1987 because of a
prior commitment and said therft^ staff ' s time was consumed
with the Seabrook issue. Does FEMA give preference to licensing
over safety issues?
10. What provisions have been made to segregate the prisoners
at the Plymouth County House of Correction from other people
evacuating in the case of an emergency at Pilgrim?
11. Will the NRC make a restart decision regarding evacuation
planning on potential solutions proposed by BECO, or on completed
plans which have been verified with letters of agreement and
approved by the local communities and the Commonwealth of
Massachusetts?
53
The Chairman. Dr. Healy.
Dr. Healy. Thank you, Mr. Chairman.
The Plymouth Committee on Nuclear Matters, formally consti-
tuted by the Board of Selectmen on August 19, 1986, consists of
nine members of diverse backgrounds and experience, with exper-
tise in the medical and legal fields; in business and industry, in-
cluding the utilities; in physics and engineering, in planning and in
public policy.
The committee members while differing sometimes radically in
their opinions have one common passion, that of the discovery of
what is fact. We have done our best to put aside our individual
biases in order to listen to knowledgeable others.
Thus far, the committee has issued two reports. The first on the
Plymouth Radiological Emergency Response Plan; the second on
Environmental Radiation Monitoring. In the first report, we said
the following in March 1987:
There are deficiencies in the Plymouth Radiological Emergency
Response Plan which are serious enough in the committee's judg-
ment to preclude reasonable assurance that adequate protective
measures can and will be taken by the town and the state in the
event of a radiological emergency.
Hence, the committee made the following recommendations:
1. That there be a comprehensive revision of the Plymouth Radi-
ological Emergency Response Plan. This task is incomplete.
2. That there be an appointment made of a full-time civil defense
director. That individual will begin on January 11, next Monday.
3. Development of funds for emergency preparedness from Feder-
al, State and utility sources. The only funds forthcoming have been
from Boston Edison.
4. Full town participation in a comprehensive drill prior to Pil-
grim's coming back on-line. This has not been done.
Regarding the second committee report, the Committee on Nucle-
ar Matters is strongly concerned with what it considers to be the
insufficient number of monitoring stations, the minimal and per-
functory involvement of the State in the monitory process and the
complete lack of an oversight monitoring system.
All of the many reports reviewed by the Committee on Nuclear
Matters indicate to its members that the Pilgrim nuclear power
plant does have a continuing environmental impact. In all the ma-
terials reviewed, however, Edison, NRC and the Commonwealth
hold that offsite releases from the plant, as indicated by current
monitoring, have not exceeded technical specifications.
Boston Edison Co., the NRC and the Commonwealth then draw
the conclusion that there has been no measurable impact upon the
citizenry. They further claim that even if there had been any
impact, it would have been minimal and far less than the effects of
previous worldwide weapons testing or of the Chernobyl accident.
The Committee on Nuclear Matters takes little comfort in the
above comparisons. Any environmental impact is our concern and
needs to be examined. Let us not forget that the impact of such ef-
fects is cumulative. The committee questions the adequacy of cur-
rent monitoring around Pilgrim I, even though it is more extensive
than that at some other nuclear plants.
54
Hence, the committee recommends increased monitoring, higher
quality monitoring, proper timing of monitoring to reveal effects of
specific plant incidences which involve radioactive releases and
prompt reporting of the results. Accomplishment of these recom-
mendations is basic to an investigation of the impact of the station
upon citizens' health; an investigation which has yet to be accom-
plished.
We respectfully request your assistance, Mr. Chairman, on two
related matters which may not be the direct concern of your com-
mittee. We request that you exert your considerable leadership at
the national level to help mitigate the unintended, negative conse-
quences of past congressional action and inaction which have led to
America's hometown becoming, in fact, a high level nuclear dump
site. We beg you to assist in relieving us of this burden. Only Con-
gress can do it, not the utilities and not Boston Edison.
We ask that you monitor closely the progress of the Department
of Energy's work at the Yucca Mountain drilling site in Nevada to
insure that the nation will obtain as soon as possible a long, over-
due, permanent repository for high level nuclear waste.
We also respectfully suggest that you help to initiate a congres-
sional review of the role and the performance of the Nuclear Regu-
latory Commission, and reasserting of congressional authority rela-
tive to the nuclear industry. It is needed. We request that you in-
troduce corrective legislation which will ensure congressional au-
thority and responsibility.
Thank you very much for this opportunity, Mr. Chairman. It is
deeply appreciated. I shall be happy to answer any questions inso-
far as I am able.
[The prepared statement of Dr. Healy (with attachments) fol-
lows:]
55
TESTIMONY BEFORE THE LABOR AND HUMAN RESOURCES COMMITTEE
OF THE UNITED STATES SENATE
(Senator Edward M. Kennedy, Committee Chairman)
By Dr. Grace M. Healy, Chairman
COMMITTEE ON NUCLEAR MATTERS
TOWN OF PLYMOUTH, MASSACHUSETTS
Thursday, January 7, 1988
The Plymouth Committee on Nuclear Matters, formally constituted by the
Board of Selectmen on August 19, 1986, consists of nine members of diverse
backgrounds and experience with expertise in the medical and legal fields, in
business and industry including the utilities, in physics and engineering, in
planning, and in public policy.
The Committee members, while differing sometimes radically in their
opinions, have one common passion - that of the discovery of what is fact .
We have done our best to put aside our individual biases in order to listen
to knowledgeable others. We have researched facts, gathering available
information from voluminous written materials and reports, from interviews of
relevant parties and from public hearings. We have visited the plant,
participated in simulated emergency and training drills, consulted with
technical experts and deliberated with one another during lengthy committee
meetings .
Our deliberations have, at times, been difficult. In the end, we have
managed to reach consensus on most recommendations. It is clear that we
stand together in our concern for the safety of all residents of Plymouth.
Thus far the Committee has issued two Reports: the first on the Plymouth
Radiological Emergency Response Plan; the second on Environmental Radiation
Monitoring. In the first report we said the following in March 1987:
There are deficiencies in the Plymouth Radiological Emergency Response
Plan which are serious enough, in the Committee's judgment, to preclude "...
reasonable assurance that adequate protective measures can and will be taken
(by the Town and State) in the event of a Radiological Emergency." There is
reason to believe that as things stand now, the Selectmen cannot fulfill
their legal responsibility, particularly during a Radiological Emergency,
".... to provide for the health and safety of persons and their property
II
The Plymouth Radiological Emergency Response Plan is a "paper" plan,
essentially untested relative to mobilization of some of the essential
personnel. Hence, the Committee made the following recommendations:
1. Comprehensive revision of the Plymouth Radiological Emergency
Response Plan.
This task is not complete.
56
Page 2
2. Appointment of a full-time Civil Defense Director, with staff as
needed, with adequate interim headquarters, and with long-term
plans for location in one of the new Town buildings.
The Civil Defense Director will begin work on January 11. 1988.
3. Development of funds for emergency preparedness from federal, state
and utility sources.
Only funds from Boston Edison are being made available to the Town.
4. Full Town participation in a comprehensive drill prior to Pilgrim's
coming back on-line.
This has not been done.
The Committee holds that the Plan must be operat ionalized. Procedures
must be specified and tested. Commitments of personnel and materials must be
legally formalized. Anything less is unacceptable.
Regarding the second Committee Report:
The Committee on Nuclear Matters, in an attempt to understand the
monitoring of environmental radiation associated with the Pilgrim Nuclear
Power Station, reviewed documents provided by Boston Edison and interviewed
knowledgeable persons, including but not limited to Boston Edison
representatives. Nuclear Industry representatives. Department of Public
Health representatives and State Officials.
The Committee on Nuclear Matters is strongly concerned with what it
considers to be the insufficient number of monitoring stations, the minimal
involvement of the State in the monitoring process, and the complete lack of
an "oversight" monitoring system.
All of the Reports reviewed by the Committee on Nuclear Matters (1982-
1987) indicate to its members that the Pilgrim Nuclear Power Plant does have
a continuing environmental impact. In all of the materials reviewed,
however, Boston Edison Company, the N.R.C., and the Commonwealth bold that
offsite releases from the Plant (as indicated by current monitoring) have not
exceeded technical specifications. Boston Edison Company, the N.R.C., and
the Commonwealth then draw the conclusion that there has been no measurable
impact upon the citizenry. They further claim that even if there had been
any impact it would have been minimal, and far less than the effects of
previous worldwide weapons testing or of the Chernobyl accident.
The Committee on Nuclear Matters takes little comfort in the above
comparisons. Any environmental impact is of concern and needs to be examined
if public health is to be protected. Let us not forget that the impast of
such effects is cumulative! The Committee questions the adequacy of current
monitoring around Pilgrim I, even though it is more extensive than that at
some other nuclear plants. Hence, the Committee recommends increased
monitoring, higher quality monitoring, proper timing of monitoring to reveal
effects of specific plant incidences which involve radioactive releases, and
prompt reporting of the results. Accomplishment of these recommendations is
basic to an investigation of the impact of PNPS upon citizens' health. . . an
investigation which has yet to be accomplished.
57
Page 3
The two Committee Reports mentioned here are being made available to
your staff, Mr. Chairman, as will be future reports and recommendations from
our Committee.
We respectfully request your assistance on two related matters which may
not be the direct concern of your Committee. We request that you exert your
considerable leadership at the national level to help mitigate the unintended
negative consequences of past Congressional action and inaction which have
led to America's Home Town becoming, in fact a high level nuclear dump site.
We beg you to assist in relieving us of this burden. Only Congress can do
it, not the utilities - not Boston Edison.
We ask that you monitor closely the progress of the Department of
Energy's work at the Yucca Mountain drilling site in Nevada to insure that
the nation will obtain as soon as possible a permanent repository for high
level nuclear waste.
We also respectfully suggest that you help to initiate a Congressional
review of the role and performance of the Nuclear Regulatory Commission, and
the reasserting of Congressional authority relative to the Nuclear Industry.
If it is needed, we request that you introduce corrective legislation which
will ensure Congressional authority and responsibility.
Thank you very much for this opportunity, Mr. Chairman; it is deeply
appreciated. I shall be happy to answer any of your questions insofar as X
am able.
58
TOWN OF PLYMOUTH
COMMITTEE ON NUCLEAR MATTERS
REPORT TO THE SELECTMEN
ON
THE PLYMOUTH RADIOLOGICAL EMERGENCY RESPONSE PLAN
March, 1987
MEMBERS :
59
THE COMMITTEE ON NUCLEAR MATTERS
Grace M. Healy, Chair
Charles W. Adey, Vice-Chair
Ann Waitkus Arnold
Theodore L. Boeen
Marie P. Fehlow
Kenneth T. Holmes
Kathleen M. Leslie
Anthony V. Lonardo
John P • Rooney
James W. Ryan
Howard E. Shetterly
SUBCOMMITTEE MEMBERS:
Ann Waitkus Arnold
Kenneth T. Holmes
60
TOWN OF PLYMOUTH
THE RADIOLOGICAL EMERGENCY RESPONSE PLAN
INTRODUCTION
As one of its tasks, the Committee on Nuclear Matters assumed respon-
sibility for a review of the Plymouth Radiological Emergency Response Plan
(RERP). The following is the result of research undertaken by the sub-
committee, and of the deliberations of the entire committee.
In order to determine Plan adequacy and feasibility, information was
sought from many sources. Subcommittee members reviewed written materials:
other Emergency Response Plans (ERP); Federal Emergency Management Agency
(FEMA) Regulations; reports on the adequacy of various RERP's; testimony of
public interest groups, and one available section of Secretary Barry's
report. Subcommittee members also contacted, in person and by telephone,
representatives from: (1) Local, Regional and State Civil Defense Offices,
(2) FEMA, (3) various Town Offices; (4) State Office of Handicapped Affairs;
and (5) Boston Edison.
SUMMARY CONCLUSIONS AND RECOMMENDATIONS
There are deficiencies in the Plymouth RERP. Moreover, these
deficiencies are serious enough, in the Committee's judgment, to preclude
"... reasonable assurance that adequate protective measures can and will be
taken (by the Town and State) in the event of a Radiological Emergency."
There is reason to believe that as things stand now, the Selectmen cannot
fulfill their legal responsibility, particularly during a Radiological
Emergency, ".... to provide for the health and safety of persons and their
property . . . ."
The Plymouth RERP is a "paper" plan, essentially untested relative to
mobilization of some of the essential personnel. As long as it is untested,
difficult questions can remain unanswered and difficult decisions can be
avoided. This is a situation unacceptable to the members of the committee.
Thus, we respectfully urge Selectmen to assign tasks and timelines to
appropriate personnel and/or offices to ensure accomplishment of the
following :
A. Comprehensive revision of the Plymouth RERP.
1. Correction of outdated information.
2. Elimination of specific deficiencies noted below.
3. Complete specification of implementation procedures.
4. Specification of procedures for ongoing updating and
coordination with local, area, and state plans.
B. Appointment of a full-time Civil Defense Director, with staff as
needed, with adequate interim headquarters, and with long-term plans for
location in one of the new Town buildings.
C. Development of funds for emergency preparedness from federal, state
and utility sources. (Appointment of liaison for same.)
61
D. Full Town participation in a comprehensive drill prior to Pilgrim's
coming back on-line. (While actual citizen evacuation may not be feasible,
full participation must at least include all responsible personnel being in-
£lace and carrying out assigned tasks.) Coordination of agencies, their
services and lines of responsibility - local, state, federal levels must be
test ed .
The Committee further recommends that all deficiencies be remedied and
all recommendations be implemented prior to reactor start-up.
There was one dissenting opinion expressed concerning the above. The
objection relates to making total task accomplishment a condition for reactor
start-up when longer time may be required for some tasks. The dissenting
opinion does not represent disagreement on deficiencies or recommendations,
but on timelines. In all cases there is agreement on need and urgency for
act ion .
SPECIFIC DEFICIENCIES AND RECOMMENDATIONS
Following are specific deficiencies found by the Committee on Nuclear
Matters and some recommended corrective measures; they have been grouped in
eight categories: (A) Advance Information, (B) Notification and Communication
Systems, (C) Evacuation Routes, (D) Evacuation Time Estimates, (E) Transport
of Dependent Populations, (F) Reception Centers and Public Shelters, (G)
Medical Facilities, and (H) Radioprotective Drugs.
A. ADVANCE INFORMATION
DEFICIENCIES:
1. Inadequate public information in Emergency Preparedness Zone (EPZ).
2. Lack of multi-lingual information (Italian, Portuguese, Spanish,
Japanese) .
3. Inadequate distribution of Emergency Preparedness Information (EPI)
brochures .
4. No information for people without access to transportation.
5. No information about staging areas (pick-up points).
6. Tourist and transient information inadequate or non-existent.
7. No educational effort outside the Town of Plymouth.
/
62
ADVANCE INFORMATION (Continued)
RECOMMENDATIONS :
1. Implement a comprehensive, ongoing public educational program through
new8 ads, cable TV programs, radio public service announcements, and
informational packets included in utility bills. Include an outreach
program for non-English speaking people in these activities.
2. Develop emergency information posters (multi-lingual), with maps
explaining:
- Protective Actions - Location of Public Transportation
- Evacuation Routes - Local Radio Station of EBS
- Location of Public Shelters - Staging Area Locations
3. Post Emergency Information Posters in public locations:
Hotels, motels, restaurants, gas stations, phone booths, recreation
facilities, tourist sites, informational centers, theaters, airports,
bus stations, trolley cars, and all public buildings.
4. Develop survey to identify special populations:
a. Non-English speaking people.
b. Transport dependent groups:
- 15% of Plymouth households have no car;
- 50% of households have one car, but one half of workers have jobs
outside of Plymouth.
c. Special needs people:
- Federal regulations require notification of "all segments of
society."
- Deaf and hard-of-hearing people must be identified beforehand so
they can be alerted by appropriate means.
5. Distribute updated pamphlets semi-annually to:
- General public and all recommended locations in #3 above.
- Multi-lingual pamphlets should be available in the same places.
63
B. NOTIFICATION AND COMMUNICATION SYSTEMS
DEFICIENCIES:
1. Siren System
a. The siren system is not equipped to confirm that all sirens have
been sounded during an exercise. There are no provisions for
determining which sirens are not working.
b. Present siren system does not warn hearing-impaired persons. No
alternate plan exists to notify this segment of the population.
2. Radio Communications
a. Department of Public Works radio equipment used for Civil Defense
is unreliable and inadequate.
b. Present system for notifying local officials is unreliable.
c. Plymouth County radio network (Sheriff's) is inadequate/
inefficient .
RECOMMENDATIONS:
ALL PROCEDURES FOR NOTIFICATION OF AN ACCIDENT AT PILGRIM I SHOULD BE
REVIEWED.
1. Investigate the "hard-wire" system or other alternatives that confirm
siren activation. Alert officials who will dispatch personnel to areas
with defective sirens to activate sirens manually and to warn public
from vehicles and loudspeakers.
2. Develop procedures to confirm activation of every siren. Specify
numbers of vehicles and personnel required for #1 above.
3. Test sirens weekly on the same day and at the same time.
4. Identify hearing impaired people and install telecommunication devices.
5. Provide closed captioning for the Emergency Broadcasting System.
6. Install tone alert radios in every school bus, transport vehicle, and
other vehicle specially licensed to transport children, the elderly, and
handicapped persons in the Emergency Preparedness Zone.
7. Upgrade Plymouth County Radio network hardware. Test the hardware on a
regular basis.
64
EVACUATION ROUTES - LIMITED ACCESS AND EGRESS
DEFICIENCIES;
1. Proposed routes (Routes 3 and 44) are completely inadequate for
effective handling of anticipated volume of traffic. Traffic is already
jammed due to the heavy volume of tourists in the summer months, and
during heavy winter storms, or when roads are under construction or
repair.
2. Voluntary evacuation (Evacuation Shadow Phenomenon) is not taken into
account .
RECOMMENDATIONS :
The following are not remedial; they simply address worsening of the
problem.
1. New development along evacuation routes should require an impact study
by developers with specifications set by appropriate Town Offices. The
study should be reviewed by the Planning Committee.
2. Prior to approval of road construction/repair (along evacuation routes)
the appropriate Town Office must make an impact assessment and develop
alternative routes.
D. EVACUATION TIME ESTIMATES
DEFICIENCIES:
Present time estimates are based on outdated information and have major
f laws .
Evacuation Time
assumptions :
Estimates (ETE) is based on several questionable
It assumes there will be no mass voluntary evacuation not in
planned boundaries (shadow-phenomenon) as occurred at Three Mile
Island, which could cause major route blockage and back-ups.
It assumes that emergency personnel will remain in place and not
evacuate with their families.
It assumes that communities outside the Ten Mile EPZ have developed
adequate plans to augment evacuation and sheltering efforts,
although Massachusetts Civil Defense Agency (MCDA) states no such
plan exists.
It assumes the timely presence of State Police and National Guard.
Large discrepancies exist between
Regulatory Commission (HRC) ETE's.
Boston Edison and the Nuclear
EVACUATION TIME ESTIMATES (Continued)
4. Panic and traffic disorder have not been adequately considered:
a. Blocking of cross streets
b. Disregard of traffic signals
c. Driving in left hand lane
d. Abandoned vehicles
e. Driver confusion
f. Failure of traffic control
g. Accidents
These considerations plus ineffective traffic control could result
in more than a 50% reduction in traffic flow, which would mean the
evacuation time could be more than doubled.
5. No adequate estimates for time required to evacuate non-car-owning
people dependent on public transport.
6. Estimates of the number of vehicles at public beaches is inadequate.
7. Estimates required by federal regulations are lacking.
a. Separate times for adverse weather - fog, rain, flooding, snow,
storms .
b. Day versus night, workday versus weekend, peak transient versus
non-peak transient, and evacuation versus non-evacuation in
adjacent sectors.
c. Separate estimates for "special population groups" on an
"institution by institution" basis (e.g., schools, hospitals,
nursing homes, correctional facilities).
RECOMMENDATIONS :
1. The new Boston Edison Company (BECo) ETE's must:
a. be based on realistic assumptions,
b. include all specific time estimates required by FEMA,
c. take into account mass voluntary evacuation consequences,
d. address previously stated shortcomings.
2. The new £TE must be completed prior to plant operation.
3. Documentation should be provided by BECo to assure the ETE's provide a
workable means to evacuate all residents of the EPZ based on a wide
range of accident scenarios.
66
E. FLAMS TO TRANSPORT DEPENDENT POPULATION
(People without access to cars, school children and children in day
care, hospital and nursing home residents, handicapped persons, campers,
persons in correctional institutions.)
DEFICIENCIES:
1. Numbers of vehicles needed and sources for them have not been analyzed.
2. No contracts or letters of agreement have been signed with MBTA, bus
companies, drivers, ambulance companies, and other entities providing
public transportation and personnel support for the plan.
3. There are no particular plans for evacuating handicapped people. This
segment of the population has not even been identified.
4. Plans call for individuals to make arrangements with local CD for
transportation. Local CD will then contact MCDA Area II for assistance;
however, the Area II plan does not contain information on how to procure
additional transportation.
5. Schools - There are no separate plans or procedures for each school and
day care center. Bus companies and drivers have not signed agreements
to perform during an evacuation. The school plan lacks detailed pro-
cedures. Estimated time to mobilize National Guard for schools is three
hours, and Guardsmen may not be familiar with road network.
RECOMMENDATIONS:
1. Conduct a survey to determine transportation needs of all people
dependent on public transportation in all sectors of EPZ. Provide
specific and separate information for summer/non-summer, weekday/weekend
populations .
2. Document available resources and resource needs, such as transportation
contractors, trained personnel, drivers trained in emergency response
procedures, special care personnel and equipment for disabled persons.
3. Obtain written agreements with transportation contractors and drivers.
A. Develop specific, adequate plans to evacuate each dependent group, such
as the population in nursing homes, hospitals, schools, camps,
residential homes, correctional institutions, day care centers.
5. Provide for special needs population - physically and mentally
handicapped people:
a. Provide notification in advance of special evacuation procedures
for disabled people;
b. Plan for delivery of necessary services during an emergency with
trained assistance for each handicapped person designated
beforehand ;
c. Provide beepers, backup personnel for vacation times, special
equipment and medications.
7
67
F. RECEPTION CENTERS AND SHELTERS
Bridgewater State College and Taunton State Hospital
DEFICIENCIES:
1. There are no clearly defined functions for the reception centers and
shelters .
2. There are no letters of agreement, or contracts with reception centers.
(Who provides what and who pays?)
3. There are no adequate plans, equipment, supplies or personnel to
implement purposes for reception centers. (Such as contamination
monitering, decontamination, congregate care, ...)
4. Public shelter locations are not identified.
5. Adequate plans for public shelters are non-existent (personnel,
supplies, etc.)
6. Resettlement and/or reentry plans have not been formulated.
7. The option of sheltering in private homes versus evacuation is not
addressed .
RECOMMENDATIONS :
1. Define specific and separate functions for public shelters and reception
centers .
2. Specify conditions for which sheltering in private homes might be
preferable to evacuation.
3. Conduct survey of potential shelters adequate to accommodate peak summer
populations .
4. Identify and contract for an adequate number of reception centers and
public shelters to accommodate EPZ population.
5. Provide adequate plans for equipment, supplies and personnel for centers
and shelters.
68
G. MEDICAL FACILITIES
DEFICIENCIES:
1. There are inadequate plans for treating large numbers of victims of
radiation exposure.
2. The two hospitals listed in the Flan (Jordan and St. Luke's) can treat
only a limited number of people with radioactive contamination.
3. One hospital is within the EPZ and could be simultaneously receiving and
evacuating patients.
RECOMMENDATIONS :
1. Clearly determine response capacity of Jordan and St. Luke's Hospitals.
2. Identify all possible referral hospitals outside EFZ.
3. Document capacity, types of care and provisions available at referral
hospitals outside EFZ.
4. Obtain signed agreements with referral hospitals.
5. Develop procedures for transportation of patients outside the EPZ.
H. RADIOFROTECTIVE DRUGS
PRESENT POLICY:
The Massachusetts Department of Public Health does not advise distribu-
tion to the general public of Potassium Iodide (KI) as a radioprotective
drug.
RECOMMENDATION:
That the Department of Public Health provide for the distribution of
Potassium Iodide or a proven alternative to the general Plymouth population
prior to reactor start-up.
In conclusion, the Committee notes, once again, that the deficiencies
identified herein and the recommendations made relative to the Plymouth RERP
are by no means exhaustive or all-inclusive. Those listed are, however,
serious enough that, were they not to be addressed, the selectmen might be
unable to "... provide for the health and safety of persons and their
property ..." during a radiological emergency. Hence, the Committee respect-
fully urges the Selectmen to give immediate attention to the matters con-
tained in this report. Even after the current revision of the RERP and the
implementation of recommendations, regular monitoring by the Town will be
needed so that improvements in the plan may be made as they become necessary.
69
TOWN OF PLYMOUTH
COMMITTEE ON NUCLEAR MATTERS
COMMITTEE REPORT
ENVIRONMENTAL RADIATION MONITORING
PILGRIM NUCLEAR POWER STATION
December 1987
70
COMMITTEE MEMBERS:
Grace M. Healy, Chair
Charles W. Adey, Vice-Chair
Ann Waitkus Arnold
Theodore L. Bosen
Marie P. Fehlow
Kathleen M. Leslie
Anthony V. Lonardo
John P. Rooney
Howard E. Shetterly
SUBCOMMITTEE MEMBERS:
Kathleen M. Leslie, M.D.
Marie P. Fehlow, R.N,
The Connnittee thanks Mrs. Pauline M. Howe for her invaluable
assistance in editing and typing this Report.
71
REPORT ON
PILGRIM NUCLEAR POWER STATION
ENVIRONMENTAL RADIATION MONITORING
OVERVIEW
The Committee on Nuclear Matters, in an attempt to understand the monitoring
of environmental radiation associated with the Pilgrim Nuclear Power Station,
reviewed documents provided by Boston Edison and interviewed knowledgeable
persons, including but not limited to Boston Edison representatives, Nuclear
Industry representatives, Department of Public Health representatives and
State Officials.
The Committee on Nuclear Matters is strongly concerned with what it considers
to be the insufficient number of monitoring stations, the minimal involvement
of the State in the monitoring process, and the complete lack of an
"oversight" monitoring system.
The Committee respectfully urges the Selectmen to consider well these
recommendations and to request both Boston Edison Company and the
Commonwealth of Massachusetts to act expeditiously on these recommendations,
which the Committee considers to be basic and modest.
INTRODUCTION
This document contains Committee recommendations, with a sampling of the
pertinent materials reviewed. The latter are intended to provide some
background for the recommendations made herein.
There are two sections in this document:
Section I: Summary, Conclusions and Recommendations
Section II: Background Materials
* Excerpts from PNPS-1 Environmental Monitoring Program Reports
Numbers 15, 17, 18.
* Excerpts from PNPS-1 Environmental Monitoring Program Report
Number 19 and Radioactive Effluent and Waste Disposal Report
January - June 1987.
* Department of Public Health Monitoring Program.
* Glossary
It should be noted that Section II is only an outline of "Findings." The
reader is referred to the complete Boston Edison Program Reports, which are
available at the Plymouth Public Library.
72
SECTION I
SUMMARY, CONCLUSIONS AND RECOMMENDATIONS
RADIATION MONITORING AMD THE PILGRIM NUCLEAR POWER STATION
SUMMARY
1) The presence of Pilgrim Nuclear Power Station (PNPS)-related isotopes
has been documented offsite in shellfish, ocean fish, algae, ocean floor
sediment, and garden produce. In addition, PNPS-related isotopes are
present in water samples from the discharge canal, and a single isotope,
H-3 (Tritium), has been found in a nearby pond. Onsite locations that
monitor for airborne radiation are positive for Co-60 (Cobalt).*
2) Environmental radiation monitoring:
a) Airborne radiation is measured weekly for beta particles,
quarterly for gamma radiation.
b) Thermoluminescent Dosimeters (TLDs), which monitor gamma radiation,
are analyzed quarterly.
c) Liquid effluent from the plant's discharge canal is analyzed weekly
by Boston Edison and monitored weekly by the Department of Health
(DPH).
d) Stack monitors which record gaseous, particulate, and Iodine
(1-131) releases from PNPS are reviewed weekly by the DPH and
analyzed weekly by Boston Edison.
3) Monitoring data are made available to the public in the local library
six months after the year ends. (Environmental Radiation Monitoring
Program Report.)
4) The NRC has faulted Boston Edison's TLD program in the SALP Report for
November 1, 1985 through January 31, 1987:
"... problems were identified in the licensee's environmental
thermoluminescent dosimeter (TLD) program. Commitments made by the
licensee during previous assessment periods to improve the
environmental TLD program were not implemented. Because of these
problems, the validity of the environmental TLD data cannot be
assured. This indicated lack of management involvement in this
area and a lack of understanding and thoroughness with regard to
resolution of technical issues."
5) Monitoring of residential areas contiguous to the plant is virtually
non-existent.
6) The DPH, NRC, and Boston Edison do not react quickly enough and strongly
enough, with additional monitoring — particularly offsite, when there
are unplanned radiation releases.
* Throughout this report, symbols such as Co , are written as Co-60.
This representation is used extensively in Boston Edison and State reports
and in non-technical informational materials.
73
CONCLUSIONS
All of the Reports reviewed by the Committee on Nuclear Matters (1982-1987)
indicate to its members that the Pilgrim Nuclear Power Plant does have a
continuing environmental impact. In all of the materials reviewed, however,
Boston Edison Company, the N.R.C., and the Commonwealth hold that offsite
releases from the Plant (as indicated by current monitoring) have not
exceeded technical specifications. Boston Edison Company, the N.R.C., and
the Commonwealth then draw the conclusion that there has been no measurable
impact upon the citizenry. They further claim that even if there had been
any impact it would have been minimal, and far less than the effects of
previous worldwide weapons testing or of the Chernobyl accident.
The Committee on Nuclear Matters takes little comfort in the above
comparisons. Any environmental impact is of concern and needs to be examined
if public health is to be protected. The Committee questions the adequacy of
current monitoring around Pilgrim I, even though it may be more extensive
than that at some other nuclear plants. Hence, the Committee recommends
increased monitoring, higher quality monitoring, proper timing of monitoring
to reveal effects of specific plant incidences which involve radioactive
releases, and prompt reporting of the results. Accomplishment of these
recommendations is basic to an investigation of the impact of PNPS upon
citizens' health.
74
RECOMMENDATIONS
1. The Commonwealth of Massachusetts should establish a comprehensive,
state-of-the-art radioactive monitoring system, the purpose of which is
to measure instantaneously the type and quantity of radioactive
emissions and effluents at each release point of nuclear reactors. The
intent of the Committee in this recommendation is the establishment of
an independent monitoring (oversight) system which will go far beyond
the minimum monitoring now done by the Department of Public Health.
2. Such a system will require substantial resources. To that end, the
owners of nuclear power plants within the Commonwealth of Massachusetts
should be assessed the costs of establishing and operating the
comprehensive, state-of-the-art monitoring system.
3. Since an extended time period will be involved in bringing this
comprehensive monitoring system on line, the following immediate
response is recommended:
As an interim measure, the committee recommends that a qualified state
team should be established as soon as possible to monitor plant
activities relative to radiological releases which affect the well-being
of the citizenry. This team will be located onsite and report to
appropriate State decision makers. This will not be a continuing
arrangement, but merely a first step toward the permanent system
specified in recommendation number 1.
4. Boston Edison should increase its air particulate, gaseous radioiodine
and soil surveillance stations. These additional stations should be
adequate to ensure that no substantial radioactive material can be
released without detection.
5. Boston Edison should install additional TLD's around the Plant to ensure
reliable quantification of total offsite dose rate.
6. Boston Edison should increase the numbers of samples collected and the
locations and frequency of collection of shellfish.
7. Boston Edison should improve quality control with respect to its
radiation monitoring so that equipment failure is immediately
recognized.
75
SECTION II
BACKGROUND MATERIALS
PILGRIM NUCLEAR POWER STATION
ENVIRONMENTAL RADIATION MONITORING PROGRAM
Excerpts from REPORT NO. 18 (1985), REPORT NO. 17 (1984) and REPORT NO. 15
(1982).
ENVIRONMENTAL RADIATION
A. AIRBORNE
Airborne radiation is monitored at the locations listed by Boston Edison
in table 4.8.2. of Report #18. (See the following page.) Particulates,
radioiodine, and soil are sampled. The collection system consists of a
cellulose particulate filter and a charcoal filter cartridge which are
used to collect particulate matter and iodine nuclides respectively.
Analyses of the particulate filters for beta radiation is performed
weekly. 1-131 analyses are performed weekly as well. In addition
quarterly composite particulate samples are tested for gamma emitting
nuclides. Soil analyses are performed once per three years for gamma
isotopes.
FINDING
Cobalt (Co-60), attributed to operation of PNPS, has been found at
onsite locations including the overlook, pedestrian bridge, and
warehouse. It has been identified in the soil at the pedestrian bridge.
B. DIRECT
Dosimeters, located at twenty areas (as listed in table 4.8.3) are
analyzed on a quarterly basis for gamma radiation.
FINDING
According to Boston Edison, "beyond the 'exclusion area' (for this
purpose, the, 0.25-0.7 mile region), dose rates show no significant plant
effect "
Environmental Radiation Monitoring Program, Report No. 18 (1985),
pp. 3-16, 3-17.
76
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77
C. WATERBORNE
Waterborne radiation is monitored at the plant's discharge canal, at
Bartlett Pond (which is 1.7 miles SE of the plant) and at Powder Point
Bridge (which is 7.8 miles NNW of the plant). Discharge canal samples
are collected every one-half hour; weekly "grab samples" are taken from
the Bartlett Pond and from Powder Point Bridge seawater. Analysis is
monthly for gamma isotopes and quarterly for H-3 .
FINDING
Cesium (Cs-137), Cobalt (Co-60), and Tritium (H-3) have been present in
discharge canal samples. H-3 has been found at Bartlett Pond. These
isotopes, according to Boston Edison, are attributed to operation of
PNPS.
D. AQUATIC
Aquatic samples include shellfish, Irish moss (algae), lobster, fish and
ocean floor sediments.
1. Shellfish
Shellfish samples are analyzed quarterly for gamma isotopes.
Locations sampled are discharge outfall, Duxbury Bay, Manomet
Point, Plymouth or Kingston Harbor, and Marshfield.
FINDING
Samples from the discharge canal have been positive for Mn-54,
Zn-65, Co-60, Co-58, and C8-137. Samples from Manomet Point have
been positive for Mn-54, Co-60, Cs-137, Zn-65. Testing for Co-60,
Cs-137 has been positive in Warren Cove samples. According to
Boston Edison, all of these isotopes are attributable to operation
of PNPS.
2. Algae
Algae samples are collected quarterly from the discharge canal,
Manomet Point, and Ellisville.
FINDING
Samples from the discharge canal have demonstrated Zn-65, Cs-137,
Mn-54, Co-58 and Co-60. Algae from Manomet Point have demonstrated
Mn-54 and Co-60. Ellisville has been positive for Mn-54 and Co-60.
According to Boston Edison, all of these isotopes are attributable
to operation of PNPS.
3. Lobster
Lobster is collected four times per season in the vicinity of
discharge point and annually offshore. It is analyzed for gamma
isotopes.
FINDING
No plant attributable isotopes were found.
7
78
4. Fish
Gamma isotopic analyses are performed from four separate fish
groups: bottom oriented, near bottom, anadromous, and coastal
migratory. They are caught in the vicinity of the discharge canal
as well as at a control point at a distance offshore. Analysis is
quarterly for bottom and near bottom fish, in season for anadromous
and coastal migratory. A control analysis from fish caught
offshore is performed annually.
FINDING
j Bluefish and cod samples from the discharge canal have been
/ positive for Cs-137. A salmon sample from the mouth of the North
/ River in Hanover was positive for Cs-137. This isotope was
< attributed by Boston Edison as being due to radioactive releases
— from PNPS.
5. Sediments
Sediment samples are taken semi-annually at Rocky Point, Warren
Cove, Plymouth Harbor, Duxbury Bay, Plymouth Beach, Manomet Point,
and a control point in Marshfield.
FINDING
Analyses performed at Duxbury Bay, Plymouth Beach, Warren Cove,
and Marshfield demonstrated Cs-137. This is attributed "....to
some extent..." to the fission products related to fallout from
previous weapons testing. Rocky Point, Manomet Point, Duxbury Bay
have had positive values for Co-60 which Boston Edison attributes
to operation of PNPS.
E. TERRESTRIAL
Terrestrial samples include milk, cranberries, vegetables, and beef
forage or cattle feed.
1. Milk
Milk is collected from the cows at the Plymouth County Farm and
Whitman Farm, semi-monthly when the animals are on pasture,
otherwise at a monthly interval. Analyses for gamma isotopes,
Sr-87, Sr-90, and 1-131 are performed.
FINDING
The 1982 Report states that of the isotopes present, i.e., Sr-90,
Sr-89, Cs-137, ",..PNPS-1 probably contributed much less than 0.01%
of the measured concentration..." Most is attributed by Boston
Edison to fallout from nuclear weapons testing.
Environmental Radiation Monitoring Program, Report No. 17 (198A),
p. 3-47.
8
79
2. Cranberries
Cranberries from a Manomet Point Bog (2.6 miles SE), Bartlett Road
Bog (2.8 miles SSE/S), and Pine Street Bog (17 miles WNW) are
analyzed for gamma isotopes at the time of harvest.
FINDING
Cs-137 has been found at the Manomet Point Bog at a level
greater than ten times average background for that isotope. A
comprehensive study of cesium uptake in cranberries was performed
during 1978. This report identified fallout from previous nuclear
weapons testing as the primary source of cesium in cranberries.
3. Vegetables
Vegetable samples are collected at the Karbott Farm and Bridgewater
Farm as well as other nearby gardens.
FINDING
Co-60 at farms 1.5 miles SSW and 1.0 miles W were attributed to
controlled releases from PNPS. In addition, Cs-137 present in the
sample at the farm 1.5 miles SSW was attributed to PNPS.
4. Beef Forage
Beef forage is tested annually from the Plymouth County Farm,
Whitman Farm, and Bridgewater Farm.
FINDING i
No plant related isotopes have been found.
It might be of interest to the reader to note the selected gamma exposure
data from the 1982 Report which are found on the following pages. If one
compares gamma exposure across each of the quarters at each station listed,
one can clearly see some patterns of increased exposure. There are, however,
inconsistencies between the distance of some stations from the Plant and the
level of reading obtained during a given quarter.
Such inconsistency needs to be addressed by Boston Edison and by the
Commonwealth. At the least, there should be an increase in the numbers of
TLD's, particularly in areas contiguous to the Plant. Stations should form
a tight ring around the plant and rings should be replicated, as far as
feasible, in circles of widening radii.
Environmental Radiation Monitoring Program, Report No. 15 (1982),
p. 3-69.
80
GAMMA EXPOSURE (TLD) SELECTED DATA FOR FOUR QUARTERS OF 1982
Distance and Microrads per Hour
Station Location Direction . Quarter of 1982:
(Designation) from Reactor First Second Third Fourth
OFFSITE STATIONS:
East Weymouth (EW) * 23 miles NW
Kingston (KS) 10 Miles WNW
Sagamore (CS) 10 miles SSE-S
Plymouth Airport (SA) 8 miles WSW
North Plymouth (NP) 5.5 miles WNW
Plymouth Center (PC) 4.5 miles W-WNW
South Plymouth (SP) 3 miles WSW
r- 1^ Manomet (MS) 2.5 miles SSE
.^ Manomet (ME) 2.5 miles SE
-- Manomet (MP) 2.25 miles ESE-S
^ Cleft Rock Area (CR) 0.9 miles S
* Control Station.
ND No Data due to missing TLD.
Continued
10
4.00
8.30
11.84
8.62 74c_,^
4.41
6.45
8.14
8.55 ^-^v,
5.22
ND
6.82
6.50 ^G^j-u
2.68
5.89
15.40
6.87 ^^(^.^
4.59
8.47
14.11
8.21 -iU.,^
ND
4.60
7.62
6.01 y'llo^^^
5.91
6.80
12.91
6.61 °i ^^J
4.73
8.28
20.77
9.28 <5U.^^
6.46
9.33
16.43
HD Vl«^
5.11
7.19
10.91
7-59 Hv,,^
7.97
8.89
15.52
8.57 -/^o^
81
GAMMA EXPOSURE (TLD) SELECTED DATA FOR FOUR QUARTERS OF 1982
Distance and Microrads per Hour
Station Location Direction Quarter of 1982:
(Designation) from Reactor First Second Third Fourth
ONSITE STATIONS
Rocky Hill Road (ER) 0.8 miles SE
Microwave Tower (MT) 0.38 miles S
Rocky Hill Road (WR) 0.3 miles W-WNW
Rocky Hill Road (B) 0.26 miles SSE
Property Line (H) 0.21 miles SSW
Property Line (I) O.IA miles W
Public Park. Area(PA) 0.07 miles N-NNE
Overlook Area (OA) 0.03 miles W
Property Line (PL) 0.34 miles NW
Ped. Bridge (PB) 0.14 miles N
East Breakwater (EB) 0.35 miles ESE
Warehouse (WS) 0.03 miles SSE
4.63
6.14
6,91
10.84
^^/^c^
4.06
9.55
13.21
9.44
A.J
4.64
11.22
17.15
9.85
4.02
8.94
8.28
11.15
k<Uo^
8.11
15.97
11.43
12.89
4.34
8.98
10.93
9.31
5.07
8.73
11.26
7.30
lyeio K^
6.95
22.51
30.99
22.97
^J^-" i-'t^
4.38
7.29
11.75
10.31
^-^
8.32
17.49
22.81
17.60
^^^
4.84
8.18
10.10
7.77
6.38
10.83
26.60
14.03
q.i^-s
Geographic Regional Averages:
Near Plant 0 - 0.16 miles 09.18 14.89 22.92 15.47
Exclusion Area 0.25 - 0.68 miles 5.54 9.10 11.22 9.56
Distant Neighborhood 0.7 - 6.5 miles 4.39 8.03 11.74 7.86
Background 8-21 miles 4.08 6.87 10.55 7.63
* Control Station.
ND No Data due to missing TLD.
11
82
PILGRIM NUCLEAR POWER STATION
ENVIRONMENTAL RADIATION MONITORING PROGRAM
Report Number 19
January 1 - December 31, 1986
The following information was excerpted from the above mentioned report when
it became available from Boston Edison Company. Only "Findings" are included
herein since explanations of data collection locations and methods were
described earlier.
RESULTS OF ANALYSES
A. AIR PARTICULATE FILTERS
FINDING
There were no positive measurements of any nuclides characteristic of
reactor operations attributable to PNPS-1 observed in the quarterly
composite samples. There were positive measurements of nuclides
characteristic of reactor operations attributable to the Chernobyl
Nuclear Power Plant accident in the second quarter composite samples.
These nuclides were: Ru-103, Cs-134 and Cs-137. In addition, high
concentrations of Be-7 were also seen.
B. IODINE
FINDING
As a result of the Chernobyl accident, positive indications of 1-131
were detected in the charcoal filters in all stations from week #20
through week #24 (late May to early June) with the highest
concentrations seen during week #21.
C. SOIL
FINDING
Soil analyses are performed once every three years for gamma isotopes.
See 1982 report.
D. DIRECT RADIATION
1. CONTINUOUS TLD
FINDING
Beyond the "exclusion area" (for this purpose, the 0.25-0.7 mile
region), dose rates show no significant plant effects.
2. FIELD SURVEY
FINDING
Survey results are within the expected natural background exposure
rates in the northeastern part of the United States.
12
83
E . WATERBORNE
FINDING
There were no positive measurements of nuclides characteristic of
reactor operation observed at any of the three sampling locations. The
only positive measurements observed were due to naturally occurring
nuclides (K-40 and AcTh-228).
F. SHELLFISH
FINDING
There have been positive measurements of Be-7, Mn-54, Co-60, AcTh-228
and K-AO in samples from the Discharge Canal. In addition, there have
been positive measurements of Be-7, AcTh-228 (peak) and K40 at Warren
Cove; AcTh-228 and K-40 at Duxbury Bay; and Be-7, AcTh-228 and K-40 at
the control station in Marshfield. Tl\|gj;:£_vrasone positive measurement
of Ru-103 at Manomet Point in a sample which was collected on 7/8/86.
The observed concentrations of Mn-54 and Co-60 were the result of PNPS-1
liquid releases. "Qie contribution of Ru-103 was due to Chernobyl-
related radioactivity^ The observed concentrations of Be-7, AcTh-228
and K-40 are due to the natural occurrence of these nuclides.
G. ALGAE (IRISH MOSS)
FINDING
There have been positive measurements of Be-7, Co-60, Ru-103 and K-40 at
the Discharge Canal. In addition, there have been positive measurements
of Be-7, Co-60, Ru-103, 1-131, AcTh-228 and K-40 at Manomet Point
(Station 15-3 miles-SE); and Be-7, Co-60, AcTh-228 and K-40 at the
control station at Ellisville (Station 22-8 mi-SSE).
The measured concentrations of Co-60 at the Discharge Canal are
certainly due to liquid effluents from PNPS-1. The observed
concentrations of Co-60 at Manomet Point and Ellisville were the result
of PNPS-1 liquid releases. The highest concentration of Co-60 was seen
at the Discharge Canal.
H. LOBSTER
FINDING
The results are unremarkable in that there were no positive measurements
of any isotopes other than K-40 in either the indicator or the control
samples (K-40 is a naturally occurring nuclide).
13
84
I. FISH
FINDING
A striped bass sample collected on 10/2/86 at the Discharge Canal
Outfall Area indicated a positive measurement of Cs-137.
J. SEDIMENTS
FINDING
It is clear that positive measurements of Co-60 and Cs-137 were
observed. The highest concentration of Co-60 was observed in a sediment
sample (24-26 cm) taken from Rocky Point (Station 11) on 5/19/86. In
addition, Co-60 was observed in all of the sediment segments (0-30 cm)
obtained from Rocky Point on 5/19/86 and in two sediment segments (16-20
cm) from Duxbury Bay collected on 5/29/86. The concentrations of Co-60
at Rocky Point are due to liquid .affluents from PNPS-1 . The
concentration of Cs-137 at the 24-26 cm level from Rocky Point was most
likely due to controlled liquid releases from PNPS-1. The measured
concentration of Be-7 , and to some extent Cs-137, at Duxbury Bay,
Plymouth Harbor and Marshfield are attributable to the fission products
related to fallout from previous weapons testing. ,
K. MILK
FINDING
The positive measurements of 1-131 in the samples from week #19 through
week #27 (late May until early July), and the positive measurements of
Cs-134 and Cs-137 from week #21 through week #27 were attributable to
Chernobyl-related radioactivity. There was only a small amount of
strontium released during the Chernobyl accident which resulted in
negligible Sr-89 and Sr-90 in the Chernobyl-related radioactivity.
The highest concentration of Sr-90 occurred at Plymouth County Farm
(collected on 9/4/86) and the highest concentration of Sr-89 occurred at
the Plymouth County Farm (collected on 6/19/86). However, there were no
positive measurements made of either Sr-89 or Sr-90, there were only
indications of the presence of Sr-90. It is unlikely that PNPS-1 is the
major source of the indicator station activity.
Prior to week #21 and after week #27, the highest concentration of
Cs-137 occurred at Plymouth County Farm (3.5 mi-W) in early September
(Collected on 9/4/86). Edison claimed that the primary source of Cs-137
was other than PNPS-1, and was most likely due to fallout from previous
atmospheric weapons testing.
14
85
L. CRANBERRIES
FINDING
The only manmade radionuclide detected was Cs-137, which appeared in the
Manomet Point Bog sample (collected on 9/23/86). Claim was again made
that the measured concentration was due to fallout from previous weapons
testing and a lack of adequate potassium in the soil.
M. VEGETATION
FINDING
The only nuclides observed, other than naturally occurring Be-7,
AcTh-228 (peak) and K-40, was Cs-137. A positive measurement of Cs-137
was detected in vegetation collected from two locations on 9/16/86.
Because of the absence of Cs-134 Edison again concluded that weapons
testing fallout was the primary source of Cs-137.
N. FORAGE
FINDING
The following positive measurements were detected at two stations: Be-7,
Ru-103, Cs-134, Cs-137 and K-40. The beef forage samples were both
collected on 6/19/86. Edison again concluded that the contribution of
Ru-103, Cs-134, and Cs-137 were due to the Chernobyl accident.
In addition to the above data from the 1986 Report, some data from the
Radioactive Effluent and Waste Report (January - June 1987) can be found on
the following page. These data are of interest in that they demonstrate
continued releases of materials into Cape Cod Bay during periods of Plant
shut-down. Plant decontamination accounts for increased numbers of batch
releases. (The decrease in average stream flow in number 6 was due to the
use of one pump rather than three.)
15
86
SOURCES OF DATA:
PILGRIM NUCLEAR POWER STATION
ENVIRONMENTAL RADIATION MONITORING PROGRAM
REPORT NUMBER 19
January 1 - December 31, 1986
AND
RADIOACTIVE EFFLUENT AND WASTE DISPOSAL REPORT
January 1 - June 30, 1987
BATCH RELEASES OF RADIOACTIVE MATERIALS IN LIQUID EFFLUENTS
INTO CAPE COD BAY
January July to January
to June December to June
1986 1986 1987
1. Number of batch releases 143
125 211
2. Total time period for
batch releases (Hours) 368.7 216.7 439.7
3. Max-i'mum time period for
a batch release (Hours) 8.42 10,4 16.2
4. Average time period for
batch releases (Hours) 2.57 1.7 2.0
5. Minimum time period for
a batch release (Hours) 0.25 0.08 0.25
6. Average stream flow during periods
of release of effluent into a
flowing stream (Gallons per
""■""'^^ 234,500 155,000 79,200
16
87
DEPARTMENT OF PUBLIC HEALTH RADIATION MONITORING PROGRAM
This report is based upon data supplied to Dr. Kathleen Leslie and Ms. Marie
Fehlow by Robert M. Hallisey, Director, Radiation Control Program,
Massachusetts Department of Public Health (DPH).
The DPH monitors radiation emissions from PNPS via three routes:
(1) thermoluminescent dosimeters (TLDs), (2) main stack and reactor building
vent monitors, and (3) discharge canal releases recording equipment.
A. TLDs
DPH TLDs have been in place since the third quarter of 1981. They are
located at twenty-four sites within a five-mile radius of the plant.
TLDs measure gamma radiation and are read quarterly. Some State TLDs
are located together with those of Boston Edison and the NRC , some are
located separately. According to Mr. Hallisey, monitoring is necessary
only within the five-mile radius because, should increases in radiation
levels be demonstrated close to the Plant, "doses at further distances
can be calculated using the inverse square law."
FINDING
The State has not found any levels of radiation that exceed background
at their TLD stations.
B. Stack Emissions
The DPH visits PNPS weekly to inspect the automatic strip chart recorder
from the main stack and the reactor building vent for quantitative
release rates from each stack of gaseous effluents, particulates, and
1-131.
FINDING
Inspection of reports from 1/86 - 10/86 revealed no gaseous releases
which exceeded technical specifications.
C. Liquid Releases
The DPH visits PNPS weekly to inspect the recording of liquid releases
from PNPS into the ocean.
FINDING
Inspection of reports from 1/86 - 10/86 revealed no releases of liquid
effluents which exceeded technical specifications.
17
88
GLOSSARY
1) Radiation - Radiation is energy in the form of waves or particles that
can penetrate matter. Although the term "radiation" includes such
things as light or radio waves, it is most often used to mean "ionizing"
radiation, which can produce charged particles ("ions") in materials it
strikes .
2) Ionizing radiation - Has the ability to knock electrons out of atoms,
creating electrically charged ions. These ionized atoms have the
ability to damage living tissue. Examples: x-rays, gamma rays, alpha
particles .
3) Nonionizing radiation - Does not have the above property. Examples:
microwaves, sound waves, light.
4) Radioactivity - Results from the release of radiation from the nucleus
of an atom with an unstable ratio of protons to neutrons in order to
achieve stability.
5) Particulates - Microscopic particles that may be radioactive.
6) Noble gas - A gas that is chemically and biologically nonreactive, e.g.,
xenon and krypton.
7) Alpha radiation - Consists of positively charged particles. Alpha
radiation will be stopped by the outer layer of skin; it can be stopped
completely by a sheet of paper. However, the potential hazard from
alpha emitting materials is due to the possibility of internal
deposition to the body by ingestion or inhalation.
8) Beta radiation - Beta particles are similar to electrons, but originate
in the nucleus of the atom. Beta is more penetrating than alpha
radiation and can pass through 0.5-1 centimeter of water or human flesh.
A sheet of aluminum a few millimeters thick can stop beta radiation.
There is also an inhalation hazard from beta radiation.
9) Gamma radiation - Consists of photons (wave energy) that can be very
penetrating. Depending on the energy levels, gamma radiation can pass
through the body. Dense materials such as concrete and lead are used
for shielding against gamma radiation.
10) Effluent (radiological) - Release of radionuclides originating from the
reactor vessel into the environment.
11) Manmade radiation - Radiation from medical and dental use of X-rays and
radioactive materials to diagnose and treat disease, giving an average
dose of 90 mr/year/person. Another 10 mr/year/person are received from
fallout from nuclear weapons testing, nuclear power plants, industrial
uses of radioactive materials and minute emissions from certain consumer
products such as color television sets.
Continued
18
89
GLOSSARY (Continued)
12) Natural background radiation - Radiation from natural sources such as
cosmic rays, granite, natural gas; an average of 100 millirems/year/
person.
13) Rad - Radiation absorbed dose or amount of energy deposited in living
tissue by ionizing radiation.
14) Rem - A unit for measuring the biological effects on a person from a
dose of radiation. A rem of exposure produces a constant biologic
effect regardless of the type of radiation.
15) Millirem - 1/1000 of a rem.
19
90
The Chairman. Thank you, Dr. Healy. I think we'll hear more
about some of these issues when we hear from some of our State
officials and the relationship between their authority and the
power of the Federal Regulatory Commission, and I look forward to
that.
Let me ask you. Dr. Healy. You're familiar with Dr. Cobbs'
report about the increased leukemia rates that he discovered?
Dr. Healy. Yes.
The Chairman. And we'll make that report a part of the record.
Rather than my reading through that, perhaps you could briefly
describe the conclusions.
Dr. Healy. Well, what Dr. Cobbs did is he made note of the
highly unusual incidents of leukemia in a five-town range, which
includes: Plymouth, Kingston, Duxbury, Marshfield, and Scituate
and what he attempted to do was to connect this incident with ra-
dioactive emissions from the plant.
What he — my understanding is what he hypothesized was that
the topography, the coastal wind circulation and the coastal fogs
formed a natural barrier, which would hold and entrap radioactive
residues from Pilgrim I.
Our committee is aware that there is some disagreement with
the topography-wind hypothesis, but we are checking into it with
our experts, but quite frankly, Mr. Chairman, our committee is not
so much interested in such theories. We are far more interested in
the data that we can get from the field, and those data, and only
those data, we feel from the monitoring, are going to allow us to
get to any causal inferences, and we strongly recommend
The Chairman. Now, the State has looked into this as well, has
it not?
Dr. Healy. The State has used data from — my understanding is
that the State has analyzed and reanalyzed data from the Cancer
Registry, but those data our committee feels are flawed in that the
procedures and the methodology are flawed. It is my understanding
that they are moving toward a comprehensive study at this time,
but our committee will be recommending that we go far beyond the
State to the national level.
The Chairman. I think the suggestions which you make, and
which Mary Ott and others have made with regard to health stud-
ies are excellent suggestions, as we have heard in your testimony,
and read about in preparation for the hearing, and also in some of
the communications that we have received from many of you and
from others. It seems that the kind of pattern that we have heard
here is very similar to the type of pattern that we heard about in
connection with Three Mile Island in 1979 when this committee
held hearings on the health implications of that particular difficul-
ty.
So I have written a letter to the National Institutes of Health, to
Dr. Wyngaarden, who is the Director of the NIH, and asked him to
do a health study. My request for investigation refers to, and I
quote, "reports of excessive leukemia in certain Massachusetts
towns downwind from the Pilgrim I power plant in Plymouth"; and
I have specifically asked him to have his people determine whether
there is a causal connection. I have also told him the he might
91
want to take a look at the problems at Three Mile Island as well. I
have sent that out today.
I will be in touch personally with Dr. Wyngaarden, and as soon
as I get some results or some response, I will share it with you and
other members of the community.
[The information referred to follows:]
92
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COMMITTEE ON LABOR AND
HUMAN RESOURCES
WASHINGTON DC 20510-6300
January 7, 1987
Dr. James B. Wyngaarden, Director
National Institutes of Health
14 North Drive
Bethesda, Maryland 20814
Dear Dr. Wyngaarden:
Over the past year, a number of individuals and groups have
urged the Committee to hold hearings on the subject of adverse health
effects of radiation exposure. They are obviously concerned about
those dangers in the context of potential nuclear power plant
accidents. They are also concerned about those dangers as a
result of the possibility of low-level radiation emanating from
such plants. And, of course, considerable alarm has been
expressed with respect to this subject as it relates to the
accident which occurred at the Three Mile Island (TMI) plant.
It has been my view that hearings may be appropriate at-
such time as there are adequate data available, and when
appropriate scientific inquiries have been conducted. At that
time, a comprehensive public airing of the relevant information,
and consideration of proposals for remedial action could be useful
and productive.
In view o
prompted legit
relating to th
Institutes of
into this enti
taking address
been a causal
excesses of ca
similar report
towns "downwln
Massachusetts ,
that situation
f the number of incidents and situations which have
imate concern, and because of the dearth of data
is subject, it would be helpful for the National
Health (NIH) to conduct an appropriate inquiry
re question. I would urge that such an under-
the question of whether the TMI accident has
factor in what has been described as "observed
ncer." In addition, because there have been
s of excesses of leukemia in certain Massachusetts
d" from the Pilgrim I power plant in Plymouth,
it would be helpful to have your assessment of
as well.
I am sure you are familiar with the studies which have
already been carried out with respect to increased cancer rates
near nuclear test sites in Nevada. Other studies have focused
upon radiation exposure in Colorado and Utah. Those studies,
which have been sponsored by the Department of Energy, the
National Academy of Sciences, and state and local health
93
Dr. James B. Wyngaarden
PaRo 2
departments, have suggested a possible association between the
test sites and the higher incidence of cancer. Accordingly, it
would be appropriate for the NIH, as the foremost biomedical
research center in the world, to address the question of whether
a causal connection does or does not exist. And I would suggest
that such an undertaking use as its first "models" for evaluation
the TMI and Pilgrim I cases which I have described.
You know of my continued confidence in the high quality
work of NIH. I look forward to learning the results of your
examination of this critical health issue.
Edward M
Chairman
94
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
V National Institutes of Health
I \ National Cancer Institute
Ta Bethesda. Maryland 20892
^ JIN < ^: -mi
The Honorable Edward M. Kennedy
Ufiited States Senate
Wasfiington, D.C. ^OSin
Dear Senator Kennedy:
I am pleased to respond to your Ijtter of January 7, 1988 regarding potential
health risks associated with low-level radiation. Specifically, you raised
concerns about the health consequences of nuclear power plant accidents, adverse
effects related to nuclear power plant operations, and cancer risks linked to
radioactive fallout from nuclear weapons testing.
The National Institutes of Health is actively involved in studying the adverse
effects of ionizing radiation, and we concur with your view that the risks at
low lavels need further clarification. We know, of course, that radiation can
cause cancer, but the biological effects of quite low levels are a subject of
current scientific conjecture. Recause new information relevant to the
assessment of low-level risks will be available within the next one or two
years, we do not believe public '^tscussions at this time would oe as fruitful as
they might be in the future. Our reasoning is discussed below.
The descriptive studies of leukemia clusters around the Pilgrim power plant in
Massachusetts, and several plants in the United Kingdom, have led us to initiate
a large-scale evaluation of cancer deaths occurring among persons living near
the over 100 reactors operating in the ilnited States. We are correlating county
mort»'ity data from the 1950s through early 1980s with reactor operations to
determine whether the previous reports might be chance occurr-ences based on
small numbers, or whether there might be valid reasons for concern. This
evaluation should be completed within about one year.
One of the major radioactive isotopes emitted during nuclear power plant
operations, and from nuclear weapons testing, is iodine-131. For the past three
years we have been collaborating with Swedish colleagues on a study of 40,000
patients given low doses of iodine-131 for diagnostic reasons. This large study
will be finished within one year and will prove invaluable in estimating the
possible adverse effects from this environmental contaminant. We have also
evaluated descriptive mortality data regarding possible cancer risks in the
general population living downwind of the Nevada nuclear test site. While many
reported associations are unsupported by these data, a small increase in
leukemia in southwest Utah cannot be ruled out at this time. Our contract-
supported study with the University of Utah should provide more definitive
answers within the next year. Finally, staff members have conducted studies of
the military personnel participating at nuclear weapons tests, and have
confirmed that leukemia was increased above expectation, but apparently only for
participants at one test series. No excess -mortal ity from other malignancies
was found among participants at any test series.
95
Page 7. - The Honorable Edward M. Kennedy
The most serious health impact of the Three 'lile Island (TMI) accident that can
be identified with certainty is mental stress to those living near the plant,
particularly pregnant women and families with teenagers and young children.
Although increased risks of cancer, birth defects and genetic abnormalities are
potential long-term consequences of low-level irradiation, few if any such
effects are likely. The average dose of radiation to the 36,000 people living
within a five-mile radius of the plant was only ?-R mrera, or approximately what
might be received from natural background radiation within one or two weeks.
There is no serious possibility that this dosage would result in any deleterious
effects that could be detected epidemiologi cal ly. (In contrast, at Chernobyl in
the USSR the average dose to the ?4,ono people living near the reactor was
estimated as 44,000 rarem.'l The Pennsylvania Oepartment of Public Health, in
consultation with the Centers for Oisease Control, however, is conducting
periodic health and behavior surveys of the population living near TMI.
Although psychological effects are temporary in most individuals, the ultimate
impact of these effects remains to be fully assessed, as does the degree to
which they may differ from those caused by other accidents or disasters. The
mental stress following T'^I, of course, has been aggravated by the fear that a
larger release of radiation might take place, with consequences that could be
disastrous as now exemplified by the Chernobyl accident. While we are thankful
that such an event has not occurred in the United States, we should profit from
these experiences by taking steps to minimize the risks of such accidents in the
future.
Finally, within two years the National Academy of Sciences and the United
Nations will complete their next reports on the biological effects of low-level
radiation. We are also awaiting the publication of these scientific documents
before embarking upon our next revision of the Radioepidemiological Tables
mandated by Congress.
It is important to stress that useful information about very small health
effects, like those associated with very low levels of radiation, is extremely
difficult and expensive to obtain. An indirect approach, such as studying
populations with higher-level exposures and extrapolating the results to lower
levels, tends to be far more productive. For example, studies of the workers at
nuclear power plants would be particularly informative because the doses, though
low, would be higher than to the general population, and cumulative doses could
reach levels where radiation effects might be detectable, ^y law, radiation
doses ^n recorded on individual workers, and we have contacted the Nuclear
Regulatory Commission about the value of creating a registry of the almost
100,000 workers they monitor each year in the United States. Your encouragement
and support for the development of such a registry would be invaluable and
greatly appreciated.
In closing, I appreciate your continued support for our medical research
program, and I will keep you informed on developments in the area of radiation
studies as results from our investigations become available.
Si ncerely ,
James (i. Wyngaarden, M.O.
Director
■ <»^*f< ««.
96
I think the National Institutes of Health probably has as good a
capability and capacity to do that as any in the country. Hopefully,
they will coordinate their work with the State officials and local
officials as well.
I would hope that they would be able to call on much of the ex-
pertise that we have heard this evening and other expertise as well
in their consideration.
Let me ask, because we want to move on, Mr. Abbott, about one
suggestion that has been made which is whether we ought to have,
create independent of the NRC, an independent body to oversee the
public health aspects of nuclear plant radiation releases. I don't
know if you have any opinions about that. I don't know quite how
we would set it up.
Mr. Abbott. Well, Mr. Chairman, there is a definite perception
of the public that the NRC is still promoting nuclear power, rather
then being most concerned about the health and effect of nuclear
power.
I think part of what I was trying to express was that the percep-
tion of the public was that really nothing was being done to protect
it, and I don't think we have any comfort level that the NEC is
doing it. Whether — I have pleadings to the State of Massachusetts
to have another Federal agency which is to be kept totally inde-
pendent of the promotion of nuclear power; then that might do the
job.
The Chairman. I noted your testimony, Mary Ott, with regards
to the difficulties that you had in getting information, having to
run through the Freedom of Information Act to get that, that is
obviously enormously discouraging. I don't know whether you have
any reaction to some independent health advisory group to monitor
these types of activities.
Of course, we would have to decide who appoints it; who it is ac-
countable to, and whether we are just creating more bureaucracy,
but maybe you can give some thought to it. We might try to circu-
late some suggestions along those lines and try to get some of your
reaction to them.
And, Anne, I'm still troubled by your report in terms of how any
evacuation plan is going to have to deal with some of those who
have physical or mental limitations. You, as I understand, have
made those representations to FEMA, have you?
Ms. Waitkus-Arnold. FEMA, yes.
The Chairman. And I understand that one of the major conclu-
sions FEMA reached when they withdrew their approval was that
the evacuation plan contained inadequate planning for the evacu-
ation of the special needs population.
Ms. Waitkus-Arnold. Right.
The Chairman. And I think you should take some sense of satis-
faction that someone at least listened to what, I think, is really one
of the most provocative, unbelievable things that I've heard in pre-
paring for the hearing. I must say I was absolutely dumbfounded. I
should probably have known about it, but I think it must have
stirred the heart and soul of any citizen to think that that's the
way we're going to treat our fellow citizens, particularly those who
are facing some physical challenge.
97
I want to thank all of you very much. You have been extremely
helpful. I think the questions that you have raised have enormous
potential impact for the people living in the area and throughout
the state. We're very grateful to all of you for your hard work. It is
quite clear from your testimony and from your fuller statements
the amount of time and the expertise that you have put into this
consideration, not only yourselves, but with your fellow citizens. It
is really citizenship at its very best.
I'm grateful to you, and I will take the liberty, when I talk to Dr.
Wyngaarden, to mention each of you, and to send along your testi-
monies, and, hopefully, NIH will have your input when they do
their work. I want to thank all of you for your presentations.
Thank you very much.
[Applause.]
The Chairman. Our next panel is comprised of some representa-
tives and public officials who represent people who live in this
area, and also the representative of one of our foremost public in-
terest organizations. All of these witnesses have worked long and
hard on Pilgrim I questions. I welcome them here this evening to
share with the committee their judgments and concerns.
First, we have Senator Bill Golden, who I'm sure is no stranger
to any of you nor to me. Bill has been unrelenting in his attention
to Pilgrim and I look forward to his testimony.
We'll also hear from State Representative Larry Alexander, who
has previously testified before Congress on Pilgrim. Peter Forman,
State Representative from Plymouth, who led a state legislative
committee effort on the subject of Pilgrim; David Malaguti, who is
the chairman of the Plymouth Board of Selectmen, and who has
devoted a lot of time on the issue; and Ms. Rachel Shimshak, from
the Massachusetts Public Interest Research Group, an organization
which over the last several years has issued three major reports
dealing with the Pilgrim I plant.
I welcome all of you here and look forward to your presentations.
Why don't we go left to right. Three minutes each.
STATEMENTS OF LAWRENCE ALEXANDER, STATE REPRESENTA-
TIVE; PETER FORMAN, STATE REPRESENTATIVE; DAVID MALA-
GUTI, CHAIRMAN OF THE PLYMOUTH BOARD OF SELECTMEN;
AND RACHEL SHIMSHAK, MASSACHUSETTS PUBLIC INTEREST
RESEARCH GROUP
Mr. Alexander. Thank you, Senator. I also would like to thank
you for this opportunity, and I have some additional materials
which I would like to offer to your committee, as an appendix,
along with copies of my testimony.
As chairman — house chairman of the Massachusetts Legisla-
ture's Joint Committee on Energy
The Chairman. Wait a second. I forgot to swear you in.
[Applause.]
[Witnesses sworn.]
Mr. Alexander. Well, if that's the case, let me change my
speech. [Laughter.]
Just kidding.
98
Senator, I testify today with great appreciation for your concern
about this very important subject. I'm State Representative Larry
Alexander. I'm house chairman of the Legislature's Joint Commit-
tee on Energy, and I believe that there are two significant issues
associated with nuclear power that warrant major Federal investi-
gations immediately.
First, Congress should order an in-depth, nationwide analysis of
whether people suffer adverse health consequences as a result of
living near nuclear powerplants. I was delighted to hear about your
request to the National Institute of Health in that regard.
Second, I believe that Congress should order an intense investiga-
tion of the safety systems that operators of European nuclear reac-
tors have added to their nuclear powerplants to determine whether
operators of American nuclear powerplants should make similar
modifications.
Let me discuss each of these two issues in a little more detail.
First of all, with respect to the health effects of living near nuclear
reactors, there is an increasing body of scientific evidence that
seems to suggest that routine and accidental releases of radiation
from nuclear reactors may be causing increased leukemia, cancer,
infant mortality, congenital defects and other adverse conse-
quences.
For that reason, I filed a bill to have Massachusetts set its own
standards for radioactive emissions from nuclear powerplants,
which it is allowed to do under federal law. I'm pleased to say the
bill passed the House, but it has failed to pass the Senate yet, but I
hope that ultimately, we'll be able to pass that law.
The Massachusetts Department of Public Health has found sta-
tistically significant increased incidences of leukemia in communi-
ties near the Pilgrim reactor. There was a 59-percent increase in
blood disorders, including leukemia, for Plymouth, Kingston, Dux-
bury, Marshfleld, and Scituate for the years 1982 through 1984. In
1985, there were three times as many cases of these blood disorders
than would normally be expected for women in Plymouth — six
cases instead of two — and the total increase for the five towns from
1982 through 1985 was a statistically significant 43 percent.
Dr. Sidney Cobb, whom you alluded to earlier, found that there
seemed to be an increase in infant mortality and congenital defect
rates that took place in coastal communities adjacent to or north of
Plymouth soon after significant radioactive emissions were dis-
charged from Pilgrim in the 1970's.
There also seems to be some evidence of perhaps increased leuke-
mia for people living downwind from Maine and Connecticut reac-
tors. And there was a recent study in Lancet magazine suggesting
a possible correlation between proximity to nuclear power plants
and increased leukemia incidences in England.
Therefore, I hope that Congress will do a major analysis of this
issue on a nationwide basis to put this issue to rest one way or the
other for citizens who live near those nuclear powerplants.
Let me turn now briefly to the issue of nuclear reactor safety,
particularly with reference to the General Electric Mark I reactor
found at Pilgrim. I have serious doubts about the adequacy of the
containment structure at Pilgrim.
99
Many European reactors have safety features that American re-
actors don't have. Some, for instance, have a filtered vent to pre-
vent overpressurization and a consequent breach of containment.
The filters trap most of the radiation.
My understanding is that Boston Edison does not plan to put any
filters in the vents that it is going to put in at the Pilgrim plant. I
find that strange. Even the owners of the Shoreham reactor in
Long Island have announced their intention to install a filtered
vent, and I fail to see why the Pilgrim owners do not plan to do so
as well.
Many European reactors also have an additional, independent
decay heat removal system that serves as a type of backup cooling
system in case of failure of the original residual heat or emergency
core cooling system. Some of the European systems have done that,
and yet Boston Edison has not seen fit to install this system here.
If it's good enough for some of the European plants, I wonder why
it is not good enough to have here.
A federal investigation, preferably independent of the NRC,
should be undertaken immediately of the filtered vent, the bun-
kered RHR system, and other European safety systems to deter-
mine whether they should be added to American nuclear power-
plants.
Congress should also consider requiring construction of a second
steel-reinforced concrete containment structure and molten core
barriers before General Electric Mark I-designed plants, such as
Pilgrim, are allowed to continue to operate. Pilgrim should also not
be allowed to restart unless the Governor reaches a threshold de-
termination that an evacuation plan can adequately protect public
health and safety, and local officials and the Governor have ap-
proved such a plan.
Let me add one final word with regard to Pilgrim. I am becoming
more and more convinced that we may not need the power from
Pilgrim.
Boston Edison's own forecast of electric supply and demand
shows that it probably won't need Pilgrim power from 1990 to the
year 2000. With conservation and energy produced by small-power
facilities, we may not need electricity from Pilgrim.
So, therefore, all of us should ask ourselves why we should take a
risk that we don't have to take. All of us should ask ourselves the
ultiniate question, do we really need to take the risk of Pilgrim re-
opening when we may not even need the power it might produce?
[Applause.]
Thank you very much.
[The prepared statement of Mr. Alexander follows:]
100
LAWRENCE R. ALEXANDER
REPRESENTATIVE
exM ESSEX DISTRICT
5-* LONGVIEW DRIVE
MARBLEHEAO MA OI919
TEL 631.7646
ADM
iiSTRATivE Assistant
MELISSA eURKE
HOUSE OF re:pre:sentatives
STATE HOUSE. BOSTON 02133
Charrman
Commtllee on Energy
ROOM 640 STATE HOUSE
Teu 722-2090
Research Director
MICHAEL ERNST
TESTIMONY OF STATE REPRESENTATIVE LAWRENCE R. ALEXANDER,
HOUSE CHAIRMAN OF THE MASSACHUSETTS LEGISLATURE'S JOINT COMMITTEE ON ENERGY,
BEFORE THE LABOR AND HUMAN RESOURCES COMMITTEE OF THE UNITED STATES SENATE
JANUARY 7, 1988
I would like to thank you, Mr. Chairman, and the members of this committee,
for your deep concern over this issue and for holding this important hearing
here in Massachusetts so that you can hear directly from the citizens who
are most affected by the Pilgrim nuclear power plant.
As House Chairman of the Joint Committee on Energy of the Massachusetts
Legislature, I believe there are two significant issues associated with nuclear
power that warrant major federal investigations immediately.
First, Congress should order an in-depth nationwide analysis of whether
people suffer adverse health consequences as a result of living near nuclear
power plants.
Second, Congress should order an intense investigation of the safety
systems that operators of European nuclear reactors have added to their nuclear
power plants, to determine whether operators of American nuclear power plants
should make similar modifications.
Let me discuss each of these matters in more detail.
With respect to the health effects of living near nuclear reactors, there
it an increasing body of scientific evidence that seems to suggest that routine
101
and accidental releases of radiacton from nuclear reactors may be causing
increased leukemia, cancer, infant mortality, congenital defects and other
adverse consequences.
The Massachusetts Department of Public Health has found a statistically
significant increased incidence of leukemias in communities near the Pilgrim
reactor. There was a 59 percent increase in blood disorders including leukemias
for Plymouth, Kingston, Duxbury, Marshfield and Scituate for the years 1982
through 1984. In 1985, there were three times as many cases of these blood
disorders than would normally be expected for women in Plymouth (6 cases instead
of 2), and the total increase for the five towns from 1982 through 1985 was
a statistically significant 43 percent.
Dr. Sidney Cobb, the distinguished epidemiologist who originally identified
this increase in leukemias, has also found that an increase in infant mortality
and congenital defect rates took place in coastal communities adjacent to
or north of Plymouth soon after significant radioactive emissions were discharged
2
from Pilgrim in the 1970's. Evidence also seems to suggest some increased
3
leukemias for people living downwind from Maine and Connecticut reactors.
Dr. Bailus Walker, President of the American Public Health Association, and
a former Massachusetts Commissioner of Public Health, has recommended a regional
analysis of the health consequences of living near nuclear reactors.
Dr. Jay Gould recently released a national study revealing higher infant
4
and fetal mortality rates in counties close to boiling water reactors. He
believes that emissions from nuclear reactors are associated with nearly 9,000
5
excess deaths each year.
The United States is not the only country in which studies show possible
adverse health consequences for people living near nuclear power plants.
A 1987 study in Lancet magazine suggests a significant correlation between
proximity to nuclear power plants and increased leukemia incidence in England.
102
Other studies also suggest a need for further investigation.
While it is very difficult to prove a definite causal link between the
50 million curies of radioactive emissions released from American nuclear
reactors and the specific adverse health effects that people have suffered,
the growing body of epidemiological evidence suggesting the possibility of
such a link makes it imperative that we explore this issue in more detail.
The only way to do this thoroughly is for Congress to order a comprehensive
nationwide epidemiological study of this matter immediately.
Let me now turn to the issue of nuclear reactor safety, particularly
with reference to the General Electric Mark I reactor found at Pilgrim. I
have serious doubts about the adequacy of the containment structure at Pilgrim.
Former NRC Commissioner James Asselstine has stated, "America can expect
to see a core meltdown accident within the next 20 years, and it is possible
that such an accident could result in off-site releases of radiation which
are as large as, or larger than, the releases estimated to have occurred at
o
Chernobyl." American reactors, he notes, "were not designed to withstand
9
large-scale core meltdowns."
Many European reactors, on the other hand, have safety features that
American reactors do not have. Some, for instance, have a filtered vent to
prevent overpressurization and a consequent breach of containment. Their
filters trap most of the radiation. The owners of the Shoreham reactor in
Long Island have announced their intention to install such a filtered vent.
Pilgrim should not restart until and unless Pilgrim has such a filtered vent.
Many European reactors have an additional, independent decay heat removal
system that serves as a back-up cooling system in case of failure of the original
residual heat removal (RHR) system and of the emergency core cooling system.
This back-up system is also independently powered in case of station blackout
and is "bunkered" underground to protect against earthquake damage and sabotage.
103
S«iss authorities have started retrofitting some Swiss reactors with this
system, including an older boiling water reactor.
The Pilgrim reactor was shut down in 1986 due to failures of the RHR
system. It does not have a back-up, bunkered RHR system. If Europeans are
installing additional cooling systems in their boiling water reactors, why
shouldn't Boston Edison install the same system to provide more protection
against meltdowns at the Pilgrim reactor? Boston Edison should install a
bunkered RHR system at Pilgrim before restart.
A federal investigat ion--preferably independent of the NRC--should be
undertaken immediately of the filtered vent, the bunkered RHR system, and
other European safety systems to determine whether they should be added to
American nuclear power plants. Congress should also consider requiring construction
of a second steel-reinforced concrete containment structure and molten core
barriers before General Electric Mark I-designed plants such as Pilgrim are
allowed to continue to operate. Pilgrim should also not be allowed to re-start
unless the Governor reaches a threshold determination that an evacuation plan
can adequately protect public health and safety, and local officials and the
Governor have approved such a plan.
Let me add one final word with regard to Pilgrim. I am becoming more
and more convinced that we may not need the power from Pilgrim. Boston Edison's
own forecast of electric supply and demand shows that it probably won't need
12
Pilgrim power from 1990 to 2000. With conservation and energy produced
by small-power facilities, we may not need electricity from Pilgrim.
All of us should ask ourselves why we should take a risk that we don't
have to take. All of us should ask ourselves Che ultimate question--do we
really need to take the risk of Pilgrim re-opening when we may not even need
the power it might produce?
Thank you very much.
104
FOOTNOTES
1. "Health Surveillance of Che Plymouth Area," Mass. Department of Public
Health, March 16, 1987. (Appendix A)
2. "Testimony of Sidney Cobb, M.D.," presented to the Joint Committee on Energy,
March 24, 1987. (Appendix B)
3. Ibid.
4. "Nuclear Emissions Take Their Toll;" Gould, J.M. et al; Council on Economic
Priorities Publication N86-12; December, 1986, p. 7. (Appendix C)
5. Ibid., p. 9.
6. "Cancer Near Nuclear Installation," Beral, V., Lancet, March 7, 1987, p.
556. (Appendix D)
7. Bibliography of over 100 relevant research papers. (Appendix E)
8 "Testimony of Commissioner James K. Asselstine, U.S. N.R.C., before the
Subcommittee on Energy Conservation and Power of the Committee on Energy
and Commerce," May 22, 1986, p. 3. (Appendix F)
9. Ibid.
10. "International Nuclear Reactor Hazard Study," Anderson, R. et al. Volume
II, September, 1986; v, , ..
"Europeans Head Toward Filtered Vented Containments after Chernobyl,
Nucleonics Week, June 12, 1986.
11 "Muehleberg Begins Backfit for Bunkered Emergency Cooling System," Nucleonics
Week November 13, 1986. Telephone conversations between staff of Commissioner
:KIi^lstine, November, 1986, and staff of Joint Committee on Energy.
12 "Conservation and Load Management," Boston Edison, Exhibit V-1 ("Boston
Edison's Long Range Resource Plan:" Between 1990-2000, Boston Edison
will have more than 500 MW of capacity beyond its reserve capacity needs-Boston
Edison receives less than 500 MW of capacity from Pilgrim), submitted
to the Department of Public Utilities in November, 1987. (Appendix G)
105
The Chairman. Provocative. [Laughter.]
Representative Forman.
Mr. Forman. Thank you, Senator. My name is Peter Forman.
I'm the State representative for Plymouth and Kingston; I'm a resi-
dent of Plymouth. I recently served as house chairman of the legis-
lature's Joint Special Committee to investigate the plant.
I want to congratulate you for this hearing. While many state
and local officials have been quite vocal and active trying to keep
pressure on the NRC, it is obvious that there is little state or local
jurisdiction over nuclear plants, and is almost exclusively under
Federal control. As such, we are very pleased that you have taken
this initiative.
I understood from your staff that the focus of the hearing was
not so much on Edison's performance, rather the performance of
the federal agency, particularly the NRC, who regulates the utili-
ties. So I would like to offer a few broad observations about the
NRC's work.
One of the most commonly heard criticisms is that the NRC is
too much an advocate to nuclear power and not a watchdog. I
would like to give you two examples of how I think some of the
NRC's thinking is oriented to keeping the plants open.
The first is the lack of decommissioning plans. In the many
meetings held, we have come away with a sense that one reason
NRC is reluctant to close any plant is because nobody seems to
know what to do with the plant once it is closed. That sort of per-
petuates an interest in making sure that they are open so those
very tough questions don't have to be addressed immediately.
I would urge, as a previous witness has, that Congress and the
Administration not allow any delay in selecting a Federal disposal
site because I think that's one of the reasons we don't want to ad-
dress the issue of decommissioning.
In the meantime, though, I think everyone would be well served
with decommissioning plans for power plants, including Pilgrim,
and I would like to urge the NRC and Boston Edison, along with
any State, Federal, and local officials to begin planning for decom-
missioning, so area residents and ratepayers and State officials will
know what's in store for us when a plant is permanently closed.
The second example of NRC gravitation toward keeping plants
open is their grading system of plants' performance. We're all fa-
miliar with the SALP reports and their three performance ratings.
None of these rating categories include failures or fail rates. There
are no objective criteria or performance ratings that would trigger
a license revocation or a review of licensee performance. I think
that the public and nuclear industry need to see clear standards as
to exactly what constitutes a poorly run or a failing plant.
The issues surrounding public health are, of course, paramount,
but I get the sense that the NRC works in short-term, incident spe-
cific reviews of whether or not a plant is responsible for any threat
to public health. I would urge the Congress, or an agency other
than the NRC, begin some sort of comprehensive, long-term studies
to the public health impact, if any, around nuclear powerplants.
These studies should include the exposure to health histories, as
well as the cumulative exposure to the general public.
106
I would like to make another general observation about work
place safety not related to radiation exposure. Not too long ago,
Edison had a project to remove asbestos from the plant. One of the
plant employees suggested to me that the work was poorly done
and that there was unnecessary risks of asbestos exposure to the
employees in the area. Questions were raised about as OSHA's abil-
ity to supervise or investigate this problem. And I think some work
needs to be done to insure that the NRC regulations and the indus-
try standard to reduce radiation exposure, as well as NRC's almost
exclusive jurisdiction over nuclear plants, does not reduce nonra-
diation related workplace safety standards.
On another matter, questions have been raised about the rela-
tionship with contract workers in the plant; who do they answer to,
what kind of quality control is achieved and how well do they work
with other employees, and understand the NRC regulations. I
would hope that the NRC will conduct some sort of fuller investiga-
tion into those questions.
As house chairman of the Joint Special Legislative Committee
dealing with Pilgrim, there were two matters that we simply were
not able to resolve. One was the issue of Mark I designs. Is there,
in fact, an increase of containment failure in a Mark I design? Do
these higher risks, if any, compensate for some other measures?
The other is over charges of past releases. And Mr. Abbott, I
think, has probably done the best job in documenting one such re-
lease in 1982.
Should the NRC refuse an adjudicatory hearing on Pilgrim's li-
cense, then, at least I hope the NRC, or your committee, would
have some sort of hearings on these two issues because these are of
critical concern to the area residents, and we simply do not have
the resource in our State legislature to begin sorting out the issues
of past releases or the Mark I containment issue.
Finally, I would like to very quickly touch on the issue of emer-
gency preparedness. The NRC has created what, I think, is a real
jurisdictional mess over the issue of emergency preparedness. By
requiring local approval of plans, the NRC may or may not have
given States the power to close plants. How far this power actually
goes is unclear, but I think it is in everyone's interest that it needs
to be clarified, clarified preferably by Congress, not the NRC. This
should be done as soon as possible, so that state officials will have
some sense as to how much power, if any, state and local officials
have in closing a plant and preventing a plant like Pilgrim from
coming back on line or preventing one from opening up through
the use of the emergency preparedness plans.
Again, Senator, let me congratulate you for focusing some con-
gressional attention on this, and particularly on the NRC and its
role as a federal regulator.
[The prepared statement of Mr. Forman follows:]
107
TESTIMONY OFFERED BY
STATE REPRESENTATIVE PETER FORMAN
BEFORE THE SENATE COMMITTEE ON LABOR AND HUMAN RESOURCES
JANUARY 6, 1988
108
Wi^t Cotranottfoeallif nf ,i3!lassacI{U2ctts
^iouse of ^eptfsentniib^
,^tat£ ^mise, Boston 02133
PETER FORMAN
1ST PLYMOUTH DISTRICT
1 MT PLEASANT ST
PLYMOUTH MA 02360
TEL. 746-0344
ROOM 40, STATE HOUSE
TEL. 722-2240
Commiltees on
Health Care
Insurance
Special Commilteei on
Reapporiionmenl
Pilgrim Nuclear Power Planr
MARGARET GARDNER
LEGISLATIVE ASSISTANT
Senator Kennedy:
My name is Peter Forman . I am the State Representative
for Plymouth and Kingston and a resident of Plymouth.
Recently, I served as House Chairman of the Legislature's
Joint Special Committee to Investigate the Pilgrim Nuclear
Power Plant.
Let me congratulate you for this hearing. While state
and local officials have been quite vocal and active in
keeping pressure on Edison and the NRG, it is obvious that
there is little state or local jurisdiction over nuclear
plants. This is a matter of almost exclusive federal control
and as such we are pleased to see Congressional attention
being focused on this issue.
I understand from your staff that the intent of this
hearing is not so much to review Pilgrim's history or to
investigate the work Pilgrim has been doing. Rather, it
is to review the performance of the federal agencies,
specifically the NRC , in regulating Pilgrim.
One of the most commonly heard criticisms is that the
r^ .. „.. . 1 ,
109
enough of a watchdog. Let me give you two examples of how
NRC thinking is oriented to keeping plants open. One is
the lack of de-commissioning plans.
From the many meetings held on Pilgrim, I have come
away with a sense that one reason NRC is reluctant to close
plants is because nobody seems to know what to do with a
plant once it has been closed. Clearly, part of the problem
is the lack of a permanent disposal or storage site for
the high-level waste. This issue needs to be addressed
and I hope that neither the Congress nor adminisitration
will allow any further delays on selecting a federal site.
In the meantime, though, everyone would be well served
to have decommissioning plans for power plants. I would
like to urge the NRC and Boston Edison, along with state
and local officials, to begin planning for decommissioning.
Area residents should know what will be done with a
permanently closed site. Likewise, the state and utility
ratepayers should know the expected cost of decommissioning.
The second example is of NRC grading of plant
performance. As we have seen in the SALP reports, there
are three performance ratings. None of the three is a failing
grade. There are no objective criteria on performance that
would trigger a license revocation or hearing to review
licensee performance. The public and nuclear industry need
to see clearer standards as to what constitutes a poorly
run or failing plant.
no
The issues surrounding public health are, of course,
the greatest concern. However, the NRC seems to work in
short-term, incident-specific reviews of whether or not
a plant is responsible for a threat to public health.
The Congress, through an agency other than NRC, should
begin comprehensive, long-term studies of the public health
impacts, if any, of nuclear power plants. These studies
should include employee exposure and health histories, as
well as cummulative exposure risks to the general public.
As you know, there has been an above-average occurence
of certain cancers in the South Shore area. The State
Department of Public Health is conducting a long overdue
study.
Frankly, I doubt there will be any definite conclusion as
to the possible causes of this slight elevation - if in
fact there is a cause. However, it would have been useful
to have had long-term studies around other plants to see
if there were common events, or what the history has been
around other plants.
Let me make another observation about general workplace
safety. Not too long ago, Edison had a project to remove
asbestos from the plant. An employee has suggested to me
that the work was poorly done and there were unnecessary
Ill
risks of asbestos exposure. Quescions were raised about
OSHA's ability to supervise and investigate this work. I
think some work needs to be done to ensure that NCR
regulations, the strict standards to reduce radiation
exposure, and NRC ' s almost exclusive jurisdiction over nuclear
plants does not reduce non-radiation work place safety
standards .
On another matter, questions have been raised about
the relationship of contract workers in a plant. Who do
they answer to? What kind of quality control is achieved?
How well do contract workers work with regular employees?
How well do contract workers understand and follow NRC
regualtions? These are matters which I have not seen fully
studied .
There were two important matters in the Special
Committee's work which we simply were unable to resolve.
One was the issue of Mark I designs. Are there serious
flaws? Can they be compensated by other measures? Is there
an increased risk of containment failure in a Mark I?
The second was an overcharge about part releases. The
best documented charge is over the 1982 release already
discussed by Mr. Abbott. We did not have the expertise
or resources to determine what was released and over how
large an area.
112
Should the NRC refuse an ad judicutory hearing on Pilgrim
license then there should at least be NRC or Congressional
hearings on these two issues.
Finally, I would like to touch on the issue of Emergency
Prepardness. The NRC has created a real jurisdictional
mess over this issue. By requiring local approval of plans
the NRC may or may not have given states the power to close
plants. How far this power actually goes is unclear but
it should be clarified preferably by Congress and as soon
as possible.
Senator, again let me congratulate you for focusing
some Congressional attention on the role of the NCR and
their performance.
113
The Chairman. Thank you very much. Senator Golden.
Mr. Golden. Mr. Chairman, I want to thank you first for your
continuing and long standing interest in this issue, and particular-
ly for responding to the request of local officials to bring this hear-
ing to us this evening. I particularly thank you for the opportunity
to testify before you this evening.
I believe that the Pilgrim nuclear power station should be closed
for reasons of safety, reliability and economics. There is over-
whelming evidence that you will hear tonight that it is one of the
worse managed nuclear powerplants in the country. Its contain-
ment vessel has been proven to be defective, no emergency plans
exist to adequately protect the public in the event of a serious acci-
dent at the plant. Evidence has also been mounting of serious secu-
rity and radiological control problems at the plant, and a recent
study has demonstrated that it would be less expensive to shut Pil-
grim down than it would be to allow it to start up again; yet no
level of government has acted decisively to shut this plant down.
Under the Atomic Energy Act, States have almost no power re-
garding the safety of nuclear powerplants. Federal authority,
which is embodied in the Nuclear Regulatory Commission, has a
virtual monopoly regarding the operation of nuclear plants. Unfor-
tunately, the Nuclear Regulatory Commission has failed to distin-
guish between plants that are safe and those that are not.
Rather than providing a fair and open forum for resolution of
nuclear safety concerns, as well as a mechanism for closing unsafe
plants, the NRC has chosen instead to be an advocate of the nucle-
ar industry. Despite all the well documented problems at Pilgrim,
the NRC has chosen to keep the plant licensed.
In July of 196— in 1986, I filed on behalf of myself and 49 other
State legislators and Massachusetts, Public Interest Research
Group and other players, a petition with the NRC requesting a
formal hearing on suspension or revocation of Pilgrim's license to
operate. Both the Government and the Attorney General has since
filed similar show cause petitions with the NRC requesting hear-
ings on the Pilgrim's license.
The NRC's failure to consider fully and fairly and in a timely
manner these petitions has convinced us that we cannot rely on
the NRC to protect the public from the dangers presented by the
Pilgrim nuclear power plant. We urge and respectfully request that
you join our efforts by using the power of this committee to
demand that the NRC hold formal hearings, so that Boston Edison
may demonstrate why it should be allowed to operate a plant that
is unsafe, unreliable and uneconomical.
A year and a half ago, I testified at length before the Congres-
sional Subcommittee on Energy Conservation and Power in Wash-
ington, DC, on the problems at Pilgrim. Unfortunately very little
has changed since that hearing, and the problems what I discussed
in that testimony have not been resolved. Accordingly, I would like
to submit that testimony again to your committee, and a copy of it
has been submitted. ^
' The testimony referred to appears with the written statement.
114
The fact of the matter is, Senator, that we need your help. We
are in a situation where we have a utility that plans to file for re-
start of this plan even though they don't have the approved man-
agement performance, even though there is no emergency plan to
adequately protect the public, even though the containment vessel
is flawed and we have a 90 percent rate of failure in the event of a
serious accident of the plant, and even though radiological control
problems seem to threaten the health of workers and the general
public. The NRC has determinedly been an advocate for the indus-
try. It has sought to shut out public participation.
You have opened the door tonight to that public participation to
state and local officials and the general public. We deeply appreci-
ate it. We would ask that you continue that effort by using the
power of this committee to request the NRC, in fact, hold an evi-
dentiary hearing on why the license of the Boston Edison Co.
should not be suspended or revoked.
[Applause.]
The Chairman. Excellent testimony.
[Booing.]
The Chairman. Voices of Boston Edison. Let me say we tried to
get the NRC to have such a hearing with regard to Seabrook. We
were unable to do so. We were joined by just about the whole con-
gressional delegation — and also Senators from New York that — we
work together, the Senators from New York [laughter] and we'll
continue to try and do so.
I really am troubled by the fact that we can't get such an open
hearing. We are going to insist on it, as we did on Seabrook. I men-
tioned earlier what I would do, if we're unable to get the NRC to
open — I would certainly hope that they will. I will take every
action I possibly can to see that they do. I know — I'm sure I speak
for my colleagues. Senator Kerry and Congressman Studds. But if
we're unable to do so, we certainly can testify. I give you my assur-
ance I certainly will, and I'll bring all the testimony that we heard
today and try to present it in as effective way as I possibly can.
David Malaguti. Is that how it's pronounced? Did I say it right?
Mr. Malaguti.
Mr. Malaguti. Yes, Senator. As a matter of fact, you're just fine.
Senator, I'm the chairman of the local Board of Selectmen, and
on behalf of my board, I would welcome you to Plymouth. It is a
pleasure and an honor to have you here. We would like to see you
more often, perhaps, but it is indeed a pleasure. I'm afraid that at
this point my testimony, some of it, might be old hat, but I think it
is important enough to state again.
The Plymouth Board of Selectmen has discussed at regularly
scheduled and posted meetings and has taken the following posi-
tion. The Pilgrim power station should not be permitted to restart
until an effective radiological emergency response plan approved
by the town of Plymouth is in place. I quote from the Board's letter
to the NRC, dated September 2, 1987.
The Plymouth Board of Selectmen recommends that the Pilgrim Nuclear Power
Station located in our community not be allowed to restart until the radiological
emergency response plan of this town is in an effective form.
115
That position statement was taken after receiving a first report
of the town's Committee on Nuclear Matters dated March 1987,
and on the advice of the civil defense director. Our position was re-
iterated in a second letter to the NRC, dated November 16, 1987.
Our present radiological emergency response plan dated May 1985, is inadequate,
outdated and has serious deficiencies. While we are working hard to bring into
being a new plant that would permit us to provide for the health and safety of our
citizens during a radiological emergency, an approved plan does not exist at this
time. It will take several more months of work before such a plan can be presented
for the action of the Board of Selectmen.
Senator, the magnitude of this problem can be glimpsed if you
will just bear in mind two population figures. When Pilgrim station
opened in 1972, the population of Plymouth was 19,000. Today it is
in excess of 44,000. Our town is 17 miles in length. Stretching along
the ocean, we have three major escape routes: Route 3A, Route 44
and the Route 3 Expressway. All routes suffer from traffic grid-
locks periodically, especially during the tourist season when people
flock throughout our historic town. Winter storms, fall hurricanes,
and other adverse weather conditions only exacerbate the problem.
The town of Plymouth is in the best position to assess the pub-
lic's safety. We are the population most at risk, and we have the
experience of the years in dealing with disaster. No public utility
must be permitted by the Nuclear Regulatory Agency to dictate a
evacuation plan, thereby usurping the traditional powers and au-
thority of the local elected officials. We are not about to surrender
our rights to govern ourselves. We are united with our Massachu-
setts civil defense director, our State public safety director and
with our governor. We maintain, as did Governor Dukakis in his
letter of December 17, 1987, that the Pilgrim nuclear power station
should not be permitted to restart the reactor until all safety issues
are resolved, and until adequate approved emergency response
plans have been developed by this town and state.
We recommend that your committee exert congressional pres-
sure on the NRC to keep the Pilgrim nuclear power station closed
until an effective town-approved emergency plan has been devel-
oped for the safety of our citizens and for the protection of their
property in this state.
I thank you Senator for the opportunity to testify.
[Additional material supplied follows:]
116
K ••.'. \ ,1 M. 1' ! !'
\^./ iHK shL ;'rMi:N
\\l' I 1\'.1 , c l.:i . 1 . .: .'. .11 . MM
^.M-l 1 ir. I ■-; . I.I \i. i.: : i . , 'i i
September 2, 1987
Honorable Lando Zech
Chairman
Nuclear Regulatory Conmiission
Washington, D.C. 20555
Dear Chairman Zech:
Please convey to the Nuclear Regulatory Commission the
consensus of the Plymouth Boar^ of Selectmen which, simply
stated, recommends that the pilgrim Nuclear Power Station
located in our community not be allowed to restart until the
Radiological Emergency Response Plan of this town is in an
effective form. Our present RERP is dated May 1985 and is
under intense revision. It is Inadequate as to response
time, evacuation procedures, and reception centers.
The recent FEMA report to the Nll^C documents the
inadequacies of the Commonweal t'-> of Massachusetts' RERP. The
Board of Selectmen recognizes ^he same flaws in the operative
plans of this community.
The public safety would be at risk if the Pilgrim Nuclear
Power Station is permitted to open without a valid
radiological emergency plan in place.
We remind the NRC that this community of over 40,000
citizens is entirely within the ten mile emergency planning
zone and that our geographic location and our few and over-
burdened evacuation routes pose serious problems in any
emergency plan, whether for natural or radiological disaster.
The issue has been well studied and documented by the Nuclear
Matter Advisory Committee of this town as well as by our
Civil Defense Director.
117
Ilonoi Jblo Latuio "f~:)<, Cli.:irmn:i
NucJeor Rcqulatory CotnnisEiun
3eptenibir 2, 1"87
Page 2
The Plymouth Board of Selectmen i ecommends that the Pilgrim
Nuclear Power Station not be permitted to restart until an
effective, tested Radiological Emergency Response Plan is in
place.
i
The'public safety ought not to be placed at risk.
Very truly yours,
David F« Nalagutl, Chairman
Board of Selectmen
CO Secretary of Public Safety, HA
Boston Edison, President <€weenev
118
■- 1
• J' i
M o \- •
Tho.MaL- S. I'uriey. Di:.-eccor
Office of iJuclcar Reactor Regulation
Washington, D.C. 2C555
Dear Di;. Murlcy:
Thank y:>u for ■■our Novercber 2, 1987, letter As you noted in
our letter of September 2, 1987, the Plymouth Board of
Selectmen had arrived, at^. a ponsensus that the Pilgrim Nuclear
Power Station ought not be granted permission to re-start
until an effective Radiological Emergency Response Plan
(RERP) was in place. An "effective plan" would be one
acceptable to FEMA and bearingf*its approval.
The Board reiterates this position and, in viev; of the August
1987 report of the Federal Emergency Management Agency which
withdrew interim approval of the existing RERP, the Board
feels that the Town of Plymouth's RERP of May 1985 is not
only seriously out-dated, but cannot be considered an
adequate protection of the public safety during a time of
potential radiological danger to our citizens.
Wo, who are sworn to uphold the public safety, are in the
best position to know the present status of planning and
readiness in our community, and we ask you to consider our
views above all others. It is our town, completely within
the Emergency Planning Zone (EPZ) , and our citizens, who are
most at r isk .
To restate our position: The RERP for Plymouth is under
intense revision and updating by our Civil Defense
organization and our advisory committeec. Our present plan ,
dated May 1985 has serious deficiencies and it will take
several nonths before a final draft can be brought to this
Board for its consideration.
The restart of the Pilgrim Nuclear Power Station under the
foregoing conditions would be dangerous and not in the public
vjelf are .
119
piGvicu.-..- :.;'.:cn p.o;-i:c;.d by trio c: oir.Tnu r. i t y ir cor.iijrictio;.
witn t'.\c ri\il D^-'Lcr.de orgar i::ations cf the Ccni~.cnwealt:i o:
Kassac'.v.:- :tcs , ui.c- ?ilcjii-i Kuclcai PowfJi' Station, v,-ith icE
pact t: -.:.-. •lee", bisiccry, ought not be ferT.ittec^ to restart.
Very t v ;. _" y y o i; r s ,
BOARD Cy SBLiCCTMEN
David F. !:alGguti
Chairman
cc Peter 'vl . Agnes,- Jr., Assistant Secretary of Public Safety
Robert J. Boulay, Directors' Mass . Civil Defense
Peter Forraan, Representative
Edward P.Kirby, Senator
Stephen J. Sweeney, President; Boston Edison
Dr. Grace Healy, Chairman; Nuclear Matters Committee
120
The Chairman. Ms. Shimshak.
Ms. Shimshak. Thank you, Senator. It's an honor to testify
before you tonight, and also to sit with so many distinguished legis-
lative representatives, of which I'm not one.
My name is Rachel Shimshak. I'm an advocate for Massachusetts
Public Interest Research Group. MASSPIRG is a statewide organi-
zation, working on consumer and environmental protection and
energy issues. We have about 150,000 members across the State. I
appreciate the opportunity to testify tonight about the historically
troubled Pilgrim reactor.
MASSPIRG has followed the problems of Pilgrim over the past
decade and has conducted several studies on emergency planning
issues and the economic benefits of closing the reactor and invest-
ing in alternatives. I've brought with me copies of those reports
and I would like to submit them for the record, if I could.
In July of 1986, as Senator Golden mentioned, MASSPIRG, along
with many state legislators, elected officials and dozens of citizen
groups represented here tonight, submitted a show cause petition
to the Nuclear Regulator Commission which detailed management,
structural, emergency planning and radiological exposure problems
at the reactor. MASSPIRG is certainly not alone in its criticism of
the plan. Reports from the NRC, the Department of Public utilities,
the Federal Emergency Management Agency, the State Depart-
ment of Public Safety, and even Boston Edison's own review panel,
the Hogan Commission, have detailed their criticism of Boston
Edison's management and of Pilgrim's plant. If a horse had as
many problems as the Pilgrim plant has, it would have been shot.
[Laughter, applause.]
It would be wise to acknowledge Edison's inability to correct
these problems and to put the plant out of its misery by closing it
permanently.
Today I would like to focus my comments on the conclusions of
an emergency planning survey released this fall entitled "No
Exit". MASSPIRG's earlier reports generally looked at the adequa-
cy of the emergency plans themselves. This report approached the
emergency plans from a different angle. It looked not at the plans
themselves, but at the people who would be asked to follow them.
Such information is crucial to assessing the feasibility of the plan,
particularly in light of the General Accounting Office's finding
that, quote, "No Federal agency assesses public knowledge of radio-
logical emergency procedures."
In the summer of 1987, MASSPIRG surveyed 363 residents of the
Pilgrim emergency planning zone to determine what people knew
about the official emergency plan, and whether they would follow
those plans in case of an accident at the plant.
The key findings of this survey show that residents are even less
informed about Pilgrim emergency plans then they were at the
time of MASSPIRG's last survey conducted in 1983. Moreover, they
said they would refuse to follow official instructions in the event of
an emergency. Let me just review a few of the findings of the
report.
First, residents have only a limited knowledge of emergency
plans for their communities. Only 56 percent of those surveyed said
that they had received the emergency public information booklet
121
from Boston Edison, the operators of the plant, compared with 67
percent who remembered receiving the booklet in 1983. Moreover,
only 23 percent of those surveyed said they had actually read the
booklet, compared to 38 percent in 1983.
Second, many residents would not follow the emergency plan in
case of a serious problem at Pilgrim. For instance, the most
common response to an accident at Pilgrim, about 27 percent of the
people polled, would immediately evacuate; a direct contradiction
of the instructions contained in the emergency information booklet.
In nice big letters in the booklet, incidently.
Second, only 19 percent of those questioned said that they would
go to one of the designated reception centers in case of an evacu-
ation, and two thirds of those few who would follow the emergency
plan, would go to the Hanover Mall, which is no longer an official
reception center.
Perhaps the most stunning thing that we found concerned school
age children. Of the 37 percent surveyed who had school age chil-
dren, nearly half said that they would try to pick up their school
age children from school in the event of an emergency. Again, pre-
cisely what the emergency booklet instructed them not to do. Just
9 percent of parents said that they would follow the instructions to
meet their children outside the danger zone. And then, just for
good measure, 79 percent of the respondents felt that Pilgrim
should remain shut down if management and safety problems per-
sist.
Allowing the Pilgrim plant to reopen in light of these results and
the serious management and safety problems that persist at the
plant, would be like giving a drunk the keys to drive home. MAS-
SPIRG recommends that the Pilgrim plant not be
The Chairman. Did they indicate who those 9 percent parents
were that were going to leave their children? [Laughter.]
Ms. Shimshak. Nine percent said that they would actually
follow, I
The Chairman. I guess that doesn't say they would actually
leave them.
Ms. Shimshak. Right.
The Chairman. It doesn't include, as I understand it, the chil-
dren going to private schools; is that correct?
Ms. Shimshak. There are currently no plans for those people.
The Chairman. What do they do? Do they stay behind and take
that wonderful tablet?
Ms. Shimshak. Perhaps they could wait for the buses, for the
buses to arrive from Boston to pick them up.
The Chairman. A serious question. Do you know the number of
children that would be in the private and parochial schools; are
there many?
Ms. Shimshak. I'm sure that there are, but perhaps you can.
Mr. Malaguti. I don't have the numbers.
The Chairman. OK, please continue.
Ms. Shimshak. MASSPIRG recommends that the Pilgrim plant
not be opened unless it is determined that, one: a workable plan
can be developed; two: such plans have been effectively disseminat-
ed and implemented, and three: that outstanding management,
safety and economic questions have been resolved.
122
We also recommended that Boston Edison use this unique oppor-
tunity to implement the conservation and load management recom-
mendations of the Hogan report, rather than spend more money on
this plant. Thank you.
[The prepared statement of Ms. Shimshak follows:]
123
A4ifS5PIRG
MASSACHUSETTS PUBUC INTEREST RESEARCH GROUP
Testimony of
Rachel Shlmshak
Advocate, Massachusetts Public Interest Research Q*oup
Before the
Labor and Human Resources Committee of the United States Senate
Concerning public health impacts associated with proposed restart of
Pilgrim I nuclear power plant
January 7, 1988
29 Temple Place, Boston, MA 02111 (617) 292-4800
124
Good ev«nin(j, Mr. Cnairnan and members of the Committee. My naae is
Rachel Shimahak and I an an advocate for the Massachusetts Public Interest
Research O-oup (MASSPIRC). MASSPIRG is a statewide organization worlclng on
consuoar and environioental protection and energy Issues. We have over 170,000
citizen oembers across the state of Massachusetts.
I appreciate the opportunity to appear before you today to discuss the
historically troubled Pilgrim reactor. MASSPIRG has followed the problems at
Pilgrim over the past decade and has conducted several studies on emergency
planning issues and the economic benefits of closing the reactor and
investing in alternatives. In July of 1986, MASSPIRG, along with 50 state
legislators and over a dozen citizen groups, submitted a "Show Cause" petition
to the Nuclear Regulatory Commission (NRC) which detailed management,
structural, emergency planning and radiological exposure problems at the
reactor .
MASSPIRG is certainly not alone in its criticism of the plant. Reports
from the NRC, the Department of Public Utilities, the Federal Emergency
Management Agency, the state's Department of Public Safety, and even Boston
Edison's own review panel (the Hogan Commission) have detailed their criticism
of Boston Edison and the Pilgrim plant. If a horse had as many problems as
the Pilgrim plant has, it would have been shot. In our Judgment, it would be
wise to acloiowledge Edison's inability to correct these problems and put the
plant out of its misery by closing it permanently.
Today I would like to focus my comments on the conclusions of an
emergency planning survey we released this fall entitled, "No Exit."
MASSPIRG' 3 earlier reports generally looked at the adequacy of the emergency
plans themselves. This report approached the emergency plans from a different
angle — it looked not at the plans themselves but at the people who will be
asked to follow them. Such information is crucial to assessing the
125
feasibility of the plana, particularly in light of the General Accounting
Office's finding that "no federal agency assesses public knowledge of
radiological emergency procedures." ( GAO Report to Hon. Edward J. Markey,
House of Representatives, "Nuclear Regulation: Public Knowledge of
Radiological Emergency Procedures," June 1987, p. 1)
In the summer of 1987, MASSPIRG surveyed 363 residents of the Pilgrim
emergency planning zone (EPZ) to determine what people knew about the
official emergency plans and whether they would follow those plans in case of
an accident at the plant.
The key findings of this survey show that residents are even less
informed about Pilgrim emergency plans than they were at the time of
MASSPIRG's last such survey, conducted in 1983- Moreover, they refused to
follow official instructions in the event of an emergency.
Let me review a few of the findings in the report:
1 ) Residents have only a limited knowledge of emergency plans for
their communities. Only 55} of those surveyed said they had
received the Emergency Public Information booklet from Boston Edison, the
operator of the plant, compared with 57» who remembered receiving the booklet
in 1983. Moreover, only 235 of those surveyed said they had actually read the
booklet completely, compared to 38' in 1983.
2) Many residents would not follow the emergency plans in case
of a serious problem at Pilgim:
• the most common response to an accident at Pilgrim (27?
of those polled) would be immediate evacuation--a direct contradiction of
instructions contained in the emergency information booklet;
• only 19' of those questioned said they would go to one
of the designated reception centers in case of an evacuation, and two-thirds
126
of these few who would follow the emergency plans would go to the Hanover
Mall, which is no longer an official reception center;
• of the 37S surveyed who have school-age children,
nearly half iUSi) said that they would try to pick up their children from
school in the event of an emergency — precisely what the emergency booklet
instructs them not to do; just 95 of parents said they would follow the
Instructions to meet their children outside the danger zone.
* Seventy-nine percent of the respondents felt that Pilgrim should
remain shut down if management and safety problems persist.
Allowing the Pilgrim plant to reopen in light of these results and the
serious management and safety problems that persist at the plant would be like
giving a drunk the keys to drive home. MASSPIRG recommends that the Pilgrim
plant not reopen unless it is determined that:
1) workable plans can be developed;
2) such plans have been effectively disseminated and implemented; and
3) outstanding managment, safety, and economic questions have been
resolved .
We also recommend that Boston Ediston use this unique opportunity to
implement the conservation and load managment recommendations of the Hogan
report rather than spend more money on this plant.
Thank you very much.
127
The Chairman. I want to move along, but I have some questions.
First of the legislators. First of all, I congratulate you on the report
that was made for the Joint Special Committee, and I'm going to
make the recommendation contained in the report a part of the
hearing record as well.
Representative Forman spoke about the adequacy of the ability
of local and State governments to deal with some of the NRC rul-
ings.
Do you have suggestions of ways in which the NRC should
expand the role of the State and local communities? Or if you want
to think about it, you can later make it a part of the record.
[Excerpts from the report referred to above follows:]
128 '
SENATE No. 2023
Z'ht CommontDtaltt of 0iaMat!bnietti
REPORT
of the
JOINT SPECIAL COMMITTEE
ESTABLISHED FOR THE PURPOSE
OF MAKING AN INVESTIGATION AND STUDY
Relative to
THE PILGRIM NUCLEAR GENERATING
FACILITY AT PLYMOUTH
(under the provisions
of Senate Order No. 2044
adopted in the year 1986).
July, 1987
129
SENATE - No. 2023
Z>f)t CommontDealtt ot 0iasiiad)ufitttii
FOREWORD
The Pilgrim Nuclear Generating Station has been shut down since
April 1986. The Nuclear Regulatory Commission has been sharply
critical of the Boston Edison Company's management of the plant.
The Massachusetts Legislature responded with the establishment
of a special joint committee to investigate and study the problems at
the facility. This report is the culmination of the committee's work.
We recognize that this is not the final work on Pilgrim. Debate over
Boston Edison's improvements, possible re-start, and how fully our
recommendations are followed will continue. We also recognize that
state authority over nuclear power is limited. Thus our recommen-
dations should be seen in that light.
We do hope, however, that the report will serve as a major reference
point as public debate continues and decisions are made. As Chairmen
of the committee, our aim was to provide an open forum where all
the issues could be reviewed objectively.
We have succeeded in our efforts if the report contributes to the
enhancement of public safety and public health in the
Commonwealth.
Finally, we wish to thank the committee members for their hard
work and patience, as well as the individuals and agencies identified
herein that contributed greatly to this report.
SENATOR THOMAS C. NORTON,
Senate Chairman.
REPRESENTATIVE PETER FORMAN,
House Chairman.
130
SENATE - No. 2023 [August
This report has been prepared by Brian J. Prenda,
M.P.A., Lisa Kaminski, Kevin Considine, Linda Marley
and Liicy DeLaney for the Special Committee to
investigate and study the Pilgrim Station Nuclear facility
at Plymouth.
The staff of the Special Committee extends its sincere thanks to
those who so generously contributed their time and expertise to the
preparation of this report.
131
1987] SENATE - No. 2023 97
RECOMMENDATIONS
I) Creation of the Division of Nuclear Facilities Safety.
II) Endorsement of Comprehensive Load Management and
Conservation Programs.
Ill) Prioritize Massachusetts Based Electrical Generating
Facilities.
IV) Department of Public Utilities to Establish a Five-year
Supply Plan without reliance on the Pilgrim Plant.
V) Committee Review of the Nuclear Regulatory Commission
(NRC) Systematic Assessment of Licensee Performance
Report (SALP) and Recommended Measures to Correct
Serious Functional Deficiencies at the Pilgrim
Nuclear Generating Facility at Plymouth.
VI) Improved Emergency Preparedness Plan.
132
98 SENATE — No. 2023 [August
RECOMMENDATION I
CREATION OF A DIVISION OF
NUCLEAR FACILITY SAFETY
After many hours of deliberation over topics such as emergency
preparedness and planning, monitoring of radiation and other aspects
of nuclear safety, the committee has concluded that many areas
regarding public safety need immediate attention and improvement.
After reviewing and hearing the testimony of the Department of
Public Health (DPH) and the Department of Public Safety, the
committee concluded that lack of funding, along with shortfalls in
strict compliance with many sections of Chapter 796 of the acts of
1979, have led to a less than appropriate handling of radiation
monitoring and emergency preparedness. The committee, therefore,
recommends that the Commonwealth adopt and implement the
formation of a Division of Nuclear Facility Safety to oversee nuclear
generated power production in the Commonwealth.
The Division of Nuclear Facility Safety shall provide the following
provisions and services:
The Division of Nuclear Facility Safety shall be a division of the
Department of Public Safety and shall be responsible for monitoring
the operation and modification of the two nuclear power plants within
the Commonwealth. In addition, it shall be responsible for developing
emergency response plans in conjunction with Massachusetts Civil
Defense for responding to accidents involving nuclear power plant
facilities. Major activities shall include: installation, operation and
maintenance of a system for remote monitoring of radioactive
discharges from the nuclear power plants, in conjunction and under
the supervision of the Department of Public Health; development and
review of the Massachusetts Radiological Accident Emergency
Preparedness Plan (MRAEPP); oversight of training of state and
local civil defense personnel responsible for implementation of the
MRAEPP. Enforcement of rules and regulations prescribing
standards for in service testing of pressurized systems at nuclear power
plants which the Department of Public Safety oversees.
1) The Massachusetts Radiological Accident Emergency Prepared-
ness Plan.
The Massachusetts Radiological Accident Emergency Prepared-
133
1987] SENATE - No. 2023 99
ness Plan shall establish a program for statewide, integral
management procedures in the event of an accident which may occur
at a nuclear power reactor site. The primary purpose of the plan is
to provide a coordinated response by state and local governmental
officials for the protection of the citizens of the Commonwealth. The
plan shall include site specific planning to cover the urgency of
protecting citizens living near nuclear plants; a concept of operations
so that the plan can be effectively carried out; and an effective
allocation of resources and personnel. The plan shall pre-assign the
duties and responsibilities that would be taken by all the respondents
to a nuclear accident thus enabling actions to be made quickly and
efficiently.
The Massachusetts Division of Nuclear Facility Safety and the
Massachusetts Civil Defense Agency shall share the primary
responsibility for developing the plan with integral component
agencies such as the state police and the Emergency Planning Zone
(EPZ) communities' local officials. The utilities' security and safety
personnel must also play a major role in planning. Specifically, the
Division of Nuclear Facility Safety shall be responsible for the
technical functions of this effort, and the Civil Defense Agency shall
be responsible for the operational aspects. The plan shall be reviewed
every year for accuracy and proper appropriation to assure a fully
functional quality plan. The appropriate components shall be
distributed to the proper state, county and municipal agencies and
organizations in the Commonwealth for implementation.
The Division of Nuclear Facility Safety shall plan to expand the
EPZ to 50 miles from each reactor with the understanding that greater
planning and preparedness efforts are necessary closer to the reactor
and that evacuation will not likely be recommended for all areas
within a 50-mile radius. These plans should be tailored to meet each
community's specific needs.
The Division of Nuclear Facility Safety shall clarify evacuation
plans for regional schools which have students from at least one, but
not all, towns in the school system which are part of an EPZ. Division
and Civil Defense officials working with school administrators and
parents' groups must develop workable student and teacher
evacuation plans and establish criteria for determining when, if ever,
it would be appropriate to send children home first to evacuate with
their families.
The Division of Nuclear Facility Safety shall establish emergency
134
100 SENATE — No. 2023 [August
evacuation time estimates and traffic control plans based on
evacuations of people within the EPZ to reception centers at least 30
miles from the reactor and should anticipate secondary or shadow
evacuations.
The Division of Nuclear Facility Safety shall commission a site-
specific probabilistic risk analysis of severe accident probabilities at
Pilgrim and the consequences of radioactive releases and the probable
health effects at various distances from the plant.
Major operations specified in the Plan and agency responsibilities
are outlined in Recommendation VI.
2) Monitoring.
The committee recommends that the Division of Nuclear Facility
Safety and the Department of Public Health adopt and develop a
Remote Monitoring System (RMS) which shall incorporate three
major components: gross gamma detectors radially positioned around
each nuclear power station; an automated, isotopic gaseous effluent
monitor system which samples from major engineering release points;
and a reactor parameter data communication link to each facilities'
on-site computer. In addition there shall be provided liquid effluent
monitors, which will be located at each plant's liquid discharge points.
All of these RMS components shall be connected through a dedicated
data communications link to provide instantaneous readings to the
Division of Nuclear Facility Safety Headquarters. Technical staff
shall review the data and perform analyses of plant conditions.
a) ENVIRONMENTAL RADIATION MONITORING SYS-
TEM: The Division of Nuclear Facility Safety shall develop a dual
ring system of environmental radiation monitors utilizing gross
gamma detectors and automated isotopic detectors which shall be
installed and maintained around each reactor site that would measure
a change in radiation levels resulting from a radioactive release at the
reactor site. This system shall serve a multitude of purposes. It shall
define the existence of a radioactive release sufficiently large enough
to impact upon the environment, as well as detect a release through
an unmonitored release path. In addition, the system shall provide
a backup capability should the effluent monitoring system be
inoperable, and shall also help reveal the presence of atmospheric
conditions (windshear) which could result in plume dispersal not
following anticipated direction of travel.
The Environmental Radiation Monitoring System shall be
135
1987] SENATE - No. 2023 101
developed to provide the following features: (1) up to 16 monitors
per site (1 detector for each 22.5 degree segment) at a distance of
approximately 2 miles from the reactor site; (2) minimum detection
level of 1 microRoentgen per hour (natural background levels are
approximately 7 to 10 micro Roentgens per hour); (3) maximum
detection limit is at least 10 Roentgens per hour (one million times
normal background levels); (4) automatic transmission of radiation
readings to the Nuclear Facility Safety Division headquarters
computer system every 8 minutes; and (5) transmission of alarm
signals to the Nuclear Facility Safety Division headquarters in the
event of high radiation levels or failure of environmental monitoring
system components.
b) REACTOR PARAMETER DATA LINK: The Massachusetts
Division of Nuclear Facility Safety shall install a direct data
communication link between the Division headquarters computer and
each nuclear reactor's control room computer for the monitoring of
the Commonwealth's two nuclear power reactors and their safety
systems. This data link shall be developed for early notification of
events that could lead to nuclear accidents. This system is an essential
element in providing continuous plant safety assessment, early
detection of abnormal conditions, and evaluation of nuclear plant
transients.
The system signals to be received at the Division's headquarters
shall be the same signals available to the nuclear plant personnel on-
site. The Division shall select particular parameters to be transmitted
to them from an index containing all available plant system
information. Parameters selected by the Department provide detailed
information on the operation characteristics of all essential plant
safety systems.
Some major features that are available that may be included in this
system are: (1) 1,000 to 1,300 parameters (signals) per reactor
accessible for transmission every two minutes; (2) technical
parameters include: reactor power levels, reactor water levels, steam
generator water levels, containment temperatures, engineered safety
system availability, and essential pump flow rates; and (3) system
software for displaying either current or historical signals.
c) THE RADIOACTIVE GASEOUS EFFLUENT MONITOR-
ING SYSTEM: The Division of Nuclear Facility Safety and the
Department of Public Health shall be directed to utilize and
136
102 SENATE - No. 2023 [August
implement a custom designed automated system to monitor gases
routinely released by nuclear power plants. The Radioactive Gaseous
Monitoring System is designed to identify and quantify the
radioactive components of the gaseous discharges from each stack and
other gaseous release points to the environment and transmit the
information immediately to the Division so that appropriate
emergency action can be directed in the event of a nuclear accident.
The Radioactive Gaseous Effluent Monitoring System is a state of
the art, computerized system which continuously transmits data from
the nuclear power plant to the Division's headquarter computer.
This system includes the following features: (1) dedicated computer
at the power plant sites for operation and analysis; (2) minimum
detection level of 10 to 13 microCuries/ cubic centimeter; (3)
maximum accident detection limit of 10 microCuries/cubic
centimeter; (4) collection and analyses of radiation in three forms:
iodines, particulates, and noble gases; (5) automatic background level
checks; (6) automatic check on source verifications; (7) remote
computer access to determine operational status and data; (8) signal
alarms in the event of high radiation levels or failure of a system
function; (9) detection of specific isotopes based on radiation energy;
and (10) accelerated operation rates designed to maximize data
collection during an accident.
d) EMISSION STANDARDS: It is essential that Massachusetts
Public Health Officials review and determine the maximum
permissible levels of airborne radioactive emissions from nuclear
power plants that do not threaten the public health and safety. By
adopting state emission standards as authorized by the Clean Air Act
amendments of 1977, the Commonwealth will ensure that safe
standards are in place and strictly enforced. Until such standards are
set by the Department of Public Health, the federal standards should
be adopted as state standards so that the state officials immediately
have the power to inspect onsite and off-site monitoring equipment
and have independent enforcement authority over emissions. The
state shall assess all licensees for the cost of setting up a monitoring
system for the Commonwealth.
Perhaps the most important safety function of a monitoring system
is to assist emergency response officials in determining the extent of
a serious accident and the amount and direction of radiation releases.
We recommend installation of a comprehensive and sophisticated new
137
1987] SENATE - No. 2023 103
monitoring system similar to the one that is already installed and
functioning in Illinois to provide substantially more public protection.
3) Possible Adverse Health Effects From Pilgrim Radioactive
Emissions
a) Radiation exposure can cause cancer, birth defects and
chromosomal damage. The Department of Public Health has
determined that there has been a significant increase in leukemia cases
in the area surrounding Pilgrim, although the department is still
studying what the cause of those leukemias may be.
b) The Special Committee recommends that four health studies be
conducted:
1) A follow-up study on the leukemia cases in the Plymouth area
to determine what environmental or occupational exposures may
have caused those leukemias.
2) A study to test the theory that coastal winds may concentrate
the radioactive emissions from the Pilgrim plant in such a way
as to cause adverse health consequences in coastal areas.
3) A regional study of adverse health impacts, including leukemia
incidences, birth defects and infant mortality, downwind from
other nuclear reactors in New England.
4) A health study of all past and present Pilgrim employees to
determine the adverse effects, if any, of exposure to radiation
from Pilgrim.
4) The cost of the Division of Nuclear Facility Safety and the
Department of Public Health's monitoring system should not
be borne by all taxpayers but by the utility ratepayers through
an assessment of the nuclear plant licensees.
138
104 SENATE - No. 2023 [August
RECOMMENDATION II
ENDORSEMENT OF COMPREHENSIVE LOAD
MANAGEMENT AND CONSERVATION PROGRAMS
The special committee investigating the Pilgrim Nuclear Generating
Facility reviewed testimony involving energy supply, load
management and conservation measures during several hearings. The
committee concluded that in order to meet current and future power
supply demands all utilities in the Commonwealth must implement
stringent load management and conservation programming. The
committee stresses that authority should be given to the Department
of Public Utilities to oversee the implementation of aggressive load
management and conservation programs for any electric utility relying
on the continual operation of the Pilgrim Generating Facility.
Load Management
The committee endorses the concepts contained in the Final Report
of the Boston Edison Review Panel as they relate to increased load
management programs by Boston Edison Company. The committee
recommends that the Department of Public Utihties (DPU) be
required to encourage and assist Boston Edison in implementing the
specific load management programs. The DPU shall also be required
to encourage and assist Commonwealth Electric Company in
implementing appropriate cost-effective load management programs
that offer the company similar energy-saving results.
Boston Edison Company should identify and fund effective "load
management" measures, such as radio-controlled water heaters and
nighttime water chilling systems, which reduce peak energy use and
are cheaper than the cost of producing electricity from new power
plants. In addition, the utility should provide incentives for
commercial and industrial sector customers to form "load-shedding
cooperatives," where a group of participants agrees to share minimal
energy use reductions during peak demand emergencies.
139
1987] SENATE - No. 2023 105
Conservation
The special committee endorses the concepts contained in the Final
Report of the Boston Edison Review Panel as they relate to increased,
cost-effective conservation programs by Boston Edison Company.
The DPU should be required to encourage and assist Boston Edison
in implementing the specific conservation programs. The DPU shall
also be required to encourage and assist Commonwealth Electric
Company in implementing appropriate, cost-effective conservation
programs that offer the company similar energy-saving results. The
DPU should direct all utilities to make significant investments in
energy conservation and energy efficiency programs, known as
"demand-side management" programs, to reduce the energy demand
of all utilities' customers. The DPU should set target investment levels
and participate in the design of demand-side management programs.
Such programs should include, but not be limited to the following,
where shown to be cost effective:
1) The special committee recommends all utilities should employ
d.esign teams to go into buildings that use large quantities of
electricity to identify the full package of demand-side
management measures and practices that are cheaper than the
utilities commensurate cost of producing electricity from new
power plants over the useful life of the conservation measures.
The utility should then fund the purchase and installation of
identified cost-effective measures.
2) All electric utility companies should offer their customers
incentives for a wide range of efficiency measures. This incentive
program should go far beyond the limited scope of current and
prior utility rebate programs for refrigerators and efficient lights.
3) All electric utility companies should also provide incentives for
electrical energy efficiency in new construction including hook-
up fee and penalties.
4) All electric utility companies should convene an auction for
energy efficiency improvements similar to the bidding process
that is currently being used to promote the development of small
power and co-generation facilities.
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106 SENATE - No. 2023 [August
5) The committee recommends that the DPU should be allowed
to provide all utilities with a profit, or "rate of return" on the
investment the company makes in demand-side management
programs. This rate of return, to be recovered from the
company's ratepayers, could be at least as high and/ or up to two
percentage points higher than the rate the utilities are authorized
to receive for capital investments in new power plants.
141
1987] SENATE - No. 2023 107
RECOMMENDATION III
PRIORITIZE MASSACHUSETTS BASED ELECTRICAL
GENERATING FACILITIES
I. The Committee recommends that the Energy Facilities Siting
Council and the Department of Public Utilities give priority
consideration to the construction of non-nuclear electric generating
plants located within the Commonwealth when reviewing the plans
of any electric utility for the construction of a new generating plant.
The Massachusetts General Laws and regulations promulgated by
regulatory agencies require utility companies to provide ratepayers
with electricity at the lowest possible economic cost and with the least
possible environmental impact. In planning to meet the electrical
energy needs of ratepayers, the Department of Public Utilities, the
Energy Facilities Siting Council, and the utilities should consider and
evaluate the following factors:
1) The full "life cycle" economic costs of each energy resource
option. These include costs for construction, financing,
operation and maintenance, and decommissioning. With respect
to energy efficiency and load management programs, costs for
materials and installation and program administration should
be considered.
2) The full environmental costs of each energy resource option.
Environmental impacts associated with the siting of facilities,
degradation of outdoor and indoor air quality, potentially
adverse impacts on water quality, and risks to public health
should all be fully considered when deciding which energy option
to pursue.
3) The number of jobs created by the use of each energy resource
option. The number of long- and short-term jobs that are directly
and indirectly created as a result of developing various energy
resource options should be considered and compared. Other
state and local economic development costs and benefits, such
as support of indigenous industry and inflows or outflows of
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108 SENATE - No. 2023 [August
capital resulting from development of each energy resource
option should also be considered.
4) The reliability of the energy resource option. Massachusetts
needs affordable and reliable energy resources to help sustain
a healthy economy. Energy resource options that decentralize
and diversify the region's fuel mix, and which reduce reliance
on non-indigeous fuels, should be prioritized.
All potential resource options — including energy efficiency
improvements and practices, load management measures and
practices, small power production, co-generation, and small and large
oil, natural gas and clean coal technologies should be evaluated and
compared using the above criteria.
The Committee believes that priority should be given to
Massachusetts based plants. The Committee is concerned about the
increased dependence on plants located outside Massachusetts for our
electric generating needs. It believes that this trend increases the
likelihood of supply disruptions, thereby complicating unduly our
ability to forecast long range supply. This trend of reliance on plants
outside Massachusetts is also detrimental to our economy, since it
creates jobs in other states that would otherwise benefit Massachusetts
workers.
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1987] SENATE - No. 2023 109
RECOMMENDATION IV
DEPARTMENT OF PUBLIC UTILITIES TO ESTABLISH A
FIVE-YEAR SUPPLY PLAN WITHOUT RELIANCE ON
THE PILGRIM PLANT
The Committee has found that the Pilgrim Nuclear Generating
Facility at Plymouth, Massachusetts has suffered from serious and
continuous mismanagement. Although significant efforts are being
made by its owners to rectify the management problems, considerable
uncertainty remains over the reUability of the plant to contribute to
the electric supply needs of the Commonwealth.
The Committee therefore recommends that the Department of
Public Utilities (DPU) establish a five-year plan for ensuring adequate
supply without consideration of the electrical production of Pilgrim
plant. Due to the uncertain future of Pilgrim, the DPU should
establish a supply plan for the Commonwealth that does not require
any dependence on the Pilgrim plant. Such plan shall include a
forecast of future supply and demand which delineates each source
of power and its location. January 1, 1988 is the due date for the
implementation of the initial five-year plan.
The Committee recommends that in determining whether to restart
the Pilgrim Nuclear Power Plant, the availability of sufficient cost
effective and safe alternate energy resources shall be taken into
consideration.
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RECOMMENDATION V
COMMITTEE REVIEW OF THE NUCLEAR REGULATORY
COMMISSION (NRC) SYSTEMATIC ASSESSMENT OF
LICENSEE PERFORMANCE REPORT (SALP) AND
RECOMMENDED MEASURES TO CORRECT SERIOUS
FUNCTIONAL DEFICIENCIES AT THE PILGRIM NUCLEAR
GENERATING FACILITY AT PLYMOUTH
The Pilgrim nuclear power plant has a well documented, and well
publicized, history of problems. This history has called into question
both the level of safety when Pilgrim is operating and Boston Edison's
ability to run the plant. With an issue as emotional as nuclear power,
the loss of public confidence must be addressed in addition to the
actual safety problems.
Massachusetts, particularly residents of Southeastern Massachu-
setts, have every right to demand that Pilgrim be one of the best run
plants in the country rather than one of the worst. Clearly the initiative
for this belongs to Boston Edison. Pilgrim has been "off-line" for more
than a year. During that time the utility has undertaken significant
initiatives to improve its performance. In some cases they have taken
a lead in the nuclear industry to address certain problems. More work
remains to be done, however, and how effective the company is in
its work will have to be judged when it is completed.
This is neither a "pro-nuclear" nor an "anti-nuclear" report. The
committee feels that where there are problems, they must be
addressed, prior to restart, and that the plant should not operate until
all major deficiencies are corrected. Individual members will have
their own views on nuclear power but everyone agreed that the
overriding issue here was not to resolve the nuclear debate but to
address the problems of one particular plant.
The committee heard testimony on specific operations and plant
problems from Boston Edison, the Nuclear Regulatory Commission,
and representatives from citizen groups. In addition, the committee
has had access to Public Safety Secretary Charles Barry's report to
the Governor on the plant and volumes of NRC reports.
145
1987] SENATE - No. 2023 111
To try and identify every single problem and the appropriate
solutions would be beyond the committee's capability and
jurisdiction. The sheer number of technical matters, the lack of expert
staff, and the debate within scientific and regulatory circles over some
issues made it unrealistic for us to devise the specific solutions to many
particular problems. Likewise, it makes little sense to list every specific
problem since it would make more difficult our aim to focus public
attention on the most substantive problems.
The committee does feel, though, that it is useful for the Legislature
to summarize the patterns of problems and our perceptions of the
work which needs to be done. This, we hope, will not only focus
greater attention on the major problems but also give the Legislature
and the public some standard by which we can measure Edison's
progress.
The NRC, on many occasions, has claimed it will force Edison to
prove significant improvements before restart is allowed. As part of
their process they will develop a detailed check list of matters requiring
solutions. The committee urges the NRC to include our concerns as
part of that process. If addressed, we feel plant safety will be enhanced
and public confidence raised.
The Nuclear Regulatory Commission recently issued the Pilgrim
Systematic Assessment of Licensee Performance (SALP) for the 15-
month period of November 1, 1985 through January 31, 1987. SALP
is a comprehensive assessment of the plant analyzed into twelve
functional areas. The report identifies recurring programmatic
weaknesses in five functional areas including: radiological controls;
surveillance; fire protection; security; and assurance of quality.
These five functional areas received low SALP grades of 3. The
NRC rates on a 1,2, and 3 basis and defines a 3, the lowest rating,
as follows:
"Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable
and considered nuclear safety, but weaknesses are evident;
licensee resources appear to be strained or not effectively used
so that minimally satisfactory performance with respect to
operational safety is being achieved."
The following is an outline of the problems in each of the five
functional areas as reported by the NRC, followed by the committee's
recommendations.
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112 SENATE — No. 2023 [August
(1) RADIOLOGICAL CONTROL: "This assessment covers
radiation protection, effluent monitoring and controls,
radwaste shipping and environmental monitoring. SALP
found that the licensee made numerous improvements in the
overall quality of the radiological controls program. However,
implementation of the program continues to be weak. When
problems with program implementation or adequacy are
identified, corrective actions are sometimes not adequate or not
implemented resulting in the need for further NRC involve-
ment. In the area of effluent monitoring and control, the
licensee implemented the new effluent technical specifications
in a generally acceptable manner, however, failure to take
action on significant long standing deficiencies in the
environmental Thermolumenescent Dosimeters (TLD)
program detracted from the good effort."
COMMITTEE RECOMMENDATIONS:
a) — Aggressively supervise the radiological control program.
b) — Establish and implement measures to verify program imple-
mentation and implement corrective actions for deficiencies.
c) — Interactions with personnel outside the radiological group
should be significantly strengthened.
d) — Continued clean up of plant and reduction of contaminated
areas.
e) — Strengthen the role and company jurisdiction of radiation
control department over the other departments.
f) — Exposure histories of past and present employees and con-
tracted workers be compiled, continually updated, and
reported to DPH and Nuclear Facility Safety Division.
g) — Improve programs for replacement of thermoluminescent
dosimeters.
h) — Improve training of employees in radiological environmental
technical specifications.
i) — Improve control and accounting of special nuclear material
under one gram.
j) — Improved access control to high radiation areas.
k) — Improved inspection of vehicles leaving site for any con-
tamination.
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1987] SENATE - No. 2023 113
(2) SURVEILLANCE: "Individual surveillance tests were well
conducted and controlled. The response to recurring local leak
rate test failures was also positive. However, the licensee has
been slow to recognize and correct weaknesses in the control
of the program tests. This lack of progress is reflected in the
large number of surveillance-related licensee event reports and
NRC violations issued during the current period. The control
of the program is fragmented and not always effective and
appears to depend more on historical past practice then in a
well-founded, systematic approach. This is a major weakness
that must be corrected. The licensee's measuring and test
equipment control program also need improvement."
COMMITTEE RECOMMENDATIONS:
a) — Significant site and corporate management attention is needed
to correct deficiencies in this area,
b) — Place a single qualified individual in overall charge of the
surveillance program.
(3) FIRE PROTECTION: "The licensee has been slow to
strengthen the fire protection program. Problems included
inadequate surveillance procedures, degraded fire barriers,
inoperable fire protection system equipment, and poor quality
fire brigade training. Although action has been taken to address
these concerns the program has suffered from a chronic lack
of attention and should be closely monitored."
COMMITTEE RECOMMENDATIONS:
a) — Significantly reduce the amount of inoperable fire protection
equipment in the station,
b) — System for assessing priority needs and timely correction of any
deficiencies in fire barriers and protection equipment,
c) — Improved supervision and training of fire watchers,
d) — Provision for independent water and power supplies,
e) — Completion of all Appendix R improvements,
f) — System to control combustible material on-site.
(4) SECURITY AND SAFEGUARDS: "The previous SALP
report identified serious NRC concerns regarding the licensee's
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114 SENATE — No. 2023 [August
awareness of, and attention to, NRC physical security
objectives and the need for additional management attention
to, and support of, the security program to insure that the
program was properly implemented. The previous SALP
report also identified NRC's belief that the licensee had initiated
actions to resolve those concerns and that the security program
was receiving increased management attention. However,
shortly after the beginning of this assessment period, it became
apparent to the NRC that, due to the number and complexity
of the identified problems and some other problems which were
then surfaced, far more extensive management attention and
resources would be required. As evidenced during this
assessment period, the need for additional attention and
resources by the licensee continued until late in this assessment
period. As a result, little physical progress toward improving
the program was accomplished by the licensee during the
period."
COMMITTEE RECOMMENDATIONS:
a) — High level corporate and site management attention to the
recently established priority level for the security program
upgrade should continue in order to implement commitments
and develop an effective program.
b) — NRC/ Boston Edison review of relationship of contracted
security force over Boston Edison and other contracted
employees. Does Security have adequate power to control
plant personnel and question employee activities?
c) — Develop and implement effective program to eliminate any
presence or use of alcohol and drugs.
d) — Elimination of any violations or weaknesses in security
barriers.
(5) ASSURANCE OF QUALITY: "Although the licensee has
exhibited good performance in certain activities such as outage
control and engineering and has displayed initiative in its safety
enhancement program, significant deficiencies still were found
to exist in radiological controls, surveillance, fire protection
and security. Some of these deficiencies have existed
149
1987] SENATE - No. 2023 115
throughout the period and have been identified in previous
SALP reviews, and by the Hcensee's own quahty assurance
organization. The ambiguity of the site organizational structure
and the instabihty in the corporate and site management team
have resulted in the licensee's inability to address and resolve
these long-standing problems without repeated prompting and
overview by NRC. Senior corporate management was slow in
confronting the problems and in implementing corrective
actions. Late in this assessment period and immediately
following it, the licensee took steps to address its organization
weaknesses. However, the effectiveness of these efforts in
improving the licensee's performance remains a matter of
continuing NRC interest and concern."
COMMITTEE RECOMMENDATIONS:
a) — Continue senior management attention to identify problems to
ensure that they are promptly and effectively resolved,
b) — Improve tests and surveillance of equipment program,
c) — Greater authority of quality control staff over other
departments to resolve any conflicts between procedures and
personnel in different operation groups,
d) — Improve training and supervision over contract workers,
e) — Improvements in visual surveillance system to properly identify
and describe deficiencies,
f) — Improve training, testing and requalification of personnel.
(6) PLANT/ EQUIPMENT
COMMITTEE RECOMMENDATIONS:
a) — Maintenance requests back log be eliminated.
b) — Complete review of maintenance and testing schedules with all
incomplete testing being finished and any deficiencies
corrected,
c) — Identification and repair of Main Stream Isolation Valve and
RHR pumps which caused initial spurious scram which closed
the plant,
d) — NRC investigation and public explanation of recent reports of
deficiencies in certain General Electric reactors, including
Pilgrim. The public should be informed of the possible
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problems and any action taken by General Electric or Boston
Edison which has corrected these deficiencies. All uncorrected
problems should be corrected,
e)^ — The NRC and General Electric should also make available to
the public the General Electric report.
(7) GENERAL MANAGEMENT CONCERNS: The following are
recommendations which address general management areas
which the committee feels need review.
COMMITTEE RECOMMENDATIONS:
a) — Staff vacancies in key areas should be filled to adequate levels,
b) — Demonstration that the new programs, divisions and personnel
can actually perform as planned,
c) — Resolution of inter-group conflicts and clearer lines of
authority for safety, ALARA (As low as reasonably
achievable), and fire protection personnel over other divisions,
d) — Review and planning of transition from outage and
maintenance mode to on-line operation so that they are
prepared if restart is approved.
(8) REACTOR CONTAINMENT: In its most recent SALP report
the NRC noted the following: "Plant hardware changes were
also impressive, particularly the planned Mark I containment
enhancements. The modifications go considerably beyond NRC
recommendations and show a concern for nuclear safety."
Nevertheless, serious concerns have been raised, both inside and
outside of the NRC, about the Mark I containment and its
possible failure in the event of a major accident. The Committee
has sent a letter to Boston Edison seeking more information on
exactly what work is planned to enhance the containment
system. In addition, the committee strongly urges that prior to
restart the NRC, the state, and Boston Edison shall hold a public
hearing on:
a) The possible defects or weaknesses of the Mark I containment;
b) the work planned by Boston Edison to improve it;
c) the schedule for that work;
d) NRC studies and others done on the integrity or possible failure
of the containment in the event of a major accident. The
containment is such a crucial safety feature in nuclear plants that
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1987] SENATE - No. 2023 117
all work to strengthen any weaknesses must be completed prior
to restart,
e) An evaluation of any additional safety features such as filtered
venting of the containment, molten core barriers, underground
residual heat removal system, and a secondary steel containment.
(9) STANDBY GAS TREATMENT SYSTEM: Prior to refueling
the problems identified with the Standby Gas Treatment System
should be corrected,
(10) DECOMMISSIONING PLAN: It is unclear what happens to
the plant and storage of radioactive waste when the plant is
permanently closed. The questions of the cost involved
decommissioning, the impact on Plymouth taxes, waste storage,
security, and dismantling or "seaUng" of the reactor building are
of great concern to area residents. The NRC, the state and Boston
Edison should develop decommissioning plans, well before a
scheduled closing, to answer these and other questions.
The Committee after intensive review of the NRC SALP report
recommends the Boston Edison Company immediately take positive
action on all of the above recommendations. Boston Edison should
improve all of the categories which received grades of category 3 on
the most recent SALP report. The two primary causes for the NRC's
category 3 findings were slowness in making improvements and lack
of management attention. These problems should be resolved so that
none of the functional areas maintains a category 3 grade. It is
imperative that all improvements are completed before action is taken
to restart the Pilgrim Nuclear Power generating facility at Plymouth.
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RECOMMENDATION VI
IMPROVED EMERGENCY PREPAREDNESS PLANNING
Emergency preparedness is the last layer of protection for public
health and safety in the event of an accident at a nuclear plant. Until
recently, emergency planning seems to have been perceived more as
a regulatory requirement than a form of protection which might be
called into use. As public concern over nuclear plants has increased
over the past year, so has emergency planning come under greater
scrutiny.
This scrutiny has found the obvious current emergency planning
is inadequate. The primary responsibility to correct these inadequacies
rests with the state. Working with federal officials, local officials, and
the utility the state must take immediate action to develop plans that
are more realistic and dependable.
The federal government has reserved to itself most powers dealing
with nuclear power plants. The state, however, is left with almost total
responsibility in protecting the public should an accident ever happen.
While this may be jurisdictionally awkward there is no substitute for
state and local planning. Local and state officials are the most
qualified to prepare and implement emergency plans.
It is unacceptable to this committee for a private utility or federal
agency to try and fulfill or usurp state and local responsibility. The
committee feels that prior to restart emergency plans must first be
reviewed and approved by town officials, in the Emergency Planning
Zone (EPZ) communities, and by the state. Nuclear Regulatory
Commission (NRC), Federal Emergency Management Agency
(FEMA), Boston Edison, the State, and towns should work on a
schedule to coordinate the review and decision on whether to approve,
prior to restart.
There is growing debate over how far states can use the planning
approval requirement as a means of preventing a new plant from being
licensed or of closing a licensed plant, if a state does not believe an
emergency response plan can adequately protect the public health and
safety. It appears that the NRC, Congress, and undoubtedly the courts
will be reviewing this issue as more states withhold approvals.
The state should pursue two courses. State and local governments
should develop the strongest possible emergency plans. The public's
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1987] SENATE - No. 2023 119
health and safety demands nothing less. If, after those plans are
developed, the Governor feels they are still inadequate then he may
withhold approval.
The committee heard testimony from the Department of Public
Safety about the need to plan beyond a set limit of ten miles. The
Department stressed, though, that with deficiencies in current ten mile
planning any work beyond the ten mile zone should not deflect any
attention from the communities within the zone. Communities closest
to the plant require a higher level of planning than communities
farther away. The Department also testified that while Civil Defense
is the primary agency for dealing with emergencies other divisions are
involved such as the National Guard, Public Safety, and Public
Health. The Department noted that coordination between state
agencies for nuclear emergency planning needs to be improved.
Local Civil Defense officials from several towns in the EPZ testified
before the committee. Their concerns included:
A) Lack of a reception/ decontamination area;
B) A need for greater technical and material assistance from the
state and utility;
C) Criticism that the plans lacked specific written agreements with
parties which might be involved with an emergency, such as bus
companies and hospitals;
D) A need to plan for regional school systems in which students
come from one but not all towns within the EPZ; and
E) The need for more inter-community planning in order to have
a coordinated regional plan.
The town of Plymouth has created its own local advisory committee
on nuclear matters. That committee has thoroughly reviewed the
town's emergency response plan. Their report has been made available
to the committee and demonstrates the kind of detailed planning
necessary for a strong response plan. It also demonstrates the
indispensable role of local governments in developing plans. Many
of their recommendations would be helpful to other towns. Their
report is included (see Appendix 9).
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While primary responsibility for planning rests with state and local
officials there is necessary assistance which should come from the
utility. This includes technical advice as well as material support
accepted by the state, a county, or a town. The committee feels that
this assistance should be paid for through utility assessments which
will be passed on to utility ratepayers rather than all taxpayers.
Specific improvements to the emergency plans need to come from
the utility, towns and state. The committee recommends the following
improvements:
BOSTON EDISON PLANNING ASSISTANCE:
(1) Boston Edison Company should provide updated and accurate
Evacuation Time Estimates under a wide variety of accident
scenarios. This will enable state and local officials to better plan
traffic management in the event of an emergency.
(2) Identification, notification and workable evacuation plans for
mobility impaired and individuals who will have difficulty being
notified of an emergency or in being familiar with the emergency
response procedure. Such individuals include the physically
disabled, those depending on public transportation, the hard
of hearing and those who speak limited English. Greater
attention to these individuals will help ensure that no one is
excluded from the planning.
BOSTON EDISON EQUIPMENT:
(1) Boston Edison should improve Public Alert Systems including
testing. Sirens should be tested more frequently with improved
monitoring and identification of individual siren deficiencies.
Siren systems should be audible in the entire EPZ, and loud
enough to be heard in buildings with closed windows. In
addition, this system should be supplemented with an adequate
number of loudspeaker equipped vehicles.
(2) Review and supply of needed equipment for shelters and
reception areas for evacuations. During summer months local
population swells, increasing the need for sheltering areas for
non-resident visitors.
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1987] SENATE - No. 2023 121
(3) Provide greater information in the event of an emergency.
During an incident, people may not have written information
on hand about procedures to be followed. This- is particularly
true for non-residents. Printed material with procedures for an
emergency should be pre-printed for quick distribution in group
shelters, relocation areas, hospitals, public transportation, and
through school children during an emergency.
(4) Boston Edison should update the Nuclear Energy Pamphlet to
impress upon the public the importance of following official
instructions. Necessary information should include maps,
location of public shelters, locations of public transportation
facilities, Emergency Broadcast System affiliates, traffic routes,
reception areas and personal safety precautions.
EMERGENCY PLANNING ZONE (EPZ):
(1) Clarify that when any part of a town lies within an EPZ, the
entire town shall be part of the EPZ. Planning and resources
for these towns will have to be upgraded.
(2) Clarify planning for regional schools which have students from
at least one, but not all, towns in the school system which are
part of an EPZ.
(3) Clarify authority of Public Safety to plan for a radiological
emergency beyond a 10 mile EPZ. (See Recommendation I —
Division of Nuclear Facility Safety)
(4) Evacuation time estimates and traffic control plans should be
based on evacuations of people within the EPZ to centers well
beyond the 10 mile zone and should anticipate secondary or
shadow evacuations.
STATE PLANNING:
(1) Increase state assistance to local planners. This should include
technical assistance as well as financial assistance for local use.
The goal should be coordinated regional planning as well as
strengthened local plans.
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(2) Inventory and where necessary create adequate local shelters
to protect non-resident visitors in the event of emergencies
which may not require e-vacuation.
(3) Identify area medical services, hospitals and medical personnel
available for use outside of the EPZs. Also evaluate any
additional services and supplies which may be necessary to serve
EPZ population in the event of an emergency, including
emergency treatment facilities and training of medical
personnel.
(4) The state and towns should participate in appropriate
emergency drills.
(5) Specific planning shall be developed for emergency notification,
evacuation planning, and traffic control planning should be
imposed in areas outside of an EPZ which pose unique
problems, e.g.: Cape Code and the Islands.
(6) Inventory of available buses, ambulances and handicapped/
elderly vans, to assist in an evacuation. Develop an inventory
of service stations and towing operations to be available along
evacuation routes.
(7) Supervise planning by towns, ensure a coordinated, regional
plan, and ensure cooperation between the utilities and area
towns.
(8) Identify and designate adequate reception and decontamination
centers and ensure the availability of adequate supplies and
equipment.
(9) Ensure appropriate annual review and publication of plans
working with the utilities, towns and Federal Emergency
Management Agency (FEMA).
(10) Evaluate and where necessary correct effectiveness of
notification and communication system between state and local
officials.
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1987] SENATE - No. 2023 123
(11) Identification, notification and workable evacuation plans for
people in all institutional facilities — such as hospitals, nursing
homes, schools and prisons — inside the EPZ.
(12) Contractual agreements for the above services where
appropriate should be made to avoid any erroneous
assumptions of transportation in the event of an evacuation.
LOCAL PLANNING:
(1) Each town in an EPZ should consider establishing a
Radiological Emergency Response Plan Committee to review
matters pertaining to emergency response planning.
(2) Local plans need more thorough documentation and letters of
agreement between involved parties to ensure clear lines of
responsibilities in the event of an emergency.
(3) Local officials should inventory local planning needs,
equipment and resources which can be provided by the
Division of Nuclear Facility Safety or the utilities.
(4) In addition to plans for their own communities, local officials
should work closely with neighboring communities to ensure
workable regional planning.
(5) Each town in an EPZ should establish plans for informing non-
residents of procedures to be followed in the event of an
emergency.
The state and utility have been ineffectual and too informal in
developing adequate emergency response plans. The committee,
therefore, finds:
A) The Pilgrim Nuclear Power Plant should not restart until, and
unless, an emergency preparedness plan, including evacuation,
has been approved by the Selectmen in the EPZ communities
and by the Governor;
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B) Federal, state, and local officials and the utility should
coordinate actions in order to reach a decision on whether to
approve emergency response plans prior to restart.
C) The cost of emergency planning should not be borne by all
taxpayers, but financed through utility assessments.
159
Mr. FoRMAN. I, frankly, don't see the problem with giving the
States the power to decide whether or not they have nuclear power
plants. I fully understand and accept the rationale that States and
local governments shouldn't necessarily regulate nuclear power
plants in monitoring them in terms of their operation as well as in
terms of the conditions of health effects. But I have a problem with
the federal government prohibiting States from deciding whether
or not they want plants in their State.
I'm also troubled by the fact that the only straw that we seem to
be grabbing at in trying to create some State authority is the use of
emergency preparedness and withdrawal of State approval or
denial of State approval for emergency plans. I think that actually
could lead to some public safety risks, depending on how the court
and the NRC interpret the State authority. So I would urge Con-
gress and the administration to consider some outright approval to
States across the country, not just because of Pilgrim, but in terms
of State authority and Federal.
The Chairman. What do we do on nuclear waste? Do we give the
States authority to reject that?
Mr. Form AN. We keep the pressure on Congress and the adminis-
tration to pick a site out in Nevada. [Laughter.]
The Chairman. Do we give those States the power to reject?
Mr. Forman. I don't think we can.
The Chairman. First of all, we might just make it normal proce-
dure if a State is going to use nuclear power, let them take the risk
in terms of storing it.
[Applause.]
Mr. Forman. If I can suggest something in response to that. We
deal with issues in this State over low level waste, solid waste and
we run into those siting problems. I think that you can clearly
infer a distinction between the State's willingness or desire to have
an operating plant sited in their State as opposed to national
public health interest of finding a disposal site which is en\dron-
mentally sound.
The Chairman. I think that's right.
Mr. Alexander. I would say, first of all, that the legal issue of
the State's problem is still up in the air. You know Governor Ce-
leste of Ohio actually withdrew the Emergency Response Plan for
nuclear powerplants there until the Commission could take an-
other look at it, and that's in the court as to whether or not he has
that authority or not.
So I would first say that it is still unclear whether Massachusetts
can say, "Well, we're not going to allow Pilgrim to operate because
we don't feel that the emergency response plan is adequate," but I
do think it would be worthwhile to allow Congress to allow States
the ability to regulate nuclear power to the extent that if Congress
has a standard, that States should be allowed to have standards
that are at least as tough as those of the Federal standards; that
way you are not going to have people who might not be as expert
weakening the standards. On the other hand, if the States should
have proper standards, it should be allowed to do so.
The Chairman. Senator Golden, we very much acknowledge the
very important contributions you have made in terms of raising so
160
many of these issues. I'm grateful for your presence here this
evening.
Let me ask you, given what you have said about the evacuation
plans, do you think it is possible to develop an effective evacuation
plan at this point?
Mr. Golden. I believe it would be very difficult. Senator, to de-
velop an effective evacuation plan. I believe, given the limited
transportation routes in this area, we've lost effectively 180 degrees
because the plant is on the shoreline, and because of the limited
north, south, east and west transportation access that we have to
the site, I believe that if the plant was to restart, it would require
significant sheltering plans with shelters that were properly
equipped and those that could withstand the pressure and stress of
the public's access to them. Right now, we don't have that. There
are people who are being sheltered in 2-foot crawl spaces, according
to the existing plan, and in buildings that don't exist any more. So
we need a lot of input
If I could just briefly respond. Senator, to your question about
access to the public. I would like to see Congress change the
Atomic Energy Act and permit the Governor of a State, as a
matter of right, to demand a show cause petition. Our Governor
has requested a show cause hearing. I believe each Governor of
each State should have that right, at legist, and that would open
the public process. The public process could also be opened up, I
believe, by enabling local government, as well as State government,
a role in the formulation and implementation of these plans, and
with that role, the veto power over the plants for their own com-
munities because they do know their communities well.
The Chairman. Let me ask just quickly and then we can move
on. You stressed in your statements you've made on this issue in
other forums, the importance of development of cheap energy. Are
your views tonight consistent with what you would like to see in
terms of development of cheaper energy?
Mr. Golden. Yes, Mr. Chairman. One form of cheap energy pro-
duction is energy conservation. As Rachel Shimshak from
MASSPIRG has indicated, this company, through its own commit-
tee, the Hogan committee, it was chaired and directed by the
United States — former U.S. Senator Saunders, indicated this com-
pany by the year 2000 saved a thousand megawatts of power. The
company in response would request a proposal, a proposal submit-
ted in excess of 2,000 megawatts.
All of that power would provide, I believe, a cheap alternative to
Pilgrim. Given the fact especially, Mr. Chairman, that since April
of 1986, when this plant was shut down, there has been expendi-
tures totaling over $300 million for replacement power and con-
struction cost on this plant. That's $300 million, and we're not any
better off today with all that expenditure than we were 20 months
ago when the plant was shut down.
The Chairman. Just quickly, Mr. Alexander.
Mr. Alexander. Thank you. Senator. Certainly the cheapest
form of power is conservation — where we don't have to produce
more power. An example of conservation's potential is the Appli-
ance Efficiency Law that was passed here in Massachusetts. This
one law alone — by only allowing stores to sell energy-efficient re-
161
frigerators — will each year by the year 2000 save us an amount of
power equivalent to approximately half of the output of the Pil-
grim nuclear power plant. One simple law will do that. The Feder-
al appliance efficiency law is going to save the equivalent amount
of energy as about 23 nuclear powerplants.
It also needs to be said that if you do need new sources of power,
it makes much more sense to have in place small generating facili-
ties that are relatively local, so that if one, for instance, has an
outage, we don't all of a sudden face the kind of crisis that the
New England power pool suggests we're going to have, when a
couple of nuclear powerplants are down for total plant mainte-
nance.
Mr. FoRMAN. I have a slightly different view on the importance
of conservation. Any sound energy policy obviously has to include
conservation, but I think that we are somewhat misguided in as-
suming that in a region that is growing, an economy that is grow-
ing £ind dependent on energy, that we're going to survive for too
long in the future simply by conserving. There is a finite limit on
how much we can conserve £ind continue to grow.
Mr. Alexander. I think one of the great problems we have in
this country is that we don't have a national energy policy that
anyone can identify, and from what I can tell, the State doesn't
either. I don't know of any states that do have a policy, and that's
a real problem. It doesn't have to be based on nuclear. Clearly, we
can have energy policy without it, but both the State and the coun-
try, we need some sound energy policy that will go way beyond
conservation and talks about generation of new power sources for
growing areas, such as a fossil plant in Weymouth. [Applause.]
The Chairman. Thank you very much. I want to first of all
thank you, and the people of Plymouth, through you, for all of
their willingness and hospitality this evening and for helping us so
much with this hearing.
I have just one point. As I understand your testimony, the Plym-
outh Board of Selectmen has made their objections known to the
NRC concerning restarting of the plant without an adequate pre-
paredness plan. I would like to ask you how the NRC has respond-
ed to your concern.
Mr. Malaguti. We have constant communication with the NRC.
We had indications that they are receptive to our comments.
The Chairman. Did they say they wouldn't restart until they
worked out the new evacuation plan?
Mr. Malaguti. No, sir. They have not.
The Chairman. Do you think they should?
Mr. Malaguti. Absolutely.
The Chairman. OK. Ms. Shimshak, we'll include all of the
MASSPIRG studies in the record. The first is the 1983 report enti-
tled "Blueprint for Chaos," and then there is the 1987 report enti-
tled "No Exit," and finally there is the other 1987 report entitled
"Nuclear Lemon." All those will be included.
[The documents referred to above follow:]
162
■-*:^Ti^. ,;',',
^^m^-i
Boston, m OZU^
617,423-1795 '
THE MASSACHUSETTS PUDLIC IfUEREST RESEARCH GROUP
163
Acknowledgments
Glenn Lamb and Carrie Wehllng, MASSPIRG summer interns, provided
»
subBtantial assistance with data collection and telephone surveys of
special institutions in the Emergency Planning Zone. Telephone surveys
of residents were conducted by Eric Dohlman, Jennifer Krouse, Paula Lenzl,
Carrie Wehllng, Arthur Rounds, Claudia Basso, Wyatfe Moor, Wayne Stec,
Leslie Stebbins, and Robert Scudder. Thanks also to Nonna Giunta for her
administrative assistance and to Matthew Mattingly for Illustrations.
Special thanks are also due Jack Dolan and Frank Willard of the
Mass. Civil Defense Agency who have given generously of their valuable
time to discuss the emergency plans at length.
Consultation was also provided by "Doc" Mark Boehnert, M.D.,
Steven Sholly of the Union of Concerned Scientists, Kathleen Welch of
NYPIRG, and Richard Udell of the Oversight & Investigations Subcommittee
of the Committee on Interior and Insular Affairs of the U.S. House of
Representatives.
Thank you all for your contributions to improving emergency
preparedness at Pilgrim.
Michael Ernst
July 20, 1983
164
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY
EMERGENCY PLANNING: AN OVERVIEW 1
The Need for Emergency Planning 1
Emergency Planning in Massachusetts 3
I. * THE EMERGENCY PLANNING ZONE 7
II. ADVANCE INTORMATION TO THE PUBLIC 10
III. NOTIFICATION DURING AN ACCIDENT 16
Notifying Authorities 16
Notifying the Public: Sirens 17
Notifying the Public: Emergency Broadcast System ... 19
Notifying the Deaf 20
IV. EVACUATION PLANS. SHELTERING, AND OTHER PREPARATIONS ... 22
The Decision to Evacuate 22
Special Population Groups . 27
Cape Cod 32
Reception Facilities 33
Medical Facilities 35
Sheltering 36
Emergency Drills 39
CONCLUSION ^1
FOOTNOTES ^3
APPENDICES
A. Telephone Survey of Residents
B. Survey of Major Campgrounds
C. Survey of Local Civil Defense Directors
D. Survey of Correctional Facilities
E. Survey of Ambulance Services
F. Survey of Nursing Homes
G. Survey of Hospitals
165
EXECUTIVE SUMMARY
As a result of the partial core meltdown at Three Mile Island, the \
Nuclear Regulatory Commission (NRC) was forced to concede that dangerous
quantities of radioactivity could escape from nuclear power reactors and
that workable evacuation plans were necessary to protect the public. A
government study estimated that a very serious meltdown at Pllgtla Nuclear
Power Station in Plymouth, MA, could kill 3,000 people. Injure 30,000
more, and cause 23,000 fatal cancers.
Effective emergency planning and preparedness can greatly reduce
radiation exposure because some reactor meltdowns would take many hours
to develop and provide ample time for evacuation. For faster developing
meltdowns, proper sheltering with breathing filters and a drug to protect
the thyroid glands would reduce the health consequences.
Unfortunately, more than two years after the NRC deadline, the
Pilgrim emergency response plans remain woefully inadequate in violation
of state and federal law. The Federal Emergency Management Agency (FEMA)
has Identified 73 deficiencies in the plans and emergency drills. MASSPIRG's
research reveals additional problems so serious as to place the population
in and near Plymouth and Cape Cod at extreme risk if a meltdown occurred.
166
- 2
Hlghllghta of MASSFIRC findings;
* Evacuation planning only applies to a lO-mlle radius around Plymouth, excluding
Cape Cod, even though government studies estimate a serious meltdown could kill
3,000 people up to 20 miles from the reactor.
* Only two-thirds of the permanent residents and no tourists have received
energency information, which is lncoiq>lete, inaccurate and contradicts the
official plans anyway.
* There are insufficient warning sirens that are not loud enough, and fully
three-<iuarters of the area residents have heard false alarms.
* There are no workable plans for evacuating the physically disabled, nursing
home residents, school children, hospital patients, campers, inmates or people
without cars.
* Cape Cod will receive no early warning of a meltdown and the Cape bridges Will
be closed to prevent Cape traffic from interfering with evacuees from closer
to the reactor.
* Sheltering, medical and evacuation reception facilities are grossly inadequate
to care for the 120,000 summer residents and tourists (not counting the
summer Cape population of 1/2 million) .
MASSPIRG calls on the NRC to consider shutting down or reducing the operating
power of Pilgrim until emergency preparedness is substantially upgraded. MASSPIRG
also recommends that the Governor establish a public emergency planning commlssioa
with local representation to oversee the development of workable emergency plans.
167
EMERGENCY PLANNING: AN OVERVIEW
"Every man for himself!" According to the director of the Indian
Head Campground, south of Plynouth, Massachusetts, that Is the extent
of the evacuation plan for as many as 1,000 campers there In case of a
meltdown at the Pilgrim Nuclear Power Plant just seven miles north.
Unfortunately, that seems an apt characterization of the evacuation plans
for all the physically disabled, elderly, nursing home residents, tourists,
hospital patients, and those dependent on public transportation who are
in the vicinity of Pilgrim Station. Even the Federal Emergency Management
Agency (FEMA) acknowledges there are no fewer than 73 deficiencies in the
emergency plana designed to protect the public in the event of a Pilgrim
2
meltdown. Taking into account Pilgrim's safety record, the need becomes
urgent to develop and implement a practical evacuation plan. This study
is Intended as an evaluation of current emergency preparedness with recom-
mendations for realistic ways to improve the current situation.
The Need for Emergency Planning
Under certain reactor accident scenarios, effective emergency response
plans could save thousands of lives. Effective public evacuation or
sheltering can reduce radiation exposure substantially. For slow-developing
reactor core meltdowns, radiation would not escape into the atmosphere for
24 hours or more, providing ample time to evacuate downwind areas. Even
for meltdowns that develop more quickly, it is essential to alert people
168
- 2
Immediately so they can take shelter before the radioactive cloud
reaches them. Like the President's Commission on Three Mile Island,
the Nuclear Regulatory Commission's own Special Inquiry Group, com-
* missioned to investigate that accident, concluded that "workable evac-
uation plans" should be a "prerequisite to continued operation of
existing and future reactors." Major Improvements in these plans were
recommended by both investigations.
En^rgency preparedness is crucial because even though the likeli-
hood of a meltdown is not great, the consequences of a serious radiation
release are horrendous: the government now estimates that a "worst-case
accident" at Pilgrim could kill 3,000 people within a year, injure 30,000
Q
more, and cause 23,000 fatal cancers. Total damages could exceed
$80 billion, not including medical expenses. Even a minute chance of
such an accident is cause for concern In light of its potential severity.
The NRC discovered that the Three Mile Island reactor was "within 30 to 60
minutes" of a major core meltdown with "potentially serious public health
9
and safety consequences." A Nuclear Regulatory Commission (NRC) report
released last summer evaluated almost 20,000 "mishaps" at nuclear power
reactors from 1969 to 1979 and concluded that accidents as serious as that
at Three Mile Island were likely to occur once every three to eight years
somewhere In the country. Directly after the Three Mile Island accident,
in fact, the President's Commission convened to study the matter and made
about 100 recommendations. Its report concluded that even the adoption
of these "necessary fundamental changes" could not assure the safety of
169
- 3
nuclear power. In fact, only a handful of these "necessary" changes
were ever adopted by the NRC.
If nuclear power In general Is cause for concern, the safety record
of the Pilgrim plant In particular Is positively alarming. Of the 54
most serious "meltdown precursors" at nuclear plants nationwide during
12
the last decade, four occurred at Pilgrim. The Plymouth plant averaged
one mishap a week during 1981 and was rated "below average" by the NK.C
In overall management and in reactor safety performance. Boston Edison,
which owns and runs the facility, was fined $550,000 in early 1982 — the
largest fine ever collected from an American nuclear power plant operator •
for disconnecting a major safety system for 2^ years and then making a
"material false statement" about it.
Emergency Planning in Massachusetts
The Nuclear Regulatory Connisslon's Special Inquiry Group on Three
KLle Island discovered that the NRC, because of a "prevailing attitude
that a serious accident with releases beyond containment simply would
not happen," iiad not taken seriously its authority over emergency plan-
ning. Both the Special Inquiry Group and the President's Coimlsslon on
Three Mile Island recommended preparedness around nuclear plants should
be transferred from the NRC to the Federal Emergency Hanageiaent Agency
(7EMA). While retaining final authority over the emergency plans, NRC
170
- 4 -
did Issue new regulations in 1980 Chat require FEMA to review and
comment on all state and local plans. Workable plans were supposed
18
to be in place by April 1, 1981. The regulations require FEMA and
the NRC to determine whether plans "adequately protect the public health
and safety by providing reasonable assurance that appropriate protective
19
measures can and will be taken in the event of a radiological emergency."
Tet even if NRC ultimately determines that a given set of plans
are inadequate, the reactor would be permitted to continue operating
provided the utility could show that any deficiencies were "not signif-
icant," that "compensating actions have been or will be taken promptly,"
20
or that "other compelling reasons" exist to permit plant operation.
Indeed, the NRC has already used this escape clause to permit the con-
tinued operation of the Indian Point reactors in New York. Despite FQ(A
findings that the emergency plans for Indian Point still contained sig-
nificant deficiencies more than two years beyond the deadline, the NRC
21
refused to take any enforcement action. NRC Commissioner Asselstine
charged the decision "made a mockery" of the NRC's regulations.
The burden of drawing up emergency plans in the Commonwealth falls
to the Massachusetts Civil Defense Agency. In the event of a serious
accident at Pilgrim, Boston Edison's reactor operators are to notify
state police while taking steps to prevent a radioactive release. The
state police in turn notify the Department of Public Health (DPH) ,
171
5 -
state and local civil defense officials and local town selectmen. DPH
has primary responsibility for determining the extent of danger presented
to the public and recommending protective actions. Radiation information
•Is obtained directly from the utility and from independent evaluation
teams in the field. These "Nuclear Incident Advisory Teams" from Boston
collect air samples downwind from the reactor and perform radiation
analyses. On the basis of this information, the DPH recommends a course
of action to the Governor. Evacuation may be ordered by the Governor, the
Commissioner of Public Health, the state director of civil defense, or by
the local Board of Selectmen. The Civil Defense Agency actually conducts
the evacuation. (The plan, of course, contains further specifications
regarding the notification of the public and evacuation procedures, and
it is these details with which the present report is particularly concerned.)
The attempt by Boston Edison and state civil defense to develop a
comprehensive emergency response plan, however, was doomed from the start
by the failure to Include local communities in the planning process.
Only long-term residents have a complete understanding of local resources,
capabilities, needs and even likely evacuation obstacles. As a result,
carefully planned "emergency" drills may demonstrate the ability of emer-
gency officials to communicate with each other, but they do not indicate
whether 100,000 local people could be notified, mobilized and evacuated
in case of a real emergency.
172
- 6
In 1977, MASSPIRG published a report evaluating emergency plans
for nuclear reactors In Massachusetts. The report, entitled "Nuclear
Evacuation Planning: Blueprint for Chaos," concluded that planning was
"shoddy and a reactor accident would place citizens' safety in Jeopardy,"
Six years later, we are forced to reach the same conclusion,
A careful review of the current emergency plans reveals major prob-
lems with every section. In Septenfcer of 1982, FEMA found 73 deficiencies.^
Not only do the plans fall short of FEMA's basic standards, but they seem
sloppily concleved and Incapable of implementation. The result, we fear
could be tragedy on a mass scale. The plan is analyzed in four chapters,
as follows: first. The Emergency Planning Zone size is evaluated to
determine whether the plan is designed to protect all the residents who
actually would be affected by an accident; second, we examine the procedure
for informing residents in advance about what to do in case of an accident
at Pilgrim; third, the emergency warning system, intended to inform residents
at the time of an accident, is evaluated; and finally, we examine the actual,
evacuation and sheltering plans and other procedures for protecting the
populace. Specific recommendations for improving the emergency plan are
offered after each section.
173
I, THE EMERGENCY PLANNING ZONE
The first consideration in regard to planning for a nuclear power
plant accident is the size of the area involved. This is known as the
Emergency Planning Zone (EPZ) , and it obviously should be large enough to
Include virtually all people who would likely be exposed to significant
doses of radiation in case of a reactor malfunction. In fact, though, current
plans limit the EPZ to areas within 10 miles of Pilgrim. This is a conse-
quence of both NRC guidelines and a determination by Boston Edison and the •
Civil Defease Agency. In any case. It proves on inspection to be absurdly
Inadequate, with the result that thousands of people who might suffer from a
nuclear accident are utterly without protection in the emergency plans. ,
The NRC has decided Chat EFZ's should be about 10 miles in radius,
with site-specific adjustments based on local "demography, topography,
land characteristics, access routes, and jurisdictional boundaries,"
The effect of these additional criteria is considered below, but it should
first be noted that even as a rough guideline, a 10-mile EPZ is wholly In-
adequate. Several lines of analysis lead to this conclusion:
* The NRC's own rationale is that 70Z of core meltdowns would not
2
result in harmful doses of radiation beyond 10 miles for a typical reactor.
By Its own estimate, then, the suggested EPZ would be inadequate for nearly
a third of all major accidents. Of this group, two-chirds will result
in harmful doses out to 20 miles, and the remainder to between 40 and 50
miles.
174
- 8 -
* A recent govemnent study determined that a worst-case accident
at Pilgrim could kill people as far as 20 miles from the reactor and cause
Injuries 65 miles away. (Boston city limits are less than 35 miles from
the plant.)
* If adequate EPZ size Is best judged under actual accident
conditions, it is useful to recall that the NRC ordered evacuation plans
developed for those living within 20 miles of Three Mile Island.
* California took seriously the hazards presented by major melt-
downs and established EPZ boundaries ranging from 18 - 35 miles from the
^ 6
reactor .
The NRC 10-mile EPZ is based on an outdated accident probability study,
and Is proposed with the suggestion that more serious accidents could be
Q
handled on an "ad- hoc basis." (Thus, the varied and complicated infor-
mation needed to effect an evacuation, much of which is not even available
for the 10-mile EPZ after three years of planning, is supposed to be
collected in a matter of hours.) Yet even the woeful inadequacy of these
guidelines is somewhat mitigated by the criteria offered for site-specific
adjustments, listed above. Unhappily, all of these criteria but one have
been Ignored in designating a 10-mile EPZ for Pilgrim. Only the jurisdic-
9
tional boundaries of area towns were considered; the high population
density of the area, particularly during the summer, was not a factor.
Neither were topography, land characteristics, or access routes. People
outside the designated EPZ are very likely to evacuate even if not required
to do so: 2,500 women and young children were ordered to leave the Three
175
- 9
Mile Island area, but 144,000 actually left. Planning must account
for this de facto evacuation and the question of access routes becomes
particularly critical. The only expressway in the area. Route 3, is
already jannned on summer weekends, and the only exits off Cape Cod are
two bridges less than 15 miles from the reactor. Incredibly, the Civil
Defense Agency has decided that if the wind is blowing south when a
serious accident occurs, the Cape bridges are to be closed. If resi-
dents Just outside the 10-mile EPZ are not included in emergency planning,
they will not receive information on where and how to evacuate or whether
to take shelter instead of evacuating. Limiting the size of the EPZ
without consideration to the certain evacuation of those outside it
therefore results in creating greater danger for residents both inside
and outside of the zone.
Recommendations :
A site-specific analysis of accident probabilities and consequences of
radioactive releases and of the probable health effects at various
distances from the plant should be undertaken promptly. Civil
Defense -should hire independent consultants for this purpose, with
Boston Edison paying all attendant costs. The ultimate objective should
be to establish an emergency planning zone including Cape Cod that covere
all persons at risk of receiving harmful doses of radiation from major
core meltdowns. ^
176
- 10
II. ADVANCE INTORMATION TO THE PUBLIC
No plan for a nuclear accident can hope to save lives If residents
know nothing of its provisions until the accident occurs. Conmon sense
dictates that the public must be familiar with evacuation and sheltering
procedures before a major crisis develops, as well as the relative
benefits of these two responses. There is evidence that many people will
evacuate before directed to do so, and many others will not evacuate even
when ordered to leave.
Recognizing the importance of advance public information for emer-
gency preparedness, FEMA and NRC developed several criteria to promote
maxlnua public education on protective actions. Specifically, the federal
ccl^terla require provision of information on nuclear radiation hatarda,
protective measures Including evacuation routes, sheltering, respiratory
protection, radioprotective drugs, special needs of tourists and the physically
2
disabled, and where to get additional Information.
Adequate dissemination of information involves using several methods
rather than just one. FEMA and NRC recommend including emergency infor-
mation In the phone book and with utility bills, as well as posting notices
In public areas. New York's public education program includes public ser-
vice announcements on the radio, newspaper advertisements, and a speakers'
program, while the EPZ for Verncnt's Yankee nuclear plant contains large
orange posters. In the Plymouth area, by contrast, a pair of emergency
pamphlets is the only method for informing the public about a nuclear
177
11 -
emergency. Beyond the general Inadequacy of this situation, some
451000 tourists who are in the area each summer weekend and 24,000
4
seasonal residents are utterly without Information. FEMA considers this
glaring omission a "significant deficiency." The Chamber of Commerce
has opposed any efforts to educate the tourists for fear of scaring
them away.
Even if the two pamphlets, prepared by the DPH and Civil Defense
Agency, were universally distributed and exemplary, they would be
insufficient to educate the public. In fact, though, they are neither.
The two publications — "Emergency Public Information," with evacuation
and sheltering instructions, and "Nuclear Energy — Questions and
Answers," with more general Information on radiation — were supposedly
mailed to all households in the EPA in the fall of 1982. MASSPIRG's
telephone survey of 100 area residents, however, discovered that only
2/3 of the respondents had ever received the pamphlets and Just 1/6
still had them available. Emergency authorities have made no effort
to ascertain how many pamphlets were received or how little their contents
were understood. Only 9X of the respondents knew they should tune in
their radio or TV to an Emergency Broadcast system station when they
g
heard the Pilgrim warning siren.
As regards the contents of the brochures, serious deficiencies
exist:
(1) The educational information on radiation in the "Nuclear
Energy" pamphlet does not convey the real danger of serious meltdowns.
178
179
- 12
The probability estlnaces of melcdowns from the outdated 1975 Reactor
9
Safety Study are called the "best available." The pamphlet also
understates the hazards of radiation releases from reactors. The effect
is to reinforce the inclination of many people to ignore evacuation
orders. Less than 1/3 of the survey respondents realized that radiation
released from a major meltdown could cause death. If ordered to evacuate,
7Z (nearly 4,000 people) would not leave.
(2) The Plymouth Town Plan stipulates that "most residents of
nursing homes will be evacuated by private automobile." but the
"Emergency" Pamphlet specifically warns that people should not pick up
12
nursing home residents because transportation will be provided for them.
(3) While the Plymouth Town Plan Includes 13 "staging areas"
where "persons without transportation will be directed for possible public
13
transport," the Emergency Pamphlet makes no mention of their existence
or locations.
(4) Sheltering instructions (found only in the Nuclear Energy
Pamphlet) provide no directions to public shelters for tourists or
residents without basements. There are no Instructions on ad hoc
respiratory protection from contaminated air.
(5) Regarding evacuation of the physically disabled, the pamphlet
siiqtly states: "The disabled and those requiring special assistance
180
13 -
^hould concact the (local civil defense) offices listed belov so that
adequate preparation can be made and assistance provided. Do not call
during an emergency unless absolutely necessary. " There is no elabor-
ation on evacuation procedures for the disabled. The MASSPIRG survey
revealed that n£ one had called the Plymouth Civil Defense to arrange
14
for evacuation assistance yet. That means when an accident happens,
everyone needing transportation assistance will be trying to call the
civil defense office at the same time everyone else in town is trying
to call there to find out what's going on. With everyone calling the
office, very few will get through (phone lines to the police are already
tied up whenever the sirens go off accidentally ).
(6) Four of the five telephone numbers listed for "local civil
defense offices" do not reach these offices and none reach the local
civil defense director. The phone nunijer listed for Carver Civil
Defense is the number for reporting burglaries at the police station, and
the first forwarding number provided for the civil defense director turned
out to be a wrong number! The failure to update phone numbers in the
18
plan quarterly was considered a "significant deficiency" by FEMA.
(7) The state plan directs that "the special needs of persons
19
within the EPZ who are ... non-English speaking" will be addressed.
181
This is especially important in North Plymouth and other neighborhoods
In the areas vhich contain large Italian and Portugese communities. The
Emergency pamphlet, however. Is published only in English.
Recommendations :
1) The Nuclear Energy Pamphlet should be updated with the latest federal
estimates of the probability and consequences of serious laeltdowns to
Impress upon the public the importance of following official instructiona
during an emerge.icy.
2) The State and Town Plans and the Emergency Pamphlet must be updated to
provide realistic and consistent emergency response plans.
3) The location of "staging areas" for public transportation must be
included on maps in all emergency information materials.
4) The location of public shelters must be Included on maps in all
emergency information materials.
5) A confidential list of all physically disabled persons in the EPZ
should be compiled by civil defense officials, and practical plana for
their evacuation should be developed. Practical plans for evacuating
the physically disabled, school children, nursing home residents, hospital
patients, canqjers, institutionalized persons and people without 24-hour
access to cars should all be clearly spelled out in all emargency information
materials.
6) The correct telephone numbers for the local civil defense offices or
directors should be Included in all emergency information materials.
7) A comprehensive public education program including radio and TV
public service announcements and a speakerNLs bureau to educate all residents
of the EPZ should be implemented to supplement the pamphlet. This program
should include an evaluation component to confirm that the public is
being adequately informed,
8) A program must be developed for providing emergency information
to tourists through distribution of Emergency Pamphlets, large posters,
and telephone book inserts to all "hotels, motels, gasoline stations,"
restaurants and other public facilities in the EPZ.
9) Emergency information materials should be distributed in Portuguese,
Italian and Japanese.
182
16
HI. NOTIFICATION DURING AN ACCIDENT
Assuming all the people In the EPZ were pro\d.ded with sufficient
Information so that they were prepared to react properly in an emergency,
it would still be necessary to provide immediate and comprehensive no-
tification as soon as trouble was detected. Federal authorities estimate
that a nuclear accident could release substantial amounts of radioactivity
as early as 30 minutes after the "initiating" event. Once again,
people living in the vicinity of the Pilgrim plant are endangered due
to Inadequate planning.
Notifying Authorities
Under current plans, the scheduled chain of emergency responses is
begun by Boston Edison's reactor operators. The very organization with
the greatest investment in convincing people that nuclear power is safe,
in other words, has the discretion to decide when (or whether) to tell
the state police that something has gone wrong. An incentive exists for
Edison's reactor operators to delay reporting until they can correct the
malfunction and then report that everything is under control. Indeed,
within the past year alone, the NRC discovered three notification viola-
tions for Boston Edison's failure to provide prompt notification of
problems which developed during reactor deration. While two NRC
183
- 17 -
Inspectors are assigned to oversee operations at Pilgrim, they are
on duty for only about half of the operating hours.
, Notifying the Public: Sirens
The NRC now requires a system capable of notifying the public In the
3
EPZ vrlthin 15 minutes — a requirement curiously Interpreted by FEMA
to refer only to people living within five miles of the site, with those
In the rest of the EPZ to be notified within 45 minutes. In fact, the
current siren warning system in and around Plymouth meets neither of
these specifications. This is demonstrated, first, by admissions from
the system's designers, and second, by results from a siren test.
Stone & Webster Engineering Corporation designed the fixed siren
alert system to reach about 902 of EPZ residents and 98% of those living
within five miles. The conqjany recommended installation of 250 tone-
activated Emergency Broadcast System (EBS) alarms to make sure the remain-
ing people within five miles were notified and to provide back-up notifi-
cation for "schools, hospitals, nursing homes, police and fire departments,
and possibly for some hotel/motel offices." Even if these EBS receivers
were provided — and they have not been — the engineering firm admits that
some people living between five and ten miles from the reactor would not
hear a siren. In effect, the very design of the siren system now in use
fails to meet federal requirements.
184
- 18 -
On June 19, 1982, the whole siren system was tested. Almost half
(473!) of the FIMA observers reported the sirens were "inaudible" or "barely
audible." The sirens "did not generally wake people that were asleep,"
and between seven and nine of the 90 sirens did not work at all. Noting,
moreover, that the test was conducted on a warm summer day, the observers
determined there was a "strong possibility that a significant portion of
households within the EPZ would not be alerted by the fixed siren signal
Q
under adverse conditions" with windows and doors closed. Their suspicions
were confirmed by nearly half of the MASSFIRG survey respondents for both
9
offices and homes. FEMA concluded that "fixed sirens alone will not Insure
the necessary coverage." After a similar evaluation at Indian Point,
the utilities there agreed to Install an additional 17 sirens.
In addition, the observers reported several unsolicited complaints
12
from residents that the sirens were often activating accidentally. The
MASSFIRG survey found that 77Z of respondents had heard unplanned sirens.
Two-thirds of these people had heard at least three and ISZ heard more than
7 false alarms! FEMA stated that accidental activation of sirens reduces
their credibility, "causing some residents to disregard the alerting signal."
This assertion was also corroborated by the MASSFIRG survey: 19Z of
respondents said if they heard the siren again, they would assume It was
accidentally activated and Ignore it. We also were asked the following
question: "Why can't they Improve the sirens so people would believe them7"
185
"Why can't they Improve the sirens so people would believe them?" ^^
To determine whether a siren was a false alarm, nearly one-third
of those surveyed said they would telephone someone — usually the
poll,ce or fire department. The fact that no one will be able to get
a call through has already been demonstrated. The superintendent of
the state prison in Plymouth con^ilained that even he could never find
out what was going on. "The sirens are always going off. The inmates
and staff panic and I don't know what to do - so I call the police but
1 can never get through."
Finally, back-up vehicles with loudspeakers are supposed to go
out and alert all areas where the sirens don't work. Unfortunately, there
is no plan for discovering which sirens don't work.
Overall. FEMA concluded the siren system did not meet "minimum
federal standards." ^^
Notifying the Public; EBS
Federal guidelines also call for civil defense officials to notify
Emergency Broadcast System (EBS) stations in the evBnt of a serious
accident. '5 Anyone watching television or listening to the radio would
be instructed to turn to an EBS station which, in turn, would provide
emergency instructions. On June 3, 1982. an accident occurred that was
claasified as serious enough to warrant notification of EBS stations, but
this did not happen.
186
20
Rumors about the severity of the accident spread as a result, and many
20
citizens were understandably upset. Even during the official
emergency drill last year, officials failed to notify one of the EBS
21
stations.
Notifying the Deaf
According to the Massachusetts Office of the Deaf, 39,000 people
in the CommDnwealth are totally deaf and another 335,000 have serious
hearing deficiencies. Of the 80,000 residents in the Pilgrim EPZ,
there are probably at least one hundred deaf people and another thousand
who would be unable to hear the warning sirens, let alone radio announce-
22
ments or telephone warnings.
Federal regulations require notification of "all segments" of the
23
population, and the state plan directs that "TV overprinting will be
provided for hearing-impaired persons on area EBS television broadcasts
during an emergency." But what of those people in the target group
who do not happen to be watching television when an accident occurs?
Local officials are to maintain "confidential listings of households and
25
individuals requiring assistance due to special needs.' No such lists
have been compiled, and no plan exists to notify the hearing-impaired
promptly in case of emergency.
187
- 21
Reconmendaclons :
1) TniC Inspectors should be on duty In the reactor control room
24 hours a day to insure the Imniediate notification of emergency officials
whenever problems develop.
2) Enough sirens should be Installed so that tests confirm lOOZ coverage
of Che EPZ with windows closed.
3) Alarms should be installed in every non-residential building in the
EPZ, with a procedure developed to confirm that the sirens are in
working order.
4) A system for determining promptly whether every siren is functioning
oust be iiq)leaented.
5) Civil defense officials should determine the number of vehicles with
loudspeakers necessary to alert residents of any area within 45 minutes in
case a siren fails.
6) Boston Wison should provide a teletypewriter for every deaf person
in the EPZ.^°
7) Capability for TV overprinting for hearing impaired tourists and
seasonal residents must be available on a 24-hour basis.
188
22 -
IV. FVACUATION PLANS, SHELTERING, AND OTHER PREPARATIONS
The Decision to Evacuate
In the event of an appreciable release of radiation, officials must
decide promptly whether to order evacuation or sheltering of the public
downwind from the reactor. Evacuation Is the preferred protective action
because it prevents any radioactive exposure. Since cars provide very
little shielding against radiation, however, sheltering in basements or
large buildings provides greater protection from radiation exposure if
there were insufficient time to evacuate before the radioactive cloud
passed through the area.
If an order to evacuate is given with insufficient time to clear the
area, thousands of people could be trapped in bumper-to-bumper traffic
and irradiated as they are overtaken by the radioactive cloud. Before
ordering an evacuation, emergency officials must be reasonably confident
that the time necessary to evacuate an area is shorter than the time it
will take for the radiation to escape from the reactor and blow through
chat same area.
The decision to order evacuation or sheltering, therefore, depends
on three key estimates: the timing of a release of radioactivity from the
reactor, the direction and velocity of the radioactive cloud after release,
and the amount of time required to evacuate the area. Unfortunately,
the weather bureau's prediction of wind velocity and direction
189
23
over the next several hours is likely to be more reliable than the
other tvro estimates. Emergency officials must rely on Boston Edison's
reactor operators to give an accurate estimate of the time of release.
Hajor accidents can result in releases of radioactivity into the air as
early as half an hour or as late as a day or more after the accident
2
begins. Depending on the particular accident scenario, guessing when
a significant release of radiation may occur could be a very speculative
task.
The estimates of the amount of time necessary to evacuate downwind
areas, while also speculative, are the only estimates that can be. pre-
dicted even roughly in advance of an accident. Boston Edison hired
transportation consultants, HMM Associates, to develop evacuation tine
estimates through the use of a sophisticated computer code. Their results,
however, are based on completely unrealistic assumptions and seriously
underestimate the time that would actually be required to evacuate each
sector.
More specifically, they ignored the fact that obstacles to heavy
traffic flow outside the evacuation zones will Impair prompt evacuation
Inside the areas ordered to evacuate, that many people outside designated
evacuation zones will also evacuate, that some drivers will panic and
create traffic disorder, that thousands of residents do not have 24-hour access
to a car and will need public transportation, and that different types of
adverse weather and evacuating at different times of the day and the week
will also affect the time necessary to evacuate various areas.
190
24 -
HMM Associates estimated It would take 160 minutes to evacuate the
10-mile sector south of Pilgrim Station. NRC consultants conducted a
3
separate analysis and produced an estimate of 410 minutes. HMM Associates
then updated its study to include a "critical bottleneck" in traffic at
the Sagamore rotary, Just one mile outside the EPZ, and concluded the
4
correct time was 315 minutes. A discrepancy of over an hour and a half
still remains. One wonders how many other traffic factors — jams on
Routes 6 and 25, for example — were not considered in one or both
analyses.
HMM Associates also stubbornly refuses to acknowledge that people
living outside the designated evacuation sectors are likely to leave. As
noted earlier, 144,000 people evacuated from around Three Mile Island even
though only 2,500 people were ordered to do so. This single piece of
evidence is so compelling as to demand that evacuation estimates be re-
considered immediately. As one study put it:
In planning for an evacuation from a nuclear
disaster, it can therefore be projected that
any order to evacuate will cause the departure
of residents not only from a designated zone
but also from its peripheries.
The attendant traffic Jams from this phenomenon would likely be so enor-
mous that untold thousands would be in extreme danger, and this situation
is exacerbated by the failure to educate those outside the EPZ about
evacuation routes or procedures.
191
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o
■a
4-1
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u
V
u
v
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u
41
192
25
Furthermore, neither the estimates by HMM Associates nor by the
NRC allow for the possibility of panic and traffic disorder. Substan-
tiating this commonsense concern was a 1980 report by transportation
consultants for FEMA: "Experiences such as major snowfalls (even in
regions accustomed to such types of weather) suggest that driver behavior
deteriorates quite regularly under circumstances of 30- to 90-minute
delays." One could expect such behavior as blocking cross streets,
disregarding traffic signals, driving in the left-hand lane against
traffic, abandoning vehicles, and many accidents as a result, according
to the study. In fact, it predicted a 50% reduction in traffic flow
compared to disciplined traffic. With ineffective traffic control,
evacuation estimates concerning the Seabrook plant should be doubled.
Yet those people preparing estimates on the time necessary to evacuate
the Plyncuth area — the estimates that will form the basis of a llfe-
and-death decision — assume that normal traffic conditions will prevail.
Moreover, the estimates by HMM Associates fail to consider the time
necessary to evacuate the nursing homes, schools, hospitals, campgrounds,
physically disabled and people without 24-hour access to cars. In fact,
g
MBTA buses will be called in from Boston. No estimates have been developed
for the time required to bring in sufficient buses at different tines of
the day, week, and year and under various weather conditions. Indeed,
federal guidelines require not just one evacuation time estimate, but a
variety of estimates for different times of the day and different weather
9
conditions for each sector around the reactor. Boston Edison's only
193
- 26
time estimates are for peak and typical population during normal and
10
adverse weather, falling far short of the multiple federal requirements.
Because of these various deficiencies — failure to account for panic,
traffic disorder, public transportation - dependent Individuals, and
so forth — the Mass. Attorney General also has concluded that the
U
evacuation time estimates are Inaccurate.
Even if HUM Associates considers these new factors, the new time
estimates will remain speculative. Given all the uncertainties involved,
the decision to order evacuation should only be made when the best
estimate for a radiation release exceeds the new evacuation time estimates
by a substantial margin.
Recommendations:
1. Given the difficulty in predicting the time when radioactivity may be
released from a meltdown, reactor operators and NRC Inspectors should be
trained to make accurate estimates under various accident scenarios. In
the event of an actual meltdown, reactor operators and NRC inspectors should
give emergency officials their best estimates together with an indication
of the level of confidence they have in these estimates.
2. Boston Edison should pay for a new evacuation time study supervised by
FEMA. The new study should assume that a substantial amount of spontaneous
evacuation will occur around the periphery of designated evacuation zones,
that traffic obstacles outside the EPZ such as the Sagamore rotary will
affect the amount of time required to evacuate the EPZ, that some drivers
will panic and cause traffic disorder and delays, and that a substantial
segment of the population will require public transportation to evacuate.
The new study must also include separate evacuation time estimates for
various special population groups, for different adverse weather conditions
and for various times of the day, week, and year.
194
195
27-
Speclal Population Groups
While all residents are at risk as a result of Irresponsible and
*
inadequate evacuation time estimates, certain individuals are at an
even greater disadvantage in case of emergency. The plans fall to address
the needs of specific populations, including handicapped persons, nursing
home residents, school children, hospital patients, and inmates as well as
everyone dependent on public transportation.
Civil defense authorities have made the assumption that private
automobiles can provide virtually all of the transportation required to
12
evacuate the population. In fact, this is false: about 13Z of Plynouth
13
households, representing over 4,000 residents, do not own a car. Also,
14
nearly half of Plymouth's workers have jobs outside the town. Should
an accident occur during a weekday, the plans state that these workers
may not be permitted to return home to pick up their families. Another
10,000 residents may therefore require transportation.
Current plans call for sending in MBTA and other area buses to pick
up residents without access to automobiles. There is no evidence that the
MBTA or any private bus lines have ever been contacted about evacuation
assistance. Beyond the fact that no written agreement exists to provide
for this (as federal criteria require ), it would take about 350 buses to
18
evacuate 14,000 people — and no one has any idea how long this would
take or whether that many buses could be made available quickly. Relying
on large fleets of local buses raises another problem: most bus drivers
would evacuate their own families from danger zones before reporting to drive
196
- 28
an evacuation bus. Two surveys of bus drivers in New York confirm this
conclusion, and the state of New York is connnitted to funding a "compre-
19
henslve study" of the mass transit evacuation problems. Finally, the
"staging areas" where people would be picked up by buses are not listed
in the emergency information pamphlet.
While federal regulations require the development of plans for "pro-
tecting those persons whose mobility may be impaired," these persons,
20
perhaps 1000, have not even been Identified yet. Although the Massachusetts
Radiological Emergency Response Plan states that lists of the physically
21
disabled and elderly will be maintained by civil defense officials, the
PlymDuth Plan says this:
Because it is not feasible to maintain
current lists of handicapped individuals
within the towns, an inventory of local
transportation resources, both private and
public, that would be called upon to assist
any individuals having special needs due to
handicaps or disabilities will be maintained
by the Director of Civil Defense. In addition,
local agencies that serve the handicapped
will be called upon to assist in the event of
22
an emergency. ^^
Even If this alternative were accepted as satisfactory. It proves utterly
unrealistic in practice. The "local agencies" are not specified, to begin
with. As for transportation resources, the MASSPIRG survey revealed that
only one of the twelve ambulance and wheel chair transit companies listed
in the plan has been contacted regarding participation in an evacuation effort.
Only one company listed is within 20 miles of Plymouth, and it closed two
years ago. Five of the six ambulance companies have no plans to assist
197
- 29 -
and are not prepared to handle radiation victims. Gilbert Gamett,
owner of Bristol County Ambulance, said he would not send any ambulances
In the event of a serious accident:
"If they want ambulances, they'll have to come get
them. No one on my staff will go anywhere near Plymouth
if there is an accident at the nuclear plant." 23
Of the three wheel chair transit companies listed in the State Plan,
one Is a duplicate listing and the second is for a company that has been
24
out of business for four years. FEMA's recent evaluation concluded that
"no information is found (in the plans) that provides protection for the
mobility impaired," calling this a "significant deficiency" in the plans.
Only one director of all the nursing homes, campgrounds, and correctional
facilities listed in the plans has ever been contacted about evacuation plans,
and contradictory plans for evacuating hospitals and schools add to the
confusion. Consider:
* There are five nursing homes in the Plymouth area alone which
27
the Plymouth Plan states have a total capacity of 380 residents. The
28
Plymouth Plan calls for an evacuation of these residents by automobile,
but the EPZ brochure tells people not to pick up nursing home residents
29
because transportation will be provided. A MASSPIRG survey found that
the actual capacity of these homes is about 430, that none had been contacted
about a radiological emergency (one spokesperson assuming they would have
to "call in the National Guard"), and that it was not clear whether the staff
was to evacuate with residents.
* Flans call for 80 to 85 school buses to evacuate students
26
198
31 -
When pressed to explain how all these different groups of people can
be evacuated, a civil defense official simply replied, "The Governor will
.declare a state of emergency and we'll order buses in here." But how
many buses are needed? From where? How long will it take for the drivers
to report and drive them to the EPZ7 Where will they go when they get
there? These are life and death questions that cannot wait to be answered
correctly during the panic of a real crisis. They must be answered now so
that all the kinks can be straightened out before a meltdown. Without
these answers an informed order to evacuate cannot be made.
Reconmiendatlons :
1) A diligent effort must be made to Identify all persons within the EPZ
who may need transportation assistance in an evacuation due to physical
disability.
2) Practical plans must be developed to provide prompt transportation for
each individual needing assistance to evacuate.
3) Civil defense officials should meet with the administrators of all
nursing homes, medical facilities, campgrounds and correctional facilities
to develop workable evacuation plans for the residents and the staff and to
Identify specific transportation needs for each institution at various times
of the day, week and year.
4) Civil defense officials should sit down with school administrators and
the P.T.A. to develop workable student and teacher evacuation plans and
establish criteria for determining when, if ever, it would be appropriate
to send children home first to evacuate with their families.
5) Civil Defense should undertake a comprehensive study, financed by
Boston Edison, of public transportation resources available at various
times of the day, week and year. Written agreements should be reached with
both transport companies and their bus drivers.
199
33 -
Reception Facilities
If any evacuation is ordered, TV and radio EBS broadcasts and the
police will direct evacuees to designated "reception centers" outside the
EPZ. Evacuees will be monitored for radiation and decontaminated (if
necessary), re-united with family members, and assigned shelter and/or
43
transportation. There are numerous problems with the feasibility and
safety of the proposed reception procedure.
The first and most glaring problem is the location of the reception
centers. Two of the three centers are in exactly the same direction as
44
the areas from which evacuees would be fleeing! If the wind were blowing
northward during an accident, evacuees north of Pilgrim would be sent
north to Hanover Mall, just 20 miles downwind from Pilgrim. Government
figures, remember, estimate a "worst-case" accident could cause deaths
20 miles downwind from the plant. Bridgewater State College has the same
problem since it is located 20 miles due west of Pilgrim. Taunton State
Hospital, the reception center for southern evacuees would also be within
the radioactive plume if the wind were blowing southwest. If is unlikely
in any case that most evacuees would stop just 20 miles downwind of a
nuclear meltdown.
A summer evacuation would send roughly 40,000 people to any of these
45
reception areas. No one could seriously contend that any of these recep-
tion centers could handle that many people within the federal guideline of
46
12 hours. During the March 3, 1982 drill, FEMA reported that Hanover
officials "questioned whether water and sewage facilities were adequate for
200
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47
potentially large numbers of people." Hanover Mall does not even
have adequate facilities for a few thousand people, let alone 40,000,
The State Plans provide for decontamination of evacuees and their
48
vehicles. Several decontamination washing solutions are recommended
for a range of body and vehicle surfaces and degrees of contamination.
The plans caution that decontamination wash "drainage must be controlled."
Current reception centers do not stock the recommended wash solutions,
nor is there provision for control of contaminated drainage. FEMA
criticized the lack of "soap, waste disposal, and contaminated clothing
bags" at the centers.
Recommendations:
1) New reception centers should be established at least 40 miles from
Pilgrim, north and west of Boston.
2) These should be adequate to accommodate the entire permanent and
transient population in the EPZ.
3) Each reception center should stock the full range of recommended wash
solutions and have the capability of collecting contaminated wash
drainage.
201
Medical Facilities
A core meltdown could result in a significant release of radioactive
gases and particulate matter into the air. This can cause genetic mutations,
cancer, serious injuries, and even death to all life forms. For this
reason, federal regulations mandate the provision of special medical care
for contaminated injured indl .-iduals . The only two hospitals listed as
providers of any medical care, however, admit they have the capacity to
52
treat only 8 or 9 contaminated persons. One of these hospitals, moreover,
is only 3*1 ailea from the plant and obviously should not be utilized.
The remaining hospital has no staff trained for radioactively contaminated
53
patients.
As a suppleuBnt to treatment at medical facilities — but by no means
a substitute — potassium iodide (KI) has been proven safe and effective
54
against radioactive iodine as a means of preventing thyroid tumors.
Laboratory workers exposed to radioactive iodine have taken KI for many years
and FEMA guidelines now call for the use of KI in the event of a nuclear
accident. ^^ It is distributed by the Tennesse Valley Authority to house-
holds near the Sequoyah reactor and throughout all EPZ's In Sweden.
National public interest organizations including the Union of Concerned
Scientists and the Health Research Group support the distribution of KI to
all dwellings in the EPZ and it's availability for sale over-the-counter
56
for summer residents and those just outside the EPZ.
202
- 36 -
Recommendations:
1) Sufficient medical facilities outside the EPZ should be Ide
to care for large numbers of contaminated individuals.
2) All emergency personnel should receive special training in
treatment of radiation victims.
3) Potassium iodide should be distributed in childproof contai
to every household in the EPZ before a nuclear accident. Inatr
should be included and the substance should be sold over-the-co
as well.
Sheltering
If there is inadequate time to evacuate the public before .
of radiation passes through an area, the recommended protective i
shelter ing.^^ As the cloud blows downwind, some of the radloact
material or "fallout" is deposited on the ground and buildings I
If a substantial amount of fallout were deposited by the radioac
cloud, then evacuation would be ordered as soon as the cloud pa;
order to minimize additional radiation exposure.
An effective sheltering strategy requires both protection i
gamma radiation emitted from the passing radioactive cloud and f
fallout as well as protection against inhalation of airborne rac
particles. The basements of large buildings and of brick homes
most protection from gamma radiation. ^^ But where are 45.000 su
tourists going to find basements in large buildings or brick horn
203
37 -
Wooden motels and cabins and tents provide virtually no sheltering
protection from a radioactive cloud, and the 24,000 sufflmer residents
typically live In cottages that are also wooden and without basements.
In fact, even for the 54,000 full-time residents, there are few
large buildings or brick homes with basements In the Pilgrim EPZ. Fewer
than 20Z of the permanent residences In Massachusetts are brick , and
about 30Z of the year-round homes In the EPZ have no basement. Con-
sequently # a substantial majority of the people in the EPZ lack adequate
sheltering facilities.
Civil Defense has still not completed a survey of available public
shelters in the EPZ. Those shelters identified already are not marked
62
on evacuation maps as required by federal guidelines.
This lack of sheltering protection is compounded by the failure to
educate the public about simple building infiltration and breathing filter
techniques. Sheltering studies have revealed that an average residence
with windows and doors shut reduces the amount of radionuclides inhaled
by about 35Z. Greater protection is afforded by weatherstripping, storm
windows and doors, and the taping of all window and door cracks in an
emergency. Further protection would be provided by the use of individual
respiratory filters such as hospital masks or wet towels or handkerchiefs.
The Emergency Public Information pamphlet, however, makes no mention of
these Important protective measures.
204
- 38
Recommendations :
1) Civil Defense should identify enough public shelters to accommodate
as many as 80,000 people who lack basements in the summer. 6*
2)* Public sheltering facilities should be equipped with necessities and
clearly marked as Civil Defense shelters. Large signs should be erected
directing tourists to the nearest shelters.
3) The location of public sheltering facilities should be clearly
designated on the maps in the Emergency Public Information brochures,
on large posters and in telephone book inserts distributed throughout
the EPZ.
4) All emergency public Information materials should include
sheltering instructions, including techniques for making home-made
breathing filters and reducing radioactive air infiltration into
sheltering facilities or homes.
5) Civil Defense should distribute hospital masks to every building in
the EPZ. ^5
205
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Emergency Drills
No planB with the complexity of evacuation plans could ever be
carried out successfully without regular and comprehensive drills. Every
year, Boston Edison and state officials hold an emergency exercise
simulating a meltdown at Pilgrim. The exercises expose liqjortant defi-
ciencies which must be corrected, but they are still not sufficiently
coi)H)rehen8lve to verify the capability to protect the public in the event
of an actual meltdown.
At last year's drill, FEMA identified many deficiencies, including
inoperable sirens, failure to activate an emergency broadcast system
station, lack of equipment for measuring radiation, and the Issuance of
an Incorrect evacuation order. The federal evaluation of this year'a
drill, held June 29, will not be completed for several weeks, but Civil
Defense and FEMA observers admitted there were significant comminicatlon
problems at least. The troubled siren system will not be tested until
FEMA Issues new evaluation criteria later this year.
A more serious problem la the failure of the exercises to dencnstrate
the capability to warn, mobilize, evacuate, and decontaminate the public.
Even FEMA has conceded this point. It is not necessary to attempt a
full-scale public evacuation to establish this capability. At a minimum,
however, all sirens should be tested, sample messages broadcast on EBS,
special institutions alerted and transportation arranged for all special
population groups needing assistance within the sector targeted for
evacuation. This is an excellent occasion to educate the public through
the media of the details of sheltering and evacuation.
206
- AO -
Another problem with the exercises Is the comprehensive prior
planning and prenotif ication of emergency personnel. Federal criteria
require occasional unannounced exercises during the evening and night-
time and under various weather conditions which more accurately test the
real emergency response capability of officials.
Recommendations:
1) Emergency exercises should include every aspect of an actual emergency
response, except evacuation of the public. Every drill should include
testing of all sirens, institutional alarms and back-up warning capability;
activation of the EBS system and broadcast of simulated emergency messages,
arrangements for transportation for all special population groups within
the sector targeted for evacuation, and bringing in some buses from each
participating bus company to report to a special institution or staging
area and then to drive the evacuation route to the appropriate reception
2) Drills should be conducted in the evening, at night, under various
weather conditions and seasons, and without prior warning.
207
41
CONCLDSION
Individually, jmy of the problems with current emergency planning
Identified in this report is serious; collectively, they point to a
crisis situation in extreme proportions. Even the Director of the
Plynouth Civil Defense office, James Ryan, has admitted "there is no
way that everyone can be evacuated."
Besides the indefensible danger presented by the emergency plane,
2
violations of state and federal law are involved. The plans are required
to provide "reasonable assurance that adequate protective measures can
and will be taken in the event of a radiological emergency." The
Massachusetts Attorney General has agreed that the current plans fail to
do this and has urged that consideration be given to the operation of
Pilgrim at reduced power or even shut down during the summer, when the
3
area is clogged with visitors whose lives are in jeopardy.
MASSPIRG has submitted a formal petition to the Nuclear Regulatory
Commission requesting immediate remedial measures, including consideration
of shutting down Pilgrim until an adequate state of emergency preparedness
- 4
is achieved. Given the NRC's recent refusal to enforce emergency planning
regulations under similar conditions at the Indian Point reactors in
3
New York , though, it will no doubt fall to the Conmionwealth to protect
its citizens. MASSPIRG therefore urges the Governor to establish a public
emergency planning commission to oversee the revision of these plans for
Pilgrim (and for the area near the Rowe reactor, to the extent its problems
are similar). The state also should commission an emergency mass transpor-
208
42
tatlon study, a new calculation of evacuation time estimates, and a
computer analysis of the consequences of major meltdowns with an eye
to expanding the emergency planning zone to Include Cape Cod and
other areas near the Plymouth plant. Until these recomnwndatlons are
Implemented — until the egregious Inadequacy of current planning is
acknowledged and corrected — the lives of thousands of citizens will
remain at risk.
!
209
- 43 -
FOOTNOTES
OVERVIEW
1. MASSPIRG Survey of Major Campgrounds, Appendix B.
2. "Interim Findings: Joint State and Local Radiological Emergency Response
Capabilities for the Pilgrim Nuclear Power Station" ("FEMA Interim Findings") ,
FEMA, September 1982.
3. "Planning Basis for the Development of State and Local Government Radiological
Emergency Response Plans in Support of Light Water Nuclear Power Plants,"
("Planning Basis"), mJREG-0396, EPA/NRC. December 1978, p, 20. Also see
Chapter IV: Evacuation Plans.
4. See Chapter IV: Sheltering.
5. "Three Mile Island: Report to the Commissioners and to the Public" ("NRC
Special Inquiry Group Report"), NRC Special Inquiry Group, 1980, p. 132.
6. "Report of the President's Commission on the Accident at Three Mile Island"
("Report of the President's Commission"), October, 1979, pp. 76-77 (emphasla
in original); NRC Special Inquiry Group Report, op. cit. pp. 131-133.
7. The NRC defines a "worst-case accident" as the worst accident considered
theoretically possible at a nuclear power plant. It may be worth noting,
however, that the accident at Three Mile Island was considered "not credible" -
which is to say, impossible - before it actually happened.
8. "Calculation of Reactor Accident Consequences ("CRAG 2") For U.S. Nuclear
Power Plants (Health Effects and Costs) Conditional on an SSTI Release,"
U.S. House of Representatives Committee on Interior and Insular Affairs,
Subcommittee on Oversight and Investigations, November 1, 1982, p. 9.
9. NRC Special Inquiry Group Report, op. cit., p. 91.
10. "Precursors to Potential Severe Core Damage Accidents" ("Precursors"),
NUREG/CR-2497, Oak Ridge National Laboratories, 1982.
11. Report of the President's Coimnission, op. cit., p. 7.
12. "PrecuTBors," op. cit.
13. "Systematic Assessment of Licensee Performance," NUREG-0834, 1981;
NRC memo from Gus Lalnas, Assistant Director for Safety Assessment, to
Darrell Elsenhut, Director, Division of Licensing, "Summary of the
Operating Reactor Events Meeting on December 16, 1981 ," December 28, 1981.
(These safety rankings are based on both the number and severity of mishaps
between December 13, 1980 and October 7, 1981.
14. Letter to F.M. Staszesky, President, Boston Edison Company from Richard C.
DeYoung, Director, NRC office of Inspection and Enforcement, NRC Docket
No. 50-293 (January 18, 1982).
15. NRC SEeclal Inquiry Group Report, op. cit., p. 131.
210
44 -
'16. Roport of the President's Commission, op. cit., p. 76.
17. 10 CFR §50.47 and Part 50, Appendix E.
18. 10 CFR i50.54(s)(2)(i).
19. 44 CFR §350. 5(b) (proposed rule; current FEMA guidelines);
10 CFR §50.4:(a)(l).
20. 10 CFR §50. 47(c)(1).
21. "In the Matter of Consolidated Edison Company of New York and
Power Authority of the State of New York (Indian Point 2 & 3)",
CLI-83-16, June 10, 1983.
22. "Interim Findings," op. cit., pp. 1,5.
I. THE EMERGENCY PLANNING ZONE
1. 10 CFR §50. 47(c)(2) ; 44 CFR 8350. 7.(b) (current guidelines).
2. Planning Basis, op. cit. ; "Massachusetts Radiological Emergency Response
Plan ("State Plan")," Appendix 3 - Pilgrim, pp. C-78-79. (The Environmental
Protection Agency recommends evacuation when the expected radiation dose to
the public is one "REM". A REM is a unit of measuring radiation exposure
and is the equivalent of receiving about 10 x-rays.)
3. Planning Basis, op. cit.
4. "CR/-.C 2," op. cit.
5. Report of the President's Commission, op. cit., p. 40.
6. "Emergency Planning Zones for Serious Nuclear Power Plant Accidents,"
California Office of Emergency Services, November 1980.
7. The Planning Basis report, op. cit., was written in 1978 and used the
probability estimates of the 1975 Reactor Safety Study. More recent
studies indicate a higher probability of accidents (Precursors, op. cit.)
and more serious consequences from them (CRAC 2, op. cit.).
8. "Planning Basis," op. cit., p. 16.
9. "Response of Boston Edison to Commonwealth of Massachusetts' First Set of
Interrogatories on Emergency Planning, " July 20, 1981, p. 2.
10. "NRC Special Inquiry Group Report," op. cit., p. 1016.
11. "A Public Meeting on the State and Local Off-Site Radiological Emergency Plan,'
Transcript of Hearing. ("Transcript of Public Hearing"), Plymouth, Mass.,
June 3, 1932, statement by Baul Cahill, then Director. Mass. Civil Defense
Agency, p. 109.
211
45
12. "Comments of Attorney General Francis X. Bellottl Relative to Off-Site
Emergency Planning for the Pilgrim Nuclear Power Station," ("Coainents of the
Attorney General"), submitted to FEMA, August 1982, pp. 11-13.
II. ADVANCE INFORMATION TO THE PUBLIC
1. "The Social and Economic Effects of the Accident at Three Mile island,"
C.B. Flynn and J. A. Chalmers, 1980, p. 22. (About 20,000 people evacuated
from Three Mile Island before any order was Issued.) On the other hand, the
MASSPIRG Survey also revealed that 7Z of respondents would not evacuate
even if ordered to do so (Appendix A, l?32). Twenty percent of respondents
in the Shoreham EPZ said they would not evacuate. ("Discussion Overview
of the RERP of the County of Suffolk," Philip B. Herr & Associates,
Nov. 29, 1982, p. 15.)
2. Criteria for Preparation and Evaluation of Radiological Emergency Response
Plans and Preparedness In Support of Nuclear Power Plants ("Evaluation
Criteria"), NUREG-0654, Rev. 1, Evaluation Criteria G. 1. ,G. 2.
. 3. Evaluation Criterion G.l.
'4. State Plan, op. cit., p. C-9.
. 5. FEMA Interim Findings, op. cit., p. 6.
6. Phone conversation with Gerald Hayes, former Plynouth Civil Defense Director.
July 12, 1982.
7. MASSPIRG Survey of Residents, Appendix A, l?23, )?28.
8. MASSPIRG Survey of Residents, Appendix A, //16,
9. Nuclear Energy - Questions and Answers, p. 4.
■10. MASSPIRG Survey of Residents, Appendix A, #43.
11. MASSPIRG Survey of Residents, Appendix A, #32
12. Town of Plymouth Radiological Emergency Response Plan ("Plynouth Plan"), p. 36.
Emergency Public Information, p. 6.
13. Plymouth Plan, op. cit., p. ANN. B-9.
14. MASSPIRG Survey of Local Civil Defense Directors, Appendix C.
15. MASSPIRG Survey of Correctional Facilities, Appendix D; Interim Findings,
op. cit., pp. 15-16.
16.
MASSPIRG Survey of Local Civil Defense Directors, Appendix C.
212
46 -
17. ' MASSPIRG Survey of Local Civil Defense Directors, Appendix C.
18. FEMA Interim Findings, op. cit., p. 6; Evaluation Criterion P. 10.
19. State Plan, op. cit., p. C-21.
20. Evaluation Criterion G.2.
III. NOTIFICATION DURING AN ACCIDENT
1. "Planning Basis," op. cit., p. 20.
2. Letter from Richard Starostecki, Director, Division of Project and Resident
Programs, NRC, to Boston Edison, dated Septeniber 28, 1982, Appendix A:
Notice of Violation.
3. 10 CFR Part 50, Appendix E, IV, D.3.
4. Evaluation Criterion E.6. and NUREG-0654, Appendix 3, p. 3-3.
5. Report on the Coverage and Performance of Sirens Around the Pilgrim
Nuclear Pover Station ("HUM Siren Report") , HUM Associates, July 15, 1982,
pp. 2-6 - 2-7.
6. Report on the Pilgrim Nuclear Power Station Siren Test, June 19, 1982
("FEMA Siren Report"), FEMA, January 1983, p. 6.
7. HMM Siren Report, op. cit., pp. 8-3, 4-7.
8. FEMA Siren Report, op. cit., pp. 11, 10.
9. MASSPIRG Survey of Residents, Appendix A, ff7 , (?13.
10. FEMA Siren Report, op. cit., p. 11.
11. Letter from Lee Thomas, Acting Deputy Director, FEMA, to William Dircks,
Executive Director for Operations, NRC, dated December 17, 1982.
12. FEMA Siren Report, op. cit., p. 9.
13. MASSPIRG Survey of Residents, Appendix A, HS, 1119.
14. FEMA Siren Report, op. cit., p. 8.
15. MASSPIRG Survey of Residents, Appendix A, 1116.
16. MASSPIRG Survey of Residents, Appendix A, l?29.
17. MASSPIRG Survey of Correctional Facilities, Appendix D,
213
47 -
18. FEMA Interim Comments, op. clt.. p. 15.
19. Evaluation Criteria E.5, E.6.
.20. Transcript of Public Hearing, June 3. 1982, pp. 79-86.
21. FEMA Exercise Report, op. clt., p. 54.
22. 7% (:59,000 deaf and 335,000 with serious hearing impairments out of
5,737,037 total residents) of Massachusetts residents have serious
hearing deficiencies. Although deaf people tend to congregate in urban
areas, it is reasonable to estimate that 2Z (54,000 permanent residents
in EPZ) or 1000 residents have serious hearing problems in the EPZ.
23. Criteria J.lO.c, E.6. ; 10 CFR Fart 50, Appendix E, IV. D. 3.
24. State Plan, op. clt., p. C-24.
25. State Plan, op. clt., p. C-24 - C-25.
26. Teletypvriters (TTY's) transmit typewriter messages over phone lines
with warning lights that signal receipt of a message. In the past, Boston
Edison offered to provide TTY's to deaf persons in the EPZ. California
has provided TTY's to all deaf persons In the state.
IV. EVACUATION PLANS, SHELTERING, AND OTHER PREPARATIONS
1. Plymouth Plan, op. clt., pp. 5-6.
2. NUREG-0654, p. 17.
3. "An Evaluation of the Evacuation Time Estimates Submitted by the Applicant
for a Peak. Population Scenario at the Pilgrim II Nuclear Power Station,"
E.P, Moeller, T. Urbanlk II, and A.E. Desrosiers. March 1981, p. 5.
4. State Plan, op. clt., p. C-86 (South 10 Miles - Normal Weather).
5. "Evacuation from a Nuclear Technological Disaster," D.J. Zlegler, S.D. Brunn
and J.H. Johnson, Jr., The Geographical Review, January 1981, p. 7.
6. "Seabrook Station Evacuation Analysis," ("Seabrook Analysts'!) Voorhuis and
Associates, August 1980, p. 63.
7. Seabrook Analysis, p. 74; "Dynamic Evacuation Analyses: Independent
Assessments of Evacuation Times from the Plume Exposure Pathway Emergency
Planning Zones of Twelve Nuclear Power Stations," FEMA-REP-3, 1981, p. 46.
214
- 48 -
8. Exercise Report - Joint State and Local Radiological Emergency Response
Exercise for the Pilgrim Nuclear Power Station, March 3, 1982 ("FEMA
Exercise Report"), FEMA, Septerier 1982, p. 45.
■ 9. Evaluation Criteria J. 8., J. 10.1., and Appendix U, pp. 4-3, 4-6, 4-7, 4-9, 4-10.
10. State Plan, op. cit., p. C-86.
11. "Comments of Attorney General Francis X. Bellotti Relative to Off-Site
Emergency Planning for the Pilgrim Nuclear Power Station" ("Comments of the
Attorney General"), submitted to FEMA, August 1982, pp. 7-9,.
12. Plymouth Plan, op. cit., p. 8.
13. MASSPIRG Survey of Residents, Appendix A, #34.
14. Town of Plynouth Planning Board Survey, 1979; MASSPIRG Survey of ReBidents,
Appendix A, #6.
15. Emergency Public Information Pamphlet, p. 6.
16. FEMA Exercise Report, op. cit.. p. 45.
17. Evaluation Criteria A.3. andC.4.
18. To evacuate 14,000 people in buses with a capacity of 40 persons would
require about 350 buses. Evacuation buses would not have room for much more
than their capacity of 40 people because evacuees are directed to bring extra
clot. ling and necessities. The civil defense estimate that only about
50 buses would be needed is clearly inadequate [FEMA Exercise Report, p. 45].
Civil defense also relies on carpooling too much [Plymouth Plan, p. 8],
There simply won't be that much extra room In the family car after the family,
pets and clothing are stuffed into cars which are becoming smaller and smaller.
19. "Response of Emergency Personnel to a Possible Accident at the Shoreham
Nuclear Power Plant," Social Data Analysis, Inc., October 1982; "Update
Report on the Status of Remedial Actions Cited in the July 30, 1982 Interim
Findings on the Adequacy of Radiological Emergency Rebponse Preparation of
State and Local Governments at the Indian Point Nuclear Power Station,"
("Update Report on Indian Point,"), December 1982, p. 6.
20. Evaluation Criterion J.lO.d; The MASSPIRG Survey of Residents discovered that
6X of households in the EPZ had physically disabled people. 62 of 20,000
households in the EPZ (1980 Census) is 1200 handicapped persons.
21. State Plan, op. cit., pp. 22-23.
22. Plymouth Plan. op. cit., pp. 39-40.
23. MASSPIRG Survey of Ambulance Services, Appendix E.
24. MASSPIRG Survey of Ambulance Services, Appendix E.
215
- 49 -
25. FEMA Interim Findings, op. cit.. p. 6.
26. MASSPIRG Surveys of Nursing Homes (Appendix F) , Campgrounds (Appendix B)
and Correctional Facilities (Appendix D).
27. Plymouth Plan. op. cit.. p. 38.
28. Plymouth Plan, op. cit.. p. 36.
29. Emergency Public Information pamphlet, p. 6.
30. MASSPIRG Survey of Nursing Homes, Appendix F.
31. Conversation with Frank. Willard. the Director of MCDA Area II Headquarters
in Bridgewater, February, 1983.
32. Plymouth Plan, op. cit.. p. 39; Emergency Public Information pamphlet, p. 6.
33. MASSPIRG Survey of Correctional Facilities, Appendix D.
3A, FEMA Exercise Report, op. cit.. p. 25.
35. Update Report on Indian Point, p. 6.
36. MASSPIRG Survey of Campgrounds, Appendix B.
37. Conversation with Frank Willard, Director of MCDA Area II Headquarters in
Bridgewater, May, 1983.
38. Transcript of Public Hearing, June 3, 1982, Statement by Paul CahlH, former
Director of the Mass. Civil Defense Agency, p. 109.
39. Conversation with Jane Peterson, Cape Cod Chamber of Commerce, February 8, 1983,
40. See Chapter I, supra, p. 7.
41. Warning sirens are only located within the 10-mile EPZ.
42. US Census, 1970 (basement data not collected in 1980 census).
43. State Plan, op. cit.. pp. C-17 - C-19; Annex E, pp. C-101 - C-113.
44. State Plan, op. cit.. p. C-17.
45. Total summer population of the EPZ is about 120.000, divided among 3 reception
centers results in roughly 40,000 evacuees per reception center.
46. Evaluation Criterion J. 12.
47. FEMA Exercise Report, op. cit.. p. 31.
48. State Plan, op. cit.. Annex E. C-102 - C-103.
49. State Plan, op. cit.. C-70 - C-72.
216
-so-
so. FEMA Interim Findings, op. clt.. p. 9.
51. 10 CFR § 50.47(b) (12); 10 CFR Part 50, Appendix E, II. E and IV. E. 7.
52. MASSPIRG Survey of Hospitals, Appendix G.
53. MASSPIRG Survey of Hospitals, Appendix G.
54. 43 Federal Register 58798, December 15, 1978.
55. Evaluation Criterion J. lO.e. and J.lO.f.
56. "Submission for the Record: Hearing on Potassium Iodide as a Thyroid Blocking
Agent in a Radiation Emergency," Gordon Thompson, Ph.D., Union of Concerned
Scientists, submitted to the U.S. House of Representatives Committee on
Interior and Insular Affairs, Investigations and Oversight Subcommittee,
March 5, 1982. The Mass. Department of Public Health opposes distribution
of KI to the public. The advantages of KI far outweigh the disadvantages.
None of DPH's arguments against use of KI override the protection that KI
can provide from radiation exposure.
The logistical problem of distributing KI after an accident has been solved by
the Tennessee Valley Authority by simply distributing proper doses of the
drug to residents within the EPZ before a meltdown occurs. The directions
will indicate the dose and emergency officials will announce when to take
the KI. Childproof caps would prevent unsupervised Ingestion by kids.
The side effects anticipated from the recommended dosage for radloprotectlon
will be very minimal. Side effects occasionally appear after years of KI
use at doses of 300 mg to 1200 mg per day. But for radiation protection,
adults would take only 130 mg per day . for 10 days, and kids Just 65 mg per
day.
A few recent studies have suggested that anticipated releases of radioactive
iodine during a reactor accident may be much lower than originally expected.
The NRC, however, conducted a substantial investigation in 1981 that concluded
that although the Reactor Safety Study may have overestimated the iodine
that would be released from small accidents, the original estimates are
probably still valid for the larger accidents. ["Technical Bases For
Estimating Fission Product Behavior During LWR Accidents," NUREG-0772,
June, 1981.1
The last issue concerning KI is whether stockpiling the drug for distribution
during an accident would be preferable to predistributing KI to all households
in the EPZ. Attempting to distribute KI to all potentially affected households
after an accident began would be a logistic nightmare if not physically impossible
57. Plymouth Plan, op. clt., pp. 5-6.
58. "Public Protection Strategies for Potential Nuclear Reactor Accidents:
Sheltering Concepts with Existing Public and Private Structures," (SAND77-1725
D.C. Aldrich, D.M. Erlcson, Jr., J.D. Johnson, Sandla Laboratories, 1978,
p. 10.
217
51
59. Population figures are from the State Plan, op. clt., p. C-9.
60. SAND77-1725, p. 26.
61. 1970 Census Data (basement data not collected in 1980).
62. Evaluation Criterion J. 10. a.
63. "Public Protection Strategies In the Event of a Nuclear Reactor Accident"
(SAND77-1555) D.C. Aldrich, D.M. Ericson, Jr.. Sandia Laboratories, 1978,
pp. 40, 42-43.
64. There are 45,000 tourists on summer weekends. There are 24,000 seasonal
residents of which close to 20,000 probably have no basement in their
cottages. 30Z of the 54,000 permanent residents don't have basements
about 15,000 people.
65. 100,000 hospital masks for distribution in the EPZ would cost $19,090
from American Scientific Products, according to sales representative Mike
Govern. (Centura Mask - 685-N)
66. FEMA's Interim Findings, op. cit., pp. 15,17.18; Exercise Report, op. clt.,
p. 54.
67. Conversation with Bob Archlla, FEMA, July 13, 1983.
68. FEMA's Interim Findings, op. cit., p. 18.
69. Evaluation Criterion N.l.b.
70. Buses drive actual evacuation routes during drills for the Indian Point
reactors, "Post Exercise Assessment (Indian Point)," FEMA, April 14, 1983.
p. 14.
CONCLUSION
1. MASSPIRG. Survey of Civil Defense Directors, Appendix C.
2. The failure to maintain adequate emergency response plans for a nuclear
accident is a violation of the Mass. Civil Defense Agency's responsibility
to protect the citizens of the Commonwealth. Mass. General Laws, Appendix
to Chapter 33, Section 13. Federal law also requires workable plans:
10 CFR 8 50.47(a) (1)(NRC) and 44 CFR g 350.5(b) (FEMA) .
3. Comments of the Attorney General, op. cit., pp. 1, 14-15.
4. Petition of Massachusetts Public Interest Research Group for Emergency and
Remedial Action, July 18, 1983.
5. "In the Matter of Consolidated Edison Company of New York and Power Authority
of the State of New York (Indian Point 2 & 3)," CLI-83-16, June 10, 1983.
218
APPENDIX A
MASSPIRG Survey of Residents in the Emergency Planning Zone
MASSPIRG conducted a telephone survey of 100 residents of the
Emergency Planning Zone (EPZ) . The survey was designed and supervised
by Martha Downey of Decision Research Corporation of Lexington, Mass,
Respondents were selected at random from local telephone books for
Plymouth, Duxbury, and Kingston. The number of respondents from each
town was determined by the populations of each town so the results are
applicable to the full EPZ, (Plymouth (pop. 35,913): 64 respondents,
Diixbury (11,807): 22 respondents, and Kingston (7,362): 14 respondents),
Half the respondents from each town were men and half women. MASSPIRG
volunteers conducted the survey between February and May, 1983.
219
Telephone Survey of 100 Raaidencs In the Eaergency Planning Zone: Sunaiery of Reeulcs
Queedon
1. Local fire response capability?
2. Quality of fire personnel and
equipment?
Anbulance response capability?
^> Quality of anbulance personnel
and equlpnent?
5. Work Indoors at office or building
other than your residence?
(If "no" or "unsure" proceed to #8)
6. Where Is office or building
located?
Hear sirens when at work with
windows and doors closed?
8. Hear sirens at residence with
windows and doors closed?
9. Aware of any other public
emergency warning systems?
Very Good
Good
Fair
Poor
Unaure
Very Good
Good
Fair
Poor
Unsure
Very Good
Good
Fair
Poor
Dnsure
Very Good
Good .
Fair
Poor
Unsure
Tea
Ho
Unsure
Kesldence
Plyscuth,
Dux., King
Outside
EFZ
No Job/
Unsure
Yes
No
Unsure
Yes
Ho
Unsure
Pilgrim
Other
No
Unsure
Plysuuth Kingston Duxbury
64 Respondents U Res. 22 gas. Totsl
24
26
2
1
II
27
21
4
0
12
21
22
4
1
16
12
21
7
0
24
32
32
0
12
4
10
7
12
U
1
53
11
0
55
2
5
8
5
5
0
0
4
5
7
0
0
2
5
5
1
0
3
3
6
2
0
3
9
5
0
2
2
3
1
3
1
0
13
I
0
12
0
2
1
11
7
0
0
4
8
8
0
0
6
14
3
0
0
5
u
26
3
30
0
9
0
0
8
35
13
54
9
46
0
0
I
15
4
10
8
21
0
8
3
18
4
16
1
2
17
83
2
14
I
1
20
87
I
3
1
8
4
13
40
38
2
1
19
40
36
4
0
20
40
30
5
1
24
220
Talephon* Survay of 100 Xesldants In ch«
Qu««tlon
crgcncy Planning Zon«;
Sui
■ry of Xtculta
10. If ooc, aware of the Pilgrim
warning?
II. What doea the Pilgrim siren
mean?
Plymouth Xingaton Duxbury
<* Raapondenta 14 Raa. 22 Rea. Total
12. Ever heard a Pilgrim warning
alren from home or job?
(If "no" or "unsure" proceed
to #16)
13. Can the Pilgrim alren be heard
veil when vlndowa and doors
art closed?
T«s
Ho
Unsure
Accident
or warning
Drill or
test
Malfuncxion
Other
Unsure
Home
Job
No
Unsure
(Home)
Well
Not well
Not at all
Unsure
(Job)
Well
1
Not well
2
Not at all
4
Unsure
1
u.
Know location of nearest
siren?
(Home)
Yes
40
No
"
Unsure
3
(Job)
Yea
3
No
0
Unsure
1
IS. How far Is the alren?
(Home)
<l/2 mile
between 1/2 mile & 1 nile
>1 mile
Unsure
Reaponse not credible
27
2
21
1
8
49
4
12
0
27
19
7
0
26
10
7
10
1
2
1
0
2
1
1
4
12
16
3
0
2
4
0
2
15
8
10
3
3
1
2
0
2
3
0
1
0
0
1
0
I
7
12
5
6
0
1
2
3
1
0
0
0
221
TtXcphen« Surwy of 100 Htddaacs la th* Eacrgaacy Planning Zona: Suanary of ILaaulta
Quaatlon
Plyaouth Klngiton Duxbury
6* Kaapondanta U Kaa. 22 Rai. Total
22.
15. (continued)
Row far la tha a Iran?
(Job) ^1/2 Bila
batwaan 1/2 mIIc ( 1 idla
> 1 Blla
Unaure
Reaponaa not credlbla
16. First reaction to Pilgrim alrcn.
If not drUlT
Evacuate
Shcltar
Radio or T.V.
Eaerifancy Broadcast Syatea atatlon
Ignore
Unaura
Teat or aalfunctlon
Call police
other
17. Can you naaa an Ea«rgency Broadcaat
, Syataa station?
18. Ever heard Pllgrla alran go off
accidentallyT
(If "no" or "unaura" proceed to 120)
Yea
Ho
Yea
Ito
Unaura
19. How aany tlaaa?
1
2
3-7
8 or Bore
Call soaeone
Radio or T.V.
Other
Unaure
Great deal
Sone
Not Buch
None
Unsure
How did you learn what you know Media
about emergency procedures? „.,. . , . .
" Official Brochure
Word of Bouth
Other
20. How would you determine whether a
alren was a falaa alar«7
21. How much do you feel you know
about eacrgency procaduree In
case of an accident at Pilgrim?
1
0
0
I
0
5
5
12
6
10
12
7
6
3
40
2*
51
9
1
8
7
2S
9
19
28
9
10
4
19
28
II
1
19
24
.7
14
0
3
7
I
2
8
1
3
0
3
8
3
0
s
3
1
4
10
3
2
1
1
0
7
7
19
9
17
17
13
7
59
41
77
18
2
10
15
39
11
29
46
11
17
6
29
44
16
4
32
35
11
21
222
Ttlcphon« Survay of 100 Kaddcnti In ch« Energcncy Planning Zone: Suarury of Raiulcs
Qu«»tlon
Plyaouch Kingston Duxbury
64 Ke«pond«nti U R««. 22 Res. ^ot»)
23. Haim you received Emergency Public
Informadon Brochure?
(If "no" or "unsure" proceed to *29)
29.
24,
When?
25. Did you read the brochure?
26. Was It helpful?
27. Do you have the brochure
available right now?
28. Where is It kept?
Any questions regarding
emergency planning?
* The response of one Plymouth man was
"Why can't they ia^rove the sirens so
people uould believe them?"
30. Dangerousness of accident at Pilgrim?
Yes
45
No
16
9) Unsure
Z
Sept "82"
3
Oct "82"
0
Fall "82"
6
Other "82"
a
Fall "81"
0
Other
5
Unsure
20
Completely
24
Partially
16
Not at all
5
Very
11
Somewhat
25
Not at all
6
.Unsure
1
Yas
16
No
29
Location given
14
Unaure
8
Yes
23
Ho
41
31. What is the safest location?
Igrim? Very
27
Somewhat
23
Not at all
8
Unaure
5
Not IfflDediate
1
Too early to tall
0
Home
15
Basement
9
Under table/bed
0
Public Shelter
1
Car
2
Other
37
9
13
3
2
1
0
0
2
0
2
3
3
11
6
0
0
8
1
0
1
8
10
1
0
6
8
8
6
4
10
1
3
1
2
0
1
0
0
2
6
6
5
0
0
1
I
0
0
5
11
223
Taltphooa Sur»«y of 100 Kaddant* In tha Ei^rganey Planning Zonal Suwury of Uaulta
Q^iaatlon ;
32.
If ordarad Co avaeuaca, whara vould you
go?
Hanover Mall
Brldgavater St. Coll.
Taunton Boap,
Whcravar dlracCad
To frlanda of family
Juac away, no particular daatlnatlon
Don't know
Uould not avacuata
Othar
Plyoouth Klngaton Duxbury
6* Kaapondanta 14 lUa. 22 Ka«. Tot«!
t3. How would you gat thataT
Own Car
Other Car
Public Traaaportatlon
Other
Uoaura
34, Do you have a car available T
(Weekdaya)
(Weeknlghta)
(Weakanda)
- Yea
No
Soaatiaea
Onaura
Tea
Ho
SoaatlBca
Unaure
Yea
No
Soaatlaea
Onaura
35.
Uhat If no car were avallablaT
Call Spouac
Neighbor
Non-Neighbor
Walk
Public Tranaportation
Contact Town Authority
Would not evacuate
Other
Unaure
6
2
1
7
IS
15
10
6
0
3
1
4
4
53
»
1
0
55
7
1
0
56
7
0
0
5
0
0
1
2
3
3
0
0
12
1
0
0
1
11
2
1
0
II
1
2
0
11
1
2
0
2
6
1
1
0
0
1
3
0
3
14
0
. 2
0
1
7
15
5
22
3
21
2
15
1
7
1
1
18
79
0
4
0
1
4
S
0
5
21
0
1
0
21
0
1
0
21
0
1
0
0
f3
0
1
3
1
3
1
0
83
11
3
0
87
t
4
0
88
•
}
0
3
50
4
6
9
1
11
10
8
224
Que»tlon
Tclcphon* Survey of 100 Kctldcnc* In Che Eaergency Flannlng Zone: Sumury of Rciult*
bury
36. If ordered Co take shelter what
would you do?
42.
37. Do you have a basement
(if not nentloned above)?
Own basesienc
Hose-not baseacnt
Neighbor basement
Public Shelter
Evacuate
Other
Unsure
Yes
No
38. Which provides greater protection:
car or basement?
Car
Basement
Unaure
39. A cloud of radioactivity would be
visible during the day.
40. The exposure to radiation from
an accident would be the aame as
a chest x-ray.
41. Boston Edison made a correct
decision to cancel Pilgrla II.
Agree
Somewhat agree
Disagree
Somewhat disagree
Unsure
Agree
Somewhat agree
Somewhat disagree
Unsure
Disagree
Agree
Somewhat agree
Somewhat disagree
Disagree
Unsure
Refused
rilgrlB officials have done everything
possible for public awareness of
emergency procedures.
Agree
15
Somewhat agree
18
Somewhat disagree
11
Disagree
13
Unsura
6
43. Desth is possible within a few months
of exposure to radiation during a
major Pilgrim accident.
Agree
Somewhat agree
Somewhat diaagree
Dlaagree
Unsure
Plymouth Kingston Dux'
64 Respondents 14 Res. M
26
12
0
6
5
7
8
25
13
7
45
14
3
14
23
13
13
0
8
10
8
39
31
4
7
18
5
0
16
20
10
6
10
9
0
3
1
1
0
1
4
1
0
12
2
3
0
6
3
2
2
0
0
2
10
8
0
3
1
2
0
225
T«l<Fhe«« Survajr e( 100 taaldmta la th* Eaargancy Flanaing Zona: Suaaary of lU
QuMtlca
Fljraouth Ungaton Dux
6* Haapondanta U Itoa. 22
alta
lury
laa. Tota]
44. Veta ea quaaclon 3.
Political ClaaalficatlonT
4i. Marital StatuaT
47.
Imr rbyateally 41««bl*4 la
)ieua«heldT
4(, At* V^
4ff. mghMt Uval •( B4«c«tlen1
Taa
31
No
6
Didn't Voca
19
Dnaura
S
lafuaad
1
Conaarvatlva
20
Modarata
24
Ubaral
11
Onaura
10
Slaila
13
Marrlad
42
Dlvorcad or Sapacated
1
Vldovad
9
tafuaad
0
Taa
3
Rd
St
U - 24
9
25-34
to
35 - U
14
45 - 54
5
55 - «4
9
65*
17
Bafuaad
0
Orada tehool
3
Se^ Ugh Mwol
1
lith School Ovad.
24
SoM Collogo
17
Collega Craduata
11
Voac Craduata Work
4
Hafuaad
0
10
51
IS
23
S
I
34
3a
14
IS
22
M
3
10
0
«
91
»
U
25
7
12
2«
1
3
4
35
29
17
10
0
226
!\t;.kvii;i\1:R I'UONU numbur
r)ATI: TOWN
IMi.CRIM liMliRCHNCY PLANNING SURVLY
"Hello, my name is . I'm calling from Opinions Unlimited,
.1 ■ Massachusetts polling firm. We're doing a survey on emergency response
in your arcn and we've selected your phone number at random,
I'd like to get your opinion ou a tew things if I may? (IF YES, PROCUED)
rirst of all, arc you a resident of 7" (IF YES, PROCEED)
(same town as above)
1. "What is your opinion of fire response capability in your area
regarding response time to emergency calls? Would your rating
be . . ." (RI-.AD CHOICLS)
"Very C.ood" 1
"Good" 2
- "Fair" 3
"of Poor" -4
(Unsure) (DO NOT READ) 5
2. "What is your opinion of the quality of the fire personnel and
equipment in your area? Would your rating be . . ."(READ CHOICTS)
"Very Good" — 1
"Good" 2 .
"Fair" 3
"of Poor" 4
(Unsure) (DO NOT READ) S
3. "What is your opinion of ambulance response capability in your area
regarding response time to emergency calls?. Would your rating
be . . ." (RliAD CHOICES)
"Very Good" 1
"Good" 2
"Fair" 3
"Poor" --4
(Unsure) (00 NOT READ) S
Nkhat is your opinion of the quality of ambulance personnel and
""Huipraent in your area? Would your rating be . T ." (READ CHOICES)
"Very Good" 1
"Good" 2
"Piii r" - 3
"Poor" -1
(Unsure) (1>0 NOT READ) b
"iio yovi ever work indoors nt an office or building other than your
res idcnce?"
Yes (INCI.UD!: SO.^IETIMES) \
•■^'o ^^;- SKIP TO Q. 3
Unsure * 5/
10.
227
-2-
'In what town is that office or building located?"
TokTl ^
Same as residence -1
Not same as residence, but job
in Plymouth, Kingston or Duxbury --2
All other towns ^ ^SKIP TO Q.8
No job/ Unsure - 4J
:>
"When you are working indoors at that office or building other than
your residence, can you hear police, fire or ambulance sirens if
the windows and doors are closed?"
Yes 1
No 2
Unsure - 3
"Can you hear police, fire or ambulance sirens at your residence
when your windows and doors are closed?"
Yes 1
No 2
Unsure "5
9 "Are you aware of any other public emergency warning systems?' (DO NOT
READ)
Pilgrim Nuclear Warning 1 CSKIP TO Q. H)
All others 2
No 3
(ACTUAL RESPONSE IF "OTHER"
(IF PILGRIM WARNING NOT MENTIONED, ASK):
"Are you aware of a warning siren in case of an accident at the
Pilgrim Nuclear Power Plant?"
Yes 1
No 2
■ V (SKI
CIP TO Q.ll )
Unsure -3
228
(II- AWARE OP PILGRIM SIRUN, ASK):
11. "What does the Pilgrim siren mean?" (DO NOT READ)
Accident 1
Drill 2
Other 3
, Unsure- - 4
(ACTUAL RESPONSE IF "OTHER"__
)
12. "Have you ever heard the Pilgrim warning siren from your home or job?
Home 1
Job 2
'^° ^ \— (SKIP TO Q. 16)
Unsure ^^
(IF SIREN HAS BEEN HEARD AT EITHER HOME OR JOB, ASK):
13. "Can you hear the Pilgrim warning siren well at (your home and/or
your job (DEPENDING ON ANSWER TO Q. 6)] when the windows and doors are
closed?"
Home Job
Well 1 Well 5
Not well 2 Not well 6
Not at all 3 Not at all 7
Unsure 4 Unsure 8
14. "Do you know the location of the siren nearest to your [home
and/or job (AS APPROPRIATE)]?"
Home Job
Yes 1 Yes 4
No 2 No 5
Unsure 3 Unsure 6
(IF YES FOR HOME OR JOB, ASK):
15. "How far would you estimate the siren is from your [home and/or
job (AS APPROPRIATE)]?" (READ FIRST THREE CHOICES)
"Less than 1 mile"---i "Less than 1 mile" — 6
"Between \ a mile "Between J a mile
and one mile" 2 and one mile" 7
"Over one mile" 3 "Over one mile" 8
Unsure (DON'T READ)--4 Unsure (DON'T READ) --9
Answer given, but Answer given, but
interviewer doubts interviewer doubts
credibility 5 credibility 10
^
229
- 4 -
16. "What would be your first reaction if you heard the Pilgrim
and a drill was not scheduled?" (DO NOT READ)
Evacuate i-1
Take shelter -.--2
Turn on radio or TV --3
Turn on radio or TV to an
Emergency Broadcast Station--4
Ignore- 5
Unsure 6
All other - 7
(ACTUAL RESPONSE IF "OTHER"
17. "Can you name one of the Emergency Broadcast Stations on radi
in your area?" (CORRECT ANSWERS: WBZ-TV CHANNEL 4« WBZ 1030
WATD 96 FM, WPLM 1390 AM/99.1 FM)
Yes - 1
No 2
(IF THEY ASK FOR THE NAMES, GIVE THEM)
18. "Have you ever heard a Pilgrim siren go off accidentally,
when it wasn't supposed to?
Yes 1
'^° ^ ^ (SKIP TO Q. 20)
Unsure 3
>
(IF YES) ,
19. "How many times have you heard a Pilgrim siren go off accident
Once 1
Twice - 2
Over 2 ---3 (ACTUAL RESPONSE IF OVER 2:
20. "If you heard the siren in the future, how would you determine
whether it was a false alarm?" (DO NOT READ)
Call someone 1
Turn on Radio or TV 2
Other 3
Unsure --4
(ACTUAL RESPONSE, IF "OTHER"
230
- s -
21. "How much do you feel you know about emergency procedures in the
case of a nuclear accident at Pilgrim? Do you feel you know a
great deal; some, but not a great deal; very little; or nothing
at all?"
A great deal 1
Some --2
• • Not much, very little 3
Nothing -- 4
Unsure- 5
22 "How 4id you learn what you do know about emergency procedures i
in case of an accident at Pilgrim?" (DO NOT READ) j
TV, radio, newspaper- -1
Official Emergency Planning Brochure 2
Word of mouth 3
Other - -- 4
(ACTUAL RESPONSE IF "OTHER"
)
23. "Have you ever received an Emergency Public Information Brochure
in the mail?"
Yes 1
^° ■ ^ \^ (SKIP TO Q."29)
Unsure ^ ^y
(IF "YES", ASK) :
24. "When did you receive it? Do you remember what month?"
Sept. '82 1 Fall '81 S
Oct. '82 2 Other '81 6
Fall '82 3 Other- 7
.Other '82 4 Unsure 8
(RESPONSE FOR "OTHER" )
25. "Would you say you read (PRONOUNCE "red") the brochure..." (REAP RESPONSES
"Completely", 1
"Partially", - 2
"or. Not at all". 3 (SKIP TO Q. 27 FOR #3 ONLY)
26. "Did you find it very helpful, somewhat helpful, or not at all
helpful?"
Very 1
Somewhat 2
Not at all 3
■ Unsure 4
27. "Do you have your emergency brochure available right now?"
Yes 1
No 2 iSKIP TO Q. 29)
231
- c -
(11- Yi-:s),
28. "Where do you keep it?" (DON'T PRESS FOR AN ANSWER]
If location given --1
Unsure of location 2
ASK EVERYONE
29. ''Do you have any questions regarding emergency planning in the
case of a nuclear accident at Pilgrim 17^' (IF YES: "What
questions?^
30.
Let's imagine for a moment that the warning siren has indicated
that there had been a nuclear accident at Pilgrim I.
"As far as you know, how dangerous is the situation? Would you
consider the situation to be . . ." (READ CHOICES)
"Very dangerous",- -------1
"Somewhat dangerous", 2
or "Not at all dangerous",- - - - - 3
Unsure - 4|
No immediate danger 5 V (DO NOT READ)
Too early to tell ------- 6_J
31 "Where do you believe is the safest location for you during
this situation?" (if siren indicates an accident at Pilgrim)(DO NOT READ)
Home --------1
Basement ------------2
Under table or bed -3
Public shelter ---------4
Car 5
Other - - - 6
(ACTUAL RESPONSE IF "OTHER"
)
32. ''If you were ordered to evacuate because of an accident at
Pilgrim where would you go?" (DO NOT READ)
Hanover Mall -----i
Bridgewater State College - - - 2
Taunton State Hospital ----- 3
Wherever directed- --4
Other --- -..-5
(ACTUAL RESPONSE LF "OTHER"
)
34
36.
232
.33. "How would you get there?" (DO NOT READ)
Personal car -----------------1
Other car (neighbor, relative, friend) - - - -I
Public transportation -- 3
Other- - - "
> Unsure ---------- ---S
(ACTUAL RESPONSE IF "OTHER"
)
"Do you have a car available for your use?"
"Weekdays" "Weeknights" "and Weekends"
Yes 1 Yes 5 Yes 9
No 2 No 6 No 10
Sometimes - - 3 Sometimes - - 7 Sometimes - - 11
Unsure- - - - 4 Unsure- - - - 8 Unsure - - - 12
35 "What would you do if you were ordered to evacuate and you
had no car available?" (DO NOT READ)
Phone spouse 1
Contact neighbor for a ride - - - - 2
Phone non-neighbor for a ride - - - 3
Walk away ^
Walk to public "staging area"
for public transportation - - - - 5
Take shelter - - - . - - 6
Other 7
Unsure ------
(ACTUAL RESPONSE IF "OTHER"
8
)
"If you were ordered to take shelter because of an accident at
Pilgrim I, where would you go?" (DO NOT READ")
Own basement ------------1
Home - other than basement ----- 2
Neighbor's basement 3
Public shelter - *
Evacuate
5
Other - - 6
Unsure -----
(ACTUAL RESPONSE IF "OTHER"
7
233
.37. IF "OWN BASEMENT"or "CELLAR", NOT MENTIONED, ASK:
"Does your home have a basement?"
Yes ------ 1
No 2
38. "Which would provide greater protection from radiation?"
"your car", - -1
"or your basement", - - - - 2
unsure 3 (DON'T READ)
"I'd like to read you five statements. Please tell me if you completely
agree, somewhat agree, somewhat disagree or completely disagree with
each statement."
39. "If a cloud of radioactivity were released during an accident at
Pilgrim, it would be visible during the day."
Completely agree 1
Somewhat agree - - - -2
Somewhat disagree -- 3
Completely disagree ------ -4
Unsure 5
40. "The exposure to a person outdoors from the radiation released
during a major accident at Pilgrim would be about the same as
the exposure from a chest X-ray."
Completely agree 1
Somewhat agree -----2
Somewhat disagree --------5
Completely disagree 4
Unsure -----S
41. "Boston Edison made the correct decision when they cancelled plans
to build Pilgrim II, a second nuclear powered generating plant."
Completely agree 1
Somewhat agree 2
Somewhat disagree --------3
Completely disagree 4
Unsure 5
234
42 "The emergency officials at Pilgrim I have done everything
they could to insure maximum public awareness of emergency
procedures . "
Completely agree ----- 1
Somewhat agree 2
Somewhat disagree 3
Completely disagree - 4
Unsure -- --------5
43 "The exposure to a person outdoors from the radiation released
during a major accident at Pilgrim could cause death within
a few months."
Completely agree -.---1
Somewhat agree ----- 2
Somewhat disagree --- 3
Completely disagree 4
Unsure ----- -...--5
44. "Did you vote "Yes" or "No" on Question 3 on the November
ballot? Question 3 proposed a law that would require that all
construction or operation of new nuclear power plants or
radioactive waste disposal facilities be subject to voter
approval in statewide elections."
Yes 1
No - - 2
Didn't vote - - • • - 3
Unsure -------4
Refused - - 5
235
- U) -
"linally, i iu>l h.i\'c ,i feu questions foi c 1 .1 ss i f i i:;i t i on injiposcs.
45. 'Vol I t iciil ly , -li) you consitlci yourself to be i\..." (RliAD CHOICES]
■ ■ "Conservative", 1
"Modciate" ,-- Z
"or , I. ibe ral" !^
. (DO N'O; RI^.AIl) Unsuie- -4
46. "Wliat is your marital status?" (lUiAP CHOlCliS)
"Single", 1
"Married" , 2
"Divorced or separated", 3
"or. Widowed". --4
Refused 5
"How many people including yourself, live in your home?"
(RldCORD NUMBER )
47. "Are there any physically disabled persons living in your household?"
Yes--- 1
No 2
48. "In which of the following groups is your age?" (READ CHOICES)
" 18-24- 1
*2S-34" 2
••35.44-. 3
'45-54'- 4
■"5 5-64" 5
"65 and over 6
Refused-- 7
49. "What is the highest level of education you have achieved?" (READ CHOICES)
"High school graduate - 1
' Some college 2
College graduate 3
"Post-graduate work or degree 4
Refused 5
"Thank you very much for your assistance. Good-bye."
50. (RECORD SEX) FEMALE--- --1 MALE 2
236
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243
NO EXIT
The MASSPIRG Survey of
Pilgrim Evacuation Planning
MASSPIRG
September 1987
244
NO EXIT
THE MASSPIRG SURVEY OF PILGRIM EVACUATION PLANNING
Authors
Josh Kratka
Rachel Shimshak
Research and Technical Experts
David Nemtzow
Alan Nogee
Survey Director
Maria Mobil ia
MASSPIRG
29 Temple Place
Boston. MA 02111
(617)292-4800
September 1987
245
ACKNOWLEDGMENT
Special thanks are owed to David Nemtzow of the Kennedy School of
Government who supervised the survey and conducted the statistical analysis,
to Maria Mobilia for coordinating the survey callers, and to the many MASSPIRG
researchers who spent hours on the phone compiling the necessary data for this
report. Thanks also to Amy Kelley for the cover design. Sue Haynie for
production of this report, and Mike Ernst of the State Legislature's Energy
Committee for reviewing an earlier draft of this document.
246
TABLE OF CONTENTS
EXECUTIVE SUMMARY 1
I. INTRODUCTION: THE LESSONS OF CHERNOBYL 3
II. SURVEY RESULTS: PILGRIM DISASTER PLANS ARE STILL A DISASTER
A. Pilgrim-Area Residents Are Inadequately Informed
About Emergency Planning 7
B. Residents Will Not Follow the Emergency Plans 10
C. The Emergency Plans Do Not Address the Needs of
Many Population Groups
1. Families With Children 12
2. The Elderly 13
3. Newer Residents 14
D. The Flaws Revealed by the Survey Render the Emergency
Plans Unworkable
1. Present Warning Methods Are Unlikely to Alert
Res ident s Quickly 15
2. Phone Lines Are Likely To Be Tied Up During an
Erne r gency 15
3. Orderly Evacuation is Unlikely to Occur 16
E. Most Residents Surveyed Want Pilgrim to Remain Shut Down ..18
III. DETAILED SUMMARY OF QUESTIONS AND RESPONSES
A. Methodology 19
B. The Survey 20
IV. RECOMMENDATIONS 33
247
EXECUTIVE SUMMARY
In light of the General Accounting Office's finding that no federal agency
assesses public knowledge of radiological emergency procedures. MASSPIRG
surveyed 363 residents of the Pilgrim nuclear power plant's Emergency Planning
Zone (EPZ) to determine what people know about the official emergency plans and
whether they would follow those plans in case of an accident at Pilgrim.
The key findings of this survey show that residents are even less
informed about Pilgrim emergency plans than they were at the time of
MASSPIRG's last such survey, conducted in 1983. Moreover, they would refuse to
follow official instructions in the event of an emergency.
1. Residents have only a limited knowledge of emergency plans for their
communities. Only 56% of those surveyed said they had received the Emergency
Public Information booklet from Boston Edison, the operator of the plant,
compared with 67% who remembered receiving the booklet in 1983. Moreover, only
23% of those surveyed said they had actually read the booklet completely,
compared to 38% in 1983. Those living in the EPZ for three years or less have
been particularly ill-informed: 47% had not received a copy of the booklet.
2. Many residents would not follow the emergency plans in case of a
serious problem at Pilgrim;
* the most common response to an accident at Pilgrim (27% of those
polled) would be immediate evacuation — a direct contradiction of instructions
contained in the emergency information booklet:
* only 19% of those questioned said they would go to one of the
designated reception centers in case of an evacuation, and two-thirds of these
few who would follow the emergency plans would go to the Hanover Mall, which is
no longer an official reception center;
248
* of the 37% surveyed who have school-age children, nearly half (48%)
said that they would try to pick up their children from school in the event of
an emergency — precisely what the emergency booklet instructs them not to do;
just 9% of parents said they would follow the instructions to meet their
children outside the danger zone.
3. The emergency plans do not adequately take into account the special
needs of children and the elderly.
4. Seventy-nine percent of the respondents felt that Pilgrim should
remain shut down if management and safety problems persist.
5. When asked whom they would trust for information in the event of an
accident. 3H of respondents said they would have no confidence in Boston
Ediaon. easily the worst score aiiong the people and groups mentioned.
Since the accident at Three Mile Island, the Nuclear Regulatory Connission
has required ccoaunities within a 10-nile radius of a plant to have workable
evacuation plans. In July 1987, the Federal Emergency Management Agency
(FEMA) found the Pilgrim plans inadequate to protect public health and safety
and withdrew its interim approval of them. The findings in HASSPIRG'a report
clearly show that, given the current level of information, the Pilgrim
emergency plans would not adequately protect the public even if the
deficiencies identified by FEMA were corrected.
In light of these results and aerious management and safety problems at
Pilgrim, MASSPIR6 recommends that the Pilgrim plant should not reopen unless it
is determined that:
(1) workable plans can be developed;
(2) such plans have been effectively disseminated and implemented, and
(3) outstanding management, safety, and economic questions have been
resolved.
249
I. INTRODUCTION: THE LESSONS OF CHER>10BYL
7 'e Chemobj'l disaster it April of 1986 provided a sobering glimpse of
' ' ''^. Lu -:.le devastation that could result from a nuclear power plant
■ ■ -idci'- The Soviet government was forced to evacuate 135,000 people living
Jichln an 18.6-mile radius around i-he plant. Thirty-one people have already
aieu a^ a direct result of the accident, and 24,000 more are expected to die of
a.-<=r ca"sed by rac'iation exposure. Fallout from the plant contaminated crops
. .;C dairy products across Eastern Europe and vas detected as far away as the
vt.ct coa-.t of the United States. On June 16, 1987, the Boston Globe quoted
:,(.:istantin Fursov, a So^ritit olf ioi.-.^ , to the tite<-L that 27 cities and villages
within an 13-mile radius of the plant are "too contaminated for people to live
in for the foreseeable future." The world learned — the hard way — that
i-oi'-'erts can and will happen, with devastating consequences.
The Chernobyl accident halped fuel the debate in the United States about
n -li.ar pcwer in genaral, and in Massachusetts over safety and evacuation
' L.OE at the troubled Pilgrim nuclear power plant.
'licensed in 1972, the Pilgrim reactor in Plymouth, Massachusetts, has led
-; -crturtd life. Initially, the plant was loaded with "bad" fuel which
substantially increased the radioactivity in the plant. As a result of this
• J other problems. Pilgrim has only produced about half as much energy as it
•.o'lld if it had been working continuously at full power over its life today.
In 1982, Boston Edison, the owner and operator of the Pilgrim plant,
reived the largest fine levied against a power plant at th?t time, for two
•sty violations and a "material false statement." The Nuclear Regulatory
commission (NRC) was so ccncemed abo-it conditions at Pilgrim that it ordered
■:..' y^iiir.y to conduct a "management overhaul" in that same year.
250
Despite promises to improve its operations in 1982, the plant continued
to receive poor grades from the NRC in its periodic management performance
reports.
RBCENT BISTORT
In early April of 1986, the reactor experienced two "unexplainable
automatic shutdowns" or "scrams," touching off 17 months of harsh criticism
from the NRC, elected officials and citizen groups across the state about
Pilgrim's problems. Ir a May 1986 Congressional hearing, the NRC labeled
Pilgrim one of the "worst managed and least saie plants in the country." The
morning papers began to carry headlines such as "Pilgrim Missed Another
Deadline for Safety Tests. "Pilgrim Workers' Radiation Exposure Among Nation's
Highest," and "New Doubts Voiced on Future of Pilgrim."
The Department of Public Utilities issued a scathing indictment of Boston
Edison in June of that year accusing the company's management of being
"paralysed" to the point where officials are no longer able to properly run the
plant. The 300-page report stated that if Edison continued along its current
path, "it will jeopardize the health and safety of its customers and the
economy of the region."
After documenting years of management, structural, and evacuation problems
at the plant, MASSPIRG submitted a 50-page petition to the NRC asking the
Commission to suspend Pilgrim's license until all of the safety issues were
resolved, and to hold a comprehensive public hearing to discuss each problem.
Joining MASSPIRG in filing the "Show Cause" petition were over 50 state
legislators, a dozen citizen groups, and statewide candidates for attorney
general and lieutenant governor. The theme of the petition was that taken
individually, the problems described are serious. In the aggregate, they
thoroughly compromise the reliability of the most important safety systems
251
*:hp plant .md destroy the fundamental principle of defense-in-depth
•^por,r,e<i by the NRC.
Some of the emergency planning deficiencies noted in the petition were:
1} Lack of advance information about emergencies for residents,
'-anintnts, and tourists;
2) Lack oi adequate medical facilities to treat contaminated individuals
i.n the event of an emergency;
3) Lack of emergency plans for Cape Cod, located 11 miles from the
P-lgriiB plant, and other communities just outside the official evacuation
;■ 'anning zone;
4) A lack of attention tc .smergency planning by federal, state and local
'jovernment agencies;
5) Lack oI adequate capability and planning for notification during an
accident, and
6) Lack of adequate plan^ for evacuating the physically disabled, nursing
home residents, school children, hospital patients, campers, and inmates of
correctional facilities.
Secretary of Public Safety Charles Barry underscored the problem areas
roted in the petition in a 100-pagc report to the Federal Emergency Management
Agency (FEMA) in December of 198d. At a December State House hearing.
Governor Dukakis submitted that report and stated that Pilgrim should remain
closed until ai' 1 previously identified management, reactor safety and
emergency planning concerns have been adequately addressed.
In light of this criticism, Edison should have been well on its way toward
cleaning up its management and safety problems by 1987. But the most recent
:'''.C pe-=crmance repor" Clo. 50-293/86-99. dated April 8, 1987) concludes that
tnere are "significant recurring program weaknesses ... and that the rate of
change was slow during most of the assessment period." In five of the twelve
functional areas graded by the NRC, Pilgrim received the lowest possible score.
Thes^- developTients and other;: led a special legislative conunittee on Pilgrim to
issue yet another report critical of the plant and its operations in July 1987.
252
E7ACDATI0N nj^NNING TODAY
After the accident at Three Mile Island in 1979, the NRC required nuclear
plants to have workable emergency evacuation plans for the population living
within a 10-mile radius around the plant. In the case of the Pilgrim plant,
Boston Edison's record of safety violations and management problems makes the
existence of feasible evacuation plans that much more critical.
After 17 months of shutdown, however, there is still no progress on the
workability of emergency plans for the Pilgrim area. On August 6, 1987, FEMA
released a report, entitled "Self-Initiated Review and Interim Finding," which
further criticized Pilgrim's emergency plans and found them "inadequate to
protect the health and safety of the public in the event of an accident," The
five reasons highlighted in the FEMA finding were:
* Lack of evacuation plans for public and private schools and day-care
centers;
* Lack of a reception center for people evacuating to the north:
* Lack of identifiable public shelters for the beach population;
* Inadequate planning for the evacuation of the special needs and
transport dependent population;
* Overall lack of progress in planning and apparent diminution in
emergency preparedness.
Many of the inadequacies cited in the FEMA report had been raised years
before by MASSPIRG in its 1977 and 1983 reports on evacuation planning,
entitled "blueprint for Chaos" I & II, and most recently in the July 1986 "Show
Cause" petition. Because several conditions which affect emergency planning
have worsened in the past few years, MASSPIRG decided to follow up its earlier
reports with this study.
The 1977 and '83 reports generally looked at the adequacy of emergency
plans themselves, as did the recent FEMA study. This report approaches the
253
5=mergC;ncy plan; rrott a diilcrexii; o I'^ie ■- it ijoks mc it the plans themselves
but at the people who w3.ll be ask?d tc follou t'n.;rr.. Such information is
crucial to assessing the feasibility of the plans, particularly in light of the
General Accounting Office's finding that "no federal agency assesses public
knowledge of radiological emergency procedures." (GAO Report to Hon. Edward
J. Markey, House of Representativc^i, "Nuclear Regulation: Public Knowledge of
Radiological Emergency Procedures," June 1987, p. 1.)
MASSPIRG surveyed 363 people vho live in the Pilgrisn Emergency Planning
Zone (EPZ) to answer these basic quest-.onti;
(1) Are EPZ residents kntiwiedgeaL'^e ;ibout the emergency plans?
(2) Will residents be wii Ling and able to follow tiiese plans?
(3) What do residents think about emergency planning and the Pilgrim
nuclear plant in general?
The survey methodology, along with the orecise questions and answers are
described in Section III.
I I . SURVEY RESULTS: PILGRIM DISASTER FLANS ARE STILL A DISASTER
A. PILGRIM-AREA RESIDENTS ARE INADEQUATELY INFORMED ABOUT EMERGENCY PLANNING
The first major conclusion to be drawn f'-om out survey is that the
residents of Plymouth, Kingston, Duxbury and Carver have, on the whole, a very
limited knowledge of the emergency plans for their communities, and that they
are even less well informed now than they were four years ago. This conclusion
is apparent from the responses to virtually every survev question which tested
familiarity with the basics of the emergency plans, from warning methods to
evacuation procedures.
A large share of the blame for this situation must be attributed to Boston
E'iison's failure to educate the public. The company has relied almost solely
on its booklet, "Emergency Public Information: What To Do In Case of an
254
Emergency at Pilgrim Nuclear Power Station," and claims to have distributed
copies of it to all residents ot the EPZ in November 1986. There have
obviously been distribution problems: just over half (56%) of those surveyed
said they had received the booklet (see Question 9). This figure represents a
noticeable step backwards from 1983. the last time MASSPIRG surveyed EPZ
residents. In 1983, 67% of those surveyed said they had received a copy of the
emergency planning booklet.
An added problem with relying heavily on written information is that not
everyone who gets it reads it. Nearly two-thirds (62%) of those who received
the booklet admitted to us that they had read it only partially or had not read
it at all (see Table 1. below). Thus, while 56% of the total sample remembered
receiving the emergency information booklet (Q. 9), a mere 23% had .read it all
the way through. In 1983, 38% of those surveyed by MASSPIRG said they had read
the booklet completely. The lack of public education suggested by these
numbers is verified by the answers to several other questions.
TABLE 1
SURVEY RESPONDENTS WHO HAD READ THE EMERGENCY PLANNING BOOKLET ...
% of Those Who % of Total
Number Received Booklet Responses
COMPLETELY 82 33 23
PARTIALLY 109 4 A 30
NOT AT ALL/NEVER 149 18 41
RECEIVED BOOKLET
DON'T KNOW/REFUSED 23 5 6
(Based on responses to Questions 9 and 10)
While most respondents knew that warning sirens would be used to signal an
accident at Pilgrim, very few knew that they should also tune in to local
255
television and radio stations to receive more complete information and
instructions on what to do (Q. 2. 12). This becomes more significant in light
of the fact that the respondents' most common reaction to learning of an
accident at Pilgrim would be to evacuate immediately, contradicting the express
directions in the emergency information booklet (Q. 11). There is a great
danger, therefore, that people will hear the siren and flee without waiting to
receive important information and instructions.
Even when evacuation is the right action to take, few of those we surveyed
would know where to go. Less than one in five named one of the three
evacuation centers specified in the booklet, and of those few who knew where to
go. a third did not know the proper route to tfke (Q. 14, 15). The problem is
even more acute for parents of school-age children. Nearly 70% of the parents
surveyed would not know where to find their children if an evacuation
occurred during school hours. The evacuation plans call for school children to
be bused to special reception centers directly from school, but the emergency
booklet does not list the locations of those centers.
We also found that the Carver residents we surveyed exhibited a noticeably
lower degree of familiarity with emergency procedures than residents of the
other three towns within the EPZ. Thirty-six percent of Carver residents, for
example, said they had never heard the Pilgrim warning siren (compared to 13%
for residents of Plymouth) (Q. 3). Not surprisingly, then. Carver residents
were the least likely to be able to distinguish the Pilgrim warning from other
warning sirens (Q. 7).
The survey as a whole reveslfid a genera'' Icck of information on the part
of the public. But Carver residents also displayed a surprising amount of
misinformation about the evacuation plans. Two-thirds of those who said they
would go to one of the evacuation centers in case of an accident named the
wrong center for their area (Q. 14).
256
It is clear that Boston Edison needs to make additional efforts to include
Carver in warning drills and to counter misinformation about the evacuation
plans.
The confusion and panic that could spread from large numbers of people not
knowing what to do in a pressure-filled situation might be impossible to quell.
But ignorance of the Pilgrim emergency plans is far from the only problem we
found.
B. RESIDENTS WILL NOT FOLLOV THE EMERGENCY PLANS
Several survey responses suggeot dtront^j.) that many people in the EPZ
would not follow the procedures outlined in the emergency planning booklet
even if they were familiar with them. This finding represents perhaps the
most serious challenge to the workability of the Pilgrim emergency plans.
Many recurrent, unsolicited comments made by survey respondents
demonstrated a pervasive belief that the emergency plans do not represent a
sensible response to a serious accident at Pilgrim. In case of a serious
accident, the first thing many respondents would do is "pray" or "Iciss my wife"
or "panic." Evacuees would head not to one of the emergency reception centers
but "whichever way the wind isn't blowing." How will the authorities warn
people in case of an accident? A surprising number answered, "What difference
does it make?"
The conclusion that EPZ residents would not follow the emergency plans is
not based merely on these off-the-cuff remarks. Many of the "hard numbers"
point in the same direction. Just 19% of those polled, for example, said they
would follow the evacuation plan outlined in the emergency information booklet
(Q. lA) . While a large part of the reason for this low number could simply be
ignorance of the plans (see previous section), only 2% of those answering the
same question said that they would go wherever directed, indicating little
10
257
willingness to wait for evacuation planners to provide any advice (Q. 14).
The survey also showed thitt most residents who have children m school in
the area will not follow the existing evacuation plans in the event of an
accident at Pilgrim. If such a situation were to arise, just 3% of parents
said they would wait for their children to come home from school and only 9X
would attempt to meet them outside the danger zone, as the emergency booklet
advises. Forty-eight percent said they would trv to pick their children up
from school — precisely the thing they are not supposed to do. Another 37%
did not know what they would do or gave another answer (Q. 18).
Again, only a part of this response is due to ignorance. Ever, when
specifically informed of the proper procedures to follow in case a family
member were in school or a hospital during an evacuation, barely over half
(51%) of the respondents thought they "would be able" to follow instructions
directing them not to try to pick up their family members themselves. Those
who gave a reason for for disobeying the instructions typically explained that
they simply could not entrust the safety of a family member to the authorities,
that this was their responsibility (Q. 22).
TABLE 2
WHAT PARENTS OF SCHOOL -AGE CHILDREN WOULD DC IN CASE OF AN ACCIDENT AT PILGRIM
DURING SCHOOL HOURS
% of Parents With
Number Children in Area Schools
Get children from school 65 48
Wait for them to come home 4 3
*Meet them outside danger zone 13 9
Other 27 20
Don't know 22 17
* Correct answer, according to emergency planning booklet.
(Based on responses to Question 18)
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258
C. THE EMERGENCY PLANS DO NOT ADDRESS THE NEEDS OF MANY POPITLATION GROUPS
As the Federal Emergency Management Agency has finally acknowledged, lack
of education and widespread distrust are not the only problems with the
Pilgrim emergency plans. Our survey revealed that the plans fail to
adequately address the needs of families with children, the elderly, and those
who have lived in the area for three years or less.
1. FAMILIES WITH CHILDREN
Whether because of the lack of an aggressive public education program or
simply because of a poorly designed plan, an ai-tempt to evacuate families with
school-age children according to the existing plans will almost surely meet
with failure. This constitutes perhaps the most serious flaw in the emergency
plans.
More than a third (3 7%) of the people surveyed have children under 16 who
go to school in the Pilgrim area (Q. 16). Few of them would be either willing
or able to follow the evacuation procedures outlined in the emergency plans if
an accident were to occur during school hours. As noted in section B and Table
2 above, virtually half of parents surveyed (48%) would actually do whet the
emergency planning booklet tells them not to do — pick up their children from
school themselves.
The evacuation plans are premised on a smooth flow of traffic in a
specific direction along the designated routes. A significant portion of the
population trying to get to schools all over the EPZ would seriously disrupt
planned traffic patterns. Though the evacuation plans call for school children
to be transported directly to special evacuation centers, seven out of ten
parents we spoke to would not know where to find their children if that
happened (Q. 19).
A different set of problems would arise if an accident occurred after
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259
school hours but while many prirents were still at work. More than a third of
the parents we polled tcl^ us that their children are sometimes left unattended
after school lets out (0. 17). .\ccording to the emergency booklet, parents
away from their homef "may not. be pf='rmitteQ to return [to the affected areas]
during the evacuation,'' leavirg unknown numbers of children to fend for
themselves.
2, rue ELDERI.Y
Many of the problems we found with the Pilgrim emergency plans are simply
exacerbated when dealing with those 65 and older. This group of survey
respondents had even le&s familiarity with the plans than did the general
population. More than a fourth did not know that there is an emergency
evacuation plan in case of an nceident at Pilgrim; few knew that warnings
and information would be sent out over local television and radio (Q. 1, 2,
12). And even if they were to hear a warning siren, a third doubted whether
they would know what the warning was for (Q. 7).
TPSl.^ 3
FAMILIARITY WITH EMHPGENCY PROCEDURES: RESPONDENTS AGE 65 AND OVER
COMPARED WITH GENERAL POPULATION
% of Total % of Respondents
Responses Age 65 and Over
Aware that emergency plans exist for
your town? Ye.=! 87 7A
26
How will people be warned of Pilgrin
accident? Siren 75 64
6
14
Gould distinguish Pilgrim siren iru_.
other sirens? Yes 5 9 45
Know how to get instructions in cir,£
of emergency?
Ye.=!
87
No
13
Siren
75
r//Radio
19
Don't Know
10
Yes
59
No
21
TV/Padic
33
Other
9
No
57
29
19
6
72
(Based on response;^ to Questions 1, 2, 7 and 12)
13
260
The elderly also face one problem that most others (aside from children)
in the EPZ do not: lack of acc<?s6 to an automobile. At any given time, as
many as 12% of these over 65 would not have a car available for their use,
compared with two or three percent in the general population (Q. 20). Locating
and transporting these people may present a difficult problem for evacuation
planners.
3. NEWER RESIDENTS
Those who have lived in the Emergency Planning Zone for three years or
less are, in general, the least well informed about emergency planning and
about the Pilgrim plant in general. Forty-seven percent of these newer
residents, who make up nearly a quarter of all those we surveyed, had not
received a copy of the emergency planning booklet (Q. 9). Moreover, only half
of them have ever heard the Pilgrim warning siren, compared with more than 80%
of the rest of those we surveyed (Q. 3). All the problems associated with
ignorance of the emergency procedures discussed above thus apply with even
greater force to this large demographic group.
It is unlikely that this problem is the result of apathy on the part of
those new to the area. Among new residents who initially thought that the
Pilgrim plant should be reopened (Q. 25), more than three-fourths (77%)
changed their opinion when informed that the NRC had found serious safety and
management problems at the plant, compared to a 54% turnaround among the total
sample (Q. 26). This was the largest turnaround we found, strongly suggesting
that it is simply lack of information which distinguishes these residents from
others. Boston Edison's failure to reach any more than half of these
residents with emergency information or warning drills thus could be a primary
cause of their inability to cope effectively with an emergency situation.
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261
J. niE Bl.AWS REVHALEi: 3Y T!'E L^URVSY RENDER THE F.^;ERGHNC•y PLANS UNWORKABLE
The probleas ou'.J med in the ;;reced.irg rhree sections reveal significant
defects in both the design and iiipi'tnentat ion of emergency plans for the
Pilgrim area. Much of the affected population is unfairiiliar with basic
elements of the plana, many who are familiar with the plans will not follow
them, ana the needs cf identifiable groups of people have simply not been
addressed either in the plans' design or in the dissemination of emergency
information.
Our survey uncovered a number of other problems which, combined with those
mentioned above, will make an GVijCUj.:ion uiiwoikaiilt .
1 . PRESENT VJARNING METHODS ARE UNLIKELY TO ALERT RESIDENTS QUICKLY
It seems apparent from out findings that a significant number of residents
might not receive effective warring and accurate information quickly enough to
be of any use during the short time in which a serious accident could develop.
Use of the v;arriing sirens alone is not enough. Over 40% of those we
surveyed said that they could not hear the sirens well or at all when their
doors and windows were closed (Q. 4). In addition, many of those who are
familiar with the sirens have heard them sl' often ("everv time there is an
electrical storm") that simply heading a siren would not immediately alert
them to an actual accident in progress (Q. 3, 6).
2. PHONE LINES ARE LIKF.LY TO BE TIED UP DURING AN EMERGENCY
Only a third of our survev sample knew that emergency information would be
available on local television and radio (Q. 12';. It is not surprising, then,
that nearly two-thirds of the pe'^nle we polled rsid that thev would use the
telephone to find out emergencv information or to find cut information about
family members (Q. 13). This ie particularly i:nderstandable in light of the
fact that the emergency information booklet contains no instructions against
15
262
y;;-'.ng the Telephone during en eiotTgency.
Thousands of peoplp all picking up the phone at nearly the same time is
sure to tie up phone lines and make communication virtually impossible, further
hindering an effective response to a serious accident at Pilgrim.
3. ORDERLY EVACUATION IS UNLIKELY TO OCCUR
The obstacles facing those trying to devise a way of evacuating all the
residents of the EPZ in case of a serious accident at Pilgrim may well be
insurmountable under the best conditions. The problems already discussed
above make it abundantly clear that those planning for evacuation now are
operating in a situation that is far from ideal.
The lack of familiarity with the existing plans and the lack of confidence
that those plans will work are the most obvious problems. Although, directed to
stay inside and wait for instructions by the emergency information booklet, the
initial response to an accident situation among many of those we surveyed
included evacuation (27%), making phone calls, packing, and gathering the
family (9%, 2%, and 12%, respectively), and a variety of responses subsumed
under the categories of "don't know" and "other" (12% and 18%, respectively)
(Q. 11). Those who would evacuate, even if properly directed to do so, would
flee in all possible directions — "whichever way the wind isn't blowing," in
the words of one respondent — forsaking the planned escape routes mapped out
in the booklet (Q. lA, 15). For many that is not an irrational decision:
Hanover Mall, one of the evacuation centers listed in the current emergency
information booklet, has withdrawn as an evacuation center!
An intensive program of public education could perhaps overcome some of
the flaws identified in the survey. It is uncertain, however, whether
education would be enough to convince parents of young children, or people with
family members in a hospital or nursing home, to leave their family members to
16
263
th'-' autboritie'j Cor e\'acuation. The plan simply does not take into account the
strong impulse, particularly of parents, to see to the safety of their children
themselves (Q. 18, 22).
Finally, the evacuation plan depends primarily on most residents' ability
tc get themselves out of the danger zone, with emergency workers left to see to
any others. Our survey showed that approximately 95% of the people in the EPZ
have access to a car at any given time (Q. 20). The effect of nearly every
automobile in the towns of Plymouth, Carver, Kingston and Duxbury taking to the
reads at the same time is unprecedented and almost unimaginable. Add to that
number the residents of the area surrounding the Pilgrim EPZ. During the Three
Mile Island emergency, for example, when authorities ordered 2,500 women and
young children to evacuate 14A,000 people took to the roads.
One respondent commented that it is virtually impoesible to get through
traffic when there is a snowstorm and a few cars break down; he could not
conceive of the problems that would ensue if the entire town of Plymouth tried
to leave at once. Most Massachusetts residents are familiar with the
monumental traffic problems caused by Cape Cod traffic on a summer weekend.
Snarls such as these would almost certainly be dwarfed by those resulting from
a full-scale evacuation of the Pilgrim EPZ.
The number of cars on the road would also make it far more difficult for
emergency workers and buses to get through to the school children and elderly
who cannot transport themselves out of town. Ironically, the widespread
availability of cars might prove the greatest obstacle to getting people out of
the danger, zone in time to protect them from a radiation release.
E. MOST RESIDENTS SURVEYED WANT PILGRIM TO REMAIN SHUT DOWN
In light of the serious problems which beset the emergency plans and the
^oor safetv record compiled by the Pilgrim plant, the residents surveyed have
arrived at the following response to this situation: keep the plant shut down.
17
264
When asked simply whether they favored reopening the plant after its
scheduled maintenance and refueling, 55% said that it should remain shut down
and only 34% favored reopening (Q. 25). When those who had not answered "shut
down" were informed that the NRC had found serious management and safety
problems at the Pilgrim plant, more than half changed their answer and said
that if those findings were correct, the plant should remain shut down.
Combining the responses to these two questions, 79% of the entire survey
sample favored shutdown in response to either Question 25 or 26, with just 17%
still favoring operation of the plant after be:ing asked both questions.
Significantly, this response held true across all political and demographic
categories: liberals and conservatives, young and old, high-school- and
college-educated people, residents of all four towns, and even households
containing Boston Edison employees favored shutdown of Pilgrim (Q. 25 & 26:
Combined Answer).
Thus, a clear majority of Pilgrim-area residents already favor shutdown
of the Pilgrim nuclear power plant. After learning more about official views
of the plant's safety, they favor shutdown by nearly a five to one margin.
Much of this sentiment can be attributed to lack of faith in Boston
Edison. When asked who they would trust for information and advice during an
emergency, our survey sample expressed the greatest distrust for Boston Edison
officials. Thirty-one percent said they would have no confidence in their
advice; the next highest negative rating was 17%. Boston Edison also had the
second-lowest positive rating (coming in just ahead of the faceless
"independent expert") and the lowest overall confidence score (Q. 23).
18
265
Hi. DETAILED SUMMARY OF QUESTIONS AND RESPONSES
A. METHODOLOGY
The survey is based on 363 telephone interviews with adult residents of
che towns of Plymouth (including Manomet), Carver, Duxbury and Kingston. These
towns comprise the emergency planning zone for the Pilgrim Nuclear Power
Station.
The questionnaire consisted of 3A questions, including eight questions on
demographic variables. Interviewing was conducted from May 5 to May 14, 1987,
by MASSPIRG researchers acting under the supervision of a John F. Kennedy
School of Government graduate student trained in scientific polling methods.
Telephone numbers for interviews were chosen randomly by computer in order
to reach residents with unlisted phone numbers and new residents whose numbers
had not yet been published. This technique yields a more representative sample
of households than use of a telephone directory to generate numbers.
The survey was a stratified random sample. This technique divides the
total population into twelve groups, known as strata, each of which consists of
men or women of a given town or telephone exchange. Within each of these
strata, individual respondents were selected totally at random. The number of
interviews conducted in a given stratum was determined in advance, according to
the proportion of the total actual population represented by that group and in
order to produce a statistically s- sni /^icant 'laiiple frrm each tcwn. Tne
results veve then weighted based on the share of actual population represented
by each stratum; the totals thus refect the disLribution by town and gender of
the actual population, not of the sample population.
In theory, 95 times out of 100 the results from the overall sample should
differ no more than 4 percentage points from what would have been found by
purveying the entire population of the towns. The sampling error for smaller
19
266
eubgroups (for example, a particular age group, or residents of one of the
towns) could be larger, depending on the size of these groups. Other errors
can result from the usual practical problems of conducting a public opinion
survey.
B. THE SURVEY
Question 1. DID YOU KNOW THAT THE STATE AND LOCAL GOVERNMENT HAVE DEVELOPED AN
EMERGENCY EVACUATION PLAN TOR YOUR TOWN IN THE EVENT OF A SERIOUS
ACCIDENT AT THE PILGRIM NUCLEAR POWER STATION?
Total
Numbei
Responses
r %
Kingston
Number
%
Age 65 an<
Number
i Over
%
Yes
314
87
37
80
40
74
No
49
13
10
20
14
26
This threshold question revealed that most respondents were aware of the
existence of emergency planning for their community. In Kingston, however, 20%
of those surveyed did not know that there is an emergency evacuation plan for
their town, and among respondents who are 65 and older, more than one-fourth
answered "no" to this question.
Question 2. IF THERE WERE A SERIOUS ACCIDENT AT THE PILGRIM NUCLEAR POWER
PLANT HOW DO YOU THINK THE AUTHORITIES WILL WARN PEOPLE?
(list all responses)
Siren
TV / Radio
Other
Don't Know
The correct answer, presented on page 1 of the official emergency planning
booklet, is that warnings will go out via civil defense sirens, police
loudspeakers, and local radio and television stations. While three-fourths of
the respondents named sirens as one warning mechanism, fewer than one in five
were aware that warnings would be issued over television and radio. Again,
20
%
of Total
Number
Responses
272
75
70
19
34
9
38
10
Number
%
Re
of Total
isponses
286
79
72
20
3
1
267
those over 65 displayed the leajt awareness of emergency procedures (only 6A%
mentioned warning sirens, just 6% named TV/radio, and 14% did not know how they
would be warned).
Question 3. HAVE YOU EVER HEARD THE PIT, GRIM WARNING SIREN?
Yes
No
Don't Know
.he qui:cj.on, hIZ U^O) said they have heard the
siren once or twice, 29% (82) have heard it 3 to 5 times, and 17% (48) have
heard it go off more than 5 timas. Twelve percent (36) did not say how many
times they had heard the siren.
More than a third of the Carver residents surveyed (36%) had never heard the
warning siren, while 86% of Plymouth residents reported having heard it at
least once. Those living in the area for 3 years or less are least likely to
have heard the siren — only 50% of those surveyed answered "yes."
Question 4. HOW WELL CAN YOU HEAR THE PILGRIM WARNING SIREN AT YOUR HOME WHEN
THE WINDOWS AND DOORS ARE CLOSED?
% of "Yes"
Numbe r to Q. 3
Well 95 33
Somewhat well 37 13
Not well 75 26
Not at all 44 15
Don't Know 40 lA
Only 46% of those who had hearr, the sir^n said that they could hear it well or
;iomewhat well when the doorr and .■:-''^"s of thrir hoves were closed.
demonstrating the need for additional ways of warning residents in case of an
emergency.
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268
Question 5. CAN YOU HEAR POLICE. FIRE OR AMBULANCE SIRENS AT YOUR HOME WHEN
YOUR WINDOWS AND DOORS ARE aOSED?
Yes
Sometimes
No
Don • t Know
Number
%
Re
of Total
isponses
273
75
49
13
36
10
1
0
Question 6. WHAT DOES IT MEAN WHEN THE PILGRIM SIREN GOES OFF?
Accident
Drill
Other
Don't Know
Number
%
Re
of Total
isponses
109
30
70
19
118
33
77
21
"Other" answers included many "evacuate," "head for the hills," "start
packing," and "kiss your ass goodbye," indicating that respondents would think
an accident was in progress at the Pilgrim plant. (The f rivolousness or
sarcasm in some of these responses indicates that many residents either
do not take the sirens seriously or do not believe warnings would be of any use
were a serious accident to occur,) Another group of "other" answers, such as
"another thunderstorm," indicated the belief that hearing the siren simply
means the warning equipment is malfunctioning.
Question 7. IF YOU HEARD A SIREN RIGHT NOW, DO YOU THINK YOU COULD TELL THAT
IT WAS BECAUSE OF PILGRIM, RATHER THAN, SAY, A FIRE ENGINE, AN
AMBULANCE. OR SOMETHING ELSE?
% of Total
Yes, could tell
Probably could
Probably could not
No, couldn't tell
Don't know
Number
Res
ponses
215
59
35
10
11
3
77
21
15
A
22
269
Again. Carver residents exhibited the least amount of familiarity with the
Pilgrim warning sirens: nearly half — 45% — answered that they could not or
probably could not distinguish the Pilgrim siren from a fire engine or an
ambulance. Also, one-third of respondents aged 65 and over expressed doubt
that they could recognize the Pilgrim siren.
Question 8. HOW WOULD YOU RECOGNIZE THAT A SIREN MEANT A NUCLEAR ACCIDENT?
% of Those Answering
Number Q. 7 Affirmatively
High pitch 25 10
Steady tone 26 10
Very loud 42 16
Persistent 30 11
Other 91 35
Don't know 61 23
Although a majority of respondents answered that they would recognize the
Pilgrim siren if they heard it (Q. 7), few respondents correctly explained
how they would tell whether a real accident were taking place. The nuclear
warning siren will be distinguishable from others by its duration (15 minutes),
or its "persistence." Only 11% of respondents gave this answer. The most
common responses of those categorized under "other" were that the siren has a
"fluctuating" or "pulsating" tone, or simply that "you could just tell."
Question 9. HAVE YOU OR ANYONE IN YOUR HOUSEHOLD RECEIVED A COPY OF THE
BOOKLET CALLED "EMERGENCY PUBLIC INFORMATION: WHAT TO DO IN CASE
OF AN EMERGENCY AT PILGRIM NUCLEAR POWER STATION"?
Total Responses New Residents (<3 yrs)
Number % Number %
Yes 203 56
Not sure / maybe 42 11
No 104 29
Don't know 11 3 4 4
Although Boston Edison claims to have distributed copies of this booklet to all
residents of the emergency planning zone in November 1986, nearly one-third of
those we surveyed (29%) had not received a copy, and another 11% were not sure
if they had received one. These distribution problems were most critical with
regard to people living in the area for 3 years or less, who made up nearly a
quarter of the survey sample: 47% of these respondents had not received the
emergency planning booklet, compared to only 41% who were sure they had.
23
33
41
6
7
39
47
270
Question 10. WOULD YOU SAY YOU HAVE READ THE BOOKLET COMPLETELY. PARTIALLY. OR
NOT AT ALL?
Number
%
of
"Yes" 01
to Q.
: "Maybe"
%
Re
of Total
:sponses
Completely
82
33
23
Partially
109
44
30
Not at all
45
18
*
Among those who said they had received or may have received the emergency
planning booklet, a full 62% admitted that they had read it only partially or
not at all. In other words, only 23% of the total surveyed said they had read
the booklet completely. The lack of actual knowledge of emergency procedures
that this implies is corroborated by the answers to many other questions in
this survey.
* The number who have not read the booklet is actually much larger than 45,
since this question was not asked of those who never received the booklet.
Question 11. IN CASE YOU HEAR THE WARNING SIREN. INDICATING A SERIOUS PROBLEM
AT PILGRIM. WHAT IS THE VERY FIRST THING THAT YOU WOULD DO?
Turn on radio or TV
Take shelter at home
Get family together
Make phone calls
Start packing
Evacuate
Other*
Don't know
* Common responses include:
"Panic" (5 respondents)
"Pray" (6)
"Kiss my wife/husband" (2)
"Get drunk/grab a six" (6)
This question was designed to find out what people would in fact do. as opposed
to what they think they are supposed to do. Only 10% said that they would take
Number
%
Re
of Total
isponses
65
18
37
10
42
12
32
9
9
2
99
27
66
18
42
12
24
271
shelter at home, as the emergency planning booklet directs on page 3; only 18%
said they would turn on the radio or TV to get information or instructions,
which the booklet also recommends (there is a degree of overlap in these
figures, as some respondents gave more than one answer).
Significantly, the most frequently named response was "evacuate," and a number
of other responses — such as "start packing" and many responses categorized
under "other" — were premised on immediate evacuation, contradicting the
express directions in the emergency planning booklet.
Question 12. DO YOU KNOW WHAT THE OFFICIAL EMERGENCY H.AN RECOMMENDS THAT YOU
DO TO GET SPECIFIC INSTRUCTIONS IN CASE OF AN EMERGENCY?
% of Total
Numbe r Responses
Yes: turn on radio/TV 120 33
Yes: other 31 9
No 206 57
Only one in three respondents knew the correct response, "tune to local radio
and TV stations," which is listed on page 3 of the emergency information
booklet. Even more disturbing, fewer than one in five respondents 65 or over
(19%) gave the correct response to this question, reiterating the concern that
the elderly may present difficult problems for emergency planners.
Question 13. WOULD YOU USE THE TELEPHONE TO FIND OUT EMERGENCY INFORMATION OR
TO FIND OUT INFORMATION ABOUT FAMILY MEMBERS?
Number
% of Total
Responses
226
117
62
32
Yes
No
Don't knew 16 4
Surprisingly, the emergency information booklet does not advise people not to
use the telephone in case of an emergency. Accordingly, nearly two-thirds of
those we surveyed said that they would use the phone — primarily to call the
police for information or to try to contact family members. In all likelihood,
this will only serve to tie up phone lines and jeopardize efficient execution
of the emergency plans.
25
272
Question 14. IF THERE WERE AN ACCIDENT AT PILGRIM AND YOU WERE TO ACTUALLY
EVACUATE YOUR HOME. WHERE WOULD YOU GO?
%
of Total
Number
Responses
Hanover Mall
46
13
Bridgewater State Colle
•ge
20
5
Taunton State Hospital
3
1
Elsewhere in Mass.
91
25
Wherever directed
7
2
Other*
119
33
Don't know
65
18
* Representative responses include:
"Whichever way the wind isn't blowing"
"Roads would be jammed up/would never get out of town"
"Alaska/Canada/Califomia/Vermont/Miseissippi"
"Good questioni"
Only 19X of the respondents said they would go to one of the evacuation centers
named in the emergency information booklet (the first three responses listed
above). IVo-thirds of these people (13X) would go to the Hanover Mall, which
has already pulled out of the evacuation plan and will not serve as a reception
center, but which is still listed as one in the booklet.
It is clear from these responses that a real evacuation would produce chaos.
Only 22 of those surveyed would listen first for directions, confirming the
conclusion suggested by Question 12 that few people would know to wait and tune
in to local media for emergency information. Moreover, many of those who
profess knowledge of the actual plans are misinformed: for example, two-thirds
of the Carver residents who said they would go to an evacuation center named
the wrong one.
Even those supposedly "in the know" evidenced a shocking lack of confidence in
the evacuation plans. Although the- sample size is admittedly very small, only
2 of 15 respondents from households containing Boston Edison employees and only
4 of 20 from households containing someone responsible for implementing the
evacuation plans said they would go to one of the evacuation centers in case of
an accident at Pilgrim.
26
273
Question 15. DO YOU KNOW WHAT ROUTE YOU ARE SUPPOSED TO TAKE TO GET THERE [TO
THE EVACUATION CENTER]?
% of Those Who Said They
Number Would Go To an Evacuation Center
Yes A3 62
No 23 3A
This question tested the knowledge of the evacuation routes mapped out in the
emergency information booklet (pp. ^-5) among those respondents who said, in
response to Question lA, that in case of an emergency they would go to one of
the evacuation centers. Even among this self-selected group, one-third
admitted that they did not know the recommended route.
Question 16. DO YOU HAVE ANY CHILDREN AGE 16 OR YOUNGER WHO GO TO SCHOOL IN
THE AREA?
% of Total
Number Responses
Yes 13A 37
No 226 62
Question 17. ARE THERE ANY TIMES AFTER SCHOOL HOURS WHEN YOUR CHILD (REN)
IS (ARE) NOT IN THE CARE OF AN ADULT?
% of "Yes" to
Number Q. 16
No 83 62
Yes 50 37
In case of an emergency at Pilgrim during after-school hours, as many as 37% of
children 16 or under could be left to fend for themselves. Parents at work
during these times "may not be permitted to return [to the affected areas]
during the evacuation," according to the anergency information booklet (p. 6).
Question 18. IF THERE IS AN ACCIDENT AT PILGRIM DURING SCHOOL HOURS, WHAT
WOULD YOU DO ABOUT YOUR CHILD (REN)?
Z of "Yes" to
Number Q. 16
Get children from school 65 A8
Wait for them to come home A 3
Meet them outside danger zone 13 9
Other 27 20
Don't know 22 17
27
274
The correct answer, "meet them outside the danger zone," was given by only 9%
of the respondents. The most common response was to go get the children from
school oneself, which people are explicitly instructed not to do on page 6 of
the emergency planning booklet. The response to this question clearly
indicates either a major flaw in the evacuation plans or the need for intensive
education to convince parents to ignore their strong impulse to find their
children themselves.
Question 19. ACCORDING TO THE OFFICIAL EMERGENCY PLAN. YOU ARE SUPPOSED TO
MEET THEM AT A SPECIAL EVACUATION CENTER AWAY FROM TOWN. DO YOU
HAPPEN TO KNOW WHERE THE CENTER IS WHERE YOU WOULD FIND YOUR
CHILD (REN)?
% of "Yes" to
Number Q. 16
Yes 39 29
No 92 69
Adding to the confusion and panic that an evacuation would cause, seven out of
ten parents we surveyed would not know where to find their children if an
accident occurred at Pilgrim during school hours.
Question 20. DO YOU HAVE A CAR AVAILABLE FOR YOUR USE DURING . . .
Total Responses Age 65 & Over
Number % Number %
WEEKDAYS?
Yes
344
95
49
90
No
11
3
5
10
Sometimes
5
2
0
0
WEEKNIGHTS?
Yes
340
94
47
88
No
13
3
6
12
Sometimes
4
1
0
0
WEEKENDS?
Yes
343
94
49
90
No
9
2
4
7
Sometimes
A
1
1
2
At any given time, 95% of the households in the emergency planning zone would
have a car available to be used. This many households each evacuating in a
separate automobile at the same time will likely create traffic problems of
unprecedented proportions, particularly in light of the fact that most people
surveyed would not knew to use the evacuation route planned for their
particular section of the EPZ (see questions 14 and 15) .
Respondents 65 and over were the only demographic group without such wide
access to an automobile. 7 to 12% of those we surveyed would not be able to
28
275
use a car at any given time, creating a different set of problems for
evacuating this group of residents.
Question 21. DOES YOUR HOME HAVE A BASEMENT?
Yes
No
Question 22. SUPPOSE YOU WERE ADVISED TO EVACUATE BECAUSE OF AN ACCIDENT AT
PILGRIM. BUT YOU HAD CHILDREN IN SCHOOL OR A FAMILY MEMBER IN A
HOSPITAL OR NURSING HOME. ACCORDING TO THE PLAN, YOU ARE
SUPPOSED TO GO DIRECTLY TO A SPECIAL EVACUATION CENTER, WHILE
YOUR FAMILY MEMBERS WERE TRANSPORTED TO THEIR APPROPRIATE
LOCATIONS. WOULD YOU BE ABLE TO FOLLOW THESE INSTRUCTIONS?
Number
% of Total
Responses
313
A7
86
13
Number
% of Total
Responses
185
128
51
35
Yes
No
Don't know A2 12
This question is similar to the one asked of parents of school-age children
(Question 18), but is far less open-ended and more likely to elicit a "yes"
response. First, the question is hypothetical — most respondents did not in
fact have children in school or family members in a hospital or nursing hone.
Second, the question spells out what the actual evacuation plans are in a way
that makes them sound reasonable and workable. Finally, the question asks
whether the respondent "would be able" to comply with such a scheme if
instructed to do so.
In spite of the clear slant of this question, nearly half those surveyed said
that they either would not follow these plans or did not know whether they
could follow them. The vast majority of those answering "no" mentioned their
need to provide for the safety of their family members themselves and not to
entrust that role to the authorities. As was clear with Q-jastion 18, the
strong desire of people to find their family members indicates either a major
flaw in the evacuation plans or the need for far better education on behalf of
Boston Edison.
29
276
Question 23. IF THERE WERE Mi ACCxji^.f A'^ PiLGRIK. YOU t-IIGHT HEAR STATEMENTS
ON THE RADIO OR OK 1/ "Y l/I I'^ RENT .'EOPLE AND ORGANIZATIONS. I'M
GOING TO MENTIOn S0.~; CT IHF.M. AND AS I DO. PLEASE TELL ME FOR
EACH ONE HOW MUCT CO:" J'' ""Cn YOU WOULD HAVE IN THEM TO GIVE YOU
ACCURATE INFO KMAT low A:ID COOu AJ)VICE. A SCORE OF 5 MEANS THAT
YOU HAVE A GREAT D' '', OF COiriDI^NCE IN THEM; A SCORE OF 1 MEANS
THAT YOU HAVE MO OJ'.'l'Il'lznr^ I!' T.iSIR /J3VICE; A SCORE OF 3 WOULD
BE SOMEWHERE If! ''.i::^, >rB'i..':.
Governor Dukakis
An official of Boston
Edison
tIJII
3"
\nt
:'ering
I12II
"1"
DK
Avei
Sec
3
-age
3re*a
36
-> -
.r
6
17
2
54
19
• -}
io
ii
31
2
2
81
An official of the U.S. 34
Nuclear Regulatory Comm.
16
3.51
Attorney General Shannon 19
An independent expert 15
12
17
18
10
3.30
3.01
Boston Edison received easily t-, : ,l -ar'.;- of any of the people or
organizations we mentioned, garr^rin,^ ^.,e r.econd-lowest positive rating, far
and away the highest negative ci"c; :...'. the Iciest average score. Even among
those respondents who believ3 t".".t ?il~r'.tp chould reopen despite findings of
serious safety problems (see Que. tier. -3 25 c-^ 26), only 32% expressed a great
deal of confidence in emergency i~for.i9tior dissemin?.ted by Boston Edison.
* "Average Score" was computed exclu'! '.ji[; those ans-.jering "don't know" or who
refused to answer. Thus, Attorney G-n^ral Shannon's 3.30 score must be
tempered by the fact that 18% did not knov. '•]'.''-': a-iount of confidence they would
have in him.
Question 24. DO YOU THINTC TH/.T IT TS LIKELY
ACCIDENT AT THE riLC-.xi: FLA>i7:
rH/T THERE WILL BE A SERIOUS
% of Total
Responses
Yes
24
Maybe
No
7-1
.20
',6
Don't know
31
Nearly half — 44% — of thos= s
Pilgrim is either likely or at It .1
across the political spectrum: '• " ' c*
L.i*. . cJ: -t 1 serious accident at
":i'Sli3. Tliis viewpoint held true
-"..■■-fle"cribed conservatives, 44% of
277
liberals, and 51% of moderates answeved either "yes" or "maybe" to this
question.
Interestingly, of those who believed that Pilgrim should not be reopened (see
Questions 25 and 26), only 53% thought a serious accident is likely or may be
likely. This total is just slightly larger than the total sample's response to
Question 24, suggesting that opposition to Pilgrim runs deeper than simply fear
of a serious accident. Other issues that may be generating public
dissatisfaction with the Pilgrim plant probably include waste disposal, smaller
scale radiation releases, and unreliability.
Question 25. PILGRIM IS CURRENTLY SHUT DOWN FOR MAINTENANCE AND REFUELING. IN
YOUR OPINION, SHOULD THE PLANT BE REOPENED OR SHOULD IT REMAIN
SHUT DOWN?
%
of To
tal
Number
Re
:sponses
123
34
200
55
Reopened
Shut Down
Other 15 4
Don't Know 24 7
Over half of those polled want Pilgrim to remain shut down, while only a third
believe the plant should reopen. As with the responses to Question 24, this
sentiment cut across political lines: 51% of conservatives, 60% of liberals,
ana 59% of moderates favored shutdown.
An interesting footnote to these figures was the response of people from
households with either a Boston Edison employee or someone responsible for
implementing the emergency plans (15 and 20 respondents, respectively). While
these figures are not statistically significant, it is nevertheless noteworthy
that a fifth of the respondents from each of these groups favored unequivocal
shutdown of the Pilgrim plant.
Question 26. STUDIES RECENTLY COMPLETED BY THE U.S. NUCLEAR REGULATORY
COMMISSION SHOW INDICATIONS OF MANAGEMENT AND SAFETY PROBLEMS AT
PILGRIM, MAKING IT ONE OF THE MOST DANGEROUS NUCLEAR PLANTS IN
THE COUNTRY. IF THESE FINDINGS ARE CORRECT, IN YOUR OPINION
SHOULD THE PLANT BE REOPENED OR SHOULD IT REMAIN SHUT DOWN?
% of Non-"Shut Down"
Number Responses to Q. 25
Reopened 60 37
Shut Down 88 54
Other 5 3
Don't Know 5 3
31
278
This question, asked only of those not answering "shut down" to Question 25, is
obviously a more loaded question and for that reason was the last question
asked in the survey, so as not to taint the other responses. Only slightly
more than a third of those who initially favored reopening Pilgrim still
believed the plant should reopen in light of the NRC's findings regarding
safety and management problems. The turnaround was most dramatic among those
who had lived in the area for three years or less, a group making up 23X of our
total sample. 77% of these respondents ans^vered "shut down" to this question
(compared to 54% on Q. 25), suggesting that many newer residents simply are not
yet fully informed about the problems that have historically plagued the
Pilgrim plant.
Questions 25 and 26: CO! £ IKED
Numbe r
% of Total
Responses
Answered "Shut Down" to
Q. 25 or Q. 26
288
Answered "Reopen" to Q. 26
60
Less than one in five respondents was unequ:vocally in favor of reopening the
Pilgri"! plant. The overwhelming sentiment in favcr of shutting down an unsafe
nuclear power plant was consistent across all demographic lines:
* all four towns in the survey favored shutdown by margins ranging
from 74% (Carver) to 90% (Kingston);
* self-described conservatives were 77% in favor of shutdown,
compared to 84% for liberals, 82% for moderates, and 72% for those
who could not or would not describe their political orientation;
* the only age group coming in at less than 70% was the 65 and over
group, 66% of whom favored shutdown;
* educational backf^rour.d slso had little effect on shutdown
sentiment: the percentag'is in fcvor of shutdown varied only between
75 and 83% when the survey sample was grouped by educational level;
* even among those from households containing Boston Edison
employees or those with official responsibilities for ir n1 ementing the
emergency plans, respondents favoring shutdown outnumbered those in favor of
reopening the plant by approximately 5 to 3.
32
279
IV. RECOMMENDATIONS
Our survey of Pilgrim area residents shows a widespread lack of knowledge
about emergency planning procedures, little faith among the population that
the evacuation plans are workable or worth complying with, strong indications
that any attempt at immediate evacuation would meet with little success, and a
broad consensus behind the idea that a nuclear plant with a safety record like
Pilgrim's should remain shut down. These conclusions are surprising only to
the extent that they present an even poorer picture of emergency preparedness
than was revealed in the last MASSPIRG survey.
MASSPIRG and a variety of other citizen groups and local and state
officials have consistently argued that the Pilgrim emergency plans are
themselves a disaster. With the rapid population growth in the Plymouth area
and the withdrawal of the Hanover Mall as an evacuation center, the plans have
deteriorated even further. FEMA has withdrawn its approval of the plans,
calling them "inadequate to protect the public health and safety in the event
of an accident." Yet Boston Edison is nonetheless considering restarting the
plant without locally and federally approved plans.
The findings in this report clearly demonstrate that restarting the plant
under the existing emergency plans could prove disastrous. Given the current
level of public information about the plans, they would not be adequate to
protect the public health and safety even if the deficiencies identified by
FEMA were corrected. Moreover, because residents responded that they would
refuse to comply with key elements of the plans, there is a serious question as
to whether any plans, no matter how good they looked on paper, could be
effectively implemented.
In light of these results and the serious management and safety problems
still remaining at Pilgrim, we strongly recommend that the Pilgrim plant should
not reopen until it is determined that:
33
280
(1) workable plans can be developed;
(2) such plans have been effectively implemented and communicated to the
public; and,
(3) existing management, safety and economic concerns have been
adequately addressed.
We call on Governor Dukakis, the State Legislature, and the Massachusetts
congressional delegation to do everything within their power to keep the
reactor closed until the above conditions have been met.
In the meantime, MASSPIRG continues to recommend that the State and Boston
Edison explore the possibility of alternatives — such as efficiency reforms,
cogeneration. small power producers, and conservation — which have the
potential to produce energy more safely, cheaply and efficiently than does the
Pilgrim nuclear power plant.
i
34
281
NUCLEAR LEMON
PUmu OPETVkTIQN vs. nETfEMEMr
I9a7 4
UTTX
ES
RATEPAYER SAVINGS FROM RETIRING
THE PILGRIM NUCLEAR POWER PLANT
Massachusetts Public Interest Research Group
(MASSPIRG)
NOVEMBER 1987
282
NUCLEAR LEMON
RATEPAYER SAVINGS FROM RETIRING THE
PILGRIM NUCLEAR POWER PLANT
Massachusetts Public Interest Research Group
(MASSPIRG)
29 Temple Place
Boston, MA 021 11
(617) 292-4800
Research Director and Author:
Alan J. Nogee
Research Assistant:
Susan Boehm
November 1987
283
ACKNOWTLEDGMENTS
The author gratefully acknowledges the assistance of Susan Boehm, a
graduate student at the John F. Kennedy School of Government. Thanks
also to Stephen Bernow, of the Energy Systems Research Group, David
Schlissel, of Schlissel Engineering Associates, and Chris Granda, of the
Legislative Energy Committee for invaluable technical input. Armond
Cohen, of the Conservation Law Foundation; Joshua Kratka, Rachel
Shimshak, Michael L'Ecuyer, and WiUiara Ryan, of MASSPIRG; and
Deborah Horvitz, my wife, provided helpful editorial comments on early
drafts of this work.
ABOUT THE AUTHOR
Alan Nogee has been an Energy Policy Analyst for over ten years. He is
author of two major national reports on utility policy - Rate Shock:
Confronting the Cost of Nuclear Power, and Gambling for Gigabucks: Excess
Capacity in the Electric Utility Industry ~ and numerous articles. He has
testified or spoken by invitation to the energy committees of the U.S. Senate,
House of Representatives, National Governors' Association, National
Conference of State Legislatures, and regulatory agencies and legislative
committees in several states. Before joining MASSPIRG in May, 1987, he
was an Energy Analyst with Environmental Action Foundation, in
Washington, D.C., and for consumer and environmental groups in
Philadelphia, Pennsylvania.
284
TABLE OF CONTENTS
1. Introduction -- Nuclear Costs and Cancellations 1
2. The High Cost of Operating Pilgrim 4
A. Edison ignores nuclear cost trends 5
B. MASSPIRG assumptions are still conservative 7
3. Economic Benefits of Retiring Pilgrim 8
A. Replacement power costs less than Pilgrim 8
B. Other shutdown costs 10
C. Ahemative scenarios show savings from retiring Pilgrim 12
4. Conclusions and Recommendations 15
Appendix A. Annual Costs of Pilgrim vs. Alternatives 16
Appendix B. MASSPIRG Nuclear Cost Estimates 23
Appendix C. Causes of Nuclear Cost Escalation 29
Notes 32
LIST OF FIGURES
Figure 1. Pilgrim Capital Cost 2
Figure 2. Electricity Generation cost -- 1988 3
Figure 3. Pilgrim Capital Cost Projection (BECO Assumptions) 3
Figure 4. Pilgrim Cost Components (BECO Assumptions) 4
Figure 5. Pilgrim Annual Generation Costs (Alternative) 6
Figure 6. Pilgrim Total Costs (Alternative) 7
Figure 7. Alternative Project Fuels 9
Figure 8. Pilgrim vs. Alternative Annual Generation Costs 9
Figure 9. Pilgrim vs. Replacement Power Costs (BECO Assumptions) 10
Figure 10. Pilgrim Operation vs. Retirement (BECO Assumploins) 11
Figure 11. Pilgrim Operation vs. Retirement (Present Value) 13
Figure 12. Cumulative Savings from Retiring Pilgrim 14
Figure 13. Savings from Retiring Pilgrim (Sensitivity to Sunk Costs) 14
Figure 14. National Average Capital Additions 23
Figure 15. Pilgrim & National Average Capital Additions 23
Figure 16. Capital Additions Projections 24
Figure 17. Cumulative Savings from Retiring Pilgrim (Sensitivity to Capital Additions) 24
Figure 18. Pilgrim vs. National Average O&M Costs 25
Figure 19. O&M Cost Projections 26
Figure 20. Cumulative Savings From Retiring Pilgrim (Sensitivity to O&M Costs) 26
Figure 21. Pilgrim vs. National Average Capacity Factor 27
Figure 22. Capacity Factor Projections 27
Figtire 23. Cumulative Savings from Retiring Pilgrim (Sensitivity to Capacity Factor) 28
LIST OF TABLES
Table 1. Alternative Assumptions Used in MASSPIRG Projections 12
Table 2. Additional Conservatisms in All Scenarios 12
Table 3. Savings to Ratepayers From Retiring Pilgrim 13
Table 4. Oldest U.S. Operating Nuclear Reactors 31
Table 5. Retired U.S. Reactors 31
285
EXECUTIVE SUMMARY
This study examines the costs and
benefits of permanently closing the
Pilgrim nuclear plant, and replacing it
with alternatives that are currently avail-
able to Boston Edison (BECO). Using
conservative assumptions which are likely
to underestimate Pilgrim's costs, and to
overestimate the cost of alternatives,
MASSPIRG has found that:
1. Utility customers would save at least
$1.5 billion (present value) over the next
25 years by closing Pilgrim, if future
Pilgrim costs were to follow historical
trends for the plant. These savings would
occur even if ratepayers had to pay for the
full utility investment in the plant to date,
including the same profit the companies
would have earned if the plant had
operated.
2. K trends at Pilgrim improved to the
most optimistic levels that could
reasonably be hoped for, utility customers
would still save money by retiring Pilgrim,
even if they had to pay for the full sunk in-
vestment in the plant.
3. Even under Edison's own assump-
tions, which are unrealistic, ratepayers
would likely benefit from Pilgrim retire-
ment, if the Massachusetts Department of
Public Utilities required utility customers
and investors to share the cost of past in-
vestment in Pilgrim according to tradition-
al regulatory practice.
This study starts with the same figures
and uses the same methods of analysis
employed by BECO in a recent presenta-
tion to the Massachusetts Executive Of-
fice of Energy Resources (EOER). The
utility's assumptions about fumre
Pilgrim performance and major costs
are compared to past performance and
cost trends at Pilgrim and other U.S.
nuclear plants, and alternative assump-
tions and cost projections are
developed.
In order to err on the side of underes-
timating Pilgrim costs, MASSPIRG
uses a number of unrealistically low
Edison estimates in all projections. The
costs of nuclear fuel, nuclear waste dis-
posal and of dismantling Pilgrim at the
end of its operating life are unchanged
from BECO projections. It is assumed
that the 15-year-old Pilgrim plant could
operate for a total of 40 years, although
no nuclear plant has operated for
longer than 26 years. To be as favorable
to Pilgrim as possible, MASSPIRG also
assumes that the cost of replacement
parts and safety upgrades will level off,
and that Pilgrim performance will not
deteriorate with age.
Replacement power for Pilgrim is
readily available from at least two sour-
ces. First, Pilgrim's owners could
"mine" electricity that is currently
wasted by inefficient lighting, applian-
ces, and other electrical equipment. A
report to Edison's Board of Directors
indicated the potential to reduce the
utility's electric demand by 1,000
megawatts (Mw), at an average cost of
less than two cents per kilowatt hour
saved. Second, Pilgrim's owners could
purcha.se electricity from small power
producers and cogenerators. Indepen-
dent power producers have bid to supp-
286
ly Boston Edison with 1,848 Mw by 19*^2.
Pilgrim capacity is 670 Mw.
While some of the independent
facilities have environmental problems,
the combined potential of the efficiency
improvements and independent power
producers could replace Pilgrim and meet
Edison's projected demand growth with
over 1,000 Mw to spare. In order to over-
estimate the cost of replacing Pilgrim, it is
assumed that all the efficieno,' savings go
to displace demand growth, with the cost
of power to replace Pilgrim based on a
range of bids from cogeneration and
small power facilities.
The table and figure below summarize
the savings to ratepayers from retiring
Pilgrim under various assumptions. The
"Pilgrim Optimistic Case" (most favorable
to Pilgrim) combines the lowest
PILGRIM OPERATION VS. RETIREMENT
Present Value (Billjon_1937j)_
reasonanie level of Piigriin costs wnii
the highest le^ei of replacenient powe^
costs. The "National Treno Case" as-
sumes that the rate of escalating costs
at pilgrim improves to the level o*" the
average nuclear plant with Pilgrim's
characteristics (age, type, location,
etc. i. anu a moderate ieve! of replace
ment power costs. Tne "Pilgrim f hston-
cal Trend Case" assumes that Pilgrim
cosl.^ coniiaue to escala'e at theii his-
toric rat 3S, and assuines the lowest
level of replacen.ent powei costs.
All cases show savinf.? to ratepayers
from retiring Pilgrim. M.^ SSPIRG
therefore recommends that the Pilgrim
njan' b' ^erf^''.r°'-*'^' c'osed. The
Department of Public Utilities shou'.d
allow no recovery of any f- ture utility
investment 'u\ the plant.
^1
Repl. Power
fptiffiistftr-
S'^utdcwn
Sunk
SAVINGS TO RATEPA^'ERS FROM RETirJNG F O.GRIM
pilgrim Historical
Trend Case
National
Trend Case
Pilgrim Optimistic
Case
BECO
Ratepayei- Pa%
SunkCt'ts
$1.56bUriOn
$813 million
$49 million
-$()lt millii'f
I « ?stors Pay ;
Sunk Costs j
$2.28 biUiou
Sl.54 billion
$773 jiiillior!
$168 miiiiori
287
1. Introduction - Nuclear Costs and Cancellations
The Pilgrim nuclear power plant, in
Plymouth, Massachusetts, is the focus of
intense controversy over health and safety
issues. (See, for example, No Exit: The
MASSPIRG Sun'ey of Pilgrim Evacuation
Planning, September 1987.) Relatively lit-
tle attention, however, has been paid to
the increasing cost of operating the
Pilgrim plant.
When Pilgrim was first turned on in
late 1972, it appeared to be a relatively in-
expensive source of electric power. Built
for $232 million, Pilgrim's construction
cost about three tirnes as much per
idlowatt of capacity as an oil- fired plant.
But uranium fuel was so much cheaper
than oil, especially after the oil embargo
of 1973, that the total cost of owning and
operating the nuclear plant was less.
It is worth noting that some nuclear
costs — such as for research and develop-
ment, fuel processing and insurance —
were heavily subsidized by federal tax dol-
lars. The Price-Anderson Act, passed by
the U.S. Congress in 1957, limited in-
dustry liability for nuclear accidents,
thereby relieving it of having to consider
fully the economic risks of nuclear genera-
tion. Other costs ~ fo'' disposing of
nuclear wastes and dismantling the plant
at the end of its operating hfe (decom-
missioning) -- could not be reliably es-
timated then or now, since the required
technologies still have not been
demonstrated."
During the 1970s, the co.st of build-
ing new nuclear plants escalated
dramatically. Nuclear construction
costs increased by over twice the infla-
tion rate, and nearly twice as fast as the
f" St cf bi i! Jin;^ coi.i-fircd pLnts.
Major causes of the increases included
technical problems that were identified
as nuclear plants gained operating ex-
perience, new safety regulations im-
posed by the Nuclear Regulatory
Commission (NRC), and management
failures to anticipate and respond ade-
quately to these pressures.
As a result of increasing nuclear con-
struction costs, and a drop in electricity
demand growth, many orders for
nuclear plants were canceled in the
1970s and 1980s. Over 110 nuclear
plants - almost half of the total num-
ber that utilities had ordered - were
canceled in various stages of construc-
tion, including a second unit planned
for the Pilgrim site."
'Power plant capacity is measured in watts. A kilowatt (Kw) is equal to 1,000 watts, enough power to light
ten 100-watt light bulbs. A megawatt (Mw) equals one million watts or 1,000 kilowatts. An amount of
electricity generated over a period of time is measured in kilowatt hours. A one megawatt plant operating
at full capacity for 1 hour would produce 1,000 kilowatt hours (Kwh) of electricity. Pilgrim's capacity is
670 MW, of which Boston Edisoa owns 74.27 p^rceat. OthLi owi.crs arc. Commonwealth Electric - 11
percent. Eastern Utilities - 10.5 percent, Massachusetts Municipal Wholesale Electric - 3.73 percent,
and Newport Electric - .5 percent. For simplicity, Pilgrim v-ill be treated in this report as it it were entire-
ly owned by Boston Edison.
288
The same factors that caused construc-
tion costs to skyrocket for new nuclear
plants have also increased the costs of
older plants. Large expenses have been re-
quired for replacement equipment and
safety improvements, called "capital addi-
tions," and for major repairs. In addition
to work needed to bring older plants up
to new safety standards, many nuclear
parts and systems have worn out sooner
than expected. ^ For the U.S. nuclear in-
dustry as a whole, capital additions in-
creased by an average of 13 percent a
year, after adjusting for inflation, between
1970 and 1986. Operation and main-
tenance costs increased by an average of
over 11 percent a year, after inflation,
during the same period. In addition, the
majority of nuclear plants failed to per-
form as reliably as their owners expected,
experiencing many more shutdov.'ns than
other types of power plants.
As a result of these increasing capital
and operating costs, some utilities have
begun to take a hard look at the cost of
continuing to operate nuclear plants. In
March, 1986, the Washington Public
Power Supply System (WPPSS) tem-
porarily closed its two-year-old operating
reactor because it was more expensive to
operate than oil or gas-fired plants. In
May, 1987, the Dairyland Power Coopera-
tive, in Wisconsin, permanently shut
down its 18-year-old LaCrosse nuclear
plant because it was no longer competi-
tive with alternatives.
The Pilgrim nuclear plant has been
subject to the same cost trends as other
nuclear plants. In fact, between 1980 and
1985, Pilgrim had the second most expen-
sive capital additions per kilowatt of any
nuclear U.S. power plant, .ind has be-
come one of the most expensive nuclear
plants in the country.^'' By the end of
1987, Boston Edison (BECO) will have
sunk S614 million into Pilgrim above its
$232 million original cost, bringing the
total investment in the plant to $846
million (Figure 1). Even after adjusting
for inflation, Boston Edison has spent
40 percent more for replacement and
new parts for Pilgrim than it initially
spent building the plant.
Largely as a result of these capital
additions, Boston Edison's own es-
timates show that in 1988, electricity
Figure 1
PILGRIM CAPITAL COST
QQQ M[llion^^Nomina[)
Year
from Pilgrim will cost 6.53 cents per
Kwh, almost twice as much as power
from oil-fired plants, at a cost of 3.34
cents per Kwh (Figure 2).
BECO also recognizes that con-
tinued Pilgrim operation will require
ongoing capital additions. Edison es-
timates that keeping Pilgrim running
will require another $1.4 billion invest-
ment in capital additions over the 25
years it estimates for Pilgrim's remain-
ing life. Pilgrim's total capital cost
would then equal over $2.25 billion dol-
lars - almost ten times the initial con-
struction cost of the plant (Figure 3).
Moreover, independent estimates dis-
cussed in the following chapters of this
289
0.07
Figure 2
ELECTRICITY GENERATION COST -- 1988
SperKWh
report indicate that capital additions and
other costs are actually likely to exceed
BECO estimates. These escalating costs
require serious consideration of whether
continued investment in and operation of
Pilgrim is economical.
In April, 1986, the Pilgrim plant ex-
perienced two "unexplainable automatic
shutdowns," or "scrams." The NRC or-
dered the plant to remain closed until
serious problems with Pilgrim and its
management are resolved. During this
time, Boston Edison has chosen to
make major upgrades in the Pilgrim
plant ~ budgeting over $150 million in
capital additions and nearly $100 mil-
lion in maintenance costs in 1987 - to
return the Pilgrim plant to service. This
study looks at whether it makes more
economic sense to retire Pilgrim than
to continue investing hundreds of mil-
lions of dollars in it. Chapter 2 looks at
Boston Edison's projections of Pilgrim
costs, compares BECO assumptions
about nuclear cost trends to the histori-
cal trends at Pilgrim and other nuclear
plants around the country, and
develops more realistic estimates of fu-
*ure Pilgrim costs. Chapter 3 examines
the cost of retiring the Pilgrim plant
and replacing it with alternatives cur-
rently available to Boston Edison.
Chapter 4 summarizes the report's
overall findings and presents
MASSPIRG's recommendations.
2.4
2.2
2
1.8 _
1.6 _
1.4
1.2
1
0.8
0.6 4
0.4
0.2 i-S-B-&<5'-»-^'^
Figure 3
PILGRIM CAPITAL COST PROJECTION
BECO Assumptions - Billion $ (Nominal)
cr--
^'
.Ji
ja^
i»72 iy//
" ^ra82 TgST- ■ 1i»2^
Year
Pilgrim Historical
Tggy 2002 2007—201 2
_ BECO Projection
290
2. The High Cost of Operating Pilgrim
A. Boston Edison projections
In May, 1987, Boston Edison
developed projections of Pilgrim's future
costs in response to a request by the Mas-
sachusetts Executive Office of Energy
Resources (EOER). Edison's projections
were also sent to the Office of the Attor-
ney General, the Department of Public
Utilities, and upon request, to
MASSPIRG.
BECO projects that the cost of
electricity from the Pilgrim plant will in-
Flgure 4
PILGRIM COST COMPONENTS
crease from 6.53 cents per kilowatt
hour (Kwh) in 1988 to 16.76 cents per
Kwli in 2012 (Figure 4), primarily as
the result of inflation. Another way of
looking at the cost of Pilgrim is to add
up the total bill to ratepayers for the
plant's costs over the remainder of its
expected life. The "present value" of
BECO's estimate of future Pilgrim
costs (discounting future dollars at the
10.55 nercenf annual rate Edison uses
to account for the declining value of
money over time) is $3.3 billion in 1987
dollars.
BECO Assumptions ~ $ per Kwh
(See next page for explanation.)
291
HOW Pttgrim Costs Are Calculated !
The grsph on the opposite p^e sbov/s how much Boston Edisoa expects to charge its cuslomeis each
year for ctectridty from Rlgripi, based on the standard ruks of utility regulation. Electric companies ■
wrc allowed to recover most operating and fuel expenses directly in rates as they are incurred each
year. Utility investment in ms^or plant and equiproeni is recovered over the operating life of the plant ;
tiiroi^ depredation charges. Utilities arc aUo allowed to charge customers for their financing costs, •
bdttdEiiig a profit on their iitvesimetH.
Tttebottamsectiooof each bar isi the graph shows the financing charges, or {sbim, that BECO ex-
pects to earn on. its PUgrnB investiaBiit. The return consists of interest payments on debt borrowed to
finaBce ^I^ib, and the profits BECO expects regulators to allow it to earn on its iDvestnrent in the
plant Ute neM area up represents d6prf^:iatif)n of BECX)'s Pllgrtm investment. The third area from
thoboUotttdcpicts nperation and nminhMiance (0&M> charges, which include labor and direct
i^perptia^ ei^nscs. Above O&M are the costs for nuclear £ueI, inchiding current estimates of waste
(Ssposal wste- The next area of the graph shows how much money is collected to pay for dscijinnui: .
jjflniag the plant at the end of its operating life. The top area indicates mwcftllanenns expenses, such
as lnsow»c<^ and local property taxes, ,
BECO expects to cam a 14:4 perceai rate orreitun on its PHgrirt mvestmeni. About 38 percent of
tbat ammmf is paid to th« federal government for income taxes. Every billion dollars invested in
Pflgtimtfaus translates into ^44 million in charges per year in rates. Each year, 1/40 of the investment
in l4]gtkD.is^ charged to ratepayers for depreciation, and that amount is subtracted trom the next
year's 'rate base,* an account In the ntifity's books representing the amount of investment on which
the nlility can earn a return. . The current fise for waste disposal assessed by the Etepartment of Ener-
gy is one-tenth of a cent per KWh. Decommissiomng cost charges are calcnlatsd to accumulate the
$325 nuBiOR (in 1^6 doQar^ Edison estimates will be necessary to dismantle the nudear plant b the
year 2^112. Property taxes average abont 1.8 percent of the %'Blue of the plant in rate base. Insuraitce
costs incTBWc over time from $5-15 miUion a year.
The cost per kilowan houi is i^dcidated by dividing the total annual cost by the number of Kwh
generated per year. KWh j>er )%» t« afunction of capacity factor (see Chapter 3, Section B) multi-
pMed by37£Q hoars per year tiates the 670,000 kilowau sixc of the plant, Edison assumes a 70 percent j
capacity factor fot future Klgpm operation. i
But based on historic iiucl^r cost
trends, Edison is greatly underestimating
Pilgrim costs. Projecting the total cost of
electricity from a power plant involves
making nimierous assumptions about
various cost components, as well as the
overall operating performance of the
plant. Three assumptions irt particular
dominate the final results: the rate of capi-
tal additions, oi>eration and maintenance
(O&M) expenses, and the amount of time
the plant can be expected to operate
(capacity factor).
B. MASSPIRG projections
MASSPIRG has compared Edison
assumptions in each of these areas to
actual performance and cost trends at
Pilgrim and other nuclear plants
around the country. The sf>ecific results
of these comparisons are presented in
Appendix B. In general, Edison projec-
tions assume that the past performance
of Pilgrim and other nuclear plants
provide no guide to future costs Consi.'?-
tent historical trends - both at Pilgrim
and at nuclear plants around the
292
country — are assumed to immediately
stop.
O&M costs, which have increased na-
tionally by 1 1.4 per year, after adjusting
for inflation, and by 13.8 percent annually
at Pilgrim, are projected to increase at
only 0.5 percent per year henceforth.
Capital additions, which have escalated
nationally at 13 percent per year after in-
flation, and much faster at Pilgrim, are
also forecast by Edison to increase by 0.5
percent per year in the future. Despite
the fact that Pilgrim has had a lifetime
capacity factor of only 50 percent, and the
national average for nuclear plants is 60
percent, Edison predicts that Pilgrim will
average a 70 percent capacity factor in the
future.
Nuclear utilities around the country
have been making similar assumptions for
many years. Each year, the utilities
project that nuclear costs will freeze at
then-current levels. Instead, real costs
have continued to rise. The basic forces
that have run up nuclear costs in the past
will continue to increase costs in the fu-
ture. These factors include technical
problems discovered as nuclear plants
gain more operating experience, un-
resolved generic nuclear safety issues,
the aging of reactor parts, and the
potential for both small and large
nuclear accidents to create new
regulatory requirements. (See Appen-
dix C for additional discussion.)
It is therefore important to examine
more realistic assumptions for nuclear
costs. MASSPIRG looks at three alter-
native assumptions for each major
nuclear cost component. In a "Pilgrim
Historical Case," future costs are as-
sumed to continue to escalate in line
with historical trends for the Pilgrim
plant. In a "National Trend Case,"
Pilgrim cost trends are predicted to im-
orove to match those of the average
plant having Pilgrim's characteristics.
For a "Pilgrim Optimistic Case," it is as-
sumed that future Pilgrim co.sts will im-
prove to a level substantially better
than would be expected based on either
Pilgrim or national trends.
The detailed basis of MASSPIRG's
alternative projections are presented in
Appendix B. Figures 5 and 6 Olustrate
the effect of the revised assumptions on
the aimual cost per Kwh and on the
total present value of Pilgrim costs to
Figure 5
PILGRIM ANNUAL GENERATION COSTS
Alternative Scenario Analysis
BECO
Opt ^ Nat^frend
-2008—-
Pila Trend
293
Figure 6
RANGE OF PfLGRIM TOTAL COSTS
Present Value (Billion 1987 $)
0-^il^^
Trench
?<fl
k53
— -Natiofrat Trer
ratepayers, respectively.
All three MASSPIRG cases share a
number of extremely conservative assump-
tions. In general, nuclear costs are as-
sumed to be increasing according to
linear trends (i.e.. a constant number of
dollars per year, after adjusting for infla-
tion) rather than according to exponential
trends (i.e., a constant percentage in-
crease per year, after inflation). The trend
of increasing capital additions is still as-
sumed to level off in a few years, despite
evidence that it may actually be accelerat-
ing. Plant performance is not assumed to
deteriorate with age, despite evidence of
declining capacity factors, particularly at
salt-water-cooled plants like Pilgrim.
For simplicity, and to be as favorable
to Pilgrim as possible, this report also
adopts a number of other Edison assump-
tions which are biased in favor of Pilgrim.
The Pilgrim plant is assumed to be
operable until the year 2012 -- a total of
40 years from when it entered service.
The oldest commercial nuclear plant has
^1
^Opttmtsticr-
Pilgrim
operated for only 26 years, and 14 reac-
tors have been retired atter less than 20
years of operation. Pilgrim's operating
license currently expires in the year
2008. and would have to be extended
by the NRC in order for the plant to
operate until 2012.
Real nuclear fuel costs are assumed to
remain stable, even though ap-
proximately half of the uranium used in
domestic nuclear plants is imported,
much of it from politically unstable
countries such as South Africa.^^
BECO's estimates for nuclear waste dis-
posal and for dismantling the radioac-
tive plant are used, despite the fact that
the necessary technologies have not yet
been demonstrated and there is there-
fore enormous uncertainty around es-
timating these costs. And it is assumed
that no serious nuclear accidents occur
at Pilgrim or at any other U.S. nuclear
plant. The conservative nature of these
assumptions is discussed in more detail
in Appendix C.
294
3. Economic Benefits of Retiring Pilgrim
There are three categories of potential
costs to ratepayers for retiring Pilgrim at
this time. First, there is the cost of re-
placement power. Second, there are costs
to shut the plant down and decommission
it, which must be paid whether the plant
is retired now or later. Third, there is the
potential cost of paying for past invest-
ment in the plant. Each cost will be con-
sidered separately.
A. Replacement power
The main cost of retiring Pilgrim would
be to replace the electricity produced by
the nuclear plant. As demonstrated in the
recent New England Energy Policy Coun-
cil study. Power to Spare, the least expen-
sive means of obtaining new power
supplies is to "mine" the electricity that is
now wasted by inefficient lighting, ap-
pliances, and other electrical equipment
in our offices, factories and homes.
Utilities around the United States have
found that they can flnance efficiency im-
provements for their customers at an
average cost of less than two cents per
Kwh. That is less expensive than opera-
tion and maintenance costs alone at
Pilgrim. A report to Boston Edison's
Board of Directors in March, 1987, found
that cost-effective efficiency improve-
ments could reduce electric demand in
Boston Edison's service territory by as
much as 1,000 Mw over the next 15
14
years.
Another readily available source of
replacement power for Pilgrim would
be the purchase, of electricity from new
plants built and owned by independent
small power producers, generally
referred to as "Qualifying Facilities" or
"QFs." Since the pas'.age of the federal
Public Utility Regulator)' Policies Act
(PURPA) of 1978, which required
utilities to purchase power from inde-
pendent producers at fair prices, there
has been a rapid increase in the
development of such facilities
throughout the country.
In January, 1987, in response to
rules enacted by the Massachusetts
Department of Public Utilities, Boston
Edison sent a Request for Proposals to
potential developers to supply 200
megawatts (Mw) of Edison's power
needs by 1992. The utility's projection
of future oil costs was set as the ceiling
price for acceptable offers. In June
Edison received bids from 61 projects,
representing a total of 1848 Mw. The
number of proposals received was well
above the utility's expectations. In fact,
in its April 1987 forecast, the New
England Power Pool h?d projected that
only 1391 Mw of independent power
would be avaibble for the ertire region
by the year 2002.
The majority of the proposals were
for co3;r.';:ali:.; TacUtics - v.liioh
produce useful heat and electricity in
the same process - and other small
power facilities using a variety of fuels
295
Figure 7
BECO-8 RFP«1: TOTAI, MT^ BID BY FUEL TlTS
iB»-.»2 u* -soy 61 ^to^tcrz
Oth«r (1 S.eX)^/-''^
^^ Natural
/
|^:'^-vvv' ;^ Ga« (31.'?;)
Wood * Peat (3.4J!) ^S;>-^,^ ■
^^^^^^^^^^
■i^:.-^', .>^'%i.^
^^^^^^^5=
=^:i;i- ;.^^•-^v>3
R«tuae (10. BX) i&r^^^^
T^-^^f
"^ir iH.iii;;'"'
-: ^- Wnd (O.St)
/'
X;'!^'''
,,:,. • v/
Coal (35.3X)
(Figure 7). Over 240 Mw would be
produced using renewable energy sour-
ces, such as biomass, wind or hydropower.
Some of the projects, particularly the
200 Mw of plants which would bum
refuse as fuel, may present emaronmental
problems. MASSPIRG does not neces-
sarily endorse all of the proposed QFs.
However, the combination of energy ef-
ficiency improvements and the large num-
ber of small power and cogeneration
projects provides a more than adequate
pool of potential replacement power for
Pilgrim. The combined potential of ener-
gy efficiency improvements and inde-
pendent power projects exceeds Edison's
share of the Pilgrim plant and its
forecast of power needed to meet in-
creased demand through the year 2012
by over 1,100 Mw.^^
Nine QF projects, representing 350
Mw, were selected by Edison as an ini-
tial "Award Group" for final contract
negotiation. The average Award Group
bid was sig:niricantly below the price of
Pilgrim-generated electricity, even
using all of Boston Edison's Pilgrim
cost assumptions (Figure 8).
If Pilgrim were lo be replaced, there
v'ould be a second round of bidding. It
is quite likely that many bids would be
lowered given the large, and previously
unknown, surplus of potential supply
o^er ^oiouii's demand. In the first
round, potential developers were bid-
ding primarily against BECO's extreme-
ly high projection of oil price increases.
The utility forecasts oil prices to in-
crease at an average rate of over ten
percent a year, approximately five per-
cent above the assumed inflation rate
between now and the year 2012. Oil
prices would increase from their cur-
rent $20 per barrel to $166 per barrel
in 2012, or to over $53 a barrel in 1987
dollars adjusted for inflation.
Figure 8
PILGRIIVI VS. QF ANNUAL GENERATION COSTS
BECO Projection - $ per Kwti
18^
8:8?
0.00
2123
Pilgrim
Year
Award Group
296
To be as favorable to Pilgrim as pos-
sible, however, the Award Group bids are
assumed by MASSPIRG to represent the
low end of a range of replacement power
costs. Efficiency savings are assumed to
be used entirely to displace demand
growth rather than to replace Pilgrim.
The average bid of the next block of 740
Mw is used as a middle estimate of
Pilgrim replacement costs. And the
average bid of all the non- Award Group
projects is adopted as a high estimate of
replacement power costs.
Using BECO's assumption of a 70 per-
cent capacity factor for Pilgrim, the total
present value of replacement power
needed would range from $2.5 billion,
based on the Award Group, to $2.9 bil-
lion, based on the average non-Award
Group bid, through the year 2012 (Figure
9). If one assumes lower Pilgrim capacitv'
factors, replacement power would cost
even less.
All the proposed QFs have projected
in-service dates before 1992, with 400 Mw
expected to be available by the end of
1990. For this study, it is assumed that all
QFs begin operation in 1992. Until that
time, replacement power costs are as-
sumed to equal energy costs from reserve
oil-fired plants, plus an additional charge
by the New England Power Pool for
providing reserve capacity. The 1987 New
England Power Pool forecast shows a
more than adequate reserve margin of
generating capacity through 1992 ~ even
if the Pilgrim, Seabrook, and Maine
Yankee plants are not in service.
Reliance on non-utility power plants
poses certain obvious risks to a utility,
since it will not control the construction
or operation of the QF plants. These risks
must be weighed against risks associated
with Pilgrim, however. Pilgrim could be
closed by federal regulators because of an
accident at another nuclear plant, as
well as by incidents at the plant iiself.
The diversity of the QF projects makes
it more likely that a given amount of
power vn\] be available at all times
The QF contracts also provide in-
sulation from important financial risks,
since they are based on payment per
Kwh produced. Their private owners
thus assume the risks of cost overruns,
poor plant performance and
profitability. Most of the Award Group
contracts are tied to the Consumer
Price Index, thereby requiring utility
customers to bear only ihe risk of unan-
Figure 9
PILGRIM VS RhPU\oEMENT POWER COSTS
BECO Assumptions - Billion $
Pilgrim
gj, Replacement power
ticipated general inflation. With
Pilgrim, however, ratepayers are ex-
pected to bear the risk of all cost in-
creases, including inflation, as well as
the risk that the plant does not perform
as reliably as expected.
B. Other shutdown costs
A decision to retire Pilgrim at this
time would involve some costs in addi-
tion to replacement power. Decommis-
sioning costs, for instance, would stil!
have to be incurred whenever Pilgrim
10
297
is retired. Actually, since the cost of
decommissioning is likely to increase as
the plant becomes more radioactive, it
would almost certainly be cheaper to
decommission it earlier. To be conserva-
tive, however, these potential savings are
not considered here. Costs that would
clearly have to be incurred to shut Pilgrim
down must be added to the cost of re-
placement pwjwer (or subtracted from the
cost of Pilgrim) to evaluate the economics
of early retirement of the plant.
In addition to direct decommissioning
costs of $126 million in 1987 dollars,
BECO estimates that closing Pilgrim will
require additional operation and main-
tenance costs over a five year decommis-
sioning period. The total decommis-
sioning and shutdown costs add $206 mil-
lion, in addition to the cost of replace-
ment power, to the present value cost of
retiring Pilgrim. Edison fails to include
these costs in its analysis of continuing to
operate Pilgrim, however, presumably be-
cause the costs would be iacurred after
the year 2012 - the last year BECO looks
at In the MASSPIRG scenarios, the
present value of the post-operation costs
are included in both early and late retire-
ment scenarios.
C. Sunk costs.
Another potential cost to retiring
Pilgrim is repayment of the money that
Edison has invested in the plant to date ~
generally referred to as "sunk costs."
POgrim sunk costs will total $846 million
by the end of 1987. In its analyses of the
cost of retiring Pilgrim, BECO effectively
assumes that ratepayers would pay for
the utility's entire investment in Pilgrim,
along with the same rate of profit it
would earn if the plant were operated
(Figure 10).
Figure 10
PILGRIM OPERATION VS RETIREMENT
4 BECO Assumptions - Billion $
23 Pll ^ Rep.Pwr K2I Shutdwn ^ Sunk
In addition to its investment in the
plant itself, Edison also includes a $50
million investment in an inventory of
nuclear fuel and $20 million in
materials and supplies in Pilgrim sunk
costs. After the Pilgrim 2 unit was can-
celed, however, BECO was able to
recover 64 percent of its investment in
nuclear fuel by selling it to other
utilities.** In the MASSPIRG
scenarios, therefore, it is also assumed
that BECO will recover 64 percent of
its current investment in fuel, materials
and supplies through sales to other
utilities.
If Pilgrim were retired, it would ac-
tually be up to the Department of
Public Utihties (DPU) to determine
who should pay for Pilgrim sunk costs.
Under a policy adopted in a Western
Massachusetts Electric Company case
in 1984, the DPU ruled that sunk cost
recovery would no longer be allowed
for investments that were not "used and
useful" to utility customers, such as
plants that were canceled while still
under construction. In a 1985
decision on excess capacity, the Depart-
ment modified its policy to allow
utilities to recover uneconomic invest-
ments over time, but without charging
11
298
20
ratepayers for financing charges. This
policy, which is followed by most state
utility commissions, results in a sharing of
sunk costs between utility ratepayers and
investors. Stockholders are also able to
share their losses with the federal govern-
ment, which allows generous tax deduc-
21
tions for investment losses.
D. Alternative scenarios show
savings from retiring Pilgrim.
Three scenarios were constructed to
cover the widest reasonable range of as-
sumptions for the costs of operating or
retiring Pilgrim. The Pilgrim Optimistic
Case combines all the assumptions
Table 1. ALTERNATIVE ASSUMPTIONS USED IN MASSPIRG PILGRIM J
PROJECTIONS
'Capacity Capital O&M Replacement
Factor Additions Expenses Power
Pil^m
Tfistorical
Trend Case
Pil^im
Historical
50%
Pilgriin
Histoi ical
to years
Pilgrim
Historical
Averge of
Aw'ard Group
QFs
Natiohaf
Ttend
Case
National
Trend
Pilgrim to 4/86
56%
National
Trend
5 years
liaiiuqal
Treiid
Average of
Next 740 MW
QFs
Pilgrim
Optimistic
C«se
National avg.
aUBWRs
63.2%
Pilgrim
Low Historical
5 years
2% Real
Escalation
Average of
all 1327 KfW
Unsigned QFs ;
Boston
Edison
70%
05% Real
Escalation
0.5% Real
Escalation
Awrage of
all 132? MW
Unsigied QFs j
Table 2. ADDITIONAL CONSERVATISMS IN ALL SCENARIOS
Jtudear^vastc
disposal: No increases from current BECO assumptions
^utdown: :;; No savings from early decommissioning
(Opacity factor No declining effect from salt-water cooling
Capital Additions: No increases after 5- 10 years
BECO-assnmed decreases in last five years of operation
No repeat of 1984 and 1987 major repairs
O&Mand
Capital AddUions: Linear rather than exponential trend increases
Miscellaneous: "W-year lifetime
No increases in nucleai insurancf
No serious acc'dents
No societal costs
No nuclear subsidies included in Plgrim costs
12
299
Figure 11
PILGRIM OPERATION VS RETIREMENT
Present Value (Billion 1987 $)
^
h^
m
^^^,^ Repl.Power
most favorable to Pilgrim — the most op-
timistic projections of Pilgrim costs, and
the highest price for replacement power,
equal to the average bids of all non-
Award Group QFs. The National Trend
Case assumes that Pilgrim costs improve
to the level predicted by the national
trend for a plant with Pilgrim's charac-
teristics. A middle estimate of replace-
ment power is used, equal to the price of
the least expensive 740 Mw of QF bids
after the Award Group. The Pilgrim His-
torical Case assumes that all Pilgrim cost
components follow the same trends they
have in the past, and that replacement
power could be obtained for the price of
the Award Group bids from QFs. Table 1
Shutdown
Sunk
summarizes the assumptions employed
in each scenario. Table 2 hsu. the addi-
tional assumptions favorable to Pilgrim
that were made in all MASSPIRG
scenarios.
The alternative scenarios indicate
that the present value of savings to
ratepayers from retiring the plant
would range from $46 million to $1.6
billion over 25 years, even if ratepayers
were to pay for all sunk costs (Table 3;
Figure 11). The $1.6 billion savings is
approximately equal to $540 for the
average Edison residential customer. If
investors were to pay sunk costs, the
savings from retiring Pilgrim would in-
crease to a range of $769 million to
SAVINGS TO RATEPAVEJK FROM RETIRING PILGRIM
Ratepayers Pay
Sonk Costs
Investors Piay
Sunk C^ts
Pilgrim Historical
"trend Case
S1.56 bUIion
$2.28 billion
Nsttlortal
TmtdCase
$813 million
$1.54 billion
Pi^m Qptinistic
Case
S49 million
$773 million
BECO •
AjHHUBptiotU
-$611 million
$168niillJon
13
300
$2.3 billion. Detailed annual costs for all
scenarios are presented in Appendix A.
Figure 12 illustrates how the present
value of the cumulative savings from retir-
ing Pilgrim changes over time in each
scenario, assuming that ratepayers pay for
the full sunk costs, including a profit on
Pilgrim investment to date. The cumula-
tive savings at any point in time is equal
to the difference between total Pilgrim
costs and the total costs of replacement
power, shutdown and sunk costs to that
time.
Graphs of cumulative savings are espe-
cially useful for looking at the effect of
changing only one assumption at a time
on the benefits of retiring Pilgrim. Figure
Figure 12
CUMULATIVE SAVINGS FROM
Present Value (Billion
13 illustrates the effect of changing
only the assumption about how
regulators might deal with Pilgrim sunk
costs if the plant were retired. The mid-
dle line represents the usual regulatory
practice for plants canceled under con-
struction, where ratepayers would
repay all sunk costs over time but with
the utility earning no profit on its sunk
investment. In this case, it is assumed
that Pilgrim sunk costs would be
charged to ratepayers over the same 25
year period as they would have been if
the plant had operated. Under tradi-
tional regulatory practice, ratepayers
would save money, at least through the
year 2008, by retiring Pilgrim, even if
all BECO assumptions about the
plant's future costs hold.
RETIRING PILG.
1987$)
rfS^rend
Pilg.Trend
Figure 13
CUMULATIVE SAVINGS FROM RETIRING PILG
BECO Assumptions Except Sunk Costs
InvestorB pay
Customers pay
14
301
4. Conclusions and Recommendations
Retiring Pilgrim would clearly save
utility customers money, under a wide
range of reasonable assumptions, even if
ratepayers have to pay a full return on the
sunk costs of the plant. The Pilgrim
nuclear plant should therefore be im-
mediately and permanently retired.
While no state official or agency has
the direct authority to order the shutdown
or retirement of a nuclear plant, the Mas-
sachusetts Department of Public Utilities
(DPU) is responsible for determining
what, if any, utility investments and expen-
ses can be charged to ratepayers, under a
broad statutory mandate to ensure just
and reasonable electric rates. If it were to
determine that ongoing investment in
Pilgrim were imeconomical, the DPU
could prohibit its owners from financing
or charging ratepayers for future invest-
ment in the plant.
MASSPIRG therefore recommends
that the DPU disallow recovery of any ad-
ditional Pilgrim investment, including the
$150 million in capital additions Boston
Edison has budgeted to spend in 1987. A
second round of bidding from potential
power suppliers should be initiated, with
reasonable assumptions about Pilgrim
costs used to set a target for acceptable
bids. Energy efficiency contractors,
who could seU energy savings to the
utility, should also be encouraged to
compete with QFs in bidding to replace
Pilgrim.
A similar process for dealing with
new power plant construction has
recently been proposed to the DPU by
the state Executive Office of Energy
Resources. Decisions to continue in-
vesting in plants that have already been
in operation are no different from
decisions to start new construction, or
to complete partially built plants. In
each case, the ongoing investment must
be weighed against potential alterna-
tives. New utility investment in power
plants should be allowed only if it
would be "used and useful" ~ necessary
to provide rehable electric service and
the most economical alternative. To
the extent that the Pilgrim plant cannot
meet that test — and this report finds
that it carmot ~ the plant should be per-
manently retired.
15
302
APPENDIX A
ANNUAL COSTS OF PILGRIM VS. ALTERNATIVES
BECO ASSUMPTIONS
Year
:ap-
IqUI
Snn.
OccvK- Net
[)e-
Na- 1
■uel
Avg.
Re-
In-
De-
n-
.0-
Oe- Fuel
K<I1
- PILSRW TOTAL
— ;•
.- IFs -;
tal
Plant
De-
ilated Plant
(er-
ter-
Rate
turn co«e
3re- sur- cal
■.m
AnnualCost
n-
^ost
Cost
ftd-
Year
pre-
Depre-
fear- red
lals
Base
on
rax
cia-
)nce
rax
•is-
Costs
in
cre-
m
in
Vinuo
di-
End
cia-
cia-
:nd
Tax
Rate
tion
sion-
[:ents
■en-
Cents
Cents
lOi'.
ions
tion
tion
Base
inj
aer
tal
per
per
(
in 11
Uions
o-f dollars )
kHh
(iBil.)knh
KlUh
m.l.
ira?
150
846
24
176
670
-104
20
51
542
56
27
24
5
11
4
1
97
227
5.5
1
0.0
3.3
.3«
1988
40
886
28
204
682
-113
21
51
421
44
30
2B
5
11
5
27
99
268
6.5
92
2.2
3.5
14;
IW
40
926
29
233
693
-122
22
50
623
44
30
29
5
11
5
24
107
276
6.7
126
3.1
3.4
Ni
IW
70
996
32
265
731
-130
23
50
440
66
31
32
5
12
5
24
120
294
7.2
152
3.7
3.7
152
1991
40
1036
34
299
737
-138
24
50
454
6B
32
34
6
12
5
24
125
305
7.4
169
4.1
4.2
174
1992
42
1078
36
335
743
-143
24
50
655
48
32
36
4
12
6
24
131
314
7.4
135
4.5
5.7
232
1997
44
1122
38
373
749
-147
27
54
661
48
32
36
4
12
4
24
138
326
7.9
202
4.9
4.1
251
1994
46
1168
41
414
754
-146
28
56
670
49
33
41
6
12
7
27
145
339
6.3
24','
5.8
4.6
272
1995
49
1217
43
457
760
-143
30
60
683
71
33
43
7
12
7
29
152
353
8.4
258
6.3
7.2
29»
1996
51
1268
46
503
765
-139
31
66
697
72
34
44
7
13
7
31
140
370
9.0
278
6.8
7.8
32'J
1997
54
1322
49
553
769
-136
33
67
706
73
35
49
7
12
8
32
148
384
9.3
294
7.2
8.5
349
1998
5b
1J78
53
606
772
-133
34
75
721
74
35
53
6
12
8
34
174
403
9.8
316
7.7
9.2
378
1999
59
14J7
57
663
774
-129
36
75
726
75
36
57
8
12
9
34
185
41B
10.2
334
8.1
10.2
42':
2000
62
1499
62
725
774
-126
38
84
739
76
34
42
9
13
9
40
194
439
10.7
358
8.7
11.1
45'
2001
65
1564
67
792
772
-121
40
84
742
77
34
47
9
13
10
40
204
455
11.1
377
9.2
12.0
491
2002
68
1633
73
366
767
-115
42
92
752
78
37
73
9
12
11
44
214
478
11.6
402
9.8
13.2
54
200J
72
1705
80
946
759
-105
44
94
755
78
37
80
10
12
11
45
225
498
12.1
425
10.3
13.9
573
2'M
75
1780
88
1035
746
-93
46
99
760
79
37
88
10
12
12
47
234
522
12.7
451
11.0
15.1
421
2005
79
1859
98
1133
727
-78
48
105
742
79
37
98
11
11
13
50
248
547
13.3
476
11.6
16.5
bV
2004
83
1942
110
1242
700
-60
51
111
741
79
37
110
11
11
14
53
240
575
14.0
508
12.4
17.8
729
2007
87
2030
124
1366
663
-37
53
118
754
78
37
124
12
11
15
54
273
605
14.7
540
13.2
16.6
765
2008
70
2100
140
1506
594
-9
43
125
718
74
35
140
13
9
14
59
287
633
15.4
570
13.9
19.9
819
20O9
56
2156
155
1661
494
26
34
94
619
64
30
155
13
8
17
43
301
652
15,9
591
14.4
21.2
970
2010
45
2200
172
1834
367
66
27
62
500
52
24
172
14
6
19
67
314
449
16.3
610
14.8
22.5
922
2011
36
2236
192
2026
210
MS
22
31
341
37
18
192
15
3
21
71
332
488
16.7
629
15.3
23.6
979
2012
29
2265
239
2265
0
0
17
0
3
0
0
239
15
0
11
75
348
488
16.8
645
15.7
25,3
1038
2013
139
20M
70
2015
70
201&
70
2017
70
2018
70
Total
Present
1
•
Value
3287
2302
2913
16
303
ANNUAL COSrS OF PILGRIM VS. ALTERNATIVES
OPTIMISTIC CASE
Ve.i-
>-
Total
Ann.
ftccuii- Net
De-
Ma-
■uel
Avj.
Re-
In-
De-
n-
.0-
De-
■uel
OW
- PILBRIN TOTAL
— >
: <- UFs -;-
tal
Plant De-
jiated Plant
fer-
ter-
Rate
turn co«e
ore- sur- cal
:m
flnnualCcret
In-
Cost
Cost
M-
Veap
pre-
Bepre-
If ear-
red
ials
Base
on
rax
ela-
uice
Tax
ms-
kists
in
cre-
in
1 in i^nus
ji-
End
cia-
::a-
End
Tax
Rate
tion
sion-
Cents
■en-
Cents
, Cents
as'.
lons
tion
tion
Base
ing
per
tal
per
per
(
in 11
Uions
0*
Jollars )
kwh
(■il.)
kNh
; kHh
B\\.
ive7
150
846
24
176
670
-104
20
51
562
58
27
24
5
U
4
1
97
226
6.1
B
0.2
1 3.3
3(
1988
45
891
28
204
687
-113
21
51
624
64
30
28
5
11
5
24
99
266
7.2
98
2.7
1 3.5
13i
1989
50
941
30
234
707
-122
22
50
633
65
31
3(1
5
11
5
21
107
275
7.4
134
3.6
; 3.6
13,
1990
70
1011
32
266
745
-130
23
50
653
67
32
32
5
12
5
21
120
295
7.°
160
4.3
• J. 7
i:t
1991
60
1071
35
301
770
-139
24
50
675
70
33
35
6
12
5
21
125
308
8.3
179
4.8
: 4.2
157
1992
66
1137
38
339
798
-145
26
50
695
n
34
38
6
13
6
21
131
321
8.6
199
5.4
; 5.7
2K
1995
69
1206
42
381
825
-150
27
54
722
75
35
42
6
13
6
23
138
338
9.1
220
5.9
; 6.1
2.
1994
73
1279
45
426
853
-150
28
56
751
78
37
45
6
14
7
24
145
355
9.6
263
7..1
. 6.6
2f>
1995
76
1356
49
476
880
-148
30
60
783
81
38
49
7
14
7
26
152
374
10.1
285
7.7
, 7.2
266
1996
80
1436
54
530
906
-147
31
66
816
84
40
54
7
15
7
28
161
396
10.7
7,'ii
B.«
: '.8
289
1997
84
1520
59
589
931
-145
33
67
843
87
41
59
7
15
8
29
172
418
li.3
334
9.'
; 8.5
:ii
1998
89
1609
65
654
954
-144
34
75
876
91
43
65
8
15
8
32
183
445
12.0
564
9.8
i 9.2
•Al
1999
93
1702
71
726
976
-142
36
75
899
93
44
71
8
15
9
32
195
468
12.6
390
10.5
1 10.2
^1 1
:»oo
98
1799
79
805
995
-139
38
84
929
94
45
79
9
16
9
36
206
498
13.4
422
11.4
: u.i
412
2001
102
1902
87
892
1010
-136
40
84
947
98
46
87
9
16
10
36
222
524
14.1
451
12.2
: 12.0
4*3
2002
108
2009
97
988
1021
-130
42
92
971
100
47
97
9
16
11
40
256
556
15.0
485
13.1
; 13.2
498
2003
113
2122
108
1096
1026
-120
44
94
987
102
48
108
10
16
11
40
251
586
15.8
517
14.0'
; 13.9
517
2004
119
2241
121
1217
1024
-108
46
99
1002
104
49
121
10
16
12
45
267
622
16.8
555
15.0
; 15.1
So.
2005
125
2366
136
1353
1013
-91
48
105
1013
105
50
136
11
15
13
45
284
659
17.8
593
16.0
■ 16.5
611
2004
131
2496
154
1507
990
-68
51
111
1018
105
50
154
11
15
14
48
503
700
18.9
657
17.2
1 17.8
6"
»07
137
2634
176
1683
951
-39
53
118
1014
105
50
176
12
14
15
51
522
745
20.1
685
18.4
1 18.0
6'71
2008
110
2744
201
1884
859
-2
43
125
970
100
47
201
13
13
16
54
543
786
21.2
726
19.6
1 19.9
'41
2009
88
2831
226
2110
721
44
34
94
849
88
42
226
13
11
17
57
365
818
22.1
760
20.5
; 21.2
786
2010
70
2902
252
2362
540
101
27
62
695
72
34
252
14
8
19
60
389
848
22.9
790
21.3
: 22.5
833
2011
56
2956
284
2646
312
171
22
31
506
53
25
284
15
5
21
64
414
879
23.7
822
22.2
: 25. s
89:
2012
45
3003
357
3003
0
263
17
0
257
27
13
557
15
0
U
68
440
930
25.1
886
23.9
; 25.3
93
2013
176
2014
88
2015
88
2016
88
2017
B8
20iB
88
lo^al
Present
ValLe
3408
2679
1
262^
17
304
ANNUAL COSTS OF PILGRIM VS. ALTERNATIVES
NATIONAL TREND CASE
Zif- Total tnn. Accii*- Net De- Na- Fuel flvg. Re- In- De- In- Lo- De- Fuel 0M1
lUl Plant De- ulated Plant fer-
Ad- Year pre- Depre- Year- red
di- End cia- cia- End Tax
tions tion t\ot\
ter- Rate tum co«e pre- sur- cal coa
lals Base on Tax cia- ance Tax iis-
Rate tion sion-
Base inj
iva?
1988
1987
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004
2005
2006
2007
2006
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
150
62
68
846
908
976
75 1051
82 1133
90 1223
94 1318
99 1417
104 1521
109 1630
115 1745
121 1865
127 1992
24
28
31
34
37
42
46
51
57
63
70
78
87
133 2125 97
139 2264 108
146 2411 121
154 2564 136
161 2726 154
170 2896 174
178 3074 199
187 3261 230
150 3410 263
120 3530 297
96 3625 333
77 3702 376
61 3763 475
(
176
204
235
269
306
348
394
445
in (illicms of dollars )
670
704
741
782
827
875
923
971
502 1019
565 1065
635 1109
713 1152
800 1192
897 1228
1005 1259
1126 1284
1262 1302
1416 1310
1590 1305
1790 1284
2019 1241
2282 1128
2579 950
2912
3288
3763
713
414
0
-104 20
-113 21
-123 22
-132 23
-141 24
-148 26
-155 27
-156 28
-157 30
-157 31
-157 33
-157 34
-157 36
-156 38
-154 40
-149 42
-139 44
-125 46
-106 48
-80 51
-44 53
2
61
135 27
227 22
346 17
51 562
51 632
50 657
50 686
50 719
50 758
54 803
56 850
60 900
66 951
67 995
75 1044
75 1083 112
84 1127 117
84 1159 120
92 1196 124
94 1224 126
99 1249 129
105 1267 131
111 1277 132
118 1275 132
125 1223 126
94 1080 112
62 890
31 655
0 333
58
65
68
71
74
78
83
88
93
98
103
108
92
68
54
27
31
32
34
35
37
39
42
44
46
49
51
53
55
24
28
31
34
37
42
46
51
57
63
70
78
87
97
57 108
58 121
60 136
61 154
62 174
62 199
62 230
60 263
53 297
44 333
32 376
16 475
11
11
12
12
13
14
H
15
16
17
17
8 18
8 IB
9 19
9 20
9 19
10 20
10 20
11 19
11
12
13
13
14
15
15
9
9
10
11
11
12
13
14
15
16
17
19
21
11
PILGRIM TOTAL ->
AnnualCost In- Cost
Costs in ere- in
Cents aen- Cents
per tal per
I^Nh (•il.lkNti
1
r
97
99
19 107
19 120
19 125
19 131
138
145
23 152
25 161
26 174
29 188
29 204
32 219
32 236
35 254
36 272
38 292
40 313
42 336
45 359
47 385
50 411
53 440
56 470
60 501
201
100
100
100
100
lOO
226
265
278
299
315
332
353
375
398
425
454
488
519
557
591
631
671
716
763
816
873
926
967
1004
1043
1113
6.9
8.1
8.5
9.1
9.6
10.1
10.8
11.4
12.1
12.9
13.8
14.8
15.8
16.9
18.0
19.2
20.4
21.8
23.2
24.8
26.5
28.2
29.4
».6
31.7
33.9
97
137
165
187
210
236
283
309
339
370
407
441
481
518
560
602
649
698
753
811
866
909
947
986
1069
0.2
3.0
4.2
5.0
5.7
6.4
7.2
8.6
9.4
10.3
11.3
12.4
13.4
14.6
15.8
17.0
18.3
19.8
21.2
22.9
24.7
26.3
27.6
28.8
30.0
32.5
- QFs -:■
Cost
in Annua'
Cents Cost
KMh Inil.-
3.4
3.6
3.6
^.2
5.7
4.1
6.5
7.0
7.5
8.2
8.7
9.6
10.3
11.0
12.0
12.7
13.6
14.7
15.8
16.5
17.6
18.6
19.7
20.9
22.2
27
113
117
119
136
186
200
215
230
248
268
288
314
340
362
394
417
448
484
519
541
578
612
648
688
731
I'otal
'resent
aiue
3928
2998
2185
18
305
AWIUAL COSTS OF 'ILGRIM VS. ALTERNATIVES
PILGRIM TREND CASE
ZAf-
Total Ann.
taujr Net
De- Ha- Fuel flvg.
Re-
n-
te-
n- Lo-
3e- Fuel Otfl <
- PILGRIM TOTAL
— >
<~ QF-s
itii
Plant De-
jlated Plant
Fer- ter-
Rate turn coae
jre- sur- cal co«
AnnualCost
n-
:ost I
Cost
M-
Vear
pre-
Depre-
Year- red lals
Base
un
Fax
:ia- ance
Fax
nis-
Costs
in
: re-
in
in t^ifi' ■-■-.
ii-
End
:ia-
:ia-
End
Fax
Rate
tion
sion-
:ent5
ci-
:ents .
Cents C
ys-
tions
tion
tion
Base
ins
per
tal
per
per
(
in «i
lions of dollars )
kNh
■il.lkHh
i-.iit ■■
ITiJ . ■'
-07
1^0
844
24
174
470
-104 20
51 542
58
27
24
5
11
4
1
97
226
7.7
8
0.3
3.3
'ce
66
912
28
205
708
-113 21
51 434
45
31
22
5
11
5
19
99
263
9.0
95
3.3
3.3
1^
>B9
73
985
31
234
750
-123 22
50 463
69
32
31
5
12
S
17
107
277
9.4
136
4.6
3.5
10-
•?o
80
104i
34
270
794
-132 23
50 497
72
34
34
5
13
5
17
120
300
10.2
165
5.6
".4
10-
■V!
88
1154
38
308
844
-142 24
50 734
76
36
38
6
13
5
17
125
314
10.8
188
6.4
4.0
lia
■h'i
97
1251
43
351
900
-149 26
50 778
80
38
43
6
14
6
17
131
335
11.4
213
7.2
5.7
16
I'S
m
1354
48
398
958
-154 27
54 830
84
41
48
b
15
6
18
133
357
12.2
240
3.2
6.0
ir
;.«
116
1472
53
452
1020
-159 28
54 888
92
43
53
6
16
7
19
146
382
13.0
29f:
9.9
6.4
'9'
;?5
126
1598
40
512
1064
-140 30
40 953
9V
47
60
7
17
7
20
159
415
14.2
326
11.1
6.8
199
■' c
133
1734
48
580
1154
-141 31
44 1024
106
50
68
7
18
7
22
173
452
15.4
364
12.5
7 "^
2;i
"17
150
1884
77
457
1229
-142 33
47 1092
113
53
77
7
19
8
23
139
489
16.7
405
13.3
7.4
T?"
■/2
157
2043
87
744
1299
-144 34
75 1147
121
57
87
8
20
8
24
205
532
18.1
451
15.4
8.0
2.i
>'.'!
lis
2209
99
843
1344
-145 34
75 1230
127
60
99
8
21
9
26
223
572
19.5
494
16.8
3.5
2"'
■'.■('
174
2382
112
954
1428
-165 38
84 1298
134
63
112
9
22
9
29
241
419
21.1
543
18.5
9.1
:>■
';■:'(
182
2545
127
1081
1484
-144 40
84 1352
140
66
127
9
23
10
29
260
463
22.4
590
20.1
9.5
7H:.
'02
191
2754
144
1225
1532
-140 42
92 1410
146
69
144
9
23
11
31
280
713
24.3
642
21.9
10.1
y<'
IT
201
2957
163
1388
1569
-150 44
94 1457
151
71
143
10
23
11
32
302
763
26.0
695
23.7
• 10.7
.!■.
iM
211
3148
184
1574
1594
-135 46
99 1499
155
73
134
10
24
12
34
325
819
27.9
753
25.6
11.3
3;.
0''!:
222
3390
213
1787
1403
-113 48
105 1532
158
75
213
11
23
13
36
349
878
29.9
313
27.7
' 12.0
3^?
' J
233
3423
244
2033
1590
-83 51
111 1553
161
76
244
11
23
14
38
375
944
32.2
381
30.0
12.7
'7
OC/
244
3847
285
2318
1549
-41 53
118 1557
161
76
285
12
22
15
40
403
1014
34.6
952
32.5
; 13.1
3€;
3
195
4042
329
2447
1415
15 43
125 1500
155
73
329
13
19
16
42
432
1080
36.8
1020
34.8
!3.9
v-
'■'?
156
4219
373
3021
1198
88 34
94 1335
138
45
373
13
17
17
45
463
1133
38.4
1074
36.6
1 14.6
427
-\-J
125
4344
420
3441
903
178 27
42 1108
US
54
420
14
13
19
48
496
1179
40.2
1121
38.2
15.5
'IS-
■■'■ 1
100
4444
474
3917
527
292 22
31 822
85
40
474
15
7
21
50
531
1226
41.8
1169
39.8
! 14.5
4,
O.'-i
80
4524
407
4524
0
444 17
0 421
44
21
407
15
0
11
54
568
1318
44.9
1274
43.4
17.5
51'
"■-5
227
■lA
114
■;5
114
'^'.';;
114
/7
114
'.3
J14
w;M:*t
4236
3306
175
306
Notes to Appendix A
Assumptions and Metiiods
Capital Additions:
BECQ: Escalation of approxiniately .5 percent per year, after adjusting for inflation, from about $30 mil-
lion per year (1986 constant dollars). Declines by 23 percent a year over last five years of plant's life.
Optimistjr.- Ljnear growth at $2.5 million per year for five years to approximately $50 nullion per year
(1986 dollars), followed by same escalation and decline as BECO. Derived from Unear regression of
Pilgrim historical experience between 1973 and 1976, treating the four years with expenditures significant-
ly above the trend line as one-time expenditures which will not recur.
National Trend: Linear growth at $3.2 million per year for five years to $69 million per year (1986 $), fol-
lowed by same pattern as BECO. Derived from ESRG multi-variate regression equation applied to
Pilgrim.
Pilgrim Trend:
Linear growth at $3-5 million per year for 10 years to $92 million per year year (1986$), followed by same
pattern as BECO. Derived from linear regression, excluding two largest outliers.
Plant-in-Service Year End:
Calculated as in BECO Exhibit 1.
= Capital Additions + Prior Total Plant Year End
Annual Depreciation:
= (Half of Year's Capital Additions -I- Prior Year Net Plant) / Remaining Life
Deferred Taxes:
Calculated as in BECO Exhibit 2.
Prior Year Accumulated Deferred Taxes + (Tax Rate x (Year's Tax Depreciation - Year's Book
Depreciation))
Year's Tax Depreciation calculated as in BECO Exhibit 2 (150% Double Declining Balance).
Materials & Supplies:
From BECO Exhibit 1.
Nuclear Fuel in Rate Base:
From BECO Exhibit 1.
Average Rate Base:
Calculated as in BECO Exhibit 1.
= Net plant Year End + Deferred Taxes ^- Materials & Supplies -t- Nuclear Fuel in Rate Base - Half of
Year's Capital Additions
Return on Rate Base:
Calculated as in BECO Exhibit 1.
= Average Rate Base x 10.338%
20
307
Income Taxes:
CaloJated as in BECO Exhibit 1.
= Average Rate Base x 4J?9%
Insurance
From BECO Exhibit 1.
Local Taxes
Calculated as in BECO Exhibit 1.
= Average Rate Base x 1S%
Decommissioning contribution:
From BECO Exhibit 1.
Sinking fund to accumulate $126 million (1986$) by 2012.
Fuel:
Calculated from BECO Exhibit 1.
BECO's annual fuel estimate adjusted by ratio of assumed capacity factor to BECO's assumed capacity
factor of 70%.
O&M Costs:
BECQ: 0.5% per year from 1990
Optimistic: 2% real growth from year when BECO projection crosses National Trend line.
National Trp.nd: Same as BECO to 1990. Linear growth of $3.6 million per year thereafter (1986$);
derived from ESRG equation applied to Pilgrim characteristics.
Pcfisimistic;
Same as BECO to 1990. Then linear growth of $4.4 milUon per year (1986$) per year derived from linear
regression of Pilgrim historical O&M costs from 1973 to 1986.
Present value of O&M shutdown costs is included in present value of year 2012 O&M. Year 2013 O&M is
assumed to be 40% of prior year; 20% for the five years thereafter. Based on BECO Exhibit 2.
Annual Costs:
= Return + Income Tax + Depreciation + Insurance + Local Tax + Decommissioning + Fuel +
O&M
Costs in Cents per Kwh:
= Annual Cost / Aimual Generation
Annual Generation = Capacity [670000 Kw] x 8760 hours/yr. x Capacity Factor
Capacity Factor:
EECQ:70%
OptimUtir-
Average of seven BWRs between 400 - 799 Mw for 1977-1986
= 63.159%
21
\i
308
From North American Electric Reliability Coimcil, Equipment Availability Report 1975 - 1986.
National Trend:
56 percent; derived from ESRG regression equation for Pilgrim and equal to Pilgrim's lifetime capacity
factor before its shutdown in April, 1986.
Pilgrim Trend:
50 percent; Pilgrim's lifetime capacity factor as of October 1987.
Incremental Costs:
Incremental cost comparison is BECO's preferred way of comparing future Pilgrim costs with alterna-
tives. Comparing Pilgrim incremental costs (which subtract shutdown and sunk cost charges from Pilgrim
total costs) to alternative costs is the same as comparing Pilgrim lota! costs to alternative costs plus shut-
down and sunk cost charges.
As in BECO Exhibit 2
= Anoual Cost - Cost of service on sunk costs
Cost of service on sunk costs includes return and depreciation (amortization) on sunk costs as of end of
1987 (846 million); plus O&M costs of $40 milLon in 1988 and $20 million per year in 1989-1993; plus in-
surance of $2.3 million per year 1988-1993; plus property taxes declining from $9 million in 1988 to $1 mil-
lion in 1993 and thereafter; plus decommissioning. In BECO Ca.<;e. S.SO million in nuclear fuel and $20
million in materials and suppUes is included in sunk cost rate base. In MASSPIRG scenarios, it is assumed
that 64% of the investment in fuel and supplies is sold to other utilities, and 36% included in rate base.
Replacement Power Costs:
Pilgrim Trend Case:
= Average Award Group Bid; from John Whippen, Manager, Energy Resource Planning & Forecasting,
Boston Edison, Letter to RFP Respondents, October 13, 1987.
Natinna] Trend Case:
= Estimated average bid from next 764 Mw supply block after Award Group.
= RFP Ceiling Price - ((RFP Ceiling Price - Average Award Group Bid)
x ((Average Supply Block Ratepayer Benefit Score - 1) / (Average Award Group Ratepayer Benefit Score
-1)))
The average Ratepayer Benefit Score of the Award Group was 1 Jl; the average Ratepayer Benefit Score
of the next 764 Mw supply block was 1.22. Each year, the supply block price was assumed to capture 22/31
of the benefits of the award group, or 70.9% of the difference between the ceiling price and the Award
Group.
RFP Ceiling Price from John Whippen, Letter to RFP Recipient, February 19, 1987.
Ratepayer Benefit Scores from Frank McCall, Letter, October , 1987.
= Estimated average bid of the entire 1327 Mw of acceptable QFs not in the Award Group. Calculated as
above. Average savings = 52.4% of Award Group.
Present Value:
The calculation of present value of a future cash stream discounts future cash flows to reflect the time
value of money. A dollar in hand today is worth more than a dollar next year, by the amount of interest
that could be earned (or the interest payments that could be deferred) by having the dollar for the year's
time.
Discount rate = 10.55%, from BECO Exhibit 1.
22
309
Appendix B
MASSPIRG NUCLEAR COST ESTIMATES
A. Capital additions
Nuclear plants have required steadily
increasing capital additions in order to
replace worn-out parts and meet new
safety standards. On average nuclear capi-
tal additions have increased at 13 percent
a year since 1970, after adjusting for infla-
tion (Figure 14). Replacement of some
reactor parts, such as cracked pipes in
Boiling Water Reactors (BWRs) like
Pilgrim, and steam generators in Pres-
surized Water Reactors (PWRs), have re-
quired as much as $100 million or more
per plant.
Pilgrim cost trends were analyzed by a
statistical technique called "linear regres-
sion analysis." An equation was deter-
mined for the straight line that best fits
Pilgrim's historical cost pattern, after ad-
justing for the effects of inflation. To
23
measure national cost trends, this
report uses equations developed by the
Energy Systems Research Group
(ESRG), a Boston- based consulting
group that has studied nuclear costs for
numerous state regulatory and con-
sumer agencies around the country.'
ESRG has analyzed nuclear cost trends
using "multi-variate regression analysis"
~ a technique which relates changes in
nuclear costs to a number of factors
such as plant type, size, location,
vintage (in-sen'ice date), and year of
operation.
In general, plants with Pilgrim's
characteristics have experienced far
greater capital additions than the na-
tional average. BWR capital additions
have escalated faster than at PWRs, for
instance, and salt-water cooled plants,
like Pilgrim, have experienced more
capital additions than fresh-water
Figure 14 Figure 15
NATIONAL AVERAGE CAPITAL ADDITIONS PILGRIM & NAT AVG. CAPITAL ADDITIONS
SpConstant 1986 Dollars per Kilowatt
45
40
35
30
25
20
15.
10.
5
0
/
280 Constant 1986 Dollars per Kw
260^
/
/
-1^74r- 1978 1962 1986
Year
, National Average
-t97Jr
978 ■ 1982"
Year
„ Pilgrim . National Avg.
ESRG Regression
23
310
Figure 16
CAPITAL ADDITIONS PROJECTIONS
Constant 1986 Dollars
1977 ■ 1961 1965 ' 1969 1993 ' 1997 2001 2005 2009"
Year
□ Pilgrim Historical
cooled plants. ESRG's regression analysis
has found that capital additions are re-
lated to plant size, type, cooling water,
age, year of in, lal operation, and whether
a plant has one or two units at a site.
Capital additions at the Pilgrim plant
have been among the highest of any U.S.
nuclear plant. Total Pilgrim capital addi-
tions over the period of 1972 to 1986
were 3.3 times the national average per
kilowatt, and considerably higher than
the regression line for plants of the
same characteristics (Figure 15).
Figure 16 displays alternative projec-
tions of future Pilgrim capital addi-
tions. Except for one moderately
Figure 17
CUMULATIVE SAVINGS FROM RETIRING PILG.
Sensitivity to Capital Additions
2000
Year
NatTrend
2012
PilgTrend
24
311
expensive repair planned for 1990,
Edison forecasts several years of declin-
ing real expenses for capital additions, fol-
lowed by a steady outlay of less than $30
million a year through the year 2007.
Capital additions are estimated to decline
by 20 percent per year over the last five
years of the plant's life. Even Boston
Edison appears to have little confidence
in its capital additions estimates,
however:
We have provided a reasonable es-
timate of Pilgrim's costs for the next
25 years. However, as you know, many
factors external to the company, such
as NRC mandated modifications, can
significantly impact Pilgrim's Custi."
MASSPIRG's optimistic projection of
Pilgrim capital additions starts with the as-
sumption that the four years witn the
highest capital additions (1980, 1982,
1984, 1987) were caused by unique events
~ such as the replacement of cracked
recirculation pipes in 1984 — which will
not recur. The remaining years still show
a consistent underlying pattern of capital
additions increases which is likely to per-
sist into the future. To be ultra- conserva-
tive, the Optimistic Case here assumes
that this trend continues only for another
five years. Capital additions are also con-
servatively assumed to decrease over the
last five years of the plant's life, even
though other utilities have testified that a
higher rate of capit^il additions may be
needed to keep them running. (See Ap-
pendix B.) Edison's estimate for 1990
capital additions is assumed to represent
a particular planned expenditure which is
included in MASSPIRG's Optimistic
Case as well.
The National Trend Case assumes that
Pilgrim's rate of capital additions declines
to the level described by the ESRG
regression equation, and continues at that
rate for five years. The Pilgrim Trend
case assumes that capital additions con-
tinue at their historic rate (with 1984
and 1987 additions still defined as non-
recurring costs) for 10 years.
Figure 17 illustrates the effect of
changing only the assumption about fu-
ture capital additions, holding all other
BECO assumptions the same. If
Pilgrim capital additions were to follow
the National Trend (an improvement
from the historical performance of the
plant), it would cost ratepayers very lit-
tle to retire the plant, even assuming
full payment of Pilgrim sunk costs, in-
cluding a profit.
B. Operation and maintenance
costs
Like nuclear capital additions, opera-
tion and maintenance (O&M) costs
have also been increasing over time, at
an average rate of 1 1.4 percent a year
for the nuclear industry as a whole. At
Pilgrim, total O&M costs have in-
Figure 18
PILGRIM VS. NATIONAL AVG. O&M COSTS
140 Constant 1986 Dollars per Kw
^974 1978
1962-— raee
Pilgrim
Year
National Avg._ ESRG Regression
25
312
Figure 19
O&M COST PROJECTIONS
Million Constant 1986$
National >enc!
rim Optimistic
-1988 1893—1998-— 2603-
Historical
creased at an annual rate of 13.8 percent,
after inflation. Total Pilgrim O&M expen-
ditures between 1972 and 1986 have ex-
ceeded the national average per kilowatt
by 78 percent. Pilgrim O&M expenses
were less than the regression line for
plants with Pilgrim's characteristics until
1983, however (Figure 18). Figure 18 sug-
gests that management decisions to defer
maintenance in the early years of Pilgrim
operation may have contributed to some
of the plant's later problems.
Not surprisingly. O&M cost in-
creases are correlated with many of the
same variables as capital additions -
plant size, age, number of units at a
site, and salt-water cooling. After the
Three Mile Island Accident in 1979,
O&M costs increased at all plants by an
average of $8.55 per kilowatt. In addi-
tion, plants located in the northeast
have had O&M costs averaging about
$8 per kilowatt above plants in other
regions.
Figure 20
CUMULATIVE SAVINGS FROM RETIRING PILG.
Sensitivity to O&M Costs
BECO
Opt
■1996- 2000
NatTrend
-2004 2008^ 2012
Pilg.Trend
26
313
Figure 21
HISTORICAL CAPACITY FACTORS
1 .00 Percent
Pilgrim
Year.
National Avg.
Alternative projections of O&M costs
are shown in Figure 19. Edison projects
substantial increases in O&M costs over
the next several years, compared to both
Pilgrim and national trends. A portion of
the near- term O&M costs also includes
replacement power costs during extended
Pilgrim shutdowns that customers are ex-
pected to pay over several years. After
1990, however, BECO projects that real
O&M costs, like capital additions, will sta-
bilize in constant dollars, mcreasing :u
only 0.5 percent per year.
The MASSPIRG Optimistic Case
projects O&M costs increasing at only
two percent a year, after adjusting for
inflation, after 1994. The National
Trend and Pilgrim Trend cases assume
that O&M costs eventually resume
their historical pattern of increase.
Figure 20 displays the effect of
changing only the O&M assumption on
cumulative savings from retiring
Pilgrim. While significant, the overall
impact is not as large as that from
changing capital additions assumptions.
C. Capacity factor
The best measure of nuclear plant
performance is capacity factor - rough-
ly, the percentage of time a plant is in-
service at full power. The capacity
factor of a given plant reflects periods
that it is shut down for refueling, main-
tenance and repair. It also accounts for
times when plants may be forced to
Figure 22
CAPACITY FACTOR PROJECTIONS
19*7?
-Tms
^f9Kr
1968 1993
Year
2-Year Rolling Avg.
T998-
2003
2008^
27
314
operate at reduced power levels.
Capacity factors of individual nuclear
plants tend to var>' a great deal from year
to year, particularly since most plants are
refueled every other year, and may be
taken out of service for several months
during that time. Across the entire in-
dustry, however, nuclear capacity factors
have tended to average consistently just
under 60 percent. Pilgrim's lifetime
capacity factor to date is only 50 percent.
At the point it was shut down in April,
1986, the plant had averaged a capacity
factor of 56 percent (Figure 21).
Some varieties of nuclear plants have
averaged better performance than others.
Between 1975 and 1985, for example.
Pressurized Water Reactors (PWRs)
averaged capacity factors of 60.8 percent,
compared to only 56.6 percent for Boiling
Water Reactors (BWRs) Uke Pilgrim.
Smaller plants, however, have generally
achieved higher capacity factors than
larger plants. Capacity factors of BWRs
between 400 Mw and 799 Mw, excluding
the Pilgrim plant, averaged 632 per-
cent between 1976 and 1986.^^
ESRG's regression analysis
describes capacity factor as a function
of plant size, general type, type of cool-
ing water and steam system, and plant
age. It shows that nuclear plants have
generally tended to increase capacity
factors over their first four yeart of
operation, and experience only flight
gains in performance over the sub-
sequent eight years. Reactors that are
cooled with salt water, like Pilgiim.
have tended to decline in perforrnance
each year.
Figure 22 illustrates ESRG's regres-
sion equation forecast for a plant of
Pilgrim's characteristics, and the
capacity factor projections used in the
three alternative Pilgrim cost scenarios.
A two-year rolling average of Pilgrim's
historical capacity factor is also s^own
Averaging each year's capacity factor
with the previous year's helps to
smooth out the year-to-year ups and
Figure 23
CUMUL-ATIVE SAVINGS FROM RETIRING PILG.
200
Sensitivity to Capacity Factor
wir
28
315
downs in capacity factor caused by refuel-
ing shutdowns every other year.
Boston Edison assumes that Pilgrim
will operate at a 70 percent capacity fac-
tor over the remainder of its life.
Pilgrim's lifetime capacity factor of 50
percent ranks 79th among 94 nuclear
plants. The probability of Pilgrim
moving from the bottom fifth to well
above the average capacity factor is quite
low, particularly in Ught of the trend of
declining capacity factors in salt-water
cooled reactors.
A 63.2 percent capacity factor - the na-
tional average for small BWRs excluding
Pilgrim - is used in MASSPIRG's Op-
timistic Case. A 56 percent capacity factor
~ equal to Pilgrim's performance before
the 1986 shutdown and the peak capacity
factor predicted by the regression equa-
tion - is used in the National Trend Case.
Finally, the Pilgrim Trend case assumes
that the plant will continue to average a
50 percent capacity factor over the rest of
its life. These estimates all conservatively
assume that the declining performance
of salt-water cooled reactors shown by
ESRG's regression equation will not
continue.
Most of the costs of owning and
operating a nuclear plant are "fixed
costs" which do not vary with how much
electricity the plant actually produces
in a given year. The iQiai cost of operat-
ing Pilgrim over the next 25 years ihere-
fore does not vary much with capacity
factor. A lower capacity factor means
that more energy would have to be pur-
chased to replace Pilgrim, however,
and means a higher cost for each Kwh
generated by Pilgrim.
Figure 23 illustrates the impact of
capacity factor on the economics of
retiring Pilgrim. Even if Pilgrim were
able to maintain the 56 percent
capacity factor it achieved before its
April 1986 shutdown, it would save
ratepayers money through the year
2003 to retire the plant, even if all
other BECO assumptions hold.
29
316
Appendix C
Causes of Nuclear Cost Escalation
The continuing existence of the factors
that have contributed to past escalation of
nuclear capital additions and operations
and maintenance costs make it likely that
those expenses will continue to escalate at
historic rates for the foreseeable future.
The forces driving the cost escalation in-
clude the persistence of unresolved safety
issues, ongoing technical problems that
are discovered as the nuclear industry
gains more operating experience, and the
aging of reactor components. In addition
to increasing costs, premature aging
problems also cast serious doubt on
whether the Pilgrim plant could be
operated for a 40-year lifetime, as Boston
Edison projects.
1. Unresolved generic safety issues.
The Nuclear Regulatory Commission
maintains a list of um-esolved safety issues
which are generic to nuclear power reac-
tors. As these issues are resolved, they fre-
quently require significant new expenses
to implement them.
Before the 1979 accident at Three
Mile Island (TMI), the NRC had resolved
20 of 142 issues identified in its 1978 Task
Action Plan, according to a 1984 General
Accounting Office report. The TMI ac-
cident added many new issues to the
Commission's Hst, and postponed action
on many of the previously identified
problems. By July 1984, the agency had
resolved only 208 of 482 total issues
identified through that time. Moreover,
new issues were being identified at the
rate of 1 1 per year, while the agency 's
schedule called for the resolution of
only 12 total issues per year. As of
August, 1987, 163 issues remained on
the unresolved issues list.
30
New generic issues are likely to be
discovered as a result of operating ex-
perience, particularly as reactors age.
The possibility of additional major
nuclear accidents also contributes to
the likelihood of new regulations. The
NRC staff has estimated that the prob-
ability of a full core melt accident at a
U.S. nuclear plant may be as high as 45
percent during the next 20 years.
Other analysts have estimated the prob-
ability to be higher.
One unresolved safety problem that
is of particular concern to Pilgrim is the
strength of the containment shell which
is designed to prevent release of
radioactive materials to the environ-
ment in the event of an accident. An
NRC task force has estimated that the
probability of failure of the Mark I con-
tainment design used Pilgrim and 25
other U.S. plants may be as high as 90
percent in some accident scenarios,
compared to a failure probability of
about 10 percent with other contain-
32
raent designs.
30
317
Another commission task force is cur-
rently studying the Mark I problem, but is
not expected to make recommendations
for more than a year. There is a substan-
tial probability that fixing the Mark I con-
tainment problem will impose costs
exceeding current BECO estimates.
2. Ongoing technical problems.
There is persistent evidence that
nuclear technology has not yet "matured,"
and that reactor operation will continue
to be plagued with safety- related and
non-safety related problems that reduce
capacity factor and require new O&M
and capital additions expenditures to fix.
The mmiber of Licensee Event Reports
(LERs) -- which document mishaps at
nuclear plants - has steadily increased. In
1986, there were 2,957 LERs filed with
the NRC, approximately the same as the
record 2,997 LERs for 1985, and well
above the 2,435 LERs reported in 1984.
Nuclear plant capacity factors have failed
to increase as the nuclear industry
predicted they would as plants matured.
33
3. Aging of reactor components.
The need to replace worn plant com-
ponents and systems has greatly outpaced
industry expectations. A 1984 NRC staff
report identified 5,893 events in safety-re-
lated systems occurring between 1969 and
1982 (17 percent of all LERs) as age-re-
lated. Additional aging problems have oc-
curred in non- safety-related systems.
Aging problems have been caused by
wear and tear, corrosion, internal and ex-
ternal radiation contamination, contact,
vibration, stress corrosion, erosion, and a
category of miscellaneous problems.
As discussed in the text, salt-water
cooling systems at reactors located on
oceans, such as Pilgrim, have been as-
sociated with more corrosion than
fresh-water systems. In addition, the
Pilgrim plant has been subject to much
higher levels of radiation contamina-
tion that many other nuclear plants.
The average Pilgrim worker was ex-
posed to 1949 rem.<; a yea' between
1984 and 1986, compared to 645 rems
per year at Millstone I, in Connecticut,
a plant the same type and about the
same age as Pilgrim." '
4. Nuclear plant lifetimes.
In addition to causing mcreasing
costs for replacement of parts and
operation and maintenance expenses,
reactor aging casts serious doubt on the
ability of nuclear plants to operate for
the 40 year period assumed by Edison
in its evaluation of Pilgrim economics.
Boston Edison's operating license
for Pilgrim currently expires in 2008,
after 35 years of operation. The utility
has recently applied for an extension of
its Hcense to the year 2012. No license
extensions for any nuclear plants have
yet been considered or granted by the
NRC, however, and there is no way at
this time of predicting whether such ex-
tensions will be granted in the future.
Niagara Mohawk Corporation, the
chief owner and operator of the Nine
Mile Point 1 nuclear plant, requested
permission from the New York State
PubHc Service Commission to use a
depreciation life of the plant that is five
yeais shorter than the plant's operating
"cense"
Recognizing the regulatory pres-
sures from the Nuclear Regulatory
31
318
Commission, relicensing should not
be assumed. If it should happen that it
is possible to relicense the plant, the
capital expenditures required would
be of such a magnitude that the unit,
for depreciation purposes, should be
considered as being new at that
time.-'^
Niagara Mohawk's testimony, in addi-
tion to contradicting BECO's assumption
of relicensing, also contradicts Edison's
assumption that capital additions expendi-
tures would not increase in real terms
over the entire last 25 years of the
plant's projected life, and would
decrease at 20 percent per year over
the last five years.
To date, no conmiercial nuclear plant
has yet operated for longer than 27
years (Table 4), and a significant num-
ber of reactors have been retired with
considerably fewer years of operation.
(Table 5)
TabU 4. OLDEST U^. OPERATING NUCLEAR REACTORS
Plant
Location
Initial
A«e
Capacity
Operation
Yankee
Rowe, MA
1960
27
185
Big Rock PoiM
Charievoix, Ml
1962
25
75
San Onofre 1
San aemente, CA
1967
20
450
Haddam Neck
Haddam Neck, CT
1967
20
600
Oyster Creek
Forked River, NJ
1969
18
550
Nine MUe Point!
Scr»ba,NY
1969
18
642
Gmna
Ontario, NY
1969
18
517
Dresdea 2
Morris, IL
1970
17
794
Robinson 2
Hartsviile, SC
1970
J7
769
Point Beach 1
Two Creeks, Wl
1970
17
485
Millstone I
Waterford, CT
1970
17
660
Sorurce: Critical Mass Energy Project;^ Nuclear Regulatory
Commission
Table 5. RETIRED U.S. REACTORS
Plant
Initial
Operation
Retirement
Year
32
Capacity
Three Mile Island 2
; ■■ 1978
1979
1
906
Pathfinder
:>: 1966
1967
1
66
Haifam
.:.: 1963
1964
1
256
Piqua
1963
1966
2
45
CVTR
1963
1967
3
65
m:: Bonus
1964
1968
4
50
={;v Elk River
;<■; 1963
1968
4
22
Fermi 1
1966
1972
6
61
:>: Peach Bottom 1
1967
1974
8
40
Indian Point 1
1962
1974
12
265
Humboldt Bay
1963
1976
13
65
Dresden 1
1960
1978
19
207
319
Notes
A federal study estimated subsidies for research and development, mining and fuel enrichment at almost
$40 billion by 1981. (Joseph Bowring, "Federal subsidies to Nuclear Power," unpublished report, Olfic*; of
Economic Analysis, Energy Information Administration, March 1980. Another estimate of construction
subsidies to nuclear power plants runs as high as $15.6 billion for the year 1984 alone. (H. Richard Heede.
Richard E. Morgan, and Scott Ridley, The Hidden Costs of Energy: How Taxpayers Subsidize Energy
Development, Center for Renewable Resources, Washington, D.C., October, 1985)
^See Nuclear Waste Fee Adequacy: An Assessment, U.S. Department of Energy, Office of Civilian Radioac-
tive Waste Management, DOE/RW- 0020, June 1987, pp. 7-10; Commercial Nuclear Power: Prospects for
the United States and the World, U.S. Department of Energy/Energy Information Administration,
DOE/EIA-0438(86, p. 20); "Nuclear Power Plant Decommissioning: Cost Estimation for Power Plaiming
and Ratemaking," Energy Systems Research Group, Boston, July, 1987.
^Charles Komanoff, Power Plant Cost Escalation, Komanoff Energy Associates, New York, 1981 .
^avid Schlissel, Trends for Nuclear Capital Additions and O&M Costs," Direct Testimony Before the
Public Service Commission of the State of Missouri Appearing for the Office of the Public Counsel, Case
No. ER-85-128, Case No. EO-85-185, June 28, 1985.
^Nuclear Plant Cancellations: Causes, Costs and Consequences, U.S. Department of Energy/Energy Infor-
mation Administration, DOE/EIA-0392, April 1983.
Schlissel, op. cit.
'' Richard Hellman and Caroline J.C. Hellman, The Competitive Economics of Nuclear and Coal Power,
Lexington Books: Toronto, 1983.
^Richard McCormack, "Whoops!" Energy Daily, April 28, 1986, p. 1
'Joseph Kricsberg, Nuclear Power Too Costly to Continue, Draft, Critiral Ma« Energy Project,
Washington. D.C.. November 1987
Ibid., from U.S. Department of Energy communication.
Schlissel, op. cit.
^^illiam Blundell, "Doubts Pervade Nuclear Fuel Industry Utility Pacts Unclear; Uranium Producers
Ailing," The Wall Street Journal, October 10, 1985; Kennedy Maize, 'Doraenici's Uranium Bill Would Trim
imports to 50 Percent of U.S. Needs," The Energy Daily, February 20, 1986.
^Power to Spare: A Plan for Increasing New England's Competitiveness Through Energy Efficiency, New
England Energy Policy Cotmcil, July 1987.
Fvial Report of the Boston Edison Review Panel, March 1987.
^NEPOOL Forecast Report of Capacity, Energy, Loads and Transmission 1987- 2002, New England Power
Pool, West Springfield, MA, April 1, 1987.
'^Boston E^soa, Request for Proposals from Qualifying Cogeneration and Small Power Production
Facilities, Appendix C, Exhibit 4, p. 18.
^^Final Report: Asset Disposal and Contract Settlement Associated With Pilgrim 2 Cancellation, Boston
Edison Company, Report #10, May, 1987
^^estem Massachusetts Electric Company, D.P.U. 84-25.
^Western Massachusetts Electric Company, D.P.U. 85-270
Nuclear Plant Cancellations, op. cit, »
33
320
^Harvey Salgo, Raymond Czahar, and Paul Raskin, TrofKJsal of the Executive Office of Energy Resour-
ces, DP.U. 86-36, April 4, 1986.
^^quations for this study were talcen from the Testimony of Stephen Bemow on "Excess Capacity and
Cost Benefit Analysis of Vogtle Generating Station" on behalf of the Georgia Office of Consumers' Utility
Counsel before the Georgia Public Service Commission, Docket No. 3673-U, August, 1987.
^Carl Gustin, Vice President, Corporate Relations, Boston Edison, Letter to Sharon Pollard, Secreatary
of Energy Resources, Commonwealth of Massachusetts, June 8, 1987. Also referred to as Exhibit 1. Ex-
hibit 2 is Carl Gustin letter of July 1, 1987..
Gustin, personal communication, October 1987.
^^ESRG; Equipment Availability Report 1976-1985, North American Electric ReUability Council, Prin-
ceton, NJ.
''ibid.
^rom Monthly Operating Reports filed with the U.S. Nuclear Regulatory Commission, courtesy of
Stephanie Murphy, Nuclear Information and Resource Service, Washington, D.C.
^Management Weaknesses Affect Nuclear Regulatory Commission Efforts to Address Safety Issues
Common to Nuclear Power Plants," General Accounting Office, GAO/RCED-84-19, September 19,
1984).
^""Efforts to Ensure Nuclear Power Plant Safety Can Be Strengthened," General Accounting Office,
GAO/RCED-87-141, August, 1987.
" NRC Testimony to U.S. House of Representatives, Subcommittee on Energy Conservation and Power,
April 1986.
Brian Jordan, "Denton Urges Industry to Settle Doubts About Mark 1 ContJiinmenl," Inside N-R-C,
June 9, 1986, p. 1.
^^Joshua Gordon, 1986 Nuclear Power Safety Report, Public Citizen, Washington, DC, September 1987.
Survey of Operating Experience from LERs to Identify Aging Trends, Status Report," Nuclear
Regulatory Commission, NUREG/CR-3543, January 1984.
David Wesscl, "Pilgrim and Millstone, Two Nuclear Plants, Have Disparate Fates," The Wail Street Jour-
nal, My 78, 1981., p. I.
John S. Ferguson, Prepared testimony on behalf of the Niagara Mohawk Power Corporation in New
York Public Service Commission Case #28225, p. 27.
34
321
The Chairman. In one of the reports you talked about the sub-
ject of advance pubhc information and education. And there are
some that would say that those people claim not to know the evac-
uation procedures, that they are against the plan anyway, so it is
not their interest to be helpful; that it is not in their interest to tell
you, even if they read the plan, that they had read the plan, if they
thought they would be helpful to Boston Edison. How do you re-
spond to that criticism? That is a criticism that may be made.
Ms. Shimshak. Having participated in a survey, people gave us
very honest answers. I believe that they told you the truth when
they said they didn't really know what to do in the event of an
emergency and they said they hadn't actually received the emer-
gency information booklet in the mail.
One thing that did stand out with people's answer to these ques-
tions is an air of cynicism. Having been through 15 years worth of
history of this plant, and seeing how many problems it has and ex-
periencing the NRC's lack of attention to those plans — those prob-
lems, I think people have a very cynical view. And even if they
were given proper instructions, my guess is they wouldn't follow
them. They'll get together with their families because that's what's
most important to them and they'll do what they think is best at
the moment, and I don't believe that that will be following the pre-
scribed directions.
The Chairman. Are you, from your own perspective, optimistic
or pessimistic as to whether that plant will restart?
Ms. Shimshak. Well, I would be tempted to say that I'm pessimis-
tic just because of the NRC's record in the past, and given the fact
that they never really shut a plant down for being £is bad as Pil-
grim is. But I must admit, I'm feeling optimism for two reasons,
and one is that you've taken an interest in this plant, as well as
many other elected officials, and, hopefully, that will stimulate
some good action on this; and also since the plant has been shut
down for 21 months, which I don't believe any of us would have
expected in 1986 when it originally closed down.
The Chairman. Thank you very much— you're a very helpful
panel, these are helpful reports. Wish we had more time to go into
the issues. I may want to submit some more questions to you, but
we appreciate the time. We are very much impressed — but not sur-
prised— by the quality of the representation of the member of the
great general court, the State Senate. By your testimony obvious-
ly— as well as Mr. Malaguti's testimony, and the very exemplary
work that has been done. I want to thank all of you very much.
[One-minute break.]
The Chairman. I want to announce for the record, we were not
able to include all the State Representatives and Senators in the
course of our hearing. We had about 10 or 12 that had made appli-
cations. We want to indicate to any of those that want to have
their statements made a part of the record, including the State sen-
ator that represents the local community that we will include
them.
We tried to get the State representative, the Board of Selectmen
and the chairman of the Energy Committee in the Great General
Court. But we want to indicate to everyone, if they want their
statement included in the record, we will keep the record open. But
322
it was really a question of trying to hear from as many of the dif-
ferent representatives who have interest and responsibilities in the
local community, from the local representatives as well as the rep-
resentatives of the NRC.
We wanted to hear all of them and not to try to go below a 3 or 4
minutes presentation; otherwise, you lose the real context of the
hearing. So those are the reasons, quite frankly. We were not in-
tending to be disrespectful to any of those persons.
We are particularly delighted now to have here an old friend of
mine, and one of our very fine public servants, the Lieutenant Gov-
ernor of our State, Evelyn Murphy. I welcome her to our hearing
as the second ranking State official in a position of responsibility in
the State for its health and well being, as she brings a special per-
spective to this hearing, and we very much look forward to her tes-
timony. I'll ask that you be good enough to stand and take the
oath.
[Lieutenant Governor Murphy sworn.]
STATEMENT OF LT. GOV. EVELYN MURPHY
Lieutenant Governor Murphy. Thank you Senator Kennedy. I
want to thank you for giving all of us the opportunity to come here
tonight and discuss the Pilgrim nuclear power plant and the seri-
ous public health and safety questions surrounding it. And you've
seen the turnout tonight on one of the coldest nights of this winter,
it is the testimony to the intense feelings that people have about
the issue.
I come here tonight, not just as Lieutenant Governor, but as the
Acting Governor to express the Governor's and my concern about
the threat to the public's health and safety of this plant, and insist
on behalf of the people of the Commonwealth of Massachusetts
upon two very reasonable specific actions.
First that the NRC hold an adjudicatory hearing in Plymouth
before this plant opens; and second, that Pilgrim not be allowed to
reopen until the emergency evacuation concerns of both FEMA and
Governor Dukakis have been satisfactorily resolved.
In June of 1986, the plant was closed because of serious charges
concerning the safety of the management facility. I won't dwell on
the specifics. You are going to hear from a panel of State officials
here tonight: Mr. Agnes, the Assistant Secretary of Public Safety;
Commissioner of Public Health, Deborah Prothrow-Smith; Attorney
General; Secretary Pollard, all prepared to supply in detail from
the State's perspective, the concerns that Governor Dukakis and I
share.
Since the closing of this facility. Governor Dukakis has laid out
three preconditions for its reopening. Public health and safety are
the crux of these criteria. First, the inadequate safety practices at
the plant must be corrected; second, the management problems
must be resolved, and third, the evacuation plan must be adequate.
These three criteria have been offered as reasonable demands for
the operation of the nuclear power plant in a heavily populated
area. They have not yet been met by Boston Edison.
This administration has the responsibility to protect our citizens.
And our insistence that the plants be operated with protection of
323
people's health and safety as the foremost guarantee is absolutely
non-negotiable.
My own reservations about this plant and nuclear power date
back to 1975 when I rejected the draft Environmental Impact
Report for Pilgrim 2. At that time the comments were on the ques-
tions of disposal of waste and about plant safety. Those issues are
the same, and remain unanswered today. So my reservations have
become more resolutions: the resolve to prevent our safety and eco-
nomic health from being held hostage to any one power source; and
the resolution to work toward the development of safe, reliable,
non-nuclear energy.
As you deliberate here tonight on the future of the Pilgrim
plant, please disregard the issues involved in supply and demand
on the New England power grid. Let me be very clear. We have
sufficient energy generating capacity for all but the most unusual
situations today. As a matter of fact, Tuesday night, demand hit a
record-breaking peak of 18,471 megawatts, that was met through
contingency purchases and other standard operating procedures,
once we hit those contingency plans. So meeting even high electric-
ity demands is possible without Pilgrim, without Seabrook and
without a crisis.
Today's problems of tight energy in New England are more due
to the lack of judicious management and maintenance practices, as
well as the needs of aggressive action on short term augmentation
of supplies, as was just discussed by the panel; some of the small
scale power that could be brought on line quickly, and some of the
energy conservation load management practices that have certain-
ly been recommended and are possible.
In recent months, the State has been very active to do this, and
we're pulling together a task force, at the Governor's request, so
the state can move aggressively on these initiatives to augment
supply and dampen demand. So we are doing that. And I would
only say to you that I would hold that question about the New Eng-
land power supply aside. It has no relevancy whatsoever tonight.
Having expressed these concerns to you, I must say that I realize
how difficult it is for you. Governor Dukakis, me and other respon-
sible public officials to make any headway against an unresponsive
Federal bureaucracy, which actually doesn't seem to care about the
health and safety of the citizens of the State.
It seems to me that the NRC has been surprisingly nonrespon-
sive to date. Let me be more specific, and go through a little bit of
the sequence here. In July of 1986, as Senator Golden mentioned, I
joined him, MASSPIRG, and many other in signing that show
cause petition for addressing three points on nuclear reactor safety,
emergency planning and maintenance. The NRC rather callously
dismissed the first two and deferred consideration on the third
point. MASSPIRG appealed denials, and Attorney General Shan-
non, who is about to testify after me, is now an intervener in those
appeals. And yet there has been no response. I find this difficult to
accept.
In October of 1987, Governor Dukakis and Attorney General
Shannon filed a show cause petition asking for the adjudicatory
hearings on whether this plant should be allowed to reopen. There
has been no response. Nor has the NRC responded to a substan-
324
live — in a substantive manner — to the two reports on Pilgrim pre-
pared by Secretary of Public Safety Charles Barry, and submitted
by Governor Dukakis at first on December 1, 1986; the second De-
cember of 1987. And it is now my understanding, Senator, you and
Congressman Studds also submitted a request that has been denied
in term of appeal to an adjudicatory hearing.
NRC has indicated that it will meet with petitioners, and this, I
believe, for all of us is unacceptable. Citizens of the State have a
right to see this case argued in a formal setting. I would encourage
you to do everj^hing in your power to see that this hearing takes
place. You have my commitment and the Governor's commitment
to fully support your efforts.
What the Governor and the people of Massachusetts have put
before the NRC, we believe to be specific and reasonable requests,
but when confronted by bureaucratic stonewalling, that reasonable-
ness is likely to turn out to be more increasing outrage.
In closing, let me make one final point regarding FEMA and the
NRC. As you know, currently FEMA's role is strictly advisory. This
has been mentioned several times. The situation here is a prime
example of how the NRC could overrule the recommendations of
both the Governor and FEMA, as it's own advisory body. This is
absurd.
The Governor and I would wholeheartedly support any congres-
sional action that you would take in passing a requirement that
the NRC be bound by the recommendations of the State govern-
ment and of FEMA. For Massachusetts, that would mean that Pil-
grim would not restart until the people of Massachusetts were sat-
isfied with the emergency plan.
We thank you once again for doing this tonight and for your in-
volvement and we're really quite grateful.
[The prepared statement of Lieutenant Governor Murphy fol-
lows:]
325
EVELYN F MURPHY
LIEUTENANT GOVERNOR
THE COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE DEPARTMENT
STATE HOUSE • BOSTON 02133
ROOM 259
(617) 727-7200
TESTIMONY OF LIEUTENANT GOVERNOR EVELYN F. MURPHY
UNITED STATES LABOR AND HUMAN RESOURCES COMMITTEE
JANUARY 7 , 1988
SENATOR KENNEDY, MEMBERS OF THE COMMITTEE. I WANT TO THANK
YOU FOR GIVING US ALL THE OPPORTUNITY TO COME HERE TONIGHT TO
DISCUSS THE PILGRIM NUCLEAR POWER PLANT AND THE SERIOUS PUBLIC
HEALTH AND SAFETY ISSUES SURROUNDING IT.
THE TURNOUT TONIGHT, ON ONE OF THE COLDEST NIGHTS OF THE
WINTER, IS TESTIMONY TO THE FEELINGS PEOPLE HAVE ABOUT THIS
ISSUE.
I COME HERE TONIGHT AS ACTING GOVERNOR TO EXPRESS THE
GOVERNOR'S AND MY CONCERNS ABOUT THE THREATS TO PUBLIC HEALTH
AND SAFETY POSED BY THIS PLANT, AND TO INSIST, ON BEHALF OF THE
PEOPLE OF THE COMMONWEALTH OF MASSACHUSETTS, UPON TWO VERY
REASONABLE, SPECIFIC ACTIONS. FIRST, THAT THE NRC HOLD AN
ADJUDICATORY HEARING HERE, IN PLYMOUTH, BEFORE THIS PLANT
OPENS. SECOND, THAT PILGRIM NOT BE ALLOWED TO REOPEN UNTIL THE
EMERGENCY EVACUATION CONCERNS OF BOTH FEMA AND GOVERNOR DUKAKIS
HAVE BEEN SATISFACTORILY RESOLVED.
326
IN JUNE 1986, THE NRC AND BOSTON EDISON ANNOUNCED THE
TEMPORARY CLOSING OF THE PILGRIM PLANT, BECAUSE OF SERIOUS
CHARGES CONCERNING THE SAFETY AND MANAGEMENT OF THE FACILITY. I
WILL NOT DWELL ON THE SPECIFICS OF THIS MATTER. MR. AGNES, THE
ASSISTANT SECRETARY OF PUBLIC SAFETY AND DR. PROTHROW-STITH , THE
COMMISSIONER OF PUBLIC HEALTH, ARE PREPARED TO PROVIDE DETAILED
DOCUMENTATION TO YOU AND THE COMMITTEE ABOUT THE CONCERNS
GOVERNOR DUKAKIS AND I SHARE.
SINCE THE CLOSING OF THE FACILITY, GOVERNOR DUKAKIS HAS
LAID OUT THREE PRECONDITIONS FOR ITS REOPENING; PUBLIC HEALTH
AND SAFETY fi^E AT THE CRUX OF THOSE CRITERIA.
FIRST, THE INADEQUATE SAFETY PRACTICES AT THE PLANT MUST BE
CORRECTED; SECOND, THE MANAGEMENT PROBLEMS MUST BE RESOLVED; AND
THIRD, THE EVACUATION PLAN MUST BE ADEQUATE.
THESE THREE CRITERIA HAVE BEEN OFFERED AS REASONABLE
DEMANDS FOR THE OPERATION OF A NUCLEAR POWER PLANT IN A
HEAVILY-POPULATED AREA. AND THESE THREE CRITERIA HAVE NOT YET
BEEN MET BY BOSTON EDISON. THIS ADMINISTRATION HAS THE
RESPONSIBILITY TO PROTECT OUR CITIZENS. OUR INSISTENCE THAT THE
PLANT BE OPERATED WITH PROTECTION OF PEOPLE'S HEALTH AND SAFETY
AS THE FOREMOST GUARANTEE IS ABSOLUTELY NON- NEGOTIABLE . .
327
t-IY OWN RESERVATIONS ABOUT PILGRIM AND NUCLEAR POWER IN
GENERAL, DATE BACK TO 1975, WHEN I SERVED AS SECRETARY OF
ENVIRONMENTAL AFFAIRS IN THE FIRST DUKAKIS ADMINISTRATION. AT
THAT TIME, I REJECTED THE DRAFT ENVIRONt'lENTAL IMPACT REPORT FOR
PILGRIM II BECAUSE OF UNRESOLVED WASTE DISPOSAL PROBLEMS AND
QUESTIONS ABOUT PLANT SAFETY. THESE ISSUES REMAIN UNRESOLVED TO
THIS DAY.
SO, MY RESERVATIONS HAVE BECOME RESOLUTIONS: RESOLUTION TO
PREVENT OUR SAFETY AND ECONOMIC HEALTH BEING HELD HOSTAGE TO ANY
ONE POWER SOURCE; AND RESOLUTION TO WORK TOWARD THE DEVELOPMENT
OF SAFE, RELIABLE, NON-NUCLEAR ENERGY.
AS YOU DELIBERATE ON THE FUTURE OF THE PILGRIM PLANT,
PLEASE DISREGARD THE ISSUES INVOLVING SUPPLY AND DEMAND ON THE
NEW ENGLAND POWER GRID. LET ME BE VERY CLEAR: WE HAVE
SUFFICIENT ENERGY GENERATING CAPACITY FOR ALL BUT THE MOST
UNUSUAL SITUATIONS. AS A MATTER OF FACT, TUESDAY NIGHT, DEMAND
HIT A RECORD-BREAKING PEAK OF 18,471 MW, AND WAS MET THROUGH
CONTINGENCY PURCHASES AND OTHER STANDARD OPERATING PROCEDLTRES.
SO, MEETING EVEN UNUSUALLY HIGH ELECTRICITY DEMANDS IS POSSIBLE
WITHOUT PILGRIM, WITHOUT SEABROOK, AND WITHOUT CRISIS.
TODAY'S PROBLEMS OF TIGHT ENERGY IN NEW ENGLAND DERIVE FROM
LACK OF JUDICIOUS MAINTENANCE SCHEDULING AND PRACTICE; A LACK OF
AGGRESSIVE PERFORMANCE TO EASE DEMAND THROUGH CONSERVATION AND
LOAD MANAGEMENT: AND A LACK OF STRONG PURSUIT OF SMALL SCALE
POWER PLANTS TO AUGMENT SUPPLY.
328
IN RECENT MONTHS THE STATE HAS BEEN VERY ACTIVE. THE
GOVERNOR HAS ASKED ME TO WORK WITH SECRETARY POLLARD, SECRETARY
GOLD, SECRETARY HOYTE , THE DEPARTMENT OF PUBLIC UTILITIES, THE
DEPARTMENT OF CAPITAL PLANNING AND OPEPvATIONS AND THE GOVEPJ^OR'S
ECONOMIC DEVELOPMENT OFFICE SO THE STATE CAN MOVE AGGRESSIVELY
ON THESE INITIATIVES TO AUGMENT SUPPLY AND DANfPEN DEMAND. AND
WE ARE DOING JUST THAT.
HAVING EXPRESSED THESE CONCERNS TO YOU, SENATOR, I MUST SAY
I REALIZE HOW DIFFICULT IT IS FOR YOU, GOVERNOR DUKAKIS, ME AND
OTHER RESPONSIBLE PUBLIC OFFICIALS TO MAKE ANY HEADWAY AGAINST
AN UNRESPONSIVE FEDERAL BUREAUCRACY, A BUREAUCRACY THAT REALLY
DOESN'T SEEM TO CARE ABOUT THE HEALTH AND SAFETY OF THE CITIZENS
OF THIS STATE. IT SEEMS TO ME THAT THE NUCLEAR REGULATORY
COMt'lISSION HAS BEEN SURPRISINGLY NON-RESPONSIVE IN DEALING WITH
THE MASSACHUSETTS GOVERNMENT AND THE PUBLIC ABOUT THIS
FACILITY.
LET ME BE SPECIFIC. IN JULY OF 1986, I JOINED SENATOR
WILLIAM GOLDEN, MASSPIRG AND MANY OTHERS IN SIGNING A SHOW CAUSE
PETITION ADDRESSING THREE POINTS: REACTOR SAFETY; EMERGENCY
PLANNING; AND MAINTENANCE. THE NRC RATHER CALLOUSLY DISMISSED
THE FIRST TWO, AND DEFERRED CONSIDERATION OF THE THIRD POINT.
MASSPIRG HAS APPEALED THE DENIALS, AND ATTORNEY GENERAL JAMES
SHANNON IS NOW AN INTERVENER IN THE APPEAL; YET THERE HAS BEEN
NO RESPONSE. I FIND THIS VERY DIFFICULT TO ACCEPT.
329
IN OCTOBER, 1987, GOVERNOR DUKAKIS AND ATTORNEY GENERAL
JAMES SHANNON FILED A SHOW CAUSE PETITION ASKING FOR AN
ADJUDICATORY HEARING ON WHETHER THIS PLANT SHOULD BE ALLOWED TO
REOPEN. THERE HAS BEEN NO RESPONSE.
NOR HAS THE NRC RESPONDED IN A SUBSTANTIVE MANNER TO THE
TWO REPORTS ON PILGRIM, PREPARED BY SECRETARY OF PUBLIC SAFETY
CHARLES BARRY AND SUBMITTED BY GOVERNOR DUKAKIS, THE FIRST IN
DECEMBER 1986, THE SECOND IN DECEMBER 1987.
AND, SENATOR, I UNDERSTAND THAT THE NRC HAS DENIED THE
REQUEST WHICH YOU AND CONGRESSMAN GERRY STUDDS SUBMITTED ASKING
FOR AN ADJUDICATORY HEARING ON PILGRIM.
THE NRC HAS INDICATED THAT IT WILL MEET WITH THE
PETITIONERS. THIS IS UNACCEPTABLE. THE CITIZENS OF THIS STATE
HAVE THE RIGHT TO SEE THIS CASE ARGUED IN A FORMAL SETTING. I
WOULD ENCOURAGE YOU, SENATOR, TO DO EVERYTHING IN YOUR P0\7ER TO
SEE THAT THIS HEARING TAKES PLACE. YOU WILL HAVE THE GOVERNOR'S
AND MY FULL SUPPORT IN YOUR EFFORTS.
WHAT THE GOVERNOR AND THE PEOPLE OF MASSACHUSETTS HAVE PUT
FORTH ARE SPECIFIC AND REASONABLE REQUESTS AND SUGGESTIONS. BUT
WHEN CONFRONTED BY SUCH BUREAUCRATIC STONEWALLING, A VOICE OF
REASON COULD BECOME TRANSFORMED INTO A VOICE OF OUTRAGE. IT IS
AN UNCONSCIONABLE ATTITUDE ON THE PART OF A PUBLIC AGENCY
SUPPOSEDLY CHARGED WITH PROTECTING PUBLIC HEALTH AND SAFETY.
330
IN CLOSING, LET ME MAKE ONE FINAL POINT REGARDING FEMA AND
THE NRG. AS YOU KNOW, CURRENTLY FEMA ' S ROLE IS STRICTLY
ADVISORY. HOWEVER, THE SITUATION HERE IS A PRIME EXAMPLE OF HOW
THE NRC COULD OVERRULE THE RECOMMENDATIONS OF BOTH THE GOVERNOR
OF A STATE AND ITS OWN ADVISORY BODY BY ALLOWING PILGRIM TO
REOPEN DESPITE FJCPERT OPINION TO THE CONTRARY. THIS IS AN
ABSURDITY. THE GOVERNOR AND I WOULD WHOLEHEARTEDLY SUPPORT ANY
CONGRESSIONAL EFFORT TO GET LEGISLATION PASSED WHICH WOULD
REQUIRE THE NRC TO BE BOUND BY THE RECOMMENDATIONS OF A GOVERNOR
AND FEMA.
FOR MASSACHUSETTS, THIS WOULD MEAN THAT PILGRIM WOULD NOT
RESTART UNTIL THE PEOPLE OF MASSACHUSETTS WERE SATISFIED WITH
THE EMERGENCY PLANS.
THANK YOU.
331
The Chairman. Thank you very much. We're grateful for your
presence here, for your taking the time.
(Let me ask you. Given the Governor's position on the Seabrook
amt on the Pilgrim, what is the implication, due to the fact that
nuclear power provides some 33 percent of the power resources for
New England, if Seabrook isn't opened and Pilgrim is not re-
opened, what are the energy implications going to be in terms of
Massachusetts, and responding first of all, and then respond to the
point that the legislators made in terms of increasing pressures in
term of the growth in the future. How are we going to deal with it?
Lieutenant Governor Murphy. Well, I think those matters go
hand in hand. We have right now sufficient energy on the power
grid to respond to even the most extreme matters that we see right
now, for instance that we had this summer.
The real issues before us are how to move now to augment our
supply. There are lots of proposed plants for small scale cogenera-
tion, hydroelectric, environmentally sound, small scale plants now
in the licensing proceedings within the State government — we are
looking to expedite those. There is the equivalent of one Pilgrim
plant right now within that licensing procedure. So we can see
ways in the short term to augment supplies. I think we can also
see ways in the short term to dampen some of the demands, conser-
vation and load management procedures, and also to take some
action which even includes the planning, which we have been
doing the last couple of days, to ask the utility companies to get
more aggressive concerning interrupting rate contracts.
So in the short term. Senator, we believe very strongly that there
is sufficient power for not only meeting today's demands, but in the
short-term summer growth. Over the longer trek, there is no doubt
that in the mid 1990's, the Federal Reserve Board study is a wise
and sound one, and that we'll need to look at some larger scaled
plants to be brought on line. That explains some of the Governor's
initiatives around natural gas, and the initiatives right now to look
at increased resources from HydroQuebec, and our looking at even
Edgar Station.
So we see a way right now of moving from the overreliance of
nuclear power to other options, diversifying what we have for all of
New England power, which makes us feel safer and insures the
kind of reliabilities, so that we can continue to have a sustained
economic growth and the jobs that we now enjoy, but it means get-
ting on with this. And I think the faster we can put to rest the con-
troversies of nuclear power and all the other options, the healthier
and safer and more reliable our energy sources are going to be.
The Chairman. I thank you very much. I think in your summa-
tion of the three major criteria which are necessary before you and
the Governor will support an opening of the plant, you have cap-
sulized the essence of the argument. All the rest of your presenta-
tion certainly supports it. I want to thank you very much for
Lieutentant Governor Murphy. Thank you.
The Chairman [continuing]. Joining us. We're grateful for your
participation in this matter. Thank you.
Our next witness is our Attorney General Jim Shannon. He is a
long-time, personal friend of mine, who was very much involved in
the Pilgrim question even before he assumed his present position.
332
He is an uniquely qualified person. Some of the ramifications of
the legal relationships between the State and Federal government
in the nuclear power field, this is an issue I know, General, that we
heard about earlier in the course of our hearing, but there have
been a good deal of comments from a number of witnesses about
how this relationship could be adjusted or changed, in order that
the principal health concerns and safety concerns and the manage-
ment concerns can be addressed by the public and by the State offi-
cials. So we're enormously interested in your own views on those
subjects, as well as what the current state of the situation is, and
what actions you are proposing to take should there be a decision
to move ahead. We look forward to your testimony, and we'll ask
you to be kind enough to stand.
[Attorney General Shannon sworn.]
STATEMENT OF ATTORNEY GENERAL JAMES SHANNON
Mr. Shannon. Thank you, Senator Kennedy. I want to thank
you for holding this hearing this evening, and also for the leader-
ship that you have brought to this very important issue to the
people of the Commonwealth and in the U.S. Senate.
The issue before you, the health implications of restarting the
Pilgrim nuclear power plant is one of tremendous importance to
everybody in the Commonwealth, but particularly to those people
who are neighbors to this plant. I commend you, too, for coming
here tonight so that the people who have been shut out of the proc-
ess can finally be heard.
The facts of this case have been very well documented. The NRC
currently ranks Pilgrim as one of the worst managed plants in the
country. This past summer, the General Accounting Office reported
that most of Pilgrim's management deficiencies remained uncor-
rected. In 1982, the NRC fined Boston Edison $550,000 for submit-
ting false information to the NRC and improperly operating Pil-
grim.
By 1985, the utility had paid additional civil penalties totaling
$90,000. In fact, between 1983 and 1985, the NRC cited Pilgrim for
52 violations, ranging from operations to surveillance and radiolog-
ical control. Finally, in April 1986, Boston Edison shut Pilgrim
down.
These facts compel an open process, one in which Boston Edison
will be required to prove to the public that its problems are solved.
Instead, it appears the NRC intends to decide the fate of this plant
on the basis of a closed inspection and evaluation.
The people of the Commonwealth deserve better than that. No
one should consider reopening the Pilgrim nuclear power plant
until there has been a full adjudicatory hearing, which clearly
demonstrates that these problems have been solved.
Senator Kennedy, both you and Congressman Studds have been
forceful in calling for these hearings. The NRC's response that a
public meeting be held is completely inadequate, if we are to insure
public health and safety.
In 1986, before my election as attorney general, I was a petition-
er along with several others here tonight, calling for a full adjudi-
catory hearing on the reopening of this plant. As Attorney Gener-
333
al, I, along with Governor Dukakis, filed a second petition for the
same full legal proceeding. The NRC essentially rejected the first,
and has yet to act on the second. The private petitioners have ap-
pealed the rejection by the NRC, and my office is taking a lead role
in that litigation.
I continue to be deeply concerned, not only about the threat this
plant poses to public health and safety, but the unwillingness of
both the utility and the NRC to address both these issues in an
open hearing. The NRC has a formal hearing process and they
should use it if they expect to restore public confidence in this pow-
erplant.
These two petitions are straightforward. They call for the NRC
to hold a hearing in which Boston Edison must prove it can operate
this plant safely and effectively; a hearing in which we can cross
examine the company's and the NRC's experts, and offer our own
independent experts to review the facts; a hearing in which the
NRC must issue a written decision which is subject to review in
courts. The public deserves a full hearing on the safety of this trou-
bled nuclear plants. Boston Edison must be held to a burden of
proof in an adjudicatory hearing to show that it can operate the
plant safely, something which it has yet to prove.
Over the past year as attorney general, I've been deeply involved
in the very serious questions surrounding the regulation of the nu-
clear power industry, both here at Pilgrim and through the licens-
ing process of the Seabrook plant in New Hampshire. Last year, I
created a nuclear safety unit in the attorney general's office be-
cause it was clear to me that these issues demanded special re-
sources and technical expertise if we were to meet the industry on
level ground. I always expected the nuclear industry to be a formi-
dable adversary but what I did not expect to find was the Nuclear
Regulatory Commission intent on insulating itself from public par-
ticipation and public process.
In Seabrook we have seen it evidenced time and time again, but
most recently and most blatantly in the Commission's decision to
change the rules and attempt to knock Massachusetts out of the; li-
censing process. And on that issue we'll meet the NRC in court.
Here at Pilgrim, we see it again in the failure of the NRC to allow
a full adjudicatory hearing on the many questions surrounding this
troubled plant. Should the NRC reject the Commonwealth's pend-
ing petition for enforcement action, then I'm prepared to take that
issue to court. The NRC should require a full adjudicatory hearing
on these issues. It has, after all, cited the plant repeatedly for its
mechanical and safety and management problems.
The issues that have brought you here tonight, the health impli-
cations of restarting this plant are both real and deadly serious.
We simply cannot allow this federal agency to continue its closed
door deliberations on a matter of this magnitude. As Attorney Gen-
eral I will use the full resources of my office to hold this utility and
this Commission accountable to the people of the Commonwealth
who deserve real answers obtained in a formal public hearing proc-
ess.
I know, Mr. Chairman, that you and the members of your com-
mittee will continue to press the NRC for such a responsible public
response.
334
I would also like to say, Senator Kennedy, that I'm deeply disap-
pointed that the management of Boston Edison has refused to par-
ticipate in tonight's hearing. They are in this room; they are sitting
in the audience. If we are to trust them, they should be at least
willing to come forward and state their case to you and to the
people of this area.
[Applause]
Mr. Shannon. I think their management has been characterized
by an ostrich-like quality for the last several years. They tell us
things have changed. I think their failure to participate tonight
raises serious questions as to whether we should trust them, and I
hope that they will join us in requesting of the NRC a full process
where they can make their case in a way that might restore confi-
dence in management and leave the people of Massachusetts feel-
ing that their health and safety will be adequately protected if Pil-
grim is ever to go back on the line.
[The prepared statement of Attorney General Shannon follows:]
335
TESTIMONY OF
ATTORNEY GENERAL JAMES SHANNON
BEFORE THE SENATE COMMITTEE ON LABOR AND HUMAN RESOURCES
JANUARY 7, 1988
Thank you, Senator Kennedy, for holding this hearing. The
issue before you — the health implications of restarting the
Pilgrim Nuclear Power Plant — is one of tremendous importance
to everyone in the Commonwealth, but particularly to those
people who are neighbors to this plant. I commend you, too,
for coming here tonight so that the people who have been shut
out of the process can finally be heard.
The facts of this case have been well documented:
-- The NRC currently ranks Pilgrim as one of the worst
managed plants in the country.
-- This past summer, the General Accounting Office
reported that most of Pilgrim's management
deficiencies remain uncorrected.
— In 1982, the NRC fined Boston Edison $550,000 for
submitting false information to the NRC and improperly
operating Pilgrim.
— By 1985, the utility had paid additional civil
penalties totalling $90,000.
— In fact, between 1983 and 1985, the NRC cited
Pilgrim for 52 violations ranging from operations, to
surveillance and raaiological controls.
— Finally, in April 1986, Boston Edison shut Pilgrim
down.
These facts compel an open process, one in which Boston
Edison will be required to prove its public claims that its
336
problems are solved. Instead, it appears the NRC intends to
decide the fate of this plant on the basis of a closed
inspection and evaluation. The people of the Commonwealth of
Massachusetts deserve better than that. No one should consider
reopening the Pilgrim Nuclear Power Plant until there has been
a full adjudicatory hearing which clearly demonstrates that
these problems have been solved.
Senator Kennedy, both you and Congressman Studds have been
forceful in calling for these hearings. The NRC's response
that a public meeting be held is completely inadequate if we
are to ensure public health and safety.
In 1986, before my election as Attorney General, I was a
petitioner calling for a full, adjudicatory hearing on the
reopening of this plant. As Attorney General, I filed a second
petition for the same, full legal proceeding. The NRC
essentially rejected the first and has yet to act on the
second. The private petitioners have appealed the NRC decision
and my office is taking a lead role in that litigation.
I continue to be deeply concerned not only about the
threats this plant poses to public health and safety, but the
unwillingness of both the utility and the NRC to address those
serious issues in an open hearing. The NRC has a formal
hearing process and they should use it if they expect to
restore public confidence in this power plant.
These two petitions are straightforward — they call for
the NRC to hold a hearing in which Boston Edison must prove it
can operate this plant safely and effectively. -- A hearing in
-2-
337
which we can cross examine company and NRC experts and offer
our own independent experts to review the facts. -- A hearing
in which the NRC must issue a written decision which is subject
to review in the courts.
The public deserves a full hearing on the safety of this
troubled nuclear plant. Boston Edison must be held to a burden
of proof in an adjudicatory hearing to show that it can operate
the plant safely something which it has yet to prove.
Over the past year as Attorney General, I have been deeply
involved in the very serious questions surrounding the
regulation of the nuclear power industry both here at Pilgrim
and through the licensing process of the Seabrook Plant in New
Hampshire. Last year, I created a Nuclear Safety Unit in the
Attorney General's office because it was clear to me that these
issues aemanded special resources and technical expertise if we
were to meet the industry on level ground.
I always expected the nuclear industry to be a formidable
adversary. But what I did not expect to find was a Nuclear
Regulatory Commission intent on insulating itself from public
participation and public process. In Seabrook, we've seen it
evidenced time and time again, but most recently and most
blatantly in the commission's decision to change the rules --
an attempt to knock Massachusetts out of the licensing
process. And on that issue, we will meet the NRC in court.
Here, at Pilgrim, we see it again in the failure of the NRC
-3-
338
to allow a full adjudicatory hearing on the many questions
surrounding this troubled plant. Should the NRC reject the
Commonwealth's pending petition for a hearing, then I am
prepared to take that issue to court.
The NRC should require a full adjudicatory hearing on these
issues. It has, after all, cited the plant repeatedly for its
mechanical, safety and management problems.
The issue that has brought you here tonight -- the health
implications of restarting this plant -- are both real and
deadly serious. We simply cannot allow this federal agency to
continue its closed door deliberations on a matter of this
magnitude.
As Attorney General, I will use the full resources of my
office to hold this utility and this commission accountable to
the people of the Commonwealth who deserve real answers
obtained in a formal public hearing process. I know, Mr.
Chairman, that you and the members of your committee will
continue to press the NRC for such a responsible, public
response.
Thank you.
-4-
339
The Chairman. Thank you very much, Attorney General Shan-
non. Let me ask you a few questions. Maybe you can review with
us for just a few minutes, what the legal situation is relevant to
the State of Massachusetts and the NRC, should the NRC plan to
give approval for the start-up of Pilgrim I. What powers reside in
you and the state to affect that decision? Maybe you could discuss
that for us if you will.
Mr. Shannon. I'll be happy to. As has been pointed out by previ-
ous witnesses, there are really two petitions which have been filed,
one which has been essentially rejected by the NRC. The Common-
wealth is now involved as intervenor on appeal of that decision.
The other one is
The Chairman. What is that?
Mr. Shannon. That is the petition which was put together by
MASSPIRG included a number of members of the State legislature,
myself, and Lieutenant Governor Murphy, and was filed during the
summer of 1986.
In the fall of 1987, I filed on behalf of Governor Dukakis and
myself another petition, based on some of the old concerns that we
had and some new ones which had been raised about this particu-
lar reactor and which had come to light after the Barry report on
evacuation planning. We're waiting for a decision from the Nuclear
Regulatory Commission on that petition.
If the NRC denies us a hearing after that process, then we'll take
that matter to the Federal court, it is our right. There has been
some suggestion that the Federal regulation completely preempts
state officials from acting to protect the health and safety of the
public; well, we don't accept that for a moment. I think that Gover-
nor Dukakis, myself, other responsible state officials have implicit
authority to act to protect the people of Massachusetts and we're
willing to act to protect the people of Massachusetts, and we're
willing to assert those arguments in court as well around the Pil-
grim plant as we are around the Seabrook nuclear plants.
The Chairman. You wouldn't draft the law the way it is now?
Mr. Shannon. That's right, Senator. I think I would be a little
clearer about where the Federal Government's authority ends and
the States' begins. What is clear though, and I was in the Congress
when that legislation was being debated, as were you, and what is
clear is that in and post-Three Mile Island era. Congress intended
for the States to play a very important role along with the Federal
Government to actively protect their own citizens.
As a matter of fact, the premise of all congressional action was
that people could not be protected unless the states were included
in that process. So I don't yield for a moment to the notion that we,
the state officials, do not have the authority to act to protect people
from the dangers of a poorly managed or poorly constructed power
plant.
The Chairman. I think that you should know that some of the
NRC people are very adamant; they say that they'll be darned if
they will let these nuclear powerplants be held hostage to the
whims of the states. How do you react to that?
Mr. Shannon. I've heard that suggestion from some people in
the NRC. The notion that that we are acting arbitrarily and capri-
ciously, particularly in this case, is just outrageous.
340
This is documented to be, by the NRC, one of the most poorly
managed nuclear powerplants we have ever seen in the history of
nuclear power. As late as just a few months ago, further deficien-
cies were pointed out in the way in which the Pilgrim nuclear
power plant has been run, by the Nuclear Regulatory Commission.
They have fined Boston Edison in the past, and yet these deficien-
cies have not been corrected. Serious questions have been raised
about this reactor over the period of the last year, so the notion
that we are acting at all arbitrarily or that this plant is being held
hostage, is, I think, an affront, and I don't think that the people of
the Commonwealth are going to buy that and I don't think people
around the country will either.
The Chairman. You are familiar with the MASSPIRG report on
the economic implications of a permanent shutdown of Pilgrim?
Mr. Shannon. I am.
The Chairman. Then you know that they conclude that the utili-
ty customers would actually save money if that happens; is that
right?
Mr. Shannon. That's right.
The Chairman. Have any of your people in the attorney gener-
al's office looked at that question?
Mr. Shannon. Yes, Senator, we have looked at the MASSPIRG
report. We do find it of real value as part of our evaluation. We are
looking at the question of economics at Pilgrim right now. While I
can't give you a definitive answer, I can say this. On the basis of
the study we have done to date, we have concluded that at best.
Pilgrim is now marginally economic. I think of the safety concerns
apart from the economics because I don't think that there is any
price we can put on the health and safety of the people who live in
the areas around nuclear power plants.
[Applause.]
Mr. Shannon. But apart from the safety concerns that I've got,
we must look at those economic questions and I think that when
we look at them, we are going to find a lot of what MASSPIRG has
said proves to be absolutely correct.
The Chairman. Is it safe for me to assume that if a decision is to
move ahead, that you are going to exercise all the rights as attor-
ney general in every possible way to do everything that you possi-
bly can to insure that that eventuality does not come about?
Mr. Shannon. Senator, as you know and the people of the Com-
monwealth know, we have been very actively involved over the last
year in asserting, at every point we can, the rights of the people of
the Commonwealth in protecting them against the Seabrook power
plant. I want to say here tonight that I feel equally about the Pil-
grim nuclear power plant. The Pilgrim nuclear power plant has
the added disadvantage of a proven record of mismanagement on
the part of the utility company which manages them, and I intend
to fight just as hard to protect people around Pilgrim as we have
around Seabrook.
[Applause.]
Mr. Shannon. Senator, I would like to ask that the petition filed
by Governor Dukakis and myself be included in the record.
[The petition referred to follows:]
341
UNITED STATES OF AMERICA
BEFORE THE NUCLEAR REGULATORY COMMISSION
PETITION OF MICHAEL S. DUKAKIS, GOVERNOR AND
JAMES M. SHANNON, ATTORNEY GENERAL FOR THE
INSTITUTION OF A PROCEEDING PURSUANT TO
10 C.F.R S2.202 TO MODIFY, SUSPEND, OR
REVOKE THE OPERATING LICENSE HELD BY
THE BOSTON EDISON COMPANY FOR THE
PILGRIM NUCLEAR STATION
Dated: October 15, 1987
342
'i. ^;
:-::^:j::::;-i
zr.D-zMi :.- 3£.-^::'J5 AA:i\zz?.:\i o- f :::e-]c:;s 3
iv. j/£R/:iV 3
3. 3e::d'3 pas: pe?,- dr:ianc£ 4
iEZ^'s 3A1? Evaluaf.ons 5
3£:o'3 '.eg^laiDcy Viola': i op.s
;. I'.zzz-.'.z ;:;^:::a o? 3ECo's ?E::^FOR'iA"iCE level .... 9
SEZd's 193" 3A1? Report "- "'
Rec3-:i Reoorto of Violations 2
-/:je:ice iha: indizates thai .a plast specific
= RA fZll-O.VED 3^: I'IPLEMENTATION OF AMY INDICATED
SAFilr AZDlZ:Z\-:y.iS SHOJLD 3£ REQUIRED PRIDR
:z p:'-3r:'V3 restart • • 1-2
r _• - J -■ — r - r " ; i. J £ -J \ TE E'^ERGENCY PREPAREDNESS ... 15
343
aSFORS THE 'i'JCLz.\R RE^'JLATDRY 3 0«''! I 33 : 3>l
PETinON DF MICH'VEL S. DUKAKIS, lOVER-jQR i,-;D
JAMES '1. 3HANM0M, ATTORNEY GENERAL -OR "-{-.
INSTITUTION OF A PROCEEDING PURSUANT TO
10 C.r.R §2.202 TO MODIFY, SUSPEND, OR
REVOKE THE OPERATING LICENSE HELD 3Y
THE BOSTON EDISON COMPANY FOR THE
PILGRIM NUCLEAR STATION
I. INTRODUCTION
Governor Michael 3. Dukakis and Attorney General
JaTies M. Shannon, pursuant to 10 C.F.R. §2.206, hereby request
that the Director of the Office of Nuclear Reactor Regulation
institute a proceeding pursuant to 10 C.F.R. §2.202 to -nodify,
suspend, or revoke the operating license ^Id oy 3oston "dison
Co.-ipany ("3EC-." or "the Co-ipany" ) for t-e Pilgrim Nuclear
Po^er Station '"PilgriTi") in Plynouth, Ma -sachuset t s . This
petition is filed on behalf of the ConTionwea It h of
Massachusetts and its citizens. The Governor and the Attorney
General oase this request on evidence of continuing serious
nanagerial deficiencies at the plant, on evidence that a clant
specific prooabi list ic risk assessment ("PRA") as well as :-.e
implementation of any safety modifications indicated thereby
should be required prior to Pilgrim's restart, and on evidence
that the state of emergency oreparedness does not orovide
reasonaole assurance that adequate protective measure; can and
344
will be taken in the event of a raaiDloqical energenc/ i^ri-.^
operations at the Pilirm olant. The Governor and f'-e Xttor-.ev
General submit that this evidence, as set forth oelow,
demonstrates the necessity of Nuclear Regulatory Com-iission
("NRC") action pursuant to 10 C.F.R. §2.202.
Further, the Governor and the attorney General oelieve that
the puDlic interest requires that the SRC exercise its
authority under 10 C.F.R. §2.202(f)-^ so that SECo. is
prevented from proceeding any further -^ith the restart of
Pilgrim— until a formal adjudicatory hearing has been held
and findings of fact are made concerning the safety questions
surrounding the continued operation of the Pilgrim plant. In
particular, the Governor and the attorney General request that
the 'ARC issue an order, effective immedi = -ely, modifying 3SCo's
operating license to preclude 3ECo. from -aking any steos m
1/ 10 C.E.R. 2.02(f) provides:
•Vhen the Executive Director for Operations/
during an emergency as determined ":>'/ the "00, or
the Director of "luclear Reactor Regulation,
Director of Nuclear Material Safety and
Safeguards, Office of Inspections and
Enforcement, as appropriate, finds that the
public health, safety, or interest so requires
or that the violation is willful, the order to
show cause may provide, for stated reasons, tr.at
the proposed action be temporarily effective
pending further review.
2/ At each step of BECo's so-called "power ascension"
program there is an increase in the probability of an
accident at Pilgrim as well as in the ootential
consequences of such an accident. See Affidavit of
Steven C. Sholly (attached hereto as Attachment 1).
- 2 -
345
Its power ascer. 3.3r. pr^gra^n ^nt^l the hearing is nald and i-^. e
findinqs are made.
Recent events at Pilgri.'n indicate that 3'=:Co. has not
corrected the lonq-standmg ^anaqerial shortcomings that have
olagued the plant. In the areas of security, radiological
controls, personnel management, and corporate culture, the
-nanagement of Pilgri-n continues to be seriously flawed. ^s a
result, Pilgrim poses an unreasonable risk to puolic health and
safety. Its continued operation under the present ;
circumstances is ni7\ical to puolic health and safety.
^. 0VERVI3W
PilgriTi commenced co.7.mercial operatio- in June, 1972, when
3ECo. received an operating license for t-e plant. During the
intervening fifteen year period of operation by 3SCo., Pilgrim
has nad a capacity factor of approximately 50 percent, -
which compares quite unfavorably with the average for all "ew
England nuclear plants of approximately 67 percent. -
4/
2/ The "caoacity factor" for a plant is a measure of
oerformance" in terms of the power it has actually delivered
over a period of time relative to the power it was caoaole of
delivering over that same period of time. It is calculated by
dividing the actual number of kilowatt hours oroduced oy the
plant m the period of measurement by the product of the
plant's rated" kilowatt capacity and the numoer of hours m the
period.
4/ Electric Council of New England, New England Nuclear News,
fjune, 1937) (Attached hereto as Attachment 2) .
346
3. 3E.:-'3 PAST ?ERrO?>V'-:
ilanc has 09en oat of service
\pz.'., 19S6, w-
the NRC, m Conf 1 nat ory Actior. letter 36-10, oraered a
shutdown after rec_imng operational proble-^s at the pla-.t.-
?ilqri.T> has been beset with managerial probleiis from tne
outset. 3ECo. has consistently received low ratings m the
VJac's Systematic Assessment of Licensee Performance ("SAL?")
reoorts. Pilgrim has been identified by the 'JRC as one of t-.e
worst run and least safe plants m the country- and 3ECo.
was ordered to initiate performance/management improvement
programs in 1982 and 1984.- 3ECo. has been the subject of a
long line of enforcement actions as a result of regulatory
violations. While the NRC's efforts to spur 3ECo. to a higher
level of oerformance have, on occasion, met with some initial
success, a review of 3ECo's performance -^cord, however, shows
that all such successes have been short l.ved. Indeed, 3ECo.
5/ Confirmatory \ction Letter 36-10 was clarified and expanded
Tn an suosequent letter, dated August 27, 1937, from the MRC
Region 1, Regional Administrator to 3ECo's Chief Operating
Officer. (attached hereto as Attachment 3). In this letter,
3SCo. was informed that:
In light of the number and scope of the
outstanding issues, I (the Regional
Administrator) am not prepared to aporove
restart of the Pilgrim facility until you
(BECo.) provide a written report that documents
3ECo's formal assessment of the readiness for
restart operation.
5/ 3oston Olobe, May 23, 1986.
7/ Order 'lodifymg License Effective Immediately, 47
Fed. Reg. 4171 (January 23, 1987).
347
appears co r.ave an organic inaoility to -nanage Pilgm
a n
effective and safe iianner.-
3/
* * aRPn '
3ECo's S\LP Evaluations
3ECo. has consistently received low ratings m SAL?
9/
report s .-
8/ Altho'jqh It IS the f
Pilgrim plant which are
significant that finding
confirm 3ECo's manageria
extend to the other aspe
Edison Company, "^assachu
Docket No. 87-lA-A (1987
generating unit). Of pa
3ECo. responds to the id
half-hearted (although s
solutions that treat the
series of decisions by t
Utilities that address 3
sources of power in the
the construction of the
Company, MDPU 905 (1982)
to meet its future power
■.'Jo. 36-270 (found reason
and/or skill to fulfill
ailings of 3ECo's
the subject of th
s have been "nade
1 deficiencies an
ct s of Its busine
setts Department
) ( imprudence in
rticuiar relevanc
entification of d
ometimes quite sh
symptoms, not th
he f^assachuset t s
ECo's need to co-.
aftermath of the
Pilgrim II nuclea
(ordering BECo.
needs); Soston "
to believe 3ECo
public service ob
management of the
is pet It ion, it is
in other settings tha
d indicate that thev
ss . See e.g. , 3os
on
of Public Utilities
operation of oil fired
e to the notion that
eficiencies with
owy) , short-term
e disease, is the
Department of Public
■■-der and develop new
.991 cancellation of
3oston
son
' unit
-. 0 develop a new "plan
iison Company, MDPU
lacked commitment
ligat ion)
9/ The 3ALP process is the mechanism by which the NRC on a
periodic oasis -systematically assesses the overall oerformance
of a licensee. For each assessment period (generally 12 to 13
months) a 3oard of NRC officials evaluates, in accordance with
preestaolished attributes and rating guidance, the licensee's
performance for each of the various, preest ablished functional
areas and rates the licensee's performance m each area. The
3oard also compares the licensee's performance for the current
period with that of the previous assessment period and
identifies, for further followup and inspection, any areas
where the licensee's corrective action to improve oerformance
has not been fully effective.
Arizona Public Service Company, (Palo Verde Nuclear Generating
Station, Unit 2), DD-86-8, 24 NRC 151, 156 (1986).
348
:n 135';, 3£Co. received ratings mdicacing sig*
1 : .ca- 1 >je-.<'.iB3
in three of the nine fanctional areas evaljated. The -lost
recent SAL? Report, seven years later, indicates that
conditions have not iTiproved but rather have vor~'ned. 3EC~.
received ratings indicating significant weaknesses m five of
the twelve fanctional areas evaluated. It has only once
received a SALP Report without a rating indicating a
significant weakness. On all other occasions, it has received
reports indicating significant weaknesses in at least two
functional areas. (See Appendix I: 3ECo. SALP History
Tabulat ion )
Of particular significance, every time Quality Assurance
has been assessed as a separate functional area during a SALP
review, 3ECo. has received the lowest po.--ible rating. These
findings are indicative of the inef f ect i /^ness of 3SCo's
-nanaqeTient . They are a neasure of its i-.aoility and/or its
lack of coTTiitTient to run the plant m a effective and safe
■nanner.
Although 3EC0. has at one tiie or anotner received the
lowest possible rating in all but three of the twelve
functional areas covered by the :)RC's SAL? process, these
individual poor SAL? ratings are not the nost troubling asoect
of 3ECo's SALP record. Instead, the -nost trouoling and telling
facet of 3ECo's SAL? record is the Conpany's distinct inability
to naintam any per iod-to-?eriod performance improvements.
3ECo. has at one time or another improved its SALP oerformance
- 6
349
in eignt fjnctionai areas. However, ic has not oeen ao'.e to
sustain the increased level of performance m seven of t-ose
eight areas. In all but one instance, 3ECo's I'^proved
perforTiance proved to be short-lived and its oerf oriiance
subsequently fell back to lower levels. This is not surprising
as an ever recurring the-ne in MRC evaluations of 3ECo'3
perfor'^ance is that NRC oversight and prompting is necessary at
1 0/
every stage of Pilgrim's operation. — The increased NRC
attention (i.e., oversight and prompting) that a "3" rating
calls for has, on occasion, produced better performance bv
3ECo. However, when that level of attention returns to that
norm, 3ECo's performance falls below the norm. BECo's 3ALP
track record is oroof of the proposition that BECo. by itself
has not effectively operated Pilgrim and ' nat the short-term
solutions It has adopted m response to :riticism have
mvariaoly permitted the reoccurrence of ---.e original oroolems.
** 3ECo's Regulatory Violations **
BSCo., an enforcement action record that is a mirror of its
3\L? Report record. It has had at least one Severity Level III
violation during each of the past six years. -=— ( See
10/
, g., 1987 S.MP Review at 3; 1936 SAL? Review at 7,
11/ \s set forth in 10 C.-.R. Part 2, Aipoendix C ; General
Statementof Policy and Procedure for NRC Enforcement Actions,
regulatory violations are categorized into five descending
levels of severity. Level III corresponds with "violations
tnat are cause for significant concern."
- 7 -
350
\ODi:-.i:-<
H2d. viol at: 3'J3 TAa'Jl.M'ION'S - SEVERITY LIV~1
VIOLATIDNS ) In Che area d? Sec^niy aTd Safe^jar^s, 3"Co. -.ai
a Severity Level III violation m all but one of fne years
oetween 1931 and 1936. In 1932, a civil oenalty m tne a-nount
of $550,000 -- at the tme the largest oenalty to have ever
oeen assessed by the NRC -- was levied against ?ECo. for
serious plant operations violations and for sabmitting false
information to the NRC. — While the number of such Severity
Level III violations discovered at Pilgrim has not exceeded two
m any single year since 1981, the number of Severity Level IV
violations per year has more than doubled in the past few years.
BSCo's enforcement action record also mirrors its SALP
Report record m demonstrating 3ECo's chronic recidivism. It
nas been cited five times for Radiologic =•. 1 Controls violations
involving vaste shipment packaging requirements. —
It has oeen cited five times for Security and Safeguards
violations involving the control of sensitive material such as
<eys to vital areas, security plans, and firearms. —
1_2/ U.S. General Accounting Office, Reoort to the Honorable
Mfonse M. D'Amato, U.S. Senate: Maclear Regulation Efforts to
Ensure N'uc^ear Power Plant Safety Can 3e Strengthened
(3AD-RCED-a7-141 August, 1987), pp. 36-3''.
13/ See NRC Enforcement Summary Tables taken from various SAL?
Reports (attached nereto as Attachment 4).
14/ Id.
351
c. ?;£C;.-.: ::;j:::a Or becd's =>:.-': j-^-'-/. ,z. ie/^i
'he Tiost recent indicia o-
level of 3lCd'3 oerfor-'a-.:
m Tianaging Pilgrm are consisten': with its past oerf or'^anc? .
They confirti the nocion that 9ECo. appears to oe orianically
incapable of Tianaging a nuclear facility. Notwithstanding the
frequent incantation by senior TianageTieht of a progra-n for t -.e
"pursuit of excellence," the addition of new personnel and the
expenditure of larg-? sums of Tioney, — the available evidence
indicates that 3ECo. has not changed. Its 1987 SALP Report
shows that the Company continues to merit the lowest possible
ratings in many functional areas. 3ECo. continues to be
incapable of maintaining performance gains. On the basis of
news reoorts, it appears that 3ECo's management of the Security
and Safeguards function is deteriorating, -ot improving,
"urther, -n the basis of statements made ■/ NRC officials at a
recent meeting, the :IRC has received and .s investigating
allegations that the company may be compromising safety oy
overworking its or its contractors' employees m an effort to
return the olant to service soon. This evidence sumests that
3ECo'3 claim to oe approaching readiness for restart may
15/ E.q,
NRC Docket ••10. 50-293, Offic
Office of Nuclear Reactor Regulation,
Edison Re: Pilgrim Status and ^ctivi
Readiness," pp. 13-14, 13-20 (Septemb
"9/24/37 MRC/3EC0. Readiness Meeting"
Steohen J. Sweeney, President and Chi
3oston Edison Company, to the 'J . S . 4o
Suocommittee on Energy Conversation a
on Energy and Commerce July 16, 1986,
as "Attachment 5" ) .
iciai
":iee
ties
er 24
). .(T
ef Ex
use 0
nd Po
. ra
t mg
Lead
,'l9
est 1
ecut
f Re
wer
4-5
n s c r 1 p
W 1 1 n
mg to
3^) ( h
mony S
ive Of
o resen
of the
( att ac
t ot
3osto
Rest
e *' e 1 n
uomi t
art
after
*■ ed bv
i « 3 ^ ,
t a 1 1 V
Comm
h "* d h
es.
It t ee
ereto
9 -
352
16/
oe riast .■ and -nisleading. —
** 3ECo'3 193'' 3MP Repo:
On ^oril 3, 1987, the NRC released a S^LP Report for 3ECo.
wnich was based on the results of various inspections and
evaluations conducted at Pilgrim over the period from
Novemoer 1, 1935 through January 31, 1987. Ratings were given
for 3ECo's performance in twelve functional areas. In keeping
with Its past record, 3ECo. received the lowest possible
17/
ratings in five of the twelve functional areas. — it
received the highest possible rating in only two functional
areas.— ^ The picture painted in the SALP report is one of a
plant witn "(p)oor management control," an "obscured ... chain
of command and wea<ened accountability," ;nd " ( s ) signif icant
recurring program weakness
in some fu-.ctional areas,
,.11/
showing the effect of ... long-term probleis. —
16/ 3ECo's claim of readiness should be measured against its
Idootion of 9/24/37 SRC/BECo. Readiness Meeting, o. 43. This
tendency to ignore reality m the operation of the nlant nas
been or«vously found to be undesiraole. See 3oston Edison
Tomoany, MDP'J NO. 1009-F (1982) (3ECo. denied where evidence
estaolished that it had imprudently underestimated the
necessary time required to perform outage tasks).
17/ The five areas were: Radiological Controls, Surveillance,
Fire Protection, Security and Safeguards, and Assurance of
Quality.
13/ The two areas were: Outage Management, "Modifications, and
Technical Support Activities and Engineering and Corporate
Tecnnical Suoport.
19/ 1987 SAL? REPORT at 3.
10 -
353
Df part.cjlar i-iportance to this Petit. 01, were SM?
ratings in three areas where =5ECo. hai previo^slv i-norovei .ts
perf orTiance. in the fjnctional areas of Sa rvei I lance , ?ire
Protection, and Licensing Activities, 3ECo. had m the oast
iTiproved its ratings between periods -- m fire orotection, it
had gone from a "3" to a "1" oetween its third and fourth SA'^P
Reports — but by the tine of the review for the 1937 ShL?
Report, Its perf oriiance had fallen back to earlier levels.
With respect to the functional area of Security and
Safeguards, the 1937 SALP Report discussed continuing hardware
proolems, BECo's excessive reliance upon contractors, and
TianageTient ' s failure to give this area sufficient
20/
attention. — The report noted that BECo's corrective
actions for deficiencies in this area hai not generally been
effective and referenced three degradat lo-.s m vital area
barriers that had occurred during the ev=.-jation neriod.— ^
20/ Id. at 31-34.
21/ The CoTi-ii ssion' s regulations define a "vital area" as any
area wnich contains:
any equipnent
failure, dest
directly or 1
and safety by
'Stem, device
ion, or rele
rectly endang
» sy
ruct
ndi r
exoosure to radiation
•material, the
f w h 1 c n could
f or
ase 0
er the ouolic health
or
systems which
protect publi
failure, desc
considered vi
( 1 ) ( emphasis
located withi
to vital equi
least two ohy
§73.50(b) ( i) .
be controlled
author i2at ion
to which barr
"channel pers
§73.45(0) ( 1) (
would be required to
c health and safety f
ruction, or release a
tal areas. 10 C . F . R.
added ) . Such areas
n a protected area su
pment requires passag
sical barriers." 10
Access into a prote
through the checking
and identity at entr
lers surrounding the
ons and material." 1
1) and 73.50(c) .
- 11 -
qui p-ient
function to
ollowng such
re also
§■73. 2(h) and
are to "be
ch that access
e through at
C- .R.
cted area is to
of
y cont rol ooint s
protected area
b C.F.R
354
** .Recent :^e ports of Vi^litnr. s **
On the basis of news reports and statements -lade oy ".^Z
officials at a recent -neetinq, it appears that 3ECo. has
suffered fron at least four significant Security and Safe^uarrs
lapses m the past six months: a Tiisplaced lun; a misplaced
set of sensitive -ceys; a "serious degradation in a vital area
barrier;" and ineffective identification cards. — While all
four alleged lapses would be significant, t.ne latter three
would be a particularly strong indication of BECo's failure to
learn from its past mistai^es -- nearly identical lapses have
occurred in the past. —
Further, allegations have recently been made which ^i^C
stated at a recent meeting that they are investigating that
3ECo. may oe compromising worker and/or c.ant safety by
24/
requiring excessive overtime. —
III. EVIDENCE VHW INDICATES THAT A PLANT SPECIFIC
??^A FOLLOWED 3Y IMPLS-^ENT ATION OF ANY INDICATED
SAFETY MODIFICATIONS SHOULD 3E REQUIRED I^O
PILGRIM'S RESTART.
Pilgrim is a GE Mark I design olant . As such, it has a
primary containment which, by nearly unanimous agreement, has
an extremely high probability of failure m the event of
22/ Boston Glooe, Seotemoer 4, 1987, p. 1; 3oston Glooe,
September 9, 1937, o. 21; 3oston Herald, September 10, i93 ,
p.' 24.
23/ See 1985 SALP Reoort, o. 40; 1933 SAIP Reoort , op. 41-43,
T982 SAL? Report, p. 38 (included in Attachment 3 hereto).
I±/ Boston Globe, September 29, 1987, p. 21.
12 -
355
certa.T a?r.3e-. ts. — '' This charac.erLStic is esper.allv
critical since Mark I design reactors, such as ?ilgri-n, do not
have the backup of a secondary contam-ient structure which can
withstand any significant position pressure. ( "P'/^s" ) .2-i'^ i-,
fact, Pilgrm's so-called "containment building" is not reallv
designed to perform a backup function. It has "blow panels"
which m some design and most severe accidents would activate
and create a ready path for hazardous radioactive materials to
escape into the environment. — The combination of an
extremely vulnerable primary containment structure, a secondary
containment not designed to provide an effective backup, and
2 3/
the large population in the immediate vicinity of Pilgrim —
compel the Governor and the Attorney General to request that
the SRC modify the Pilgrim operating lice-^e to bar restart
until a plant specific probabilistic ris' assessment ("PRA") is
performed for Pilgrim and all indicated safety modifications
are implemented. 'Jntil this occurs, the operation of the olant
would oose an unreasonable threat to puolic health and
; a r e t V
29/
25/ See SUREG-1150, Reactor Risk Reference Document, Draft for
Comment, Feb. 1987, at 4-33, 4-39.
2_6/ Affidavit of Steven C. Sholly (attached hereto as
Attachment 1 ) .
22/ I_d.
28/ Id.
29/ Id.
13 -
356
Tne w-ov-ernor an 3 the Attorney "er. eral are avare -'".a" :-. e
M.RC has to date declined to order -^itigative -^odi f icat l o-:3 for
.^ark I design plants. — They sab^iit, however, that the
evidence presented here -- the comomation of extre-nely
vulnerable cont ai ment structures and a larqe oopulation
surrounding the plant -- precludes application of 'I'JREG- 11 50 ' s
finding that the probaoility of a large reactor accident witn
early fatalities is extre'nely remote. The 'rjREG-1150 findings
do not reflect the amalgam of risks posed by Pilgrim.
3E:co. has proposed a number of modifications as remedial
actions for the plant's design def iciencies .— =■ These
actions do not, however, address the inherent defects of the
plant's design m any real -^ay. The Governor and the attorney
General do, however, submit that through its so-called "safety
enhancement program," 3SCo. has put the ~:9stion of the
aooropriate modifications to be made to remedy the defects of
the Mark I design in issue.
30/ Z . g . , 3oston "dison Company (Pilgrim 'luclear Station),
55-37-14, -IRC (1937) (slip at 31-32).
31/ Letter with enclosures dated July 8, 193'', from
Mr. Ralph G. =3icd, Senior Vice President-'^luc lear , Boston idisor
Company, to Mr. Steven A. Varga, Director, "Division of Reactor
Proiects, I/II, Nuclear Regulatory Commission (attached hereto
as attachment 6 ) .
14
357
;■ : D - '
)F 1)^\o-.j:mz EMiR^i--;:^ ?'^-i?\?zj-.-^s
Withm the past twelve "nonfis, two authoritative
assess::ient s have oeen made of the PLlgrim Radiological
Sneraency Response Plan and the state of emergency preparedness
within the Emergency Planning Zone ("EPZ") for Pilgrim. —
3oth conclude that the plan and the state of preparedness "are
not adequate to protect the health and safety of the public m
the event of an accident at the Pilgrim 'luclear Power
Station."—^ 3oth also concluded that the plan and the state
of oreparedness have significant deficiencies and suggest
Dotential remedies for those deficiencies that will require a
substantial commitment of time, resources and
coooerat ion
34/
3EC0. has not quarreled with these
conclusions.—^ The Governor and the Att::ney General submit
that these conclusions compel immediate artion by the MRC. The
32/ FEMA, "Seif-Initiated Review and Interim Finding for the
pTlgrim Nuclear Power Station, Plymouth, y.\" (August 4, 193'')
(hereinafter "FEMA Self -Ini t lated Review"); Secretary of Public
Safety, "Report to the Governor on Emergency Preparedness for
an Accident at the Pilgrim Nuclear Power Station" (Dece^.cer 16,
1986) (hereinafter "3arry Report" ) .
33/ FEMA Self-Initiated Review at 1-2; 3arry Report at ''4.
34/ FEMA Self-Initiated Review, pp. 12-13, 19, 22, 29-32,
4 3-44; Barry Reoort , pp. 4 7-55.
35/ 9/24/87 NRC/3EC0 Readiness Meeting", pp. 49-54.
358
36/
autr. :'---^--'^- exoer. agen r.es — agree tnat tnere 13 -. o
reasonable assarar'.ce that the public :aT or will oe oroteoteo
in the event of an accident at Pilgri-n. It is, thus, mcu-ce-.:
jDon the NRC to take action mediately to insure that no-steos
are taken by 3ECo. which could increase the likelihood or the
3-7/
consequences of an accident. —
\. THE PL^NNIMG ^ND PREPAREDNESS DEFICIENCIES IDENTIFIED
3Y FSMA AND THE ?^ASS ACH'JSETTS EXECUTIVE OFFICE
OF P'J3LIC SAFETY
The deficiencies of the Radiological Enerqency Response
Plans for Pilgrim are manifold. Although the analyses of FEMA
and the Massachusetts Executive Office of Public Safety do not
reach the same conclusions on all issues, the following areas
of substantial deficiency have been ident.fied by both agencies:
1. the lack of any articulated eva^iation plans
for oublic and private schools =.3 well as day
carecenters;
2. the lack of any articulated evacuation plans
for the special needs population;
16/
exne
of fs
Fed.
IS e
emer
10 C
Safe
Offi
§1 I
FE^A 13 explicitly recognized by the Com-nission as
rt Federal authority on questions of nuclear power
.^o oTiergency preparedness (Memorandum of 'Jnderstan
'Reg", No. 75, 15,486 (April 18, 1985) and the Comm
xoressly required to base its findings on off-site
gency issues on FEMA's conclusions concerning sucn
.F.R. §50.47{ s) ( 3) . The Massachusetts Secretary of
ty'oversees the Ma - lachusetts Civil Defense Agency
ce of Emergency Planning, which pursuant to M.g.l.
s resoonsiole for the Commonwealth's emergency acti
1 s
?
an
he
ant
ng, 5 0
SI on
sues .
u b 1 1 c
d
147,
ties.
2''/ -ach s-ep of 3ECo's oower ascension plan corresoond'; with
"substantial" increase in" the probability of an accident at
Pilgrim. Affidavit of Steven C. Sholly (attached hereto as
Attachment 1 ) .
16 -
359
-. ". ^ L a r ■-. 0 1 a -. / a r t . ; j . a -. e i 3 / a ? ^ :i - . o -. t - a -. ^
foe tne tran spor': iepen den. popjlaiiop. ;
4. tne lack of iiientifraol'? paolic .^helier
the oeacn oooul a" lor. ;
to:
5. tie laci^ of a rsception cen.er, as requir'?i
n tne plan, for people evacuatiiq by the
nortnern route;
5. the lacK of real progress m plannnq and the
dminijtion ;n tne state of eTiergency
prepa redness .13.'
These are critical deficiencies. The olans do not e.ven
ourport to provide any -neasure of protection for significant
namoers of people: pre-school and school age children; f'ose
-vno require special measures to transport; and those without
read/ access to private transportation. They fail to address
tne significant oeach population in an adequate fashion. Thev
do not incorporate current or reliable evaluation tine
estimates ("ETEIs"). Jor io they mcorpor -. -.e a delineated
inventory of identified and identifiable Telters which are
accessiole to tne public. Moreover an integral co-^po-ent of
39/
zr.e current plans -- a nortnern receotion center — .
J_3/ FZ'^A 3e If -Initiative Review, -pp. 12-13, 19, 22, 29-32,
4 3-4 4; 3arry Report, pp. 4 7-5 5.
11/
nort
Tne
evac
m 1
recs
woul
desc
woul
~oni
i^ev 1
The lack of a reception center for
h is as worrisone as tne .Tiore genera
lacK of a northern reception center
uation from the Z?Z were successful
ight of tne assorted planning defici
ived and followed instructions to ev
facilities availaole at th
\ccording to F^'.W, aoproxi
witnou- facilities at whic
decontaminated if necessar
d find no
1 n a 1 1 0 n .
d oe left
tored and
e w at 19.
those
1 Ola
1 n d 1 c
-- a
a ^ f ■ o
acuat
eir i
mat el
h to
■/• I
eva
ates
s --
e to
es la
y 60
r eg i
c u a 1 1
g fai
t n a -
1 c as
thos
the
nated
,0 00
ster ,
Self-
ng to
1 ires ,
3 '/ a n
3 U -^ O t
e who
north
p e o o 1 ■
oe
ion
ated
17
360
-- :3 ^ IS i-.'.z a.t^aetr.er. rmaiLy, orrs.te exerr.sea ar-. ::
drills -- the most effective "neans of assari^.q o reoa rei-.es 3
nave not been held m years.
3. the: c'Jsssmt status of planning and preparedness
The specific functional deficiencies m the first four
areas enunerated above, as well as the functional areas m
which work .Tiust be done before any det er-nmat ion can be -nade if
adequate plans can be developed, encompass the entire set of
tasks required for adequate planning and preparedness:
1. Identification/EstiTiation of populations;
Identification/Estimation of resources;
2.
3.
Develop plans for emergency actions to be
tai^en for each population with potentially
available resources;
4. Obtain commitments for require: resources;
5. Provide education/information "o public;
6. Conduct exercises/drills .
At oresent, it apoears that the school/daycare oooulation
nas oeen identified but that the special needs and transport
4 "I / ,
deoendent populations have not .— ^ Preliminary estimates o.
the resources potentially available to evacuate these
populations have now oeen obtained, but neither plan
development nor obtai-.-ng commitments of resource availability
41 /
can orocee
ed m the absence of reliable ETEs. —
£0/ Executive Summary of the Reaort on E-ergencv Preparedness
ror an Accident at Pilgrim Power Station) (October 15, 193'')
Thereinafter "3arry Report Update"), p. 2.
41/ Id. 'at 2.
- 13 -
361
While 3r:co. has recently -- ^jgast 13, 193^ -- del.;erei an
ETE stady to the Commonwealth's puoiic safety officials,—
the document is still oeing reviewed by those officials a-,i
preliTiinary analysis has uncovered shortcomings that will
necessitate further work. It is, thus, unlikely that final
ETEs will be available withm the irimediate future for use m
4 3/
developing specific plans. — This shortcoming is critical.
A consequence of the unavailability of reliable ETEs is that
emergency planning is effectively on hold. Even when the ta3<
of identifying/estimating populations and resources is
completed, radiological emergency planning cannot in any real
sense proceed without reliable ETEs and a traffic management
plan. ^s FEMA and the NRC well recognize, a realistic set of
ETEs is an essential element of a workaol^ emergency plan. See
Cincinnatti Gas 5. Electric Company (Wm. -: . Zimner Nuclear Power
Station, Unit No. 1), ALA9-727, 17 NRC 76:, 770-71 (1983).
With respect to the beach population, orelimmary
population estimates and sheltering data have oeen provided to
the Commonwealth's public safety officials out, at least m the
case of the sheltering survey, these materials have oeen found
4 2/ KLD Associates, Pilgrim Station Evacuation Time Estiiates
and Traffic Management Plan "Jodate (Final Draft for Review)
August 18, 1987.
43/ 3arry Reoort Uodate, p. 2.
- 19 -
362
4 4/'
Z3 se .". a::-ej_:i-_e fjc plan ". .-. g p^rpDses. — ^'
\5a1r:, plan develop^er.z and resojrie avai'-aoili*:/ co-^^it"?-. •:
■njcp. less public ed jcat ion/ in.f or-nai ion efforts and
exercises /drills, cannot proceed asefully wit ho at reliaole
43/
final EIEs and sheltering data. —
.Jo replacement site for a northern reception center has
46/
oeen found — and no detemmation has yet been made whet he:
an emergency plan incorporating only two reception centers
47/
would provide an aaequate assurance of protection. —
44/ 3arry Report Update , p. 2; Letter with enclosures from
Rooert J. 3oulay, Director, Massachusetts Civil Defense ^gencv,
dated Sepcemoer 13, 1937, to Ralph C. 3ird, Executive Vice
President-Nuclear, Boston Edison Company (attached hereto as
Attacnment 7 )
45/ 3arry Report Jpdate , p . 2 ; See also -- 'A Self-Init:
Review at 26-27:
3efore FEMA and the RAC can make a -.eterminat ion
on tnis (whetner protective actions ^or thebeach
population are or readily can be made adequate)
It must receive the following infornation:
1)
beac
anal
numo
the
geog
of t
Che
bull
popu
capa
dist
are
clea
and
aoor
an J
nes
ysis
er o
numo
raph
ne 1
oeac
ding
lati
citi
ance
not
ciy
lett
oor 1
pda
and
of
f ?
er
ica
eng
h p
s a
on
es
s f
ope
st a
e r s
ate
ted
tne
the
erma
of d
1 di
th o
opul
vail
at e
of t
rom
n CO
te h
of
geog
ir c
oea
nent
ay V
sper
f ti
at 10
aole
ach
hese
tne
the
ow t
a::re
raphical
apacity ;
ch popula
and temo
isi tors ,
SI on; 3 )
me It wou
n ; and 4 )
for shel
beach, m
bui Iding
beaches .
public,
hey will
ement mus
d '^ s c
2)
t ion
orar
toge
an
Id t
a 1
ten
clud
s an
If
be m
t oe
r ipt 10
a deta
, mcl
V r e ^ 1
the: w
update
ake t :>
ist of
ng tne
inq th
d t nei
these
plans
ade ac
obt ai
n 0
lied
jdin
dent
1 th
d es
eva
sui
oea
« t- ha
q --
s a
the
t im
cua
tab
ch
he
nd
ate
oui i
must
cess
ned
cmgs
lole
as
46/
see
42/ 9/24 MRC/3EC0. Readiness Meeting, p. 52. 3u'
FEMA Seif-Init lated Review at 19 (The use of only two
reception centers
feasiole.") .
IS not likely to be logistically
- 20 -
363
r : n a ". 1 / , i -. i r. e a d s e n r ? of -. e w plans, ? ^ o I ■_ c
mf or.Tiacion/educaci on efforts and exer ci ses/ir : 1 1 3 canno-:, -.v
jefmition, occur. There are no plans to •.nfor-n -.he ouo".:? -;-
exercises, Tiacn less to exercise. Although the provisions 0"
10 C.r.i^. Part 50, Appendix S, Section IV.F. require that a
full participation oiennial emergency oreparedness exercise -or
Piigrm oe neld this year, the MRC is presently considerim a
request from 3£Co. for a one-tme exemption from that
requirement to allow the exercise to be postponed to the second
quarter of 1988.—''
17. COriCLJSIDN
In light of all of the foregoing deficiencies of the
current state of e^nergency planning and preparedness, as veil
as tne suostantial questions raised herei- roncerninq the
managerial aoility of the licensee, 3ECo., and the safety of
the Pilgrim reactor, the Governor and Attorney General submit
that the :JSC must take action pursuant to 10 C. F . ' . <;2.202 to
insure tnat 3SCo. does not take any action tnat could increase
eitner the ris< or the consequences of an arcident at PilTri".
Since tnat Pilgrim is a 3S "larK I design reactor, and the
£?Z population at tnis plant is among the nighest m the
country, it is evident that the deficiencies m emergenrv
planning and preparedness are significant for Pilgrim. These
43/ Letter ^itn enclosures dated Septemcer 13, 1937, from
Mr. Ralph G. 3ird, Senior Vice President-Nuclear, Boston "diso-
Company, to :IRC (attacned hereto as Attachment 3).
21
364
jgf_j.-;-. r.es are so suos-antial and t'-.eir poteitial
ratifications are 3D significant, tl^a': it is i-npossiol? to
conclade that any interim compensating actions have or can oe
ta<en. T"-.e :JRC' s regulations leave it no course other than
issuing an order modifying 3ECo's license to extend the curre-
shut down pending the outcome of a full hearing on the
significant outstanding safety issue- and the development and
•' 4 9/
certification oy the Governor of adequate emergency plans. —
Respectively submitted,
James M. Shannon
Attorney General
Commonwealth of *1assachuset t s
Michael S. Dukakis
Governor
Commonwealth -f "Massachusetts
■Dated: Octocer .5, 1937
4 9/ Compare n C.r.S. §50.54(s)(2)(ii):
... In determining whether a shutdown or other
enforcement action is appropriate, the Commission
3r-.all take into account, among other factors,
■,,-a-ner the licensee can demonstrate to the
:o--i33ion'3 satisfaction that the deficiencies
m t ne olan are not significant for the plant m
question, or that adequate interim compensating
actions have been or will be taken oromotly, or
that there are other comoelling reasons for
continued operation.
- 22 -
365
APPENDIX I: BECo. Sa,L? HISTORY T'lB'JLATIOM
Inspec .
Period
Plant
Oper .
2
Radiol .
Control
3
Maint .
Sarveil .
Fire
Prot.
2
£ Tie toe ". .
P r e D a r e -i
01/01/80
12/31/30
2
2
2
09/01/80
08/31/81
3
2
3
2
2
1
09/01/31
06/30/82
3
2
2
2
3
1
07/01/32
06/30/83
2
2
2
1
1
1
07/01/83
09/30/84
2
3
1
1
2
3
10/01/84
10/31/85
3
3
2
2
-
3
11/01/85
01/31/87
2
3
2
]
3
2
I ".spec.
Period
Secur .
Saf egds
Out.
Mod.
Mqt .
Act
Licen.
Activ,
Eng/C
Tech.
:orp
Sup
Train
Qual .Ef
Quality
A s s u r a n
01/01/30
12/31/80
2
3
-
-
-
3
09/01/80
03/31/31
2
2
-
-
—
3
09/01/31
06/30/32
2
2
2
-
—
~
07/01/82
06/30/33
2
-
1
-
-
""
07/01/83
09/30/84
2
1
1
-
—
~
10/01/34
10/31/35
2
1
1
-
—
"•
11/01/35
01/31/37
3
1
2
1
2
3
i
366
APPE^4DIX II: 3ECo. VIOLATIONS TABULATIONS
SEVERITY LEVEL III VIOLATIOHS: 9/1/81-1/31/37
Functional Area 1981 1982 1983 1984 1985 198(
.33'
?lant Operations
Radiological Controls
Mainenance
Sar vei 1 lance
rire Protection
Emergency Preparedness
Security/Safeguards
Outage Mgt . . .
Licensing Activities
Training ... Eff ness
Assurance of Quality
Engineer/Corp. Support
Severity Level
3ECo. VIOLATIOMS 3Y SEVERITY LEVEL: 9/1/81-1/31/87
31/32 82/33 33/84 34/35 85/87
I
II
in
7
1
1
2
1
IV
9
9
13
17
21
V
20
20
6
5
6
VI
2
Deviations
2
3
I
3
1
Total Violations
40
33
26
27
29
367
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
BEFORE THE COMMISSION
In the matter of
BOSTON EDISON COMPANY
(Pilgrim Nuclear Power Station, Unit 1)
Docket No. 50-293
AFFIDAVIT OF STEVEN C. SHOLLY
Steven C. Sholly, being on oath, deposes and says as follows:
I am an Associate Consultant with MHB Technical Associates, 1723 Hamilton
Avenue, Suite K, San Jose, California, 95125. A statement of my professional
qualifications is attached hereto and marked Attachment A. In brief, I have
more than six years experience in the review, analysis, interpretation, and
application of probabilistic risk assessment to the analysis of safety issues
related to commercial nuclear power plants, including issues related to
radiological emergency planning. I have served as a member of the peer
review group for the NRC publication NUREG-1050 (1984) ^Probabilistic Risk
Assessment rPRA) Reference Document. September 1984), and have more
recently sen/ed as a member of the Containment Performance Design
Objective Workshop, the Panel on ACRS Effectiveness (1985), and the Sei^ere
Accident Policy Implementation External Events Workshop (1987). I have
previously testified as an expert witness on probabilistic risk assessment and
emergency planning matters in NRC proceedings on the Catawba Units 1 and
2, Indian Point Units 2 and 3, and Shoreham Unit 1 nuclear plants, and also m
the Public Inquiry regarding the proposed Sizewell-B nuclear plant in the United
Kingdom In addition, I have co-authored two major reviews of source term
368
-2-
and risk estimate issues published in NRC reports NUREG-0956 and NUREG-
1150. I have also performed reviews of various technical aspects of the
Shoreham, Limerick, Indian Point, Sizewell, Zion, Seabrook, Millstone-3, and
Oconee-3 probabilistic risk assessments and the Vermont Yankee
Containment Safety Study.
f^HB Technical Associates ("MHB") has been requested by the Nuclear Safety
Division, Department of the Attorney General, The Commonwealth of
fj/lassachusetts, to evaluate the increase in risk resulting from a startup
program for return to power from the current refueling and modifications
outage for the Pilghm Nuclear Pov\er Station, Unit i (PNPS-i).
In its current configuration (refueled) and considering the duration of the
current shutdown, Pilgrim currently poses very little i- -k to the public health and
safety. This is due to the multiplicity of systems theoretically available to inject
water into the reactor vessel and due to the low decay heat level present in the
fuel. In the event of a core heatup transient with the plant in its current
configuration, considerable time would elapse between initiation of coolant loss
and the onset of fuel damage, time during which measures could be taken to
initiate coolant makeup and/or other recovery and mitigative actions.
Moreover, in theory a longer time period is available within which to implement
offsite protective actions due to the slower accident progression time
compared with accidents at higher power levels.
Boston Edison Company (BECO), the licensee for Pilgrim, currently envisions
restart power ascension program with a minimal number of hold points. In
brief, BECO proposes to institute holds on restart (pending approval from NRC
in accord with Confirmatory Action Letter No. 86-10), recovery from reactor
mode switch testing prior to conducting a test for shutdown from outside the
control room, and prior to movement of the scram set point above 95% power.
[Sgfi, Boston Edison Company, Pilgrim Nuclear Power Station Restart Plan.
pages IV-29 to IV-31.] The details of the power ascension program in
Attachment 13 of the Pilgrim Nuclear Power Station Restart Plan have not yet
been provided.
369
My current understanding of the BECO power ascension program is that the
program would result in a relatively rapid ascension from the current shutdown
condition to full-power operation. In so doing, the risk to the public health and
safety posed by operations at the Pilgrim plant will be increased markedly.
The Commission has concluded generally that the risks from 5% power
operation are negligible. [See, for example, SECY-84-155, 12 April 1984, and
attachments; and letter dated 15 June 1984 from Nunzio J. Palladino to Hon
Edward J. Markey, and attachments.] The evaluations upon which the
Commission has drawn these conclusions, however, were for plants with very
little operating history and no spent fuel pool inventory. Clearly, Pilgrim is
different in this regard, with a substantial long-half-life fission product inventory
present m both the refueled reactor core and the spent fuel pool. Moreover,
these evaluations did not consider the unique risks posed by accidents
resulting from externally-initiated events (specifically, in this case, seismic
events). In my opinion, the presence of more than 1 100 spent fuel assemblies,
prior operation of two-thirds of the core at equivalent full power for most of an
operating cycle, and the matter of external events render the circumstances at
Pilgrim sufficiently different from those previously evaluated for 5% power
operation that the previous evaluations understate, perhaps significantly, the
risk posed by operation of Pilghm at 5% of full power. This conclusion is
further supported by the likelihood that the primary containment will not be
inerted until operation above 5% power is commenced. In my opinion, virtually
any severe accident at 5% power with the containment de-inerted will result in
early containment failure (due to hydrogen burn or hydrogen detonation m the
primary containment, and/or other causes).
As power level increases, risk to the public increases. This is due to several
factors, including a marked increase in volatile fission product inventory and a
marked increase in decay heat level, which results in accident progression
times which are much shorter than at low power levels. This reduces the
amount of time available for implementation of recovery and/or mitigation
370
-4-
actions and reduces the amount of time available to implement offsite
protective measures.
A full-scope probabilistic risk assessment for the Pilgrim plant has been in
progress for several years. It is my understanding that this study is nearly
completed. It is my expectation that this study will identify seismic initiating
events as a significant contributor to core melt frequency (i.e., contributing 10%
or more to core melt frequency from all causes). This expectation is based on
my familiarity with seismic risk assessments performed on similar designs and
performed on other plants in the general region of Pilgnm (e.g., Shoreham,
Seabrook Units 1 and 2, f^illstone Unit 3, and Limerick Units 1 and 2).
Seismically-initiated accident sequences are accompanied by potentially
severe impacts on offsite emergency response even when there are fully-
approved and operational emergency plans. In the case of Pilgrim, the current
status of emergency planning is such that there is not adequate assurance that
protective actions can and will be taken in the event of an accident. Given the
more severe conditions of a seismically-initiated accident scenario, this
conclusion is all the more applicable.
A study of risk at 25% power for the Shoreham nuclear plant, which possesses
a nuclear steam supply system which is grossly similar to Pilgrim, Indicates that
the core melt frequency for operations at up to 25% of full power may not differ
dramatically from the core melt frequency at full power. The 25% power PRA
estimates a core melt frequency of 2.8 x 10'^ per reactor-year. [See. E.T.
Burns, S. Mays, and T. Mairs, Probabilistic Risk Assessment of the Shoreham
Nuclear Power Station: Initial Power Operation Limited to 25% of Full Power.
Delian Corporation, prepared for Long Island Lighting Company, April 1987,
page 4-12.] The full power PRA analyses for Shoreham estimated a core melt
frequency of about 6.5 x 10'^ per reactor-year. [See. Science Applications,
Inc., Final Report: Probabilistic Risk Assessment. Shoreham Nuclear Power
Station, prepared for Long Island Lighting Company, 24 June 1983, page 4;
and V. Joksimovich, et al., Maior Common-Cause Initiating Events Study:
Shoreham Nuclear Power Station. NUS Corporation, NUS Report No. NUS-
4617, prepared for Long Island Lighting Company, February 1985, page 1-8]
371
This represents less than a factor of three difference in the likelihood of a core
melt accident at 25% power versus full power. Although this assessment is for
Shoreham and not for Pilgrim, it suggests that the likelihood of an accident is
not markedly different for 25% power versus 100% power.
10. Further, a limited-scope PRA of Shoreham at 5% power was prepared for
LILCO. This study, which did not include external events, concluded that the
core melt frequency for 5% power operation was about 4.9 x 10'^ per reactor-
year. [See. Delian Corporation and Science Applications, Inc., Probabilistic
Risk Assessment. Shoreham Nuclear Power Station. Low Power Operation Up
to 5% of Full Power, prepared for Long Island Lighting Company, draft, May
1984, page 78.] This indicates that core melt frequency at 5% power is
significantly reduced from 25% power or full power, by a factor of roughly 20,
but not nearly as significantly reduced as previously predicted by the NRC staff,
which predicted a reduction factor of 1 ,000 or more. 1/ Moreover, the 5%
power reduction factor of 20 is an underestimate since the 5% power estimates
do not include external events.
11. The 5%, 25%, and 100% power PRA studies for Shoreham indicate, in my
opinion, that the core power level for Pilgrim will have at best a moderate
impact on the likelihood of an accident. Considering the uncertainties involved,
the likelihood of an accident may be nearly indistinguishable at the various
power levels indicated above. Moreover, the Shoreham results are lower than
the core melt frequency estimates for many other plants. A Brookhaven
National Laboratory review of the Shoreham PRA for internal events only
estimated a core melt frequency of 1 x 10"* per reactor-year. An average value
for full-scope PRAs completed to date is of the order of 3 x 10"* per reactor-
year.
1/ The NRC staff, in SECY-84-156, predicted core melt frequency reduction factors
for various classes of BWR accidents ranging from 1,000 to 100,000. [See,
SECY-84-1 56. Enclosure 1 , "Staff Review Process for 5 Percent Power Operation",
page 2.] Thus, in the aggregate, the NRC staff would have expected a core melt
frequency reduction of at least 1,000, compared with the Shoreham value of 20.
The results for Shoreham indicate a reduction factor approximately 50 times less
than the NRC staff expected based on engineenng judgment.
372
12, These results are especially significant for a plant with a containment design
similar to Pilgnm. Pilgrim employs a steel Mark I pressure suppression
containment. Such containments have been estimated m a variety of studies
sponsored by IDCOR, NRC, and utilities to have an early containment failure
probability -- given a severe accident -- in a range from 10-90%. This means
that there is a significant chance that, given a severe accident, the accident will
be accompanied by a large early release of radioactivity to the environment.
13. The Pilgrim plant, like all tVlark I containment design plants, also employs a
secondary containment, usually referred to as a reactor building. This
structure is not designed to withstand the high internal pressures which would
accompany a severe accident, and is unlikely to survive in a leak-tight condition
following primary containment failure. High pressure in the secondary
containment due to a severe accident would be produced by a combination of
blowdown due to primary containment failure, primary containment leakage,
phmary containment venting, and burning of combustible gases. Indeed, Mark
I plants are designed with both internal and external "blow-out panels" which
are designed to relieve pressure. In the case of Pilgrim, there are blow-out
panels at the refueling deck elevation which relieve pressure directly to the
environment. In my opinion, there is little basis for assuming that releases from
the primary containment will be significantly mitigated by the presence of the
secondary containment.
13 Based on the above considerations, it is my opinion that Pilgrim Unit 1 should
not be restarted until the offsite emergency response plans are upgraded and
evaluated to adequately protect the public health and safety. Further, it is my
recommendation that BECO be required to promptly submit the Pilgrim
probabilistic risk assessment study to the NRC for public review and evaluation
prior to restart. The review of such a study should indicate whether there
373
-7-
remain significant operational risks which must be amelioriated in order to
provide adequate protection to the public health and safety,
0
Steven C Sholly
Associate Consultant
GENERAL ACKNOWLEDGMENT
State ot_
County ot
t Ji Z,-.-.,^ ^
On this the
^^ day 01 (\2^^ZZZ^^
'9£z oetore f^e
M^^^^
OFFICIAL SEAL
MrUNA L BARRY
NOTARY PU8UC • CAUFOBNIA
3Mir« cum couirrr
My lTtT*(l §ipir«s )UW
the undersigned Notary Public aersonally appeared >
personally <nown to me
•^proved to me on the Basis of satisfactory evidence
to De the personisi whose nameisi / J sutiscnped to the
within instrument and acknowledged that h <; pxprnipn it
WITNESS my hand and official seal
NATIONAL NOTAOY »SS0CI«TI0S . J 301 J Ve^lu'a 81.0 . OQ Bo. 4625 ■ Aoooanfl -.«» CA m,ili .
374
ATTACHMENT A
PROFESSIONAL QUALIFICATIONS OF STEVEN C. SHOLLY
STEVEN C. SHOLLY
MHB Technical Associates
1723 Hamilton Avenue
Suite K
San Jose, California 95125
(408) 266-2716
EXPERIENCE
September 1985 - PRESENT
Associate - MHB Technical Associates, San Jose, California
Associate in energy consulting firm that specializes in technical and
economic assessments of energy production facilities, especially nuclear,
for local, state, and federal governments and private organizations. MHB
is extensively involved in regulatory proceedings and the preparation of
studies and reports. Conduct research, write reports, participate in
discc'ery process in regulatory proceedings, develop testimony and other
documents for regulatory proceedings, and respond to client inquiries.
Clients have included: State of California, State of New York, State of
II 1 inois.
February 1981 - September 1985
Technical Research Associate and Risk Analyst - Union of Concerned Scien-
tists, Washington. D.C.
Research associate and risk analyst for public interest group based in
Cambridge, Massachusetts, that specializes in examining the impact of ad-
vanced technologies on society, principally in the areas of arms control
and energy. Technical work focused on nuclear power plant safety, with
emphasis on probabilistic risk assessment, radiological emergency
planning and preparedness, and generic safety issues. Conducted
research, prepared reports and studies, participated in administrative
proceedings before the U.S. Nuclear Regulatory Commission, developed
testimony, aniayzed NRG rule-making proposals and draft reports and
prepared conments thereon, and responded to inquiries from sponsors, the
general public, and the media. Participated as a member of the Panel on
ACRS Effectiveness (1985), the Panel on Regulatory Uses of Probabilistic
Risk Assessment (Peer Review of NUREG-1050; 1984), Invited Observer to
NRC Peer Review meetings on the source term reassessment (BMI-2104; 1983-
1984), and the Independent Advi-sory Connittee on Nuclear Risk for the
Nuclear Risk Task Force of the National Association of Insurance
Commissioners (1984).
-1-
375
January 1980 - January 1981
Project Director and Research Coordinator - Three Mile Island Publ ic
Interest Resource Center, Harrisburq, Pennsylvania '
Provided administrative direction and coordinated research projects for a
public interest group based in Harrisburg, Pennsylvania, centered around
issues related to the Three Mile Island Nuclear Power Plant. Prepared
fundraising proposals, tracked progress of U.S. Nuclear Regulatory Com-
mission, U.S. Department of Energy, and General Public Utilities activi-
ties concerning cleanup of Three Mile Island Unit 2 and preparation for
restart of Three Mile Island Unit 1, and monitored developments related
to emergency planning, the financial health of General Public Utilities,
and NRG rulemaking actions related to Three Mile Island.
July 1978 - January 1980
Chief Biological Process Operator - Wastewater Treatment Plant, Perry
Township Municipal Authority, Hershey, Pennsylvania
Chief Biological Process Operator at a 2.5 million gallon per day ter-
tiary, activated sludge, wastewater treatment plant. Responsible for bi-
ological process monitoring and control, including analysis of physical,
chemical, and biological test results, procees fluid and mass flow man-
agement, micro-biological analysis of activiated sludge, and maintenance
of detailed process logs for input into state and federal reports on
treatment process and effluent quality. Received certification from the
Commonwealth of Pennsylvania as a wastewater treatment plant operator.
Member of Water Pollution Control Association of Pennsylvania, Central
Section, 1980.
July 1977 - July 1978
Wastewater Treatment Plant Operator - Borough of Lemoyne, Lemoyne, Penn-
sylvania
Wastewater treatment plant operator at 2.0 million gallon per day sec-
ondary, activated sludge, wastewater treatment plant. Performed tasks as
assigned by supervisors, including simple physical and chemical tests on
wastewater streams, maintenance and operation of plant equipment, and
maintenance of the collection system.
September 1976 - June 1977
Science Teacher - West Shore School District, Camp HHI. Pennsylvania
Taught Earth and Space Science at ninth grade level. Developed and im-
plemented new course materials on plate tectonics, environmental geology,
and space science. Served as Assistant Coach of the district gymnastics
team.
-2-
376
September 1975 - June 1975
Science Teacher - Carlisle Area School District. Carlisle. Pennsylvania
Taught Earth and Space Science and Environmental Science at ninth grade
level. Developed and implemented new course materials on plate tecton-
ics, environmental geology, noise pollution, water pollution, and energy.
Served as Advisor to the Science Projects Club.
EDUCATION:
B.S., Education, majors in Earth and Space Science and General Science,
minor in Environmental Education, Shippensburg State College, Shippens-
burg, Pennsylvania, 1975.
Graduate coursework in Land Use Planning, Shippensburg State College,
Shippensburg, Pennsylvania, 1977-1978.
PUBLICATIONS:
1. "Determining Mercalli Intensities from Newspaper Reports," Journal of
Geological Education. Vol. 25, 1977.
2. A Critique of: An Independent Assessment of Evacuation Times for Three
Mile Island Nuclear Power Plant, Three Mile Island Public Interest
Resource Center, Harrisburg, Pennsylvania, January 1981.
3. A Brief Review and Critique of the Rockland County Radiological Emergency
Preparedness Plan, Union of Concerned Scientists, prepared for Rockland
County Emergency Planning Personnel and the Chairman of the County Legis-
lature, Washington, D.C., August 17, 1981.
4. The Necessity for a Prompt Public Alerting Capability i" the Plume Expo-
sure Pathway EPZ at Nuclear Power Plant Sites, Union of Concerned Scien-
tists, Critical Mass Energy Project, Nuclear Information and Resource
Service, Environmental Action, and New York Public Interest Research
Group, Washington, D.C.. August 27, 1981. *
5. "Union of Concerned Scientists, Inc., Coiiinents on Notice of Proposed
Rulemaking, Amendment to 10 CFR 50, Appendix E, Section IV. D. 3," Union of
Concerned Scientists. Washington. D.C.. October 21, 1981. *
6. "The Evolution of Emergency Planning Rules," in The Indian Point Book: A
Briefing on the Safety Inyestiqation of the Indian Point Nuclear Power
Plants, Anne Witte, editor. Union of Concerned Scientists (Washington.
D.C.) and New York Public Interest Research Group (New York. NY), 1982.
7. "Union of Concerned Scientists Comments. Proposed Rule. 10 CFR Part 50,
Emergency Planning and Preparedness: Exercises, Clarification of Regula-
tions. 46 F.R. 61134." Union of Concerned Scientists, Washington, D.C.
January 15. 1982. *
377
8. Testimony of Robert D. Pollard and Steven C. Sholly before the Sub-
committee on Energy and the Environment, Committee on Interior and
Insular Affairs, U.S. House of Representatives, Middletown, Pennsylvania,
March 29, 1982, available from the Union of Concerned Scientists.
9. "Union of Concerned Scientists Detailed Comments on Petition for Rulemak-
ing by Citizen's Task Force, Emergency Planning, 10 CFR Parts 50 and 70,
Docket No. PRM-50-31, 47 F.R. 12639," Union of Concerned Scientists,
Washington, D.C., May 24, 1982.
10. Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel,
Union of Concerned Scientists, before the Subcommittee on Energy
Conservation and Power, Committee on Energy and Commerce, U.S. House of
Representatives, Union of Concerned Scientists, Washington, D.C., August
16, 1982.
11. Testimony of Steven C. Sholly, Union of Concerned Scientists, Washington,
D.C., on behalf of the New York Public Interest Research Group, Inc., be-
fore the Special Committee on Nuclear Power Safety of the Assembly of the
State of New York, hearings on Legislative Oversight of the Emergency Ra-
diologic Preparedness Act, Chapter 708, Laws of 1981, September 2, 1982.
12. "Comments on 'Draft Supplement to Final Environmental Statement Related
to Construction and Operation of Clinch River Breeder Reactor Plant',"
Docket No. 50-537, Union of Concerned Scientists, Washington, D.C.,
September 13, 1982. *
13. "Union of Concerned Scientists Comments on 'Report to the County Commis-
sioners', by the Advisory Committee on Radiological Emergency Plan for
Columbia County, Pennsylvania," Union of Concerned Scientists, Washing-
ton, D.C., September 15, 1982.
14. "Radiological Emergency Planning for Nuclear Reactor Accidents," pre-
sented to Kernenergie Ontmanteld Congress, Rotterdam, The Netherlands,
Union of Concerned Scientists, Washington, D.C, October 8, 1982.
15. "Nuclear Reactor Accident Consequences: Implications for Radiological
Emergency Planning," presented to the Citizen's Advisory Committee to Re-
view Rockland County's Own Nuclear Evacuation and Preparedness Plan and
General Disaster Preparedness Plan, Union of Concerned Scientists, Wash-
ington, D.C, November 19, 1982.
16. Testimony of Steven C. Sholly before the Subconriittee on Oversight and
Investigations, Committee on Interior and Insular Affairs, U.S. House of
Representatives, Washington, D.C, Union of Concerned Scientists, Decem-
ber 13. 1982.
17. Testimony of Gordon R, Thompson and Steven C Sholly on Commission Ques-
tion Two, Contentions 2.1(a) and 2.1(d), Union of Concernei Scientists
and New York Public Interest Research Group, before the U.S. Nuclear Reg-
ulatory Commission Atomic Safety and Licensing Board, In the Matter of
Consolidated Edison Company of New York (Indian Point Unit 2) and the
Power Authority of the State of New York (Indian Point Unit 3), Docket
Nos. 50-247-SP and 50-286-SP, Decenter 28, 1982. *
378
18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian
Point (Commission Question One and Board Question 1.1, Union of Concerned
Scientists and New York Public Interest Research Group, before the U.S.
Nuclear Regulatory Conmission Atomic Safety and Licensing Board, in the
Matter of Consolidated Edison Company of New York (Indian Point Unit 2)
and the Power Authority of the State of New York (Indian Point Unit 3),
Docket Nos. 50-247-SP and 50-286-SP, February 7, 1983, as corrected
February 16, 1983.
*
19. Testimony of Steven C. Sholly on Commission Question Five, Union of Con-
cerned Scientists and New York Public Interest Research Group, before the
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in
the Matter of Consolidated Edison Company of New York (Indian Point Unit
2) and the Power Authority of the State of New York (Indian Point Unit
3), Docket Nos. 50-247-SP and 50-286-SP, March 22, 1983. *
20. "Nuclear Reactor Accidents and Accident Consequences: Planning for the
Worst," Union of Concerned Scientists, Washington, D.C., presented at
Critical Mass '83, March 26, 1983.
21. Testimony of Steven C. Sholly on Emergency Planning and Preparedness at
Commercial Nuclear Power Plants, Union of Concerned Scientists, Washing-
ton, D.C., before the Subcommittee on Nuclear Regulation, Committee on
Environment and Public Works, U.S. Senate, April 15, 1983, (with "Union
of Concerned Scientists' Response to Questions for the Record from Sena-
tor Alan K. Simpson," Steven C. Sholly and Michael E. Faden).
22. "PRA: What Can it Really Tell Us About Public Risk from Nuclear Ac-
cidents?," Union of Concerned Scientists, Washington, D.C., presentation
to the 14th Annual Meeting, Seacoast Anti-Pollution League, May 4, 1983.
23. "Probabilistic Risk Assessment: The Impact of Uncertainties on Radi-
ological Emergency Planning and Preparedness Considerations," Union of
Concerned Scientists, Washington, D.C., June 28, 1983.
24. "Response to GAO Questions on NRC's Use of PRA," Union of Concerned Sci-
entists, Washington, D.C., October 6, 1983, attachment to letter dated
October 6, 1983, from Steven C. Sholly to John E. Bagnulo (GAO, Washing-
ton, D.C.).
25. The Impact of "External Events" on Radiological Emergency Response Plan-
nTrTq Considerations, Union of Concerned Scientists, Washington, D.C., De-
cember 22, 1983, attachment to letter dated December 22, 1983, from
Steven C. Sholly to NRC Comnissioner James K. Asselstine.
26. Sizewell 'B' Public Inquiry, Proof of Evidence on: Safety and Waste Man-
agement Implications of the Slzewell PWR. Gordon Thompson, with
supporting evidence by Steven Sholly, on behalf of the Town and Country
Planning Association, February 1984, Including Annex G, "A review of
Probabilistic Risk Analysis and Its Application to the Slzewell PWR,"
Steven Sholly and Gordon Thompson, (August 11, 1983), and Annex 0,
"Emergency Planning In the UK and the US: A Comparison," Steven Sholly
and Gordon Thompson (October 24, 1983).
-5-
379
11. Testimony of Steven C. Sholly on Emergency Planning Contention Numoer
Eleven, Union of Concerned Scientists, Washington, O.C, on behalf of the
Palmetto Alliance and the Carolina Environmental Study Group, before the
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in
the Matter of Duke Power Company, et. al. (Catawba Nuclear Station, Units
1 and 2), Docket Nos. 50-413 and 50-414, April 16, 1984. *
28. "Risk Indicators Relevant to Assessing Nuclear Accident Liability Premi-
ums," in Preliminary Report to the Independent Advisory Committee to the
NAIC Nuclear Risk Task Force, December 11, 1984, Steven C. Sholly, Union
of Concerned Scientists, Washington, O.C.
29. "Union of Concerned Scientists' and Nuclear Information and Resource Ser-
vice's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings
the Consideration of Earthquake Effects on Emergency Planning," Union of
Concerned Scientists and Nuclear Information and Resource Service, Wash-
ington, O.C, Diane Curran and EUyn R. Weiss (with input from Steven C.
Sholly). February 28, 1985. *
30. "Severe Accident Source Terms: A Presentation to the Commissioners on the
Status of a Review of the NRC's Source Term Reassessment Study by the
Union of Concerned Scientists," Union of Concerned Scientists, Washing-
ton, O.C. . April 3, 1985. *
31. "Severe Accident Source Terms for Light Water Nuclear Power Plants: A
Presentation to the Illinois Department of Nuclear Safety on the Status
of a Review of the NRC's Source Term Reassessment Study (STRS) by the
Union of Concerned Scientists," Union of Concerned Scientists,
Washington, D.C., May 13, 1985.
32. The Source Term Debate: A Review of the Current Basis for Predicting Se-
vere Accident Source Terms with Special Emphasis on the NRC Source Term
Reassessment Program (NUREG-0956) , Union of Concerned Scientists. Cam-
bridge, Massachusetts, Steven CT Sholly and Gordon Thompson, January
1986.
33. Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn K. Price,
and Steven C. Sholly on behalf of State of Connecticut Department of Pub-
lic Utility Control, Prosecutorial Division and Division of Consumer
Counsel, regarding the prudence of expenditures on Millstone Unit III,
February 18, 1986.
34. Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning
for the State of New York, prepared for the State of New York Consumer
Protection Board, by MHB Technical Associates, June 1986.
35. Review of Vermont Yankee Containment Safety Study and Analysis of
Containment Venting Issues for the Vermont Yankee Nuclear Power Plant,
prepared for New England Coalition on Nuclear Pollution, Inc., December
16, 1986.
-6-
380
36. Affidavit of Steven C. Sholly before the Atomic Safety
and Licensing Board, m the matter of Public Service
Company of New Hampshire, et al., regarding SeabrooK
Station Units 1 and 2 Off-site Emergency Planning
Issues, Docket Nos . 50-443-OL & 50-444-OL, January 23,
1987.
37. Direct Testimony of Richard B. Hubbard and Steven C.
Sholly on behalf of California Public Utilities
Commission, regarding Diablo Canyon Rate Case, PG&E's
Failure to Establish Its Committed Design QA Program,
Application Nos. 84-06-014 and 85-08-025, Exhibit No.
10",935, March, 1987.
38. Testimony of Gregory C. Minor, Steven C. Sholly et. al.
on behalf of Suffolk County, regarding LILCO's Reception
Centers (Planning Basis) , before the Atomic Safety and
Licensing Board, in the matter of Long Island Lighting
Company, Shoreham Nuclear Power Station Unit 1, Docket
No. 50-322-OL-3, April 13, 1987.
39. Rebuttal Testimony of Gregory C. Minor and Steven C.
Sholly on behalf of Suffolk County regarding LILCO's
Reception Centers (Addressing Testimony of Lewis G.
Hulman) , Docket No. 50-322-OL-3, May 27, 1987.
40. Review of Selected Aspects of NUREG-1150, "Reactor Risk
Reference Document," prepared for the Illinois
Department of Nuclear Safety by MHB Technical
Associates, September 1987.
* Available from the U.S.
Public Document Room,
Washington, D.C.
Nuclear Regulatory Commission,
Lobby, 1717 H Street, N.W.,
381
®
NEW ENGLAND NUCLEAR NEWS
NUCLEAR OENERATIOM AS A PERCENT OF TOTAL ENERGY REQUIREMENTS
APRIL, 1M7
CAPACITY FACTORS
Connecticut YankM
Millston* 1
MHIston* 2
Millstone 3
Vermont Yankee
Maine Yankee
Yankee
Pilflnm
'coastdown
WeighlBd Ayngt Capacity Factor
Nat
Barrala
Year to
KilowatttMHira
Oil Saved
Menth
Date
Cumuletlve
%
%
%
334.216,000
554,300
80.0
92.0
76 0
463,479,000
766.600
977
970
684
597,711,000
991,200
94.9
81 1
625
463,732.000
752,500
547
687
789
353,972.000
587,000
95.8
991
687
-0-
-0-
-0-
641
689
97,011,000
160.900
•771
865
70.9
-0-
-0-
-0-
•0-
529
58.6%
71 1%
67.0%
Total Nuclear Generation
Total Energy Requirements
Nuclear as % ot Total
Total Barrets Oil Saved
2,300.121.000
8.184.000,000
281%
3,814,500
TWELVE MONTHS ENDED APRIL 1987:
Nuclear Generation:
Nuclear as a Percent ol Total Energy Requirements:
Barrels of Oil Saved: .
32.699.000.000 kwhs
32 0 percent
54.227.000 barrels
/-■■
New
England
Nuclear
News
ELECTRIC COUNCIL OF NEW ENGLAND
54 MIDDLESEX TURNPIKE. BEDFORD. MA 01730
382
.e«-.
' • -; . s
JUNE 1987
(April Data)
CONNECTICUT YANKEE
On April 16, the plant shutdown because of problems with turbine control valve #4. After
chemistry holds and a load runback, the plant reached full power (94%) on April 2lst.
The Institute for Nuclear Power Operations (INPO) will conduct its annual critique of plant
operations beginning on June 8th.
MAINE YANKEE
Maine Yankee shutdown for refueling is proceeding generally according to schedule with
startup expected in early June. Very small cracks found in the disks of both low pressure
turbine rotors have necessitated the replacement of one and the repair of the other.
YANKEE
Yankee began its 18th refueling on May 2nd. The last cycle of the plant produced more
than 2 million megawatthours over a 17 month period with a capacity factor of 93 percent.
PILGRIM
Pilgrim remained off-line during the month.
VERMONT YANKEE
On April 4, Vermont Yankee came down in power and took the turbine off-line to repair
a small steam leak in a main steam drain line. The plant came back on-line the same day
and operated at full power for the remainder of the month.
MILLSTONE 1 & 2
Millstone Unit 1 operated routinely for the month of April. A scheduled refueling outage
will begin in mid-June and last for approximately 10 weeks. Millstone Unit 2 operated routine-
ly except for a trip on April 16 due to a generator exciter field circuit breaker opening on
presumed bistable transformer fault lndk:ation. Instruments in place to monitor the suspect
bistable. The unit returned to service after a 20 hour outage on April ia
MILLSTONE 3
Millstone Unit 3 returned to service after a scheduled outage. After startup on April 11,
the unit tripped on the next day while at 10 percent power level due to steam generator
low level when turbine driven feed pump oscillated. Feedwater regulating control valve
failed to open on demand due to a control air leak. The unit returned to service on April
14 after being out for 29 hours.
Qcne
PuOiith»d Dy irt«
Nuci««r inionnatlon Commtn**
of mt Etsar'C Council
ot New England
383
^ ,. NUCLEAR REGULATORY COMMISSION
Z REGION I
I til rsMK AVCfaus
• KINO or roussi*. rCNNSVLVANIA I MO*
AUG 27 1986
Docket No. 50-293
Boston Edison Company M/C Nuclear
ATTN: Mr. James M. Lydon
Chief Operating Officer ^
800 Boylston Street
Boston, Massachusetts 02199
Gentlemen :
Subject: Confirmatory Action Letter 86-10
This letter is to provide further guidance on the requirements we expect to be met
prior to the restart of the Pilgrim plant. We acknowledge receipt of Boston
Edison Company's (BECO) letter of June 16, 1986, in response to CtSTfi rmatory Action
Letter (CAL) 86-10. Your actions with regard to the issues in CAL 86-10 appear to
be thorough and technically sound., .My staff has a few remaining questions, which
have been discussed with your staff and which will be documented in Inspection
Report 50-293/86-25.
In addition to the specific plant hardware issues involved with CAL 86-10, several
other issues have been identified that require resolution prior to restart of the
Pilgrim plant. Specific technical issues of concern include: overdue survPil-
lances. malfunction of recirculation motor generator set field breakers, seismic
Qualification of emerqency diesel generator differential relays, and completion of
Appendix R modifications. Please be prepared to discuss %he%e issues at our next
management meeting at the plant on September 9. 1986! V/e would also like, to near
at this meeting the scope and status of all vour Droarams related to restart of
.Pilgrim. These include (a) the results of your six week action plan for improve-
ments, (b) the role of BcCO safety review committees, including the Program For
Fxrpllpnce Task Force, in assessing readiness for restart, and (c) the readiness of
the plant and corporate staff to support plant startup, testing, and operations.
In light of the number and scope of the outstanding issues. I am not prepared to
approve restart of the Pilgrim facility until vou nrnvide a writtpn rppnrt that
documents BECO's formal assessment of the readiness for restart operation. This
assessment should include your detailed check list for assuring that all out-
standing items have been satisfactorily resolved and that plant systems have been
restored and prepared for operation. A formal restart program and schedule should
also be submitted for NRC review and approval. This program should include hold
points at appropriate stages such as critical ity. completion of mode switch test-
ing, and at specific milestones during ascension to full power. Authorization to
proceed beyond each hold point will be contingent upon my approval and will be
based on my staff's evaluation of the operational performance of the plant. We
will have substantially augmented NRC Inspection coverage during this restart
period.
Please plan to submit your readiness assessment and restart program and schedule
at least fortv-five days before your planned startup from the current outage. My
decision on restart will be based In part on our review of these documents.
384
Your cooperation is appreciated.
Sincerely,
'7A>»»«**-'S
Thomas E. Murley
Regional Administrator
cc;
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
The Honorable E. J. Markey
J. D. Keyes
Senator Edward P. Kirby
The Honorable Peter V. Forman
Sharon Pollard
Public Document Room (PDR)
Uocal Public Document Room (LPOR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Massachusetts (2)
385
t'^r^M i «£GIONl
^-' .3' KING or 'auniA 'IMNSVLVANIA 1t4M
•...♦
APR 0 £ 1997
Cornet No. 50-293
Boston Edison Compiny M/C Nuclear
ATTN: M-. Ralph Bird
Senior Vice President - Nuclear
&Z0 3oyl stor Street
=c;-.cn. Kasjacr.. setts CZ193
Ge-*. 'em«n:
Subject Systematic Assessment of Licensee Performtnct ( SALP) Reoort
No. SO-293/86-99
"-6 R»;-or, I SAl? esarc las reviewed and evaluated the ptrfor««itc« of actfv-
T.-es at tn? Silgr-m Nuclear Power Station for the period Novtmbtr 1, :9£5
tr,rcJ9^ January 31, 1987. The results are presented 1r ih« enclostd re?:'rV
A -i9f'<; tc o-.scjss *.hi$ assessment will &» scheduled -for 4 •utually ictep:-
iz' i Ci.e T-e -reting .•:: ss leld en or near the site so that appr<:p--'i-e
i«- -.' -croc'jte r-e-acerent arc piant c'ficlals ccn discvss w1 ih ^% t-e
:-.-?-:t.-i a-d ■.rc-.-esses r.oted. It is ojr <r^tnl that this iraetlng fet ecsrSinec
«■•.'■ -.'e per-oc-c -.cra9eT:ent meeting to review Icorcv enen progpia status'
'-t SALP Boa'S -centified significant recur-lng progra n veakntsses *- i:-e
•■--rt-onal areas. Irprovewents, such as ir, tr,e are* of ene'sency preparediess.
-e-s i^sc n?:sc However, the SALP Boarc *ound the rare of such charte '.aJ
slow iurirg nost -' the assessment pencd.
We recognize tfat the Boston Edison Company (BECo) has B;adt significant scaf'-
•-; a-c '■'-ir^i.rt conritinents to inprcve per'ormance at t^:e Pllgrln rtaticr and
»e se'iieve they a'e beginning to have a positive iaipact. Aj you art aware, t.-e
S^C ■'. ><o»ing for progress In correcting the previously 1dtnt1f1«t lor:'te —
:-ei'?-i at :ie P-lgrip Station prior tp c'ani -estart. particular'/ if-' --:■.:
■'.'T-zi' areas -'tn a Category 3 rating.
In ;-e;;-«t:or fpr the SAL? netting, please oc prtparttf t.9 discuss ysar tvalua-
t-cn cr our asstssmtnt and tht status of ycur ptrfermancf ImprowtBtrt prc;-c-i
Ary ton-rents you way have regarding our resort may be discuistd at f.t mssf-:.
Acc-fi-all/^ you may provide written co.r-ents witnin 20 days after tht neet-
'■''■<3 follotiMf our iiittting and rtctipt of your wrltttn rtsponst, tht tnclosea
-eport, your rtsponst. and a summary of our findings ar d olanntd actio-* wi"'
te ;"icea in tht NkC Public document Room.
386
63
•ABLE 4
•NFQRCEMEN- SUMMARY (11/:: '85 - 01/31/67)
PILGRIM NUCLEAR POWER STATION
Sj-se"- ane Sevfity Ltve' o' V'cltnons
Seventy Level I
Seventy Leve^ II
Severity L%ve' HI
Seventy Leve" IV
Sevei-ity Leve' V
2s. ■ ati on
. • : ' o 1 1 0 n s 7s -u^ct'ca" Area
0
0
1
21
6
1
IT
•C^o
>«ve''t. Le^e s
'iT iV V .".'ev TcT«l
'■' i". Ore'sv :-s
■I'.-z' zz- zi' C:--.-:'s
"i --.e-a-ce
S.'.e- ■ 'ance
E-c-ge-cy --e:i-?c-ess
:'r.---.y Se-'ec.s<-cs
Cj".agt M«n»ctfrer,t jno
"ic-fiCiilo^ if.ivities
L-censing Activities
'c'*'ng anc C ja 1 i f icati on
E" 'eC'.' veness
-::.-c':fc :' :.r-y
1
3
1
5 3
0
c
ca'. S, :::--.
a
387
6£
'ABA t iZo'-r.^-.^eC)
Sumrn* ry
.-spection
JTese-". Severity Punctionil
s^nsf '.eve' Arta V<o1it1on ^
£S-2i V Surveillance Instrumtnt chtnntl tt$t$
wert not bting performed
monthly for tht r»tctor
building vtnt and stack waste
9<t Mnit.ors.
= :-:* V Secj"t> P«nure to perform a
Se'e;.e'--s oroper jtarcn of a package
trcught 1 nto the protected
area.
if-:: ;• -'ir'. Post tri5 review 86-01 arc
Zii'ii^c". 86-02 U: <.ec recalred
recorde' .:*«i-t$. Inadeouat?
cortrol - 3om let entries c
O'sa&ied ur.r.w.'.c-.ators.
i-:-:i ::: ne;-o1o;-Cc" * waste s+iioTe-t of solid
If'.'-z'i metall'^c oiices on rrcn-
lompactec trash lacked
re;uirea jtrong packaglftg i-z
Quality control seasures
::-;£ :, Sj've-llirce Replaceme-nt squib charges
were instaned '.n the star.:;,
liquid ccTtrol syster frc- a
3atch tCet hatf not be«n les.e:
Curing a manual Initiation c -
tne Standby Liquid Ccntrol
System.
c:-:: IV Ra::olcg'cal Radiatlor surveys of paciaceo
Coitro's irradiated reactor components
were not cocu'cnted on
appropriate radiation survey
forms anc macs.
ci-'.l "., iji.-o-:e o' Quality c ontrcl reasu-es we -e
!.= ■■-... -.at tc«e- -n trarsfe"-'re
rac"c*ct" ■'• waste sh:pmerts
388
C3
^ABlE i (Cont^njed)
Sun.Tiiry
inspecii on
Report Severity Functional
\.-:e' Level A^ea Violation
S:-14 :v Assurance 0^ Prtvlously Idtntlfled
Quall'.y intfliquaclis Involving
survtillanct ttitlng of t-e
high prtsiurt coolant
Injtciion systtm were not
corrtctea 'or six ncnths
if-".-: V S j've- ' ' a'ce Failure to sroperly cont-cl
•i«4$urinc and tejt equ'.c-art
:5-Zl ;*' Su've-'^once Eatt«ry 'ater " saa C"sc'is-;e
Test proceCjrs was not
jpaatec t.o -e'"ect sj-stetr
alteratlo-^s a-c rtstorat'sns
:•:-;: '. . ^ssurir-e if Failure a nc '•'al f unct" on
Cj«"':v fleoo't was nrt completei
by engineer- -g ptrsoinei a'te*
tney id«ntif-.ed deficient
station *ire tar»lers.
li-Z'- Su-ve'i"ance SurveiHa ice tests we^e
performec wit*o^t inreperce--.
veri f icat 'on of systei* res:.:-;
ana system restoratic*..
iz-ll Oevation F--e '"-otecf:- Failure to conply ^it^ tre
coiT.Ti traert to conduct
quarterly fire brIgaCe ar-'':
for all '1re brigade me-oe's.
i:-j- IV Secur-ty Improper paci(.a9e se«r-cn ana
Safeguards inadequate follow up.
ii'li iv Pire Protection Fire brigade members riad -^t
received the required
training.
i-.-2-. '. : t^'re '':-.e:fr- -'r» watc-.es 'ailed '.'-j ;e''':*"
the required hourly ;atrc' o'
the motor generator set -::-
389
66
C . S uomi ry
Inspection
Serct
Stve'i ty
.evel
"AqlE i (Contlnjtd)
Tunctionil
Arjj
VioUtlon
£6-37
86-37
IV
IV
IV
Pire Protection
^^odi ^ic«f.ons
-■'e Prcterfcn
In*dtquatt fire brigade Crii:
Sif«ty-r«1»t«d BOdl'lCJiions
were not perf or««d 1 n
tccordtrcc with •pplicablc
design rcqulriments.
AdcQuate procedures and
Cnwings hid not been
estiblisned •^or the stiticn
*ire wet sr s.ifStea.
-■--i.i
•-C1
87-03
'-33
:v
IV
IV
IV
IV
Oiogicc'
Fi^.ure tc 1-; ement a
rolS
radioloQ ical co'trol orocec.
for c'>ec«.inc ve-.icle'S 1ea>'-
the site .
-ve I ' laice
's'. -tenance
P'-e Protection
Radiological
Cc-t'o I s
i'S'-'a'ce
Fai.ure to ad^•re tc tie
proceOwrtJ gnveming
survei 1 ";.anc€ te;t1nc of t-e
Post Acc'der-. Sampling
Syster ( -^ASS ) system .
Lack cf ;)rocedure guidance c-
raaintena-ice cf th« neat
tracing ciortrol drcjlt ri'j^i
for the f'ASS system.
Failure to take required
action for Inoperable fire
protecf.on eculpment.
Failure to control a master
key to a* 1 lc:k.ea nl;h
'•adiation areas.
Fai''u-e and "alfuncfon
Sesc-t r. 3t cc-ipleteC afte-
a sa'et. -'elated t-s trar,-?-
cic rot r>ccur during a
■survei ■'' ence test.
390
67
'ABlE i (Continued)
S jmiiupy
inspection
neoo't Severity Punctionil
s.-:e- '.eve^ Area Violation
i'-Qi IV Surveillince A survcHlanc* test on Staniiiy
Gas Tre»UMnt Systtm failed tc
meet tht Inttrt of the Tech
Socc rcqulrttitnts.
£7-Ci IV jurveillance Failure to calibrate measur'-g
and test cqufsrent.
t"-:- v' *!od" f ication Perforr>ing pcst-aodi f Icatlc"
test or. the refuel bridge
w^thou^ a;;-rved procedure
changes.
£"-;i 'A Surveillance Maste*- test r':;ram proceCL'ei
00 not «cec. ---.ely acdress
su'vei " I*'' : test ard pest
modi f leaf test programs.
391
UNITED state:
-" > / '■ ^- r..C;-=aF REGULATOR y COWV!S.S'0'
i J ^ ■ --■ . RECn. :
i ~--i
MAY 2 0 1986 RECEl V C.L
Docket No. 50-293
Boston Edison Company M/C Nuclear
ATTN: Mr. William 0. Harrington
Senior Vice President, Nuclear
800 Soylston Street i
Boston, Massachusetts 02199
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP)
Report No. 50-293/85-99
This letter refers to the Systematic Assessment of Licensee Performance (SALP)
of the Pilgrim Nuclear Power Station for the period of October 1, 1984 through
October 31, 1985, Initially forwarded to you by our February 18, 1986 letter
(Enclosure 1). This SALP evaluation was discussed with you and your staff at
a meeting held in Plymouth, Massachusetts on March 5, 1986 (see Enclosure 2 for
attendees). We have reviewed your March 26, 1986 written comments (Enclosure 3)
and herewith transmit the final report (Enclosure 4).
Overall, your performance in the operation of the facility was found acceptable
although some areas were only minimally acceptable.
As projected in our letter of February 18, 1986, a special In-depth team in-
spection was conducted from February 18 to March 7, 1986 (Inspection Report
No. 50-293/86-06) to determine the underlying reasons for the poor performance
discussed above The team found that improvements were inhibited by (1) incom-
plete staffing, in particular operators and key mid-level supervisory personnel,
(2) a prevailing view In the organization that the improvements made to date
have corrected the problems, (3) reluctance, by management, to acknowledge some
oroblems identified by the NRC, and (4) dependence on third parties to identify
problems rather than Implementing an effective program for self-identification
of weaknesses. We believe these findings confirmed the SALP Board conclusions.
We acknowledge your discussion of program and staffing improvements in plant
operations, radiological controls and emergency preparedness. However, we
believe that tht success of your programs depends upon resolution of the four
principal factors Inhibiting Improvement noted above which, in turn, depends
heavily on MingMwnt attitudes and aggressive followup. In this regard we
request that you be prepared to discuss the scope, content and schedule of each
improvement program at a management meeting scheduled for 1:00 p.m. on June 12.
1986 at the NRC Region I Office.
392
TA5.; i.
en-:':e--es' Su^^'<>ry (:c'i/84 - io/3i.-g;)
PILSRIM NUCllAR power STATION
FUNCTIONAL AREAS
A. Pljnt Operjtions
B. Rafiiologicil Controls
C Kj-rterarce L ^::- •' ■ ca-.ioi-s
D, Survei ■! "larce
E. Efrergency Preparesress
F Security I, Safeo-arcs
G- Refueling & Outage ^'ar.agement
H Licensing Acti vi ties
":-.a"s 6> U.i'-:, .e.f' C : 2 17 5 2 27
Seve
-■ty
Level
_$
I
II
III
IV
y
DEV
Tota'
-
-
-
4
2
6
-
-
1
1
1
5
-
-
-
1
-
•
-
-
-
9
2
:z
-
-'
-
2
-
z
-
-
1
-
-
1
-
-
-
-
-
0
-
-
-
-
-
-
0
393
Injp.
Ipso.
SevB'-ly
Func-.iorjl
No.
D<tt
n/1-11/85
Lev»l
krtt
84-36
IV
P1«nt
Op«rit1ons
IV
PUnt
Optrjtions
'AS.-: 5
PILGRIM NUCLEAR POWER STATION
V1o1«t1on
F»11urt to conduct in adequate
shift turnover for control room
perjonnel auring refueling
Failure to continuously momto'"
source range mon-tl'S dj'-ng
refuel 1ng
84-39 11/21- IV Surveillance Failure to promptly Identify
12/31/84 conditions adverse to quality
(I.e. failure to initiate Fa'lu'e
and Malfunction Reports)
84-41 12/10-13/84 IV Emergency Failure to disemlnate emergency
Preparedness planning information
IV E-?':j-:y railurt to update the emerge'cy
-'e:2-i:-iss r's' I'Z pr;:e3»-ei
84-44 12/1S-1S/64 ::: Radiological Failure to follow radiation work
Contro'S permit Instructions and failure
to establish a procedure for a
remote reading teledosimetry
system
65-Cl 1/1-31/E5 V Plant Failu'-e to maintain control room
C;er4-.icrs staffing at levels required by
10 CFR S0.S4
IV Surveillance Failure to test the containTiert
cooling subsysten Immtdlately
when the low pressure coolant
Injection system was inoperable
65-03 Z/l'SS- IV S-'veil lance Failure to conduct surveillance
3/4'£5 tests for the reactor protectim
system (six txaaples)
IV Surveillance Failure to conduct rod block
surveillance Utts (five examples)
394
-3-i
Inip. I'-s; Seve'ity Functional
No. D«te Leve' A-ea V'ci*-.ion
IV P1«nt Ftllurt to proilptly correct cc-"
Operjtloni dltlonj *dver$» to gutlUy (i.e.
fillurt to t*k.« timely «ctlon
on Oujllty Aiiurtnce survt1ll»nce
f indlngj)
V Surveillance Fi11ur« to UM M» MSt current
revision of ^ MiMtei^ ^tnce test
procedure ^!-
V Surveillance Failure to calibrate test eouip-
■tnt within the calibrated penod
85-06 3'5'E:- V Plant Failure to maintain an uncall-
i/l/ll Operations brated local power range ironltor
In a bypassed state
IV Maintenance Failure to conduct a dioctyl
phthalate test of HEPA filters
following naintcnancc on the
standby gas treatment system
85-13 5/2C-24 '£5 V Radiological Failure to have the Operations
Cc-t'ols Rev.e* Con-mittee (3RI) review
tw: rai'c^:g-c4' procei-'es t-t
failure to control worii in the
fuel pool with a maintenance
request
Cevietion Radiological Failure to conduct an adequate
Controls review of systems that could
generate *n uncontrolled, un-
monitored radioactive effluent
release, as recominended in IE
Bulletin 80-10
85-17 6'13/85- IV Surveillance Failure to conduct a surveillance
7/15/65 surveillance test of the 2S0 V
battery system required by the
technical specification and to
follow station procedures for
additional battery tests
IV Radiological Failure to specify high radiation
Controls area surveillance freoje-cies
on radiation ••rd pennits
395
•-S-3
Deviation Surveillince F«11ure to conduct inse'-vice
ttjts as specified in an NRC
Submittal
85-20 7':6/S5- IV SyveiT lance FaMure to maintain the f-o
8/19/85 level setting far the "B" and
"C" Min sttaa Itne high radi-
ation monitors within technical
specification limits
85-21 7'16/£5- IV Sur^eniance Failure to maintain secondary
7/30/S5 containment
IV Su'veil'ance Failure to test alternate safety
system when an emergency diesel
generator was found to be
Inoperable
IV Surveillance Failure to initiate Failure and
Kalfunctlon Reports as required
by station procedures
85-24 8/6-e'e5 III Security Failure to maintain ar adeauate
v'tii area barne-
85-26 ; Z: £5- IV P'ant Failure to properly authorize
9 2i/£5 Operations excessive licensed operator
over-.ime as required by station
procedures (thirty-five instances)
£:-27 9 '16/85- Deviation Radiological Failure to install a protective
5 ;' c: C;--.'c"s conduit
396
; UMTED STATES
■- NUCLEAR REGULATORY COMMISSION
I nCGION I
/ U1 »*KK AVtH\Jt
KIMC O' »«USSIA rtNNSVLVANIA IMM
Ooc^.t NO. 50-293 j^^ ^5,3gc '^ ' ^- ^ ■ : ,.
Boston Edison Company M/C Nucliar
ATTN: Mr. William 0. Harrington
Senior Vice President, Nuclear
800 Boylston Street ''^'' C<
Boston, Massachusetts 02199
Gentlemen:
SuBject; Systematic Assessment of Licensee Performance (SALP) Report No 50-293.
84-34 and Your Reply Letter BECo 85-031 Dated FeOruary 12, 1985
Thank you for your reply to SALP Report No. 50-293/84-34. In your lette' you s-e-
sented additional information concerning assessments and requested we recofHioe-
some of the assessments to Better account for the assessment period's extraora- narv
circumstances (i.e., the extended outage for piping replacement).
Based on our discussions with you at the January 23, 1985 management meeting and
the information presented in your reply letter, the SALP Board founa it appropriate
to revise the declining trend of the Category 2 rating for fire protection/house-
keeping to a Category 2 rating with a consistent trend. We feel this is appropria*.
as we may not have properly accounted for the extended outage m our evaluation
for trend. However, we continue to feel that the extent of contamination tnat
existed throughout the plant was inconsistent with a Category l rating. The en-
closed SALP Report has been supplemented to reflect this change. The SAL? Boara
also found that the other ratings should remain unchanged.
With regard to the current status of your operations, we acknowledge the improving
trend of your performance in the plant operations and maintenance areas ana en-
courage you to continue your efforts in these areas. Further, we note me prog'ess
Being made in implementing your recently established Radiological Improvement Pro-
gram and encourage your efforts to decontaminate the plant, to reduce plant --aai-
ation levels, to enhance oversight of the radiation protection program, and to
establish support for the program by plant personnel.
Your cooperation with us ii appreciated.
Sincerely,
Thoatas E. Hurley^ ^
Regional Adainistrator
397
38
TABLE 2
VIOLATION SUMWARY (7/1/83 - 9/30/84)
PILGRIM NUCLEAR POWER STATION
A. Number and SevtrHy Lev«1 of Violations
Severity Level I
Severity Level II
Seventy Level III
Severity Level IV
Severity Level V
Deviation
ToUl
0
0
1
18
6
_1
26"
B. Violations Vs. Functional Area
Functional Areas
Severity Level
I II III IV V OEV
A.
Plant Operations
2
5
B.
Radiological Controls*
1
7
1 1
C.
Maintenance
2
0.
Surveillance
1
E.
Fire Protection and Housekeeping
F.
Emergency Preparedness
G.
Security and Safeguards
6
H.
Refuel inq and Outage Management
I.
Licensing Activities
Totals*
18
'Totals do not include three apparent violations and one apparent deviation in
the area of radiological controls that were identified during inspection 84-25.
NRC enforcement action was under review at the end of the assessment period.
398
39
C. SumiTiary
Insoection Insptction Stwerity
Report No. Dat« Level
83-19
83-20
83-21
83-23
83-24
84-03
84-04
84-06
8/15-10/3/83
8/8-12/83
8/22-24/83
1/20-27/84
2/7-3/12/84
2/13-17/84
IV
i:/4-ll/7/83 IV
IV
11/8-12/31/83 IV
III
IV
IV
functional
Area
Violation
Failure to review ana se-
date special orcers
Failure to vent 3iD-?5 '---
the hign point in i,-.e ::-»
spray system
Failure lo follow a Rao'-
ation Work Permit
Failure to schedule 'exte—
nal audits
Failure to document defi-
ciencies in deficiency
reports
Failure to conduct an in-
service test on a hign
pressure coolant inject'in
(HPCI) valve
Failure to review a proce-
dure for procuring safety-
related items.
Failure to record reactor
vessel cool down rate
Failure to label a contai-er
of licensed material, use
extremity dosimetry, anc
instruct workers on radi-
ation levels
Failure to maintain a pro-
cedure for the proper
operation of the contain-
Mnt atmospheric dilution
system
Failure tc follow a radi-
ation work permit
399
40
Inspection
Beport No.
84-11
84-13
Inspection
Date
4/23-27/84
4/24-27/84
84-14
5/9-11/84
84-22
7/16-20/84
Severity
Level
IV
IV
functional
Area
IV
OEV
IV
IV
IV
IV
IV
IV
IV
B
B
G
G
G
G
Violat^'on
Failure to maintain a :rc-
cedure for control 'ing
welding slag
Failure to property -o.,-ew
and approve cont- acto- :-t-
cedures involv-ng trans^c-
tation of radioacfve
materials
Failure to comply wifi fe
requirements of a Cerf *•-
cate of Compliance for a
transport package
Failure to properly docume"':
a quality assurance program
for transport packages
Failure to fulfill a t-ans-
portation training comm-t-
mtnt
Failure to instruct wor<e-s
on the presence of raa:c-
active materials
Failure to survey '•adiation
hazards
Failure to implement pro-
cedures consistent witn
10 CFR 20
Failure to control a
security key card
Failure to maintain pnoto
ID badges
Failure to respond to two
vital area alarms
Failure to maintain ore
guard radio and one of'site
communications net ooe'ao'e
400
41
Insoection
Report No.
Inspection
Date
Severity
Level
Functional
Area
Violation
IV
G
Failure to maintain e"i:-
tive compensatory measu'-es.
IV
G
Failure to maintain elec-
tive compensatory measj-es.
84-25
8/6-10/84
•
a
Failure to per'orm -ac-af:
surveys
*
B
Failure to instruct »«o-<e's
on radiation hazaros
».
B
Failure to properly approve
procedures
«
B
Failure to implement recom-
mendations in Regulatory
Guide 8.8
84-26
8/28-10/8/84
Failure to properly approve
QA program related proce-
dures
■Apparent violations and dtviations. Enforceffltnt action was under review at t.ie
end of tnc asscssmnt period.
401
.<■•■' '"-^
NUCLEAR REGULATORY COMMISSION
HtCION I
w
*a- sc
KING O' VauSSi* PVNNftV(.vAf«l* i«40«
i£? 1 i ?Sfi3
.r J
-:■:•.:■ Izi^' -;":3-> ** ! v.: ?a-
i-'s «- *-''-a- Z -a'---:-.:'-
5?- :' .:? -'es"Ce-t. N-r'ea-
;■- :-^-. --^ S'. ""^^t
E;3-.:- "ciSir-.ie-.-.:- ::irr
RECEIVED
-i"- ^'5' W. D. H.
i.i.i:' ii'i"-".: issEi!*'Es" :- -::en5EE ^e^tcrmance (Si.= )
"-f s^I ^ec";' I Si-- Eca*: cc":,;tec a •■evie* on August 25. 15E2, a': s.a .
:-T :9-':'-a"ce :' a:-.'v-,-es assoc^a-ec w^ti trie Oilg-im N^c'ea' -:«€' 5: = :
*■? -9s-"ts :•' t"-s assess-e't a'e Ccc^me-tec in tne enc'csec i^^- 5:o'C -e:
i -sef; "as res' sc-ec-'«c *3' Secte'-:e' 21. 19:;, at E'a-'t'se. "i :z
ziz.ii :-■% asjsss^e'".
-•- :"» ■'ii'.--^. yc. snc-'; De :'e:a'ec to 2'scjss our asses5ie"t a'z /C
:'a-: ;: ■-:-:.« :e'-c"^a':e i"/ ri~"ents yCw may nave 'e;3'C-'c :.- '?::-
*:.. :e :-s:.;se: at f» "leefc. Acc fona' ^y , you may cov'ce x-'tte" :: —
'"■ — 11 Coj s a-'ter f^e Tsefng
■: :-'■: :.- lesfc a-z 'ece':t o* you"- resoo'se. tie e^z'ziec '?:r't. ,:,
'?;::';9. a't i s-mTa'> ;• c-' ••nr^rgs arc D^annec arfons ••■"'' :e z' iziz -
-"5 ■'■'1 -.:"■; Icr.-e-t ncor.
'at ■ :
s ari's: • ats:.
S'n;e'e'
y .
a'-ostecK.i
an. j-'e:t3'
Division o' Project anc
Resiaent P'ograirs
:3-'s As Statec
A. V M;,..j,^ Ma-,age'. Nut'ea' Doe^ations Suooont
- - *'at-lS. Stifcn "o-ags--
402
3S
'AS.i 4
SunOS' a"; Seve'^'ty Ueve^ c* V'c'at'ofs
Seve'-^y Leve" I
0
Seve-^ty level II
0
Seve-Uy Level III
1
Seve-ity Level IV
9
Seve-ity Level V
20
Dev-ations
3
Tota" Violations
30
Vc'at'3'^s Vs. "un;t'onal
Area
'otal Oeviat'ons 3
Seve-'ty Leve's
^jnc
'::na.
AREAS
I
II
T » •
:v
V
DEV
.
5 -a-.
Ooe-a-.
•ons
4
8
Rac-o'
loq-ical
Cont-o''s
1
-
'
2
Ma-'-.i
!-ance
1
*
•
i
Su've
•" lance
5
c.-e 1
'-otect
lon/Mousetieeoiic
3
'_
6
E'^e'-aency P^i
Boa-eflness
■7
5e:u''
'ty anC
Safeguards
1
3
2
Q
Re^ue'
'-nc _ __
C
.•sensing Ac
tivitle$
Totals
1
20
Total Violations = 30
Total Deviations * 3
403
'AS_£ i (Corf "uei)
'SDe:for inspection Reoulre-
-^ °iH SuB:e:t ments Seve-
2-"-5 June It - BiOCH'ng ocen t f re T.S. V
August I aoc- w-itnout proper
control s
Failure to evaluate T.S. v
fire loading prior
to moving combustibles
into safety related
area
Failure to trinslate 10CFR50 V
oesign bases into App. B
drawings
Failure to perform 10CFR50.59 V
an aaequate safety
evaluation prior to
Changing a station
valve lineup procedure
Failure to maintain T.S. V
a fire door position
continuously annunciated
Failure to perform Fire D
daily cneciks of non- Protection
alarmed fire doors Review
as committed to tht
NRC
"' '^ August 2 - Failure to mane a T.S. IV
prompt notification
Failure to maiie a 10CFR50 V
50.72 notification
Failure to perform a T.S. IV
Icaii rate test required
by the LCO for an
inoperable Vacuum Breaker
Alarm System
404
'A=.E t (Zz'
'jec
Sjmmary
I'lsoec^' on
.psoecfon
Date
SeD'-emoe"- 7
Oc-.ooer 18
Sj:
ra" ' jre tc 'ev se
ccceaj'es 'or -ac^c-
acf i/e C scna'-ges as
comiT-ttec to tne NRC
Recu-'e-
me"*. s
.• ce'-see
Res:c' se
V-c'a-.-on
g-.-c-f
Sev 9"
32-29
N/^C)
0:-.obe' 19_-
NovernDf 15
January 31,
1983
January 25_
rearuary 28
Imcooe' eouipment
tagging
Failure to p'-ooe-ly
se*. a main steam
safety valve
Fai'ure to cooe'-ly
confol CistnDution
of tne Q-List
Fai'iu'e to use proper
methoas of access
contro I
1QC=R5:
App, B
Secy ty
Plan
Failure to prevent Security
unautr.onzed entry into Plan
vital area or followup
on a security Oeficiency
Safeguards information lCCFn.'3-4
not properly controlled
resulting in a loss of
copy of tne site pnysical
Security Plan
Failure to pe-forw
cnemistry samples
,S.
Failure to assure tnat lOCFRBO
training certification App. B
forms were completed
prior to watcn assignment
Failure to properly
control nign pressure
gas cylinoers
T.S.
:v
ZC;-
405
42
~AB.E 4 I Zor'.'r.ueC)
No
83-08
Irsoection
Cate
March 22-
Acnl 13
May 9 ■
May 13
Aor-l 4
May 3
(2)
April 19 -
May 23
Sub:ec-.
Reoui rfe-
merts
Seve-
A-sa
► a^ lure to imole- T . S . V
ment a s'.atior oro-
cecure for msoection
ana clearing of me
S3GT System inlet
plenum
Failure to conduct T.S. V
an audit of the
Radiolog'cal Envi'Dn-
mental Monitoring
P'ogram report when
requi red
Accepting, in receipt lOC^RSO V
inspection, material App. B
not in conformance
with the P.O. Require-
ments
Failure to maintain 10CFR50 IV
the 0-List App.B
Failure to update the lOCrRSC. 71(e) V
FSAR
Failure to perform lEB 79-09 D
preventive mainten- Commitment
ance as committed
to the NRC
Safeauarcs information 10CFR73.21 IV
not properly controlled
Security access card Security IV
key not properly con- Plan
trol led
406
X^fj
UNITED STATES
NUCLEAR REGULATOSY COMMISSION
REGION I
631 PARK AVENUE
KING O' 'Russia pemnsylvasia imm
Ooci>.«t No. 50-293
Boston Edison Company M/C Nuclear
ATTN: Mr. William D. Haf'ngton
Senior Vice Presiflent, Nuclear
800 Boylston Street
Boston, Massachusetts 02199
Geni'emen:
Subject; Systemafc Assessment of Licensee Performance (SA^O)
This letter and its enclosures document NRC's assessment of t-e le'-'r'^a-ce :'
licensed activities at the PUgrim Nuc>ar Power Station for tie oe'-ic Se:-.e-:e-
1, 1981, to June 30, 1982. The enclosed SALP Report, dated A^qjst 12, 1951.
Includes performance assessments for each of the nine functis-'al areas wn-:-
were evaluated. These individual assessments were discussed witn you inc y:--
staff 6y Mr. R. W. Starostecki of this office on SepiemDer 1, 1982. at fe
Boston Edison Company offices in Braintrae, MA.
Our overall assessment of the performance of NRC licensed actwties at t"ie
pilgrim facility Is that improvement has occurred since the organi rational and
personnel changes which tooii place earlier this year. There 'ow appears to De
a satisfactory level of management attention and involvement in plant sa'ety
matters. This has ennanced the plant's performance with respect to ooeratlona'
safety. We recognize tna^ efforts trt underway to improve tne management
systems and utilization of resources at the Pilgrim 'aclHty. These changes
and plans are documented in the Performance Improvement Plan which were sub-
mitted to the NRC on July 30, 1982. However, we also rea'ize that 't wT' 5e
several months before some of these improvements will be completed. Alt-^ougn
performance has improved recently, some shortcomings have iee'^ noted and we
have Included them in this report. In particular, we beHeve adS'fonal
attention is warranted on your part in tne areas of day-to-aay o'ant opera-
tions and fire protection/prevention activities. We wl'l be inc-easi-g ju'
attention to these areas to ascertain if identified wea«.ne^ses ire ae-rg
cor-ected.
In the meeting of September 1. 1982, the NRC staff bene'-'ted ''om your co-nmerts
concerning the SALP Program and the functional area performance assesS'Te-ts .
I have also reviewed your letter of Septemeer 20, 1982 and have --c'jcec
responses to your comments in this pacitage. The SALP Board also co^siae'ea
your concerns and I had the benefit of their input. The results of these
considerations are presented below.
407
TABLE 5
VIOmTIONS (9/V81 - 6/30/82)
PILGRIM NUCLEAR POWER STATION
A. nxattr tnd Severity Level of Violations
4. Interim IRC Policy Severity Level (September ^, T981 - Mareti 9. !982)
Severity Level I
Severity Level II
Severity Level III
Severity Level IV
Severity Level V
Severity Level VI
Oeviitlon
0
0
6
5
17
2
1
*• H»C Policy Severity Levels (March 10. 1982 - June 30. 1982*)
J«»»rity Level I
5*'«nty Level II
Sevtrity Level III
Severity Level IV
Sf erity Level V
Oeviitlon
0
0
1
4
3
1
38
^'^1 Violations
^'^^^^^^^gUL-Iunction.l Ar,.
'^' ^^*^r 1.1981 -March 9. 1982
Total Deviations
Severity Levels
II III IV
VI
3
3
l^_!!ll!ltenjne,
4. Sury,ivw^
5. ^^^iatectiQ,
6. Egerqtt^y^^-ji
7. Securi
9. Licenilna Aeti 4
0
TT
DEV
408
TABLE 5 (Continued)
B. VloUtions Vs. Functlonil Art»
(2) March 10, 1982 - Jun« 30, 1982*
Severity Levels
PJNriONAL AREAS
I
II
HI
IV
V
:ev
1. Plant Ooeraffons
0
0
0
1
1
1
2. RadloloQical Controls*
0
0
0
1
0
0
3. Maintenance
0
0
0
1
0
3
4. Surveillance
0
0
0
0
2
0
5. Fire Protection*
0
0
0
0
0
0
6. Emergency Preparedness
0
0
0
0
0
0
7. Security t Safeguards
0
0
1
0
0
0
0
0
0
1
0
B. Refuel 1nc
0
9. Licensing Activities
0
0
0
1
0
0
Totals
Total Violations ■ 38
Total Deviations ■ 2
• Dots not Include the following reports, not yet issued:
82-19 • Resident Inspector
82-20 - Special Health Physics
36
409
TABLE 5 (Contlnuxj)
C. Sumnary
Inspection Inspection ...
fif^ Date Subject Peo. Sev. -r«a
a-1.19 June 15 - Failure to have an operable 10 CFS III 1 :9'
Sept. 30 combustible gas control system SZ.a
(multiple exuicles of design
errors, procedural and drawing
errors, and inadequate safety
reviews]
8',. 18 June 15 - Failure to Inform the NRC of T.S. Ill 1 (?:
Sept. 30 tfie erroneous statement that an
Installed system net the requlre-
mnts of 10 CFR 50. U - Material
False Statement
81-19 August 18 - Failure to follow station pro- T.S. V 1
Sept. 30 cedure
81-19 August 18 - Failure to perform a safety 10 CFR IV 1
Sept. 30 evaluation prior to disabling 50.59
protection for an RhR pump
81-21 August 31 - Failure to post a high radia- T.S. IV 2
Oct. 2 t1on area
81-21 August 31 - Failure to adhere to radiation T.S. V 2
Oct. 2 protection procedures for
radiation work permits.
81-21 August 31 - Failure to post copies of NOV's 10 cn« V 2
Oct. 2 Involving radiation protection 19
81-22 Sept. 16 - RCIC containment Isolation valves T.S. HI 1
S«Pt. 17 were left open when their control
Instrumentation was Inoperable
81-2* Dec. 1, 1981- Operation at drywell temperatures 10 CFR IV 1
Jan. 18, 1982 (Povt FSAR descHptlon without 50.59
adequate safety evaluations
^^*^* 5!«' ii ^'*^- ^•^^"'^ " adequately prepare and T.S. V 1(4)
"'•"• 18, 1982 Implement proceoures for coping
with high drywell temperatures
37
410
C. SuniMry
Inspection
No.
Insotctlon
Oati
81-24
Dec.
Jan.
1, 1981-
18, 1982
81-24
Dec.
Jan.
1. 1981-
18, 1982
81-24
Dec.
Jan.
1, 1981-
18, 1982
81-24
Dm.
Jan.
1, 1981-
18, 1982
81-25
Oct.
Oct.
15 -
18. 1981
81-26
July 20, 1981
81-35
Nov.
Nov.
1 -
30
81-35
Nov.
Nov.
1 -
30
81-35
Nov,
Nov.
1 -
30
81-35
Nov.
Nov.
1 -
30
81-36
Nov.
Dec.
30, 1981-
4, 1981
81-36
Nov.
Dec.
30. 1981-
4, 1981
TABLE 5 (Continued)
Subject
Pea.
iev.
Failure to ppomptly evaluate and
correct conditions adverse to
quality
Security access card keys not pro-
perly controlled
Combustibles were not removed
froB area near hot work
Improper et^ulpment tagging
Failure to have all ORG members
present at a pr«-refuel1ng
mtting
Transported radioactive materials
mIU) liquid 1n druns
Control /Storage of combustible
gas cylinders was not 1n accord-
ance with station procedures
Failure to establish and Imple-
ment procedures for the control
of combustible scrap, waste, debrts
Failure to establish and Imple-
ment procedures for the control
of combustible o1l
Control of foreign material
during repairs to MSIV's was not
In accordance with procedure
A master surveillance schedule was
not established
T.S. Amendnents were not properly
entered into controlled voliaies
10 CFR
50 App B
V
Security
Plan
» • »
7
T.S.
V
5
T.S.
V
1 (
T.S.
V
8
10 zn
30.41
ii:
2
T.S.
V
5
T.S. V
T.S. V
T.S. V
T.S. VI
T.S. VI
9 di
38
411
TABLE 5 (Continue<i
C, SuflB«ry
Inspection
No.
Insptctl
Date
on
Subject
Pea. Sev.
Ar»
81-36
Nov.
Dec.
30.
4.
1981-
1981
Program and procedures were not
established for housekeeping and
system cleaning that meet the
standards stated in the QA Manual
10 CR V
50 Aoo 3
QAM
3 i:
82-01
Jan.
Feb.
18.
28.
1982-
1982
Workers were not properly In-
structed of the storage and
transfer of radioactive resins
10 CFR V
19.12
2
82-01
Jan.
Feb.
18.
28.
1982-
1982
Procedures were not adequately
established and lnvleninted to
provide required numbers of SCBA
units for fighting fires
T.S. V
5
82-02
Jan.
Jan.
1 -
15.
1982
UncaHbrated bnjsh recorders
Mere used during RPS surveillance
10 CR V
SO App B
4
32-02
Jan.
Jan.
1 -
15.
1982
Ma1nt«nanc« activities were per-
fonwd without using approved
procedures
T.S. IV
3
82-02
Jan.
Jan.
1 -
15.
1982
Instrumentation was not calibrated
at fr»quency specified In station
procedures
T.S. V
4
82-02
Jan.
Jan.
1 -
IS.
1962
Improper control of access to
Vital Areas
Security III
Plan
7
82-04
Jan.
Jan.
25
29.
*1982
Failure to Isplenent procedures
for Li^ and drawing change
revisions
T.S. V
4 (1
82-04
Jan.
Jan.
25
29.
1982
Drawings and procedures did not
Identify the as-built condition
of valves In piping systems
10 CR IV
50 App B
1
82-05
Feb.
Feb.
1 -
5.
1982
Untimely corrective action to
Internal QA Audit Deficiency
Reports
10 CR V
SO App B
1
82-06
Feb.
Feb.
10
12.
1982
Training and recual. program for
personnel who operate and process
ComnlttJiient DEV
lEB 79-19
2
radioactive waste not Implemented
as coonltted
39
412
TABLE S (Cont1nue<i)
C. Sunwary
Inspection
No.
Inspection
Date
N/A
Feb. 12. 1982
82-10
March 1 -
April 4. 1982
82-10
March 1 -
April 4. 1982
82-11
Feb. 25 -
Feb. 28. 1982
32-12
April 5 -
May 9. 1982
82-13
April 12 -
April 16. 1982
82-16
i
May 10 -
June 13. 1982
Subject
Pea.
sev.
Ar.a
Prompt Notification Systm
(sirens) not Installed by
February 1, 1982
Performed maintenance on valve with
red tag attached
Plant shielding study md.
(truck lock door panel) not
completed as ststed 1n
r«sponse to NRR
An unauthorized adjustment was
made to a leaking flange during
the conduct of the PCILAT
Failure to follow actions re-
quired by T.S. with Inoperable
reactor vessel water level
Instrumntatlon
Inadequate design control . for
Interfaces and verification
Failure to lock or control access
to a high radiation area (stuck
TIP drive)
10 Cr^
50.54
T.S.
NURES
0737
10 CFR
SO App J
OEY
IV
T.S. IV
10 CFR IV
50 App B
T.S. IV
1 (3;
9 (5;
2
( )* secondary area Involved
40
413
Testimony Submitted by
Stepfien J. Sweeney
President and Chief Executive Officer
Boston Edi son Company
to the
U.S. House of Representatives
Subcommittee on Energy Conservation and Power
of the
Committee on Energy and Commerce
July 16. 1986
L^.-^<-^ *7^
.r
414
•N-qccuc'::N
Boston Ed' son Comoany appreciates tne opportunity to address a
number of issues involving the Pilgrim Nuclear Power Station which are of
concern to this committee, the Nuclear Regulatory Commission and to ne
oersonaliy. At the outset let me stress that most of the issues raised o/
tne NRC in various reports and by this committee were of concef-n to -ne -ncre
than a year ago and that corrective actions were underway as early as
Septemoer 1985. As discussed in the following pages, those actions are
meeti ng wi th success .
In today's environment, public concern about nuclear power is
heightened substantially. Public confidence in the technology and the
institutions involved with it is at a low point.
Boston Edison Company has a great deal of work to do in this
environment to gain public confidence in our ability to manage and run
Pilgrim Station. I personally will not be satisfied until we have acnieved
a level of public and regulatory confidence tnat allows Pilgrim Station to
place among the best, we have made an internal commitment to measure
ourselves against the best, which is a significant change in now we are
approaching our current problems.
As will be evident in reviewing our testimony, we were historically
plagued by not lool^ing outside to measure our success and to jndertaKe tie
intensive self-criticism necessary to assess performance honestly and
objectively. That has changed. We are moving in a new direction, one based
on rising standards of excellence which are set, not by regulation, but Dy
the performance of those plants judged to be among the best.
415
It s.'ioul:: 3e noted triat tf^e concer-s we are add'-ess-ng :;ca/ i'-e
j,c<^3rent from tnose for whicn xe «*e'-e '.ned in 1982 T^g -ssjes t-ion ^e--?
,fa'-'j-related and failure to compiy with rogulaticns. ^oday, f^e 'ss-es
5 a ' " • /
re not directly related either to compliance or to safety. They in-.tea:
•nvo^'^e 3 rising stanaard of performance going far beycna -nere ::mc''a-:?
; -1 rules to a mud proader dimension in tie regulatory process, '-a: -e^
I'mension is one that dictates comparisons and success is neasu^ed py
relative performance. We endorse it.
Before discussing our current activities, let me offer perspectwe:
on three time i'rames.
The first time frame is 1972 to 1979 and Three Mile Island, ^ur
■7a-cr management shortcoming then was the ^ailure to recognize 'ully tnat
:he operational and managerial demands placed on a nuclear power plant a'"?
;e^y different from tnose of a conventional fossil-fired power plant.
?c$tcn Edison strjctured its nuclear organization as part of a tradit'cna'
:De^ating arm. ;^hile many members of the Pilgrim Station organization
'eccgnized the differences in the technologies, they had limited success 'n
jrgu'pg for the resources necessary to meet a set of standards that a'reaa.^
•ere "Sing fairly rapidly. This was also a period of poor quality fjel
•h'ci resulted in significant internal radiological problems that affecte:
t^e p' ant for years .
Then came Three Mile Island. From March 1979 until early 1982 the
same structure, under one vice president, attempted to deal with the
:ost-TMi demands on operations and engineering, while at the same t'me
3ursu'ng a construction permit for a second unit at Pilgrim Station. The
sraf* increased dramatically to 200, 300 and then 400 people. It was an
-nreascnaple wor<load for the structure and we paid a costly penalty 'zr -c:
'8::gn;z;rg -^ .. 5550. qco in early 1932.
416
From 1982 unti ' 111(3-1985, we ooerared «1ti a new ana ■•"c^/ec
■na-iageTien: structure mat recognized tne uniQue nature cf "uc'sar ccwe--
plants and the demands of the post-TMI period. »^e committed the ("inancal
and human resources necessary to upgrade equipment and hardware ana to
•nstali various improvement programs to meet NRC concerns. More than
5300 million went into hardware improvements, the staff grew "rzm JCC to
nearly 600 people and the organization was restructured under a san-or ;i:e
president and two vice presidents. We achieved a significant Tieasur? o-
success for wnich we were recognized by the NRC and in the plant's
outstanding operating performance in both 1983 and 1985.
But in managing the equipment improvements and the new TianageTient
systems and programs we put in place, we didn't focus enough on wnat was
going on outside the company in the industry and within the NRC. what x?
didn't see because we were so internally focused was the fact that '.- =
industry itself and the NRC were looKing under, behind and around al' of t-e
narjware and management programs reaching for e<cellence.
In our case, not seeing that put us in a defensive posture, .^e
weren't identifying weaknesses that were inhibiting continued improvement
ourselves. We weren't being self-critical, others had to tell us what -a;
wrong. We weren't holding managers accountable enough for the end •'esu't of
an action or inaction. We weren't wording well enough together.
Those problems were very real, very serious and of great concern :o
me and to the Board of Directors. I became particularly concerned about
management performance, not management systems and programs, but the results
of those systems and programs as measured by effectiveness In mid-i935. I
asked the V'ce President of Nuclear Operations to investigate my concer-^s.
which ne shared, and issue a report. As he progressed through the stu^y. "e
417
-,3 oce'- managers began iaentifying needs. In SecteiiDer 1985. «e '^z-n-i-
.-e operator staff by a third, in Oecemoer, we reorganized oUnt "anage-?-:
imorove reporting relationships and build in greater accountaoi ' i tv.
In February 1986, the NRC issued their reoort. They said the sare
►ning: We had attitude problems that were seriously interfering w-:n zw
joil'ty to get the results we should be seeing given our fi-iancia' anc -..ra-
'ssource commi tuents.
By March, we had talcen a number of other actions, ail of wn;:n a-?
jetailed in the following pages. We began eliminating those old att'tjces
-lat «ere not serving us well and began to inject the nuclear organization
,ith the sl^' 's and perspectives necessary to achieve a measure of
cerfor-nance which would place us among the best. In the same time frame *e
•nade further human resource commitments. We increased our emergency
aijnning complement five-fold, we increased the number of radiological
technicians 35 percent and we implemented an apprentice program for the
'cng-term development of skilled personnel.
The shutdown on April 12 gave us an opportunity to accelerate mar
Cange. A different approach to problem solving was taken. It stressed a
■nore deliberative and Integrated effort at identifying root causes and
ran"; corrective action. In early May, a new plant manager and a new
:ce'-it'ons section head were brought on board, nearly rounding out a new ■ ■:
lemcer plant management team. Of the 16. II were new in their pos't'ons 'i
fie :ast 8 months and 5 were new to the company. We nave new perspecf ves .
''e have people with strong nuclear navy backgrounds, people with NRC
'"scection experience and people who grew up professionally not in
:cnventional fossil-fired power plants, but in nuclear plants.
418
- 3 -
On May 27. having accsDted that management is jus: as imccrta-^: n
-u'cment. ««e *cok, the unoracedented steo of giving the new plant manager
d his new team additional time, while the unit was shut down, to become
familiar -^^'^ '^® issues, to accelerate the development of new programs an:;,
TOSt importantly, to infuse the organization with attitudes and dehavio'
.riat will make those programs work,. These are attitudes tnat demand
-elf-criticism, demand accountability, demand teamworK and demand results
«hich go far beyond mere compliance with a set of rules, regulations ana
technical specifications.
Excellence is our goal. But excellence is, after all. an attitude
..nich accepts nothing less. Achieving excellence will not be easy; we <ncw
that. We <now our problems. We have made the human resource and financial
commitment to solve them. We Know what has to be done and we are doing it.
A; i result, I am confident we will, in time, demonstrate to you, to t"e
Nuc'ear Regulatory Commission and the public that we have responded
e^-'ectively to the concerns which are shared by all of us.
As a final point. I know that an important question on tne minas :f
many pecp"e is "why should Boston Edison be believed today given the
problems over the years at Pilgrim Station''"
I hope I already answered that question in part. It is perhaps t-e
most difficult question and can only be answered fully by performance ove--
time. But in dosing I would underscore two major differences today from
the past. The first is our forceful acceptance of the need *or us to
measure our performance against an ever increasing set of standards set by
those plants judged by industry and the NRC to be among the best.
419
•3 -
'he second is the fact that we have alooted the iasic or;r:^o'=s
criter'a for good -nanagement tha: are aopHed to the nuclear navy. --e_/
rg the same principles and criteria that are in evidence at all of the ::c
rated plants.
This is a demanding industry with a vital role in the soc'al and
.,-oncmic health of the count-y. It operates in a demanding regulatory
climate as evidenced by this hearing today. For us as a company -itn a
single unit to succeed in this environment means that we must impos'e on
ourselves the highest standards of performance found in the industry, ^e
are doing just that.
The balance of this filed testimony is arranged in the order of the
si« sections on which you requested information in your letter of Ju-ly 2,
1986. we have repeated your request at the beginning of each section.
420
SOSTt>\i £D'SCW
Ralph G. Bird Ju / 3 . ' 53?
3£Co L:r. 37-1 i i
•^r. 3t3vsn i Varga. Z.'S-'.zr
C'vs^c of Rsdcro'' ^'c'act:. I/II
jniTsa ;:at33 Nlc'sj'- Regj'atory Ccmmin;cn
-^asi'-;::", ^. Z. ;C:55
License CPR-3S
!:oc!<Let 50-293
:nfc«ma-:cn segasoing 'iigsim station
S.«--Ty ENHANCEMENT PqCGSAH
Reference: NRC w3t:e'", ^'coosed EnhancsTient to tne Marfc I Containment -
?'";r--Ti 3:a:xn, aated April 30. :987
Gear Mr. Varga:
As agraed iur'nq :^"7 i. '987 jiscussions between Franlc M'raglia. USNRC.
ana Jcrn -j'tcn, 3os:cn i:'30n Comcany (3£Co). -e are suOmitt'ng :nis '■esccr^j
to ycur 'ette*- t: 3E;c :at23 Aori 1 30, '937. Enclosed for jour ■ nfomat'cn •;
a retailed :esc'":fcn or r-e Safety Ennancemenr ^r^gram (SE?) naraware
tnanges tnat 5ECo las voiunrarily e'ected to ino'ement for Pilgrim Nuc'ea--
?ower Station (?NPS). "''^e ::escrioticn of procacural changes and oersonnei
t'lining «ill ;e 'jr-i-snec .nder seoarate cover. A current 'nc! ementaricn
jt'eaule -or t-e SE' iicdi f 'cat'cns -ill also 3e '"jmisned seoarate';/. A
conait'cn is t-at tie Todi f icaticns scheduled during the current outage lo "c:
'ecu'ra 3r";r governmental aooroval. Should this conaiticn not 2e "ne: 'o'" i".'
of tiese /o'uitary too; • ' cifons . with the result tnat the cur-ent
■ id' STientafon scnedule "nust oe extenaed. tnen 3ECo lill be unaole to
■Tic'eTient fe af-ecteo .^cc'-" cations curing tne :jr-ent outage.
iaa'ticnal dccumentat'on -till 5e avai'ao-e ':r 'sviaw ay fe NRC Sta^- i:
3£Co's arainfw- of*i ces 0' tie PNPS site. CognTant 3E.Co oersonnei «i ' :e
avaiiaole at those iccat-c-s "or i-scussion witn t-e Staff
Cjr-ent eva'uafo-s of fe :e"e'it from tie SE' -nodi *icafcns are oasa:
primar'ly ucon ei<t?'S"ve. a'tnaugn still ore 1 i binary , analyses and aua'itif-e
engineering jjogments. "'-a' quantitative analyses -nust. in accordance
witn the statea long te-^ goal of tne SEP. await final identification of
■ncd'f 1 cat' ens i"c rcnoiet" tn of the Indiviaual "'ant Evaluation (!?£:•.
3ECo undef-srancs fat '"e n=C intends to issue late-- this year a
gener:: 'ette'- renu'-'ng ai' alants to serforn an !?£ as part of tne
121
ie '9' =
'j.^yramen: '3 '53^63. Ei.- r'.r..j
56-8'-:: 's'.: = ^.
S3 :r93:'':ea :.- :-e
9i3S "i9' '''"SS TC tCf^TiCt ~8
:j -avo i"/ :^8;:-:-i<
/i/^,
3; ^:
:c: Nuclear Reguiatary Conriss"on
Docurent Ccntrol Des<
Wasrnrigzcn, 2. C. 2255:
Nuc'ear Requiatory CcmrnissiGn
Region I
531 ^ark Avenue
King of Prussia, ?A 19406
Senior 'IRC Resident Insoector
^ilgrir:! Nuclear Power Station
■^r. R. H. Wessman, Project ^-'anager
^Division of Reactor Projects, I, 'II
Qff-fce of Nuclear Reactor Regulation
U.S. "Judear Regulatory Cctnmisslon
7920 No»*or< Avenue
Bethesda, ''10 2C8U
422
Vdchael S Dukaias
Ciyvemor
Charles V Barry
Secretary
'I
.■J)'.^-f, ^fa.^.j^i£yui.l£/i± I' 2 / f S /i/T/ 7J7 -TTTS
EXECUTIVE SUMMARY OF THE PROGRESS
REPORT ON EMERGENCY PREPAREDNESS FOR AN
ACCIDENT AT PILGRIM NUCLEAR POWER STATION
EXECUTIVE SUMMARY
Or. December 16, 1935, I t ransi^itted to the Gaverior a
conprer.ens •- ve reoort on safety at Pilgrim Nuclear Power
Statio". . T'-.is 13 a progress report about the activities cy
state a-d local goverriT.ent, the Boston Edison Conpany, -he
U.S. Nuclear Regulatory ConT.ission and the Federal Emerge-cy
Management ^genrv since that time to address the concerns we
found.
In April of 19S6, operation of Pilgrim Station was
halted because of several mechanical problems. The U.S.
Nuclear Regulatory Commission has ordered that the Boston
Edison Cor-pany keep the plant shut until a variety of
corrections regarding the management and operation of Pilgri'
Station have been made. As of this date. Pilgrim remains
closed, although Boston Edison has asked the NRC for
permission to restart the facility.
Rad
fac
saf
man
the
pla
ser
rec
unl
add
In
iolog
ility
e t y .
ageme
reac
nning
ious
ommen
ess a
resse
my 0
ical
wer
I f
nt o
tor.
- Pl
and
ded
nd u
d.
ece
Erne
e no
urth
f th
In
ant
the
that
ntil
ber, 1986 report, I concluded that
gency Response Plans for the Pilgrim
t adequate to protect the public health
er identified serious problems regardm
e power plant and the engineering safet
my view, these three issues -- emergen
management, and reactor safety -- were
weaknesses and deficiencies so severe t
the plant should not be allowed to res
these concerns had been satisfactorily
y o:
so
There has been a considerable amount of activi!
levels to address these concerns since "" ronnn- u?,>
In
at a;
issue':
423
-2-
MCDA/OE? has InstitJted a plar'.r.i.r.g p
and local level and revisions are well un
addition, a new system has been installed
notification in the event of an accident
We now have the advantage of a new N-iclea
Preoaredness Program and a professional s
first time is dedicated to off-site emerg
and planning. This new program and staff
the Governor's initiative in the Fiscal Y
The Governor has requested additional fun
program as a supplementary appropriation
fiscal year.
roce
for
at P
r Sa
taff
ency
are
ear
ds f
for
ss a
wav .
off
ilgr
f ety
wh 1
pre
the
1988
or t
the
t the
In
-sits
im St
Ener
c h f o :
pared:
r e s u :
b u d g ;
he ne-
c u r r e r
at ;
aer
the
!33
Nonetheless, I continue to make the finding that
adequate plans for response to an accident at Pilgrim Station
do not exist, and I reaffirm my earlier position that the
Pilgrim facility should not be allowed to restart until s-^ch
plans have been fully developed and have been demonstrated to
be workable and effective through a graded exercise of all
plans and facilities.
This finding is based on the fac
area in which I found a deficiency to
1936 report substantial work remains
determination of adequacy can be made
of a new Evacuation Time Estimate and
Study by state and local authorities
ETE is one of the most critical piece
entire process and the foundation of
planning. Our preliminary review of
more resources are required to succes
traffic management plan. The shelter
prepared by Boston Edison has been re
"for further study because is was foun
inadequate .
t that in every critical
exist in my December,
to be done before a
For example, analysis
Traffic Management
IS still underway. Tr.e
3 of information in the
effective emergency
the ETE suggests that
sfully implement the
survey which was
turned to the company
d to be woefully
Plans and implementing procedures for special need
populations remain incomplete, and it may be necessary
undertake an additional survey of people who would need
assistance in emergency response or to do further stati
analysis of this matter. The development of implementi
procedures and the identification of resources to care
school age populations also requires additional work,
regard to the adequacy of reception centers, the questi
need for a facility to serve people in the northern por
of the EPZ remains open. We cannot make decisions on t
need for or identification of a third reception center
Boston Edison has provided us with an analysis of the
adequacy of the existing two reception facilities.
s
to
s 1 1 c a :
ng
for
In
on of
t ion
he
u n t i 1
424
-3-
With regard to plant management, we have seen numero-s
changes in Boston Edison's personnel and organization for
management of Pilgrim Station. The most notable change is
the appointment of Mr. Ralph G. Bird as Senior Vice
President, Naclear, who directly reports to the company's
chief executive officer. Yet despite these changes, I car.-.o-
say at this time that the management problems have been f-illy
resolved. For example, we are concerned about recent
incidents including violation of NRC regulations m the ar?a
of plant security, and allegations of excessive overtime
worked by utility employees. We are also concerned by Boszz-
Edison's action to refuel Pilgrim Station without having
responded to my objections and the objections of several
state legislators.
The Systematic Assessment of Licensee Performance ( 3A1? )
perfomed by the NRC is the most comprehensive study and
reoort on nuclear management at Pilgrim Station. The last
SALP report was issued on April 8, 1987 and it showed
deterioration in several aspects of nuclear management since
the last report. Until a similarly comprehensive analysis of
management under the new organization has been conducted and
the above concerns resolved, I cannot say that our management
concerns have been addressed.
With regard to reactor safety issues, we have carefully
reviewed Boston Edison's "Safety Enhancement Program" (SEP).
The SEP has been undertaken since the issuance of a "Draft
Generic Letter" from Mr. Robert Bernero of the NRC concerning
safety at Mark I containment structures such as the Pilgrim
containment. We have two major concerns in the area of
reactor safety.
First, despite the fact that the NRC letter was prompted
by a finding that there was a high probability of Hark I
containment failure during certain severe accident scenarios,
the NRC has yet to adopt an official position regarding
safety enhancement. Moreover, according to NRC Region I
Administrator William Russell, with whom my staff and other
state officials met at NRC's regional offices .-. King of
Prussia, Pennsylvania on October 8, 1987, enhancement of the
Mark I containment at Pilgrim is not an issue that the NRC
believes must be finally resolved before restart.
Our second concern is the uncertainty that continues to
exist about at least one feature of the Boston Edison SEP,
the direct torus vent. No concensus has been reached on
whether installation of the torus vent creates unreviewed
425
-4-
safety issues or if the torus vent is authorized, how it w. 1 1
be used in the event of a severe nuclear accident.
The findings of my December, 1986 report have been
strengthened by two other analyses of safety at Pilgrim
Station. The Special Joint Legislative Commission to Study
Pilgrim Station has issued its report which further studies
and documents many of the same safety concerns. In addition,
the Federal Emergency Management Agency has issued a
Self-Initiated Review of plans for response to an accident at
Pilgrim Station. Based on several of the issues raised m my
report FE^A has changed its interim finding and now agrees
that the off-site plans for an accident at Pilgrim are not
adequate .
FEMA has transmitted their new finding to the Nuclear
Regulatory Commission. However, the NRC has yet to indicate
whether or not development of adequate off-site plans will be
a condition to the restart of Pilgrim, we are not satisfied
with the view recently expressed by the NRC Region I staff
that emergency planning problems must be "addressed" before
restart. Such problems must be satisfactorily resolved
before restart. Off-site response plans are just as
important as nuclear management and reactor safety in
protecting the public from an accidental release of radiation.
Therefore, for these reasons — the absence of adequate
emergency response plans, lack of demonstrable assurance that
management problems have been solved, and uncertainty about
the safety of the Mark I containment structure — I continue
to find that Boston Edison has not met the heavy burden of
showing readiness to restart the Pilgrim Nuclear Power
Plant. I also continue to believe that it remains to be seen
if adequate emergency response plans can be developed and if
all other safety issues can be resolved to our satisfaction.
Finally, I recommend that in light of the number of
outstanding issues and their complexity, and Boston Edison's
evident determination to press ahead with the effort to
restart, that there should be a full scale public hearing by
the NRC before any decision is made regarding the restart of
Pilgrim Station.
October 14, 1987 CHARLES V. BARRY
SECRETARY OF PUBLIC SAFETY
1051J
426
THE COMMONWEALTH OF MASSACHUSETTS
EXECUTIVE DEPARTMENT
CIVIC D6FENSE ACCNCT *n0 OFFICE OF EME«GENCY PREPAREDNESS
400 WOBCESTEB ROAO
PO BOX I48e
FRAWINGKAM. MASS 017010317
MICHAELS DUKAKIS
GOVERNOR
ROBERT J BOULAr
DIRECTOR
September 18, 1987
Mr. RalDh Bird
Senior Vice President
Boston Edison Company
800 Boylston Street
Boston, Massachusetts
Dear Mr. Bird:
My staff has reviewed the August, 1987 "Study to Identify
Potential Shelters in EPZ Coastal Region of the Pilorim Nuclear
Power Station," which was prepared for you by Stone and Webster,
We find that this study is deficient in several respects and
that additional work is required to provide information to
local officials which is sufficient to suoport development of
implementable shelter utilization plans. I have attached a
copy of a memorandum orepared by my staff which details our
specific concerns regarding this study.
If you have any questions or observations reoarding our
evaluation, please contact Buzz Hausner of my staff.
Thank you for your cooperation in this matter.
Sine
Director
cc: Assistant Secretary, Peter W. Agens, Jr.
Deputy Director, John L. Lovering
Mr. Buzz Hausner
427
EXECUTIVE DEPARTMENT
Civil OC'CnSE AOCnC* ^**0 0*'iCE 0' (MEWJtMCT PnCPAREDNCSS
400 WOPCESTCn »»O*0
PO BOX 1490
FflAMINOMAM, UASS OirOlfliW
'-. "c
^*^ t^*-
^■IfMO^^"
MrCHAEL S DUKAKIS
OOVEBNOfl
ROBEflT J eoULAY
OIOCC'OB
TO:
FROM:
IN RE:
DATE:
DIRECTOR BOULAY
BUZ^^USNER
SHELTER SURVEY OF PILGRIM EPZ PREPARED BY BOSTON EOISOrj
COMPANY
SEPTEMBER 11, 19fl7
We have made a preliminary review of the shelter survey of the
Pilgrim EPZ which was prepared by the Boston Edison Comoany and
its consultants. While this rtocunient comoiles some very useful
data, we feel that more work must be done to estimate the
effectiveness of shelter as a protective action.
Our principal concern is that we must be able to put data in the
hands of local officials which are sufficient for the development
of shelter utilization plans for all areas of all five
communities within the Pilgrim EPZ. With this in mind, we have
the following comments.
The survey only covers an area approximately one mile
wide along the coast. The shelter capabilities of the
entire EPZ must be surveyed and reported.
The survey does not separate out those structures which
could "most reasonably" be used as shelters from those
where shelter is less appropriate.
For Instance, it would help to have a separate list of
public buildings and facilities for each town,
including an estimation of the actual useable shelter
space and protective factors for shelter under
government authority.
Many of the shelters listed, such as jewelry stores and
pharmacies are clearly not suitable for public
shelter. In a severe emergency, every available
resource will of course be put to use. However, to
develop an implementable shelter utilization plan,
local officials must be able to match estimated needs
with the most appropriate resources available.
428
Director Boulay
Page 2
Regarding protection of the heach oooulatlon, the
survey identifies shelters within a mile of the coast
but does not indicate the distances that beach goers
would have to travel to find shelter. In addition, thp
survey must demonstrate that adequate proximate shelter
Is available for the total population at the individual
beaches .
For instance, Ouxbury beach is about seven miles lonq
and the survey should indicate the distance peonle at
Saqulsh Head are required to travel to reach adequate
shelter. Further, an implementable shelter utilization
plan must demonstrate that the nearest shelter would
not be full to capacity before the people at the most
remoten^oirits of the beaches arrived.
The survey must identify adequate shelter which is
handicapped accessible.
The survey does not distinguish between available space
and usable space. For instance, residents of Plymouth
have indicated to us that some basements listed in the
survey are no more than crawl spaces. Crawl spaces
cannot be considered for public shelter. Further, in
most buildings, a good deal of floor area will be
occupied by machinery, counters, office furniture, et
cetera. The survey must identify accurately the actual
useable shelter space available in each structure.
Stone and Webster uses a FEMA nuclear attack value of
ten square feet per person to estimate the potential
population which can be sheltered. Local Civil Defense
Officials may wish to allocate more space — uo to
twenty square feet per person — in their utilization
plans. The value used in the survey overestimates the
potential capacity of various buildings. We doubt that
17,000 people can be sheltered at Ouxbury High School,
or that 89,700 can be sheltered at the 5 Cordage Park
Buildings.
The survey must demonstrate that public shelters are
free from asbestos and other environmental hazards.
The report estimates residential "shelterinq
capability" in individual communities as between 53%
and 81X. These figures indicate that a significant
number of residents do not have adequate domestic
shelter and emphasize the need for a full study of
public shelter capacities throughout the entire EPZ,
429
Director Boulay
Page 3
Further, even if It can be established that the vast
majority of residences offer adeouate shelter, local
officials must be preoared to offer public shelter of a
known protective capability to residents who demand
assistance .
This report makes no definitive statement of what
constitutes adequate shelter to protect oeoole from the
effects of a radiolooical release from Pilorim
Station. This is necessary to determine what
facilities are most appropriate for a local shelter
utilization plan and to determine the public shelter
needs of each community.
In summary, we would say that this survey is a useful beginning
but that much more work is required before we can assess our
ability to develop implementable shelter utilization plans
consistent with the public safety concerns in Secretary Barry's
report to the Governor.
cc: Assistant Secretary Peter W. Agnes, Jr.
Deputy Director John L. Lovering
430
BOSTON EDISON
itecy \,e 0*''ces
800 Scyisto'". ifee'
Bailor, Vassacruse'.tsC2'99
Ralph G. Bird September 1 7 . 1987
U.S. Nuclear Regulatory Commission
Document Control Desk
Washington. D.C. 20555
Docket 50-293
License No. DPR-3.'^
Subject: Boston Edison Company Request for
Exemption from 10 CFR Part 50.
Appendix E, Section IV. F.
Dear Sir:
In accordance with 10 CFR section 50.12(a). Boston Edison Company requests
that the Nuclear Regulatory Commission (NRC) grant a one-time exemption from
the requirements of 10 CFR Part 50. Appendix E. Section IV. F., that would
authorize the next biennial full participation emergency preparedness exercise
for the Pilgrim Nuclear Power Station (Pilgrim) to be conducted in the second
quarter of 1988. The schedule for future biennial exercises will not be
affected by this one-time exemption, but rather will continue to provide that
such exercises will be conducted every second year (i.e.. the following
biennial exercise will be held in 1989).
The proposed deferral of the full participation exercise has been discussed
with the Commonwealth of Massachusetts (Commonwealth) and local emergency
response officials. All of the parties have indicated that they support the
proposal .
The request will not affect the onsite exercise at Pilgrim planned for
December 9. 1987.
The requested exemption is necessary because the Commonwealth, the local
governments within the ten-mile plume exposure pathway emergency planning zone
(EPZ) and the two emergency reception center communities are at present
engaged in implementing numerous improvements in their offsite emergency
preparedness programs, with the assistance of Boston Edison. These
improvements include revision of the emergency plans of the local governments
revision of the Massachusetts Civil Defense Agency (MCDA) Area II plan as well
as the Commonwealth's state-wide plan, the development of revised related
procedures the development and implementation of training programs for
officials and emergency personnel, and the upgrading of Emergency Operation
Centers (EOC's). A substantial commitment of resources and time has been made
to accomplish, these improvements, and the work is expected to continue through
the remainder of the year and early 1988.
431
U.S. Nuclear Regulatory Commission
Page 2
In view of these extensive ongoing efforts, the Commonwealth and the local
governments have indicated that they are not able to participate in an
exercise during calendar year 1987. Moreover, it is apparent that under these
circumstances, conduct of the full participation exercise will be much more
effective after the ongoing improvements have been implemented. In granting
one-time exemptions authorizing deferral of exercises for licensed plants in
the past, the NRG has recognized that the most effective and beneficial
exercises are those which include the full-scale participation of State and
local governments and that it is appropriate to defer an exercise until
program revisions or facility improvements have been completed.
Since the last full participation biennial exercise at Pilgrim, Boston Edison
has held an onsite exercise at Pilgrim 1n December 1986; has held
quarterly onsite drills in March, Jjne and August of 1987; and has scheduled
its annual onsite exercise for December 9, 1987 (in which the Commonwealth
will exercise various offsite objectives as described in BECo Ltr. #87 -147
"Scheduling of Pilgrim Onsite Exercise"). The previous exercise and drills
have included limited participation by the Commonwealth, and the March and
June 1987 drills included limited participation by several of the towns. The
towns within the EPZ have also cooperated in the full scale siren test
reviewed by FEMA, which was conducted on September 29, 1986. In addition to
its activities involving Pilgrim, the Commonwealth has also participated in
full participation exercises at the Yankee Nuclear Power Station in June 1986
and is scheduled to participate In a full participation exercise at the
Vermont Yankee Nuclear Generating Station during the week of November 29, 1987.
This request meets a number of the special circumstances listed In Section
50.12(a)(2)
First, granting the request will provide only temporary relief from the
applicable regulation and the licensee has made good faith efforts to comply
with the regulation. Over the past year, Boston Edison has assisted
Commonwealth and local authorities In a variety of ways to accomplish as many
improvements as possible In their offsite emergency response programs. For
example, Boston Edison has developed substantive Information for the
enhancement of those programs. The major products of this effort Include the
"Pilgrim Station Evacuation Time Estimates and Traffic Management Plan Update"
(August 18. 1987) prepared by KLD Associates, Inc. and "A Study to Identify
Potential Shelters In the EPZ Coastline Region of Pilgrim Nuclear Power
Station" (August 1987) prepared by Stone & Webster Engineering Corporation, as
well as Information generated In surveys to Identify the special needs and
transportation dependent populations within the EPZ.
In addition. Boston Edison Is providing assistance to the local governments in
their offsite emergency program enhancement efforts in accordance with the
Massachusetts Civil Defense Act of 1950 (Chapter 639, Section 15, Acts of 1950
as amended). This assistance Includes the provision of two professional
planners to work under the direction of the officials of each town within the
EPZ In upgrading its plan, procedures and training; one
432
U. S. Nuclear Regulatory Commission
Page 3
professional planner to assist each reception center community; and four
professional planners working under the direction of MCDA in the upgrading of
the MCDA Area II and Commonwealth program. In the first half of 1987, Boston
Edison provided introductory emergency training to about 350 personnel within
the five towns in the EPZ and enhanced introductory training modules are
currently being prepared for review by the MCDA prior to further
implementation. The planners provided by Boston Edison have also begun to
prepare task-based modules for training of specific categories of emergency
personnel and will be available to participate in the training programs. In
addition. Boston Edison is executing agreements with each of the five towns
within the EPZ, as well as the two reception center communities, for
assistance in the renovation of their EOC's. Moreover, four of the five EPZ
towns and both reception center communities, to date, have accepted BECo's
offer of funding support for full-time civil defense staff positions.
Second, literal compliance with the regulation would not serve its
underlying purpose and would result in undue hardship to Commonwealth and
local emergency response agencies by requiring an exercise of portions of the
offsite emergency plans that are in the process of significant revision and
improvement. This would necessarily Involve disruption of the ongoing process
of implementing these changes, and consequently, the imposition of additional
costs and delay In accomplishing the planned Improvements. The NRC's
emergency exercise requirements clearly were not Intended to disrupt the ^
orderly implementation of Improvements in such manner.
Finally, because granting the request will allow work to proceed without
disruption, It will result In a net benefit to the public health and safety.
The NRC has acknowledged that flexibility Is appropriate In applying emergency
planning requirements. This flexible approach Is especially appropriate in
this case, where granting the request will facilitate more prompt and
effective implementation of Improvements.
For all these reasons, Boston Edison asks that NRC grant the requested
exemption. In accordance with 10 CFR §170. 12(c), a fee of one hundred and
fifty dollars ($150.00) will be electronically mailed to your offices. If you
should require any additional Information In connection with this request,
please contact either myself or Mr. Ron Varley of my staff (telephone: 617 -
424-3832).
ii^4^
Ralph G. Bird
RAL/dlw
433
U. S. Nuclear Regulatory Commission
Page 4
cc: Dr. Thomas E. Hurley, Director
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
The Phillips Building
Washington. D.C. 20555
Mr. R.H. Wessman, Project Manager
Division of Reactor Projects - I/II
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
7920 Norfolk. Avenue
Bethesda. MO 20814
Mr. Richard Krimm. Assistant Associate Director
FEMA
500 C Street - Federal Plaza
Washington, D.C. 20472
Mr. Edward Thomas
FEMA - Region 1
J. W. McCormack Post Office and Court House
Boston. MA 02109
Mr. Peter Agnes, Jr.
Commonwealth of MA
Assistant Secretary of Public Safety
1 Ashburton Place - Room 2133
Boston. MA 02108
U. S. Nuclear Regulatory Commission
Region 1 - 631 Park Avenue
King of Prussia. PA 19406
Senior NRC Resident Inspector
Pilgrim Nuclear Power Station
Rocky Hill Road
Plymouth. MA 02360
Henry Vickers, Regional Director
FEMA - Region 1
J.W. McCormack Post Office and Court House
Boston, MA 02109
434
The Chairman. Thank you, Attorney General Shannon. Glad to
see an old friend.
We'll move right along. I'm pleased to welcome the distinguished
members of our third panel, representing the various branches in
state government involved in the Pilgrim restart question.
I remember the days when the State Secretary of Energy,
Sharon Pollard, was a freshman legislator; bright and enthusiastic,
deeply committed to public service, now she has moved onto higher
office, and I'm delighted that she has the same enthusiasm and is
an aggressive champion of the public interest in the issues we've
been discussing this evening. I'm delighted to have her with us.
Ms. Pollard. Thank you. Senator.
The Chairman. Our new Public Health Commissioner, Deborah
Prothrow-Stith, and this is her first public appearance this
evening, was recently appointed to the position. Commissioner
Prothrow-Stith will be discussing the important role the Depart-
ment of Public Health will play in determining what public health
impacts are associated with Pilgrim Power Plant. We are fortunate
to have had breakfast with the Reverend Stith this morning, so
we've been with the family all day.
Last, but not least. Assistant Secretary of Public Safety, Peter
Agnes. Peter has perhaps the most difficult job of all because he is
trying to make an unworkable evacuation plan workable. I'm look-
ing forward to hearing from him. We'll start with Peter Agnes, left
to right.
STATEMENTS OF PETER AGNES, ASSISTANT SECRETARY OF
PUBLIC SAFETY; SHARON POLLARD, SECRETARY OF STATE OF
ENERGY; AND DEBORAH PROTHROW-STITH, HEALTH COMMIS-
SIONER
Mr. Agnes. Thank you, Mr. Chairman. I'm here on behalf of Sec-
retary Charles Barry, who by Executive order is the Disaster Coor-
dinator for the Commonwealth, and also by the Governor's designa-
tion, is the liaison officer for Massachusetts to the Nuclear Regula-
tory Commission, and in that capacity, the Secretary is the princi-
pal point of contact between State officials and the NRC.
At the outset, I would like to address a point that was made by
one of the earlier speakers, Ann Waitkus-Arnold, concerning the
use of potassium iodine, not from a public health standpoint, which
the Commissioner of Public Health can do, but from a planning
standpoint. And I want to correct a matter that was referred to in
her testimony.
There is no plan today; there has never been to my knowledge a
plan in the past and there will never be under the Dukakis admin-
istration, a plan that would leave behind any member of the com-
munity, be they a special needs person or otherwise, in the event of
an evacuation by substituting some drug, such as potassium iodine,
for the safe and secure care of that person. So no one should be
misled into thinking that there is any thought given to leaving
anyone behind during an evacuation who would require attention,
care or evacuation.
Over the past 2 years, we have taken three major actions to re-
spond to the health and safety concerns of the Pilgrim nuclear
435
power plant. First, we have prepared and filed with the Governor
two comprehensive written reports, which other speakers here
have referred to, the most recent of which was released just several
weeks ago. And we would like to make those reports, which also
were transmitted to the Nuclear Regulatory Commission and to
FEMA, a part of the record of these proceedings.
These reports deal at great length with the history of emergency
planning activities, both at the State and Federal level, and with
the many specific problems associated with the Pilgrim plant. It is
our opinion, to paraphrase the Federal Regulatory Standard, that
the existing emergency plans for Pilgrim station are not adequate
to protect the public health and safety in the event of a radiologi-
cal emergency offsite; and that, therefore, the plant should not be
allowed to restart unless and until adequate plans are developed,
tested and approved by FEMA and the other safety related con-
cerns have been resolved.
The Chairman. I'm to give you a couple more minutes.
Mr. Agnes. Thank you. Senator. I have said this on many occa-
sions and I want to reiterate it tonight, our position has been clear
and consistent in the past 2 years on this point. And one of the un-
fortunate things that we — excuse me — that we are facing is the
lack on the part of the NRC a willingness to make clear precisely
what corrections or changes it will insist upon in the emergency
plans before the plant is restarted.
The second activity we have undertaken is to establish a new di-
vision in the State within the Civil Defense Agency devoted exclu-
sively to nuclear emergency preparedness. Despite all of the activi-
ties that followed Three Mile Island, at the congressional level and
at the State level, it is only in the last 2 years with an initiative
taken by Governor Dukakis, that a new division devoted exclusive-
ly to this purpose has been established and devoted to emergency
planning problems.
Third, for the first time again, a planning process has been put
in place at the State level, which requires work on the part of the
utility, local government and State government in an effort to de-
velop adequate emergency plans.
I would like to conclude my remarks, Mr. Chairman, by com-
menting briefly, but more specifically on both the progress that has
been made and also the problems that still remain.
On the progress side of the ledger, the Boston Edison Co. for the
first time is a full partner with State and local officials in emergen-
cy planning. This is evidenced by financial support the company
has provided to local communities and the fact that it has assigned
over 20 people to work in the field with State and local government
to aid in the development of draft plans. Planning resources have
been invested by the company for the first time to help State and
local officials and an inadequate emergency communication system
that was identified in our earlier report has now been replaced by
the company.
The company has produced several reports to aid in the emergen-
cy planning process, including a new evacuation time study that
was given to the Commonwealth in the fall, and also a study con-
cerning the adequacy of relying upon only two, instead of the previ-
ous three reception centers.
436
The Chairman. You've got 30 seconds, Peter.
Mr, Agnes. On the problem side of the ledger, we do have some
severe problems that remain. We do not, as I indicated earlier,
have a formally approved plan at this time. We do not have imple-
menting procedures, which are the key part of the plan, to help
deal with the evacuation and sheltering of special needs people and
school children and the infirm and the elderly. The shelter study
that has been submitted bv the company is inadequate and we are
insistent that additional wt^k be done.
The reception center study that we just recently received and
which is of great concern to residents here in the Plymouth area,
while useful, is not sufficient in our opinion, and we have deter-
mined that a third reception center for the Pilgrim plant must be
sited and we will make a decision in that regard as to a new site
very shortly.
In conclusion, I would like to say that on balance, our diagnosis
is that while the patient has improved; it remains quite ill and the
prognosis is very uncertain. It remains to be seen, in our judgment,
whether or not adequate emergency plans for the Pilgrim nuclear
power plant can be developed, and as many of the speakers here
before have indicated the only way to insure that the issues that
we have identified are aired totally and fairly is to hold an adjudi-
catory hearing before restart. Thank you, Mr. Chairman.
[The prepared statement of Mr. Agnes follows:]
437
Michael S. Dukakis
Governor
Charles V. Barry
Secretary
^oA/bn, .JLAAacAuAelt^0?y08 f'SflJ 7f7 -7775
TESTIMONY OF PETER W. AGNES, JR.
ASSISTANT SECRETARY OF PUBLIC SAFETY
JANUARY 1, 1988
GOOD EVENING MR. CHAIRMAN AND MEMBERS OF THE COMMITTEE. I
AM HERE ON BEHALF OF SECRETARY CHARLES V. BARRY WHO BY
EXECUTIVE ORDER IS THE DISASTER COORDINATOR FOR THE STATE AND
BY DESIGNATION OF THE GOVERNOR IS THE LIAISON OFFICER FOR
MASSACHUSETTS TO THE NUCLEAR REGULATORY COMMISSION. IN THE
LATTER CAPACITY, THE SECRETARY IS THE PRINCIPAL POINT OF
CONTACT BETWEEN STATE OFFICIALS AND THE N.R.C.
THE EXECUTIVE OFFICE OF PUBLIC SAFETY SUPERINTENDS TWO
STATE AGENCIES WITH RESPONSIBILITY IN THIS AREA— THE DEPARTMENT
OF PUBLIC SAFETY WHICH LICENSES NUCLEAR POWER PLANT OPERATORS
AND THE CIVIL DEFENSE AGENCY WHICH IS RESPONSIBLE FOR PREPARING
AND UPDATING EMREGENCY PLANS. MOREOVER, OTHER AGENCIES AND
DIVISIONS WITHIN OUR SECRETARIAT WOULD PLAY A VITAL ROLE IN
RESPONDING TO ANY EMERGENCY AT A NUCLEAR POWER PLANT WHERE
THERE WAS A PUBLIC HEALTH OR SAFETY IMPACT OUTSIDE THE PLANT.
OVER THE PAST TWO YEARS, WE'VE TAKEN THREE MAJOR ACTIONS TO
RESPOND TO THE HEALTH AND SAFETY CONCERNS AT THE PILGRIM PLANT.
FIRST, WE HAVE PREPARED AND FILED WITH THE GOVERNOR TWO
COMPREHENSIVE WRITTEN REPORTS, THE MOST RECENT OF WHICH WAS
438
TESTIMONY OF PETER W. AGNES, JR.
ASSISTANT SECRETARY OF PUBLIC SAFETY
PAGE TWO
RELEASED JUST SEVERAL WEEKS AGO. I WOULD LIKE TO MAKE THESE
REPORTS PART OF THE RECORD. THESE REPORTS DEAL AT LENGTH WITH
THE HISTORY OF EMERGENCY PLANNING ACTIVITIES AT THE STATE AND
FEDERAL LEVEL AND WITH THE SPECIFIC PROBLEMS ASSOCIATED WITH
THE PILGRIM PLANT. IT IS OUR OPINION, TO PARAPHRASE THE
FEDERAL REGULATORY STANDARD, THAT EXISTING EMERGENCY PLANS FOR
PILGRIM STATION ARE NOT ADEQUATE TO PROTECT THE PUBLIC HEALTH
AND SAFETY IN THE EVENT OF A RADIOLOGICAL EMERGENCY OFFSITE AND
THAT THE PLANT SHOULD NOT BE ALLOWED TO RESTART UNLESS AND
UNTIL ADEQUATE PLANS ARE DEVELOPED, TESTED AND APPROVED BY
FEMA, AND THE OTHER SAFETY RELATED CONCERNS HAVE BEEN RESOLVED.
SECOND, WE HAVE ESTABLISHED A NEW DIVISION WITHIN THE CIVIL
DEFENSE ACENCY WITH FISCAL OVESIGHT WITHIN EOPS DEVOTED
EXCLUSIVEL/ TO NUCLEAR EMERGENCY PREPAREDNESS. THIS DIVISION
IS TAKING A LEADERSHIP ROLE WITH LOCAL OFFICIALS AND UTILITY
EMPLOYEES TO INSURE THAT, UNLIKE IN THE PAST, THERE IS ONLY ONE
PLANNING PROCESS UNDER STATE SUPERVISION.
THIRD, WE HAVE ESTABLISHED A FORMAL PLANNING PROCESS TO
CARRY OUT THE RESPONSIBILITIES ASSIGNED TO US UNDER STATE LAW.
THE PROCESS INVOLVES THE UTILITY, COMMUNITY GROUPS, AND LOCAL
AND STATE OFFICIALS MEETING TOGETHER REGULARLY TO ADDRESS
EMERGENCY PREPAREDNESS ISSUES. IN DOING SO WE HAVE BEEN
CAREFUL TO UNDERTAKE THIS PROCESS ON BEHALF OF THE THREE
LICENSED PLANTS THAT AFFECT MASSACHUSETTS--PILGRIM, ROWE , AND
VERNON — AT THE SAME TIME THAT WE CONTINUE TO ABIDE BY THE
STATE'S POLICY THAT THERE SHALL BE NO PLANNING FOR THE SEABROOK
PLANT.
439
TESTIMONY OF PETER W. AGNES, JR.
ASSISTANT SECRETARY OF PUBLIC SAFETY
PAGE THREE
I WOULD LIKE TO CONCLUDE MY REMARKS BY COMMENTING BRIEFLY,
BUT MORE SPECIFICALLY ON SOME OF THE PROGRESS WE HAVE MADE AND
PROBLEMS THAT STILL REMAIN.
ON THE PROGRESS SIDE OF THE LEDGER THE BOSTON EDISON
COMPANY, FOR THE FIRST TIME, IS A FULL PARTNER WITH STATE AND
LOCAL OFFICIALS IN THE EMERGENCY PLANNING EFFORT. THE UTILITY
IS INVESTING IN THE PLANNING RESOURCES REQUIRED BY LOCAL AND
STATE OFFICIALS. THE UTILIITY HAS REPLACED AN INADEQUATE
EMERGENCY COMMUNICATIONS SYSTEM WITH A MUCH MORE SOPHISTICATED
AND ENLARGED SYSTEM. THE UTILTY HAS ASSIGNED MORE THAN TWENTY
PERSONS TO WORK WITH STATE AND LOCAL OFFICIALS AND HAS AIDED IN
THE DEVELOPMENT OF DRAFT EMERGENCY PLANS WHICH ARE CURENTLY
BEING REVIEWED BY LOCAL OFFICIALS. THE UTILITY HAS PRODUCED A
NEW EVACUATION TIME ESTIMATE STUDY THAT WE RECEIVED DURING THE
SUMMER AND HAS JUST PROVIDED US WITH A STUDY ON THE ADEQUACY OF
USING ONLY THE TWO EXISTING RECEPTION CENTERS FOR THE EPZ .
FINALLY THE UTILITY HAS MADE MAJOR CHANGES IN THE MANAGEMENT OF
ITS NUCLEAR OPERATION AND INVESTED HEAVILY IN AN ON-SITE SAFETY
ENHANCEMENT PROGRAM. ALSO, IT SHOULD BE NOTED THAT SPECIAL
TASK FORCES HAVE BEEN ESTABLISHED TO ADDRESS THE SPECIAL NEEDS
ISSUES AND TO RECOMMEND IMPROVEMENTS IN THE EMERGENCY PUBLIC
INFORMATION MATERIAL THAT IS DISTRIBUTED ANNUALLY .THESE ARE
SIGNIFICANT AND POSITIVE DEVELOPMENTS.
440
TESTIMONY OF PETER W. AGNES, JR.
ASSISTANT SECRETARY OF PUBLIC SAFETY
PAGE FOUR
SIMILARLY, LOCAL OFFICIALS AND COMMUNITY GROUPS HAVE BEEN
WORKING CLOSELY WITH THE STAFF OF THE NEW DIVISION OF NUCLEAR
EMERGENCY SAFETY WITHIN CIVIL DEFENSE IN AN EFFORT TO DEVELOP
THE BEST POSSIBLE EMERGENCY EVACUATION PLANS. IN MANY CASES,
THIS EFFORT HAS MEANT THAT LOCAL AND STATE OFFICIALS HAVE
WORKED NIGHTS AND WEEKENDS WITHOUT COMPENSATION.
ON THE PROBLEM SIDE OF THE LEDGER, WE DO NOT YET HAVE A
FORMALLY APPROVED EMERGENCY PLAN TO RESPOND TO AN ACCIDENT AT
PILGRIM STATION AND IT REMAINS TO BE SEEN WHETHER AN ADEQUATE
PLAN CAN BE DEVELOPED. THE MOST IMPORTANT AND DIFFICULT PART
OF THE EMERGENCY PLANS — THE DEVELOPMENT OF IMPLEMENTING
PROCEDURES FOR PERSONS WITH SPECIAL NEEDS (SCHOOL CHILDREN, THE
HANDICAPPED, THE INFIRM ETC.) — DO NOT YET EXIST EVEN IN DRAFT
FORM. QUESTIONS HAVE BEEN RAISED ABOUT THE VALIDITY OF THE
EVACUATION TIME ESTIMATES ANS WE HAVE DECIDED TO SUBMIT IT FOR
AN OUTSIDE EVALUATION. THE SHELTERING STUDY PREPARED BY BECO.
EARLIER IN THE YEAR IS INADEQUATE AND IT REMAINS TO BE SEEN IF
THERE IS ADEQUATE SHELTER FOR THE POPULATION. A SURVEY OF
PERSONS WITH SPECIAL NEEDS WAS PREPARED BY BECO. EARLIER IN THE
YEAR WITHOUT STATE OR LOCAL PARTICIPATION OR APPROVAL AND IS
INADEQUATE. THE RECEPTION CENTER STUDY WE RECEIVED TWO WEEKS
AGO IS USEFUL, BUT WE HAVE CONCLUDED THAT A THIRD RECEPTION
CENTER FOR THE NORTHERN EPZ RESIDENTS IS NECESSARY. WE WILL
DESIGNATE A SITE IN A SHORT WHILE.
IN TERMS OF ON-SITE ACTIVITITES, WE ARE TROUBLED BY THE
DECISION OF THE N.R.C. TO LEAVE UNRESOLVED THE SAFETY ISSUES
441
TESTIMONY OF PETER W. AGNES, JR.
ASSISTANT SECRETARY OF PUBLIC SAFETY
PAGE FIVE
PRESENTED BY BOSTON EDISON COMPANY'S PROPOSAL TO INSTALL A
DIRECT TORUS VENT TO MITIGATE THE CONSEQUENCES OF CERTAIN KINDS
OF ACCIDENTS INVOLVING THE MARK ONE CONTAINMENT. THE EDISON
INITIATIVE WAS TAKEN IN RESPONSE TO AN N.R.C. STAFF
RECOMMENDATION. IN AUGUST, 1987, DR. TOM MURLEY WROTE TO
BECO.AND ADVISED THEM THAT HE WAS NOT PREPARED TO APPROVE THE
DIRECT VENT PROPOSAL WITHOUT FURTHER INFORMATION. TO OUR
KNOWLLEDGE, BECO . HAS NOT SUBMITTED ITS RESPONSE. THIS IS JUST
ONE REASON WHY OUR CALL UPON EDISON TO PRODUCE THE
PROBABALISTIC RISK ANALYSIS WE BELIEVE HAS BEEN PREPARED IS SO
IMPORTANT.
MANAGEMENT CONCERNS ALSO CONTINUE TO EXIST AT PILGRIM. THE
MOST RECENT SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT (SALP) INDICATES THAT BECO. SCORED LOW IN A NUMBER OF
SAFETY RELATED CATEGORIES. IN AUGUST, SECURITY VIOLATIONS
OCCURRED AT THE PLANT THAT ARE THE SUBJECT OF AN ONGOING N.R.C.
INVESTIGATION. A LOSS OF POWER INCIDENT ON NOVEMBER 12, 1987
WAS THE SUBJECT OF A RECENT AUGMENTED INSPECTION REPORT.
ALTHOUGH NO VIOLATION OF REGULATORY REQUIREMENTS WAS FOUND, THE
REPORT CRITICIZES THE OVERALL MANAGEMENT OF THE RECOVERY AND
FOUND PLANNING WEAKNESS.
442
TESTIMONY OF PETER W. AGNES, JR.
ASSISTANT SECRETARY OF PUBLIC SAFETY
PAGE SIX
ON BALANCE, MY DIAGNOSIS IS THAT THE PATIENT HAS IMPROVED
BUT REMAINS QUITE ILL AND THE PROGNOSIS IS UNCERTAIN.
FOR THESE REASONS, IT IS IMPERATIVE, IN OUR JUDGMENT, THAT
THE N.R.C. HEED THE CALL BY GOVERNOR DUKAKIS AND ATTORNEY
GENERAL SHANNON TO CONDUCT AN ADJUDICATORY HEARING BEFORE
CONSIDERING ANY REQUEST TO RESTART THE PILGRIM PLANT.
I WOULD BE HAPPY TO TAKE ANY QUESTIONS.
RESPECTFULLY SUBMITTED
Peter W. Agnes, Jr.
Assistant Secretary
443
The Chairman. Thank you. Sharon Pollard.
Ms. Pollard. Thank you, Senator. It is nice to be here, and I as
well would like to thank you for holding this hearing on a subject
so important to not only the people in and around Plymouth area,
but certainly to all the people of Massachusetts.
You've asked for me this evening to speak about the demand for
Pilgrim's power in meeting Massachusetts' and New England's
energy situation. While the current supply in the Commonwealth
of Massachusetts of energy is tight, it is not so tight that the public
health and safety need be placed at risk with the operation of any
given power plants, including the Pilgrim nuclear power plant.
New analyses prepared by the New England Governors' Confer-
ence and the New England Energy Policy have indicated that New
England's power needs can be met with existing and planned re-
sources and potential new resources combined with effective man-
agement. These analyses have provided evidence that Pilgrim will
not make or break the electricity supply of New England.
In Massachusetts, State and utility officials are working to
assure that power will be available when needed and at a reasona-
ble cost, both over the short term and the long term.
Recent accomplishments of State and utility officials will im-
prove the power supply of the region. For example, the enactment
of the State appliance efficiency standards last year; a more effi-
cient building code, so that the buildings we construct in Massa-
chusetts could be ones that could use energy efficiently. The estab-
lishment of a cogeneration of small power bidding and development
process, and the approval by the Energy Facility Siting Council, of
which I chaired a couple of weeks ago, of a 300 megawatt gas unit
in Bellingham, MA. These will make substantial contributions to
the Massachusetts electricity need.
In addition, current projects will enhance future power planning
and supply. For example, State officials have requested utilities to
increase their capabilities to manage load requirements at the time
of peak demand. The State is also investing ways to fully develop
conservation, load management and cogeneration at State facilities.
Furthermore, the Executive Office of Energy Resource and others
are working with the Department of Public Utilities to establish
least-cost planning process, which will significantly enhance the de-
velopment of cost effective, socially beneficial electric resources in
Massachusetts.
What I would also like to note is that Pilgrim's past operating
performance indicates that it cannot necessarily be relied upon to
provide the power that we need. Pilgrim's lifetime operating per-
formance is worse than roughly 80 percent of all the other nuclear
power plants in the country. In the past. Pilgrim has been avail-
able to produce electricity less than half of the time that it was
needed.
In addition, there is not a strong need to operate Pilgrim for eco-
nomic reasons. While there are many uncertainties as to the eco-
nomics of future power supplies, a recent analysis indicates that
Pilgrim may not necessarily provide any economic savings to rate-
payers if it operates.
"Therefore, I would like to make it clear that while peak electrici-
ty resources are currently tight, there is no compelling need to op-
444
erate Pilgrim for power supply or econc^nic purposes if it poses an
unacceptable risk to the health and safety of the people of Massa-
chusetts.
As was indicated by my colleagues from the administration, Gov-
ernor Dukakis has not yet made a determination as to the ultimate
role which he believes Pilgrim should play, if any. The determina-
tion will be made only after the issues of plant management, con-
tainment integrity and evacuation plan adequacy have been re-
solved. Thank you very much, Senator.
The Chairman. Thank you very much. Dr. Prothrow-Stith.
Dr. Prothrow-Stith. Good evening. Senator. Let me start by
adding my thanks to you for this opportunity. I represent Secretary
Johnston of the Executive Office of Human Services and the De-
partment of Public Health as its commissioner.
We take seriously our responsibilities for the health of the citi-
zens of Massachusetts, and with regard to the Pilgrim plant we
have two responsibilities. One has to do with monitoring radiation
exposure, and the other one has to do with investigation of disease
outbreaks.
Relative to monitoring, we are the primary State agency respon-
sible for radiation control. We have conducted radiation monitoring
activities in the vicinity of the plant since the mid 1970's. These
activities include: one, a network of monitoring stations; two, peri-
odic surveys to determine the extent and seriousness of radiation
dosage received by humans and animals; and, three, periodic in-
spections of the power plants itself.
Our monitoring of radiation includes the dosimeters located at 46
sites to measure radiation. They are tested quarterly and would in-
dicate any unusual exposure to radiation among the population
within 5 miles of the reactor. We also monitor airborne radiation
at the plant. Water, milk, food, fish, and sediment samples are also
tested regularly. We conduct weekly inspections of the Pilgrim
plant, checking internal monitoring and safety protocol. In the
event of an accident, we would be responsible for a dose assessment
and for recommendations of appropriate protective actions.
The department wants to establish a state of the art comprehen-
sive monitoring program in the vicinity of Pilgrim that could serve
as an early notification system and insure prompt emergency re-
sponse in the event of any releases of radioactivity that might
present a threat to the public health and safety, and also to insure
adequate monitoring points to measure radiation in the vicinity of
the reactor.
The department wants a real time monitoring system which
would involve the transmission to a State facility of ongoing radi-
ation levels at selected locations both within the boundaries and
offsite of the nuclear powerplants. This system, similar to one in
place in Illinois, would allow the department to know instanta-
neously when radiation was released into the environment. In addi-
tion, an on-line data communication link to the state's facilities
computer would be included in this system. This would allow us to
know the status of the reactor, that is, the temperature, the pres-
sure, the water level, et cetera, on a real time basis, as well as fur-
ther provide early notification of events that could lead to nuclear
445
accidents. We believe that this improved monitoring is an impor-
tant part of a safe evacuation plan.
Our second responsibility is the investigation of disease out-
breaks.
The Chairman. Let me ask you about that monitoring program.
That is going to cost something, I imagine?
Dr. Prothrow-Stith. It will cost something.
The Chairman. Is that going to be a priority for the state or are
you going to the Federal Government or what?
Dr. Prothrow-Stith. This is something that at this point, we are
proposing; it has been proposed in the past and we are in the very
early stages of a more recent proposal.
The Chairman. Does Illinois pay for it out of State funds or do
they get some Federal funding, do you know?
Dr. Prothrow-Stith. I'm not sure.
The Chairman. OK. Well, if you might let us know on that. If it
is done with the States' funds, obviously we'll welcome that. If you
feel you have to come to the Federal Government, I'll be glad to
submit
Dr. Prothrow-Stith. An offer that we would appreciate. [Laugh-
ter.]
The Chairman. We'll stop right now, and I'll ask you to stand, if
you would. [Laughter.]
Listen carefully.
[Witnesses sworn.]
Do you solemnly swear that the testimony you have given and will continue to
give will be the truth, the whole truth, and nothing but the truth, so help you God?
The Chairman. Three years of law school. Well, that is a serious
matter. As you mentioned, the work that is done in Illinois appears
to be important and significant, and we'd like to know how it is
going to proceed and hope you keep in touch.
Dr. Prothrow-Stith. We would like to do that.
Relative to the investigation of disease outbreaks that might be
caused by contamination in the environment, we are currently con-
ducting a study in the Plymouth area into the causes of elevated
rates of leukemia, a type of cancer that is shown to be caused by
ionizing radiation.
We concluded an assessment of the 1982 to 1985 health related
data for the area around the plant in order to determine the health
of South Shore residents and how that might be affected by the Pil-
grim reactor. That assessment showed no unusual statistical trends
in the patterns of death from cancer or in the frequency of infant
mortality. Some anomalies in infant mortality and low birth rates
had been reported. The numbers are so small that it's impossible to
draw any statistically valid conclusion.
We did find, however, a statistically significant excess in the inci-
dents of leukemia among males in the five coastal communities
surveyed. These elevations are specifically among the types of leu-
kemia that can be caused by exposure to radiation.
The incidents of leukemia am.ong females was also elevated, but
not to the same significant degree. The group should question, of
course, whether Pilgrim is responsible for the high incidents of leu-
kemia. At present it is impossible to answer that question, but the
446
Department of Public Health is currently conducting two separate
investigations that may bring us closer to the answer.
First, we are conducting a case-control epidemiological study to
help us identify the possible causes of the excess leukemia. In the
course of this study, we will interview all leukemia cases diagnosed
since 1982, or their families, in the communities of Plymouth,
Kingston, Duxbury, Marshfield, and Scituate. We'll take data on
the places of residence, occupation and medical histories. This in-
formation will be compared with similar data from people without
leukemia from the same communities in order to look for any dif-
ferences. This study will help determine any association between
leukemia and possible other sources of exposure, such as Benzene,
chemotherapy, et cetera.
We must be very frank about the limitations of this study. Epide-
miology has its limits, especially in cases where we are dealing
with small populations, relatively small number of cases, small
doses and small levels of exposure, but if we don't look, we won't
learn an5^hing at all.
Second, we're looking into the possibilities that a coastal wind
pattern may have contributed to the dispersion of radiation emis-
sion from Pilgrim in a way that bypassed existing radiation moni-
toring. This work, being conducted through a contract at the Har-
vard School of Public Health, will determine the feasibility of esti-
mating the level of radiation reaching the general population. This
study is up and running and should be completed within the next
couple of months in its initial phase.
It is our objective that the combined results of these investiga-
tions will permit an informed estimate of the contributions of Pil-
grim emissions to the elevated incidence of leukemia in the vicinity
of Pilgrim. We would like to work with Dr. Winegarten, if, in fact,
NIH is very interested in doing some work here. We would be ex-
cited about that opportunity.
In summary, we are interested in increasing our monitoring ca-
pabilities so that you have state of the art capability, and also we
are very interested in continuing these studies, but as well, partici-
pating with NIH if that opportunity is available. Thank you very
much.
[The prepared statement of Dr. Prothrow-Stith follows:]
447
^.-s^y-
Mlchaal S. Dukakis
Govamor
Philip W. Johnston
Sac rata ry
150 /Ttv-fTUim/ J^tive/
6'/7-7S7-S700
'^'~™CommlM'I^n,r'**°TESTIMONY OF DEBORAH PROTHROW-STITH , M.D.
COMMISSIONER, DEPARTMENT OF PUBLIC HEALTH
JANUARY 7, 1988
GOOD EVENING MR. CHAIRMAN AND MEMBERS OF THE
COMMITTEE. MY NAME IS DEBORAH PROTHROW-STITH AND
I AM COMMISSIONER OF THE DEPARTMENT OF PUBLIC
HEALTH.
THE MASSACHUSETTS DEPARTMENT OF PUBLIC HEALTH
HAS A TWO-FOLD RESPONSIBILITY WITH RESPECT TO THE
OPERATIONS OF THE PILGRIM NUCLEAR POWER PLANT,
MONITORING RADIATION EXPOSURE AND INVESTIGATING
DISEASE OUTBREAKS.
-FIRST, WE ARE THE PRIMARY STATE AGENCY
RESPONSIBLE FOR RADIATION CONTROL. WE HAVE
CONDUCTED EXTENSIVE RADIATION MONITORING
ACTIVITIES IN THE VICINITY OF THE PLANT SINCE THE
MID-1970S. THESE ACTIVITIES INCLUDE A NETWORK OF
MONITORING STATIONS, PERIODIC SURVEYS TO
DETERMINE THE EXTENT AND SERIOUSNESS OF RADIATION
DOSES RECEIVED BY HUMANS AND ANIMALS AND PERIODIC
INSPECTIONS OF THE POWER PLANT ITSELF.
448
-2-
OUR MONITORING OF RADIATION INCLUDES
DOSIMETERS LOCATED AT 46 SITES TO MEASURE GAMMA
RADIATION, THE TYPE OF RADIATION WE WOULD FIND.
THESE DOSIMETERS ARE CHECKED QUARTERLY, AND THEY
WOULD INDICATE ANY UNUSUAL EXPOSURE TO GAMMA
RADIATION AMONG THE POPULATION WITHIN FIVE MILES
OF THE REACTOR.
THROUGH A COOPERATIVE AGREEMENT WITH THE
NUCLEAR REGULATORY COMMISSION, WE CONTINUALLY
MONITOR AIRBORNE RADIATION AT THE PLANT. WATER,
MILK, FOOD, FISH, AND SEDIMENT SAMPLES ARE TESTED
REGULARLY. WE ALSO CONDUCT WEEKLY INSPECTIONS OF
THE PILGRIM PLANT, CHECKING INTERNAL MONITORING
AND SAFETY PROTOCOLS.
IN THE EVENT OF AN ACCIDENT, THE DEPARTMENT
OF PUBLIC HEALTH WOULD BE RESPONSIBLE FOR DOSE
ASSESSMENT AND FOR RECOMMENDING APPROPRIATE
PROTECTIVE ACTIONS.
THE DEPARTMENT WANTS TO ESTABLISH A STATE OF
THE ART COMPREHENSIVE MONITORING PROGRAM IN THE
VICINITY OF PILGRIM THAT COULD SERVE AS AN EARLY
NOTIFICATION SYSTEM AND INSURE PROMPT EMERGENCY
RESPONSE IN THE EVENT OF ANY RELEASES OF
RADIOACTIVITY THAT MIGHT PRESENT A THREAT TO
449
-3-
PUBLIC HEALTH AND SAFETY AND ALSO TO INSURE
ADEQUATE MONITORING POINTS TO MEASURE RADIATION
IN THE VICINITY OF THE REACTOR.
THE DEPARTMENT ALSO WANTS A REAL TIME
MONITORING SYSTEM WHICH WOULD INVOLVE THE
TRANSMISSION TO A STATE FACILITY OF ONGOING
RADIATION LEVELS AT SELECTED LOCATIONS BOTH
WITHIN THE BOUNDARIES AND OFF-SITE OF NUCLEAR
POWER PLANTS. THIS SYSTEM WOULD ALLOW THE
DEPARTMENT TO KNOW INSTANTANEOUSLY WHEN RADIATION
WAS RELEASED INTO THE ENVIRONMENT. IN ADDITION,
AN ON-LINE REACTOR PARAMETER DATA COMMUNICATION
LINK TO THE STATE FACILITY'S COMPUTER WOULD BE
INCLUDED IN THIS SYSTEM. THIS WOULD ALLOW US TO
KNOW THE STATUS OF A REACTOR, i.e. TEMPERATURE,
PRESSURE, WATER LEVEL, etc. ON A REAL TIME BASIS,
AS WELL AS FURTHER PROVIDE EARLY NOTIFICATION OF
EVENTS THAT COULD LEAD TO NUCLEAR ACCIDENTS.
- SECOND, WE ARE RESPONSIBLE FOR
INVESTIGATING DISEASE OUTBREAKS IN THE
COMMONWEALTH, INCLUDING THOSE THAT MAY BE CAUSED
BY CONTAMINATION IN THE ENVIRONMENT. WE ARE
CURRENTLY CONDUCTING A STUDY IN THE PLYMOUTH AREA
INTO THE CAUSES OF ELEVATED RATES OF LEUKEMIA, A
TYPE OF CANCER THAT CAN BE CAUSED BY EXPOSURE TO
IONIZING RADIATION.
450
-4-
TEN MONTHS AGO, THE DEPARTMENT CONCLUDED AN
ASSESSMENT OF ALL HEALTH RELATED DATA FOR THE
AREA AROUND THE PLANT IN ORDER TO DETERMINE
WHETHER THE HEALTH OF SOUTH SHORE RESIDENTS MIGHT
BE AFFECTED BY THE PILGRIM REACTOR.
THAT ASSESSMENT SHOWED NO UNUSUAL
STATISTICAL TRENDS IN THE PATTERN OF CANCER
DEATHS OR IN THE FREQUENCY OF INFANT MORTALITY OR
LOW-BIRTHWEIGHT. WHILE SOME ANOMALIES IN INFANT
MORTALITY AND LOW BIRTHWEIGHT HAVE BEEN REPORTED,
THE NUMBERS ARE SO SMALL THAT IT IS IMPOSSIBLE TO
DRAW ANY STATISTICALLY VALID CONCLUSIONS. WE DID
FIND A STATISTICALLY SIGNIFICANT EXCESS IN THE
INCIDENCE OF CANCERS OF THE BLOOD-FORMING ORGANS
AMONG MALES IN THE FIVE COASTAL COMMUNITIES
SURVEYED. THESE ELEVATIONS ARE AMONG THE TYPES
OF LEUKEMIA THAT CAN BE CAUSED BY EXPOSURE TO
RADIATION. THE INCIDENCE OF LEUKEMIA AMONG
FEMALES WAS ALSO ELEVATED, THOUGH NOT TO THE SAME
SIGNIFICANT DEGREE.
THE CRUCIAL QUESTION, OF COURSE, IS WHETHER
PILGRIM IS RESPONSIBLE FOR THE HIGH RATE OF
LEUKEMIA. AT PRESENT, IT IS IMPOSSIBLE TO ANSWER
THAT QUESTION UNEQUIVOCALLY, BUT THE DEPARTMENT
OF PUBLIC HEALTH IS CURRENTLY CONDUCTING TWO
451
-5-
SEPARATE INVESTIGATIONS THAT MAY BRING US CLOSER
TO THE ANSWER.
FIRST, WE ARE CONDUCTING A CASE-CONTROL
EPIDEMIOLOGIC STUDY TO HELP US IDENTIFY THE
POSSIBLE CAUSES OF THE EXCESS LEUKEMIA.
IN THE COURSE OF THIS STUDY, WE WILL
INTERVIEW ALL LEUKEMIA CASES DIAGNOSED SINCE
1982, OR THEIR FAMILIES, IN THE COMMUNITIES OF
PLYMOUTH, KINGSTON, DUXBURY, MARSHFIELD AND
SCITUATE. WE WILL TAKE DATA ON THEIR PLACES OF
RESIDENCE, OCCUPATION, AND MEDICAL HISTORIES.
THIS INFORMATION WILL BE COMPARED WITH SIMILAR
DATA FROM PEOPLE WITHOUT LEUKEMIA FROM THE SAME
COMMUNITIES IN ORDER TO LOOK FOR ANY
DIFFERENCES. THIS STUDY WILL HELP DETERMINE
ASSOCIATIONS BETWEEN LEUKEMIA AND POSSIBLE
SOURCES OF EXPOSURE SUCH AS CHEMOTHERAPY AND/OR
RADIATION THERAPY.
WE MUST BE VERY FRANK ABOUT THE LIMITATIONS
OF THIS STUDY. EPIDEMIOLOGY HAS ITS LIMITS,
ESPECIALLY IN CASES SUCH AS THIS WHEN WE ARE
DEALING WITH SMALL POPULATIONS, RELATIVELY SMALL
NUMBERS OF CASES, SMALL DOSES, AND SMALL LEVELS
452
-6-
OF EXPOSURE. BUT IF WE DON'T LOOK, WE WON'T
LEARN ANYTHING AT ALL.
SECOND, WE ARE LOOKING INTO THE POSSIBILITY
THAT COASTAL WIND PATTERNS MAY HAVE CONTRIBUTED
TO THE DISPERSION OF RADIATION EMISSIONS FROM
PILGRIM IN A WAY THAT BYPASSED EXISTING RADIATION
MONITORING. THIS WORK, BEING CONDUCTED THROUGH A
CONTRACT WITH THE HARVARD SCHOOL OF PUBLIC
HEALTH, WILL DETERMINE THE FEASIBILITY OF
ESTIMATING THE LEVEL OF RADIATION REACHING THE
GENERAL POPULATION.
IT IS OUR OBJECTIVE THAT THE COMBINED
RESULTS OF THESE INVESTIGATIONS WILL PERMIT AN
INFORMED ESTIMATE OF THE CONTRIBUTION OF PILGRIM
EMISSIONS TO THE ELEVATED INCIDENCE OF LEUKEMIA
IN THE VICINITY OF PILGRIM.
453
The Chairman. Thank you very much, Doctor. We appreciate
your testimony and your comments.
Let's move to Ms. Pollard. I know that we're relying to some
degree on HydroQuebec; is that correct.
Ms. Pollard. We are receiving — 3 percent of the electricity we
use in New England is imported from Canada, so right now it is a
very small percentage. It increases to about 10 percent by the year
1991. About 10 percent of all the electricity that we use is not con-
sidered excessive. However, any additional import of electricity
beyond that would have to be looked at that for that reason, we
know from past experience that
The Chairman. Someone mentioned to me, earlier today, about
the possibility of importing energy from the midwest.
Ms. Pollard. Yes.
The Chairman. I'm unfamiliar with both possibilities, the reali-
ties and the difficulties.
Ms. Pollard. Very briefly, the governors of New England have
spoken with some of the Governors in the Midwest that have some
coal resources within their States. It would work this way. That
New England ratepayers would bill powerplants in the Midwest,
that New England ratepayers would put on those powerplants the
best available control technology to help with our acid rain situa-
tion.
It is thought that that energy would still be reasonable in terms
of the cost to the ratepayers. So there is some thought that you get
double win from this. That your access is reasonable energy prices
and that you are also helping with the acid rain situation. There is
only one problem. You would have to put a transmission line
through the State of Pennsylvania and through the State of New
York, and there is some concern that those two States might not be
thrilled about the idea.
The Chairman. Let's keep moving on. I'd like to know more
about it. We'll inquire. You are probably aware of the Department
of Energy comparing the record of powerplants nationwide, and the
Department of Energy rated New England 23 out of 26 in its abili-
ty to keep its plants open from 1983 to 1985. I wonder if you are
familiar with those findings, and if so
Ms. Pollard. We are.
The Chairman [continuing]. What you concluded.
Ms. Pollard. The Federal Department of Energy has conducted
that history. We are obviously not pleased with the evidence and
the information that was presented in that report. We have our
powerplants not maintained as well as other powerplants in other
parts of the country; our have a tendency to be down at a more
frequent rate than in other parts of the country. And we believe
that part of the problem this past summer was just precisely that.
When you have one-third of your available electricity down and
unable to be used, that's what causes you some concern and it may
cause you some problem.
We have continued — have in the past, and will continue to en-
courage the utilities to maintain their plants well and to schedule
their maintenance at times of the year when we are not experienc-
ing the greatest demand for electric.
454
The Chairman. What is the single most important criterion for
judging whether or not the Pilgrim plant should be operational?
Ms. Pollard. The health and safety of the people who live
within the radius of this power plant and that is the most impor-
tant criteria that the Governor will consider.
The Chairman. Doctor, let me ask you how you respond to some
of the criticism you heard earlier levied against the Department
concerning its interaction with residents of the local area as well
as statewide? We know you just recently become the Commissioner
with responsibilities concerning these difficulties which allegedly
had existed earlier, but I imagine you had heard of them and were
concerned about them, and I'm just wondering what kind of reas-
surance you might be able to give people in the area, and the way
you might perceive situations?
Dr. Prothrow-Stith. I think it's important to say that we are
committed to the health, and the protection of the health, of the
citizens of the Commonwealth, and as a new commissioner in the
Department of Public Health, that commitment is something that I
feel very comfortable reaffirming.
It is important to say that I think part of the history of the prob-
lem that we have had has been a situation where some promises
were made that were not able to be met and perhaps mistakes
were made. I don't know the details of those histories, but I would
say very clearly to the citizens here tonight that the commitment
is strong at the Department of Public Health and we intend not
only to complete these studies, but to work with the community, as
we have continued to do in the last few months, in order to make
sure that the health and safety concerns are addressed.
The Chairman. Well, I think from what I have known of you,
the people in this area would have a good sense of your apprecia-
tion for those concerns and your commitment because I know it
will be carried forward.
I think you talked about our request for a study by the NIH. You
might be helpful to us who are working with the NIH, in terms of
assistance in the development of that study. I would ask you to do
that at some time.
Dr. Prothrow-Stith. What I would like to do, perhaps, is to for-
ward to you some of the information that — in a cover letter, that I
could send Dr. Winegarten offering what we currently know in our
participation.
The Chairman. A final point. Boston Edison has been identified
as having a higher rate of worker exposure. Does the Department
of Public Health have the option of conducting a study of worker
exposure or is this something that is referred to OSHA.
Dr. Prothrow-Stith. The Department of Labor has that respon-
sibility. Edison and the Department of Labor are looking into that
issue. We would encourage that more be done. It is important, and
I think the NIH participation may help us with this, to look at na-
tional data and some international data, as well as worker data, as
a way to fully appreciate the health risks. So I would encourage
that more be done, and if we can help in any way, though it is not
our direct responsibility, we would be willing to do that.
The Chairman. I want to thank the panel. We had a chance to
see your full testimony and you covered many additional areas
455
which we were interested in. I think this panel has helped us to
understand better the problems of emergency planning, energy
supplies, and the public health concerns. We value very much all
of your testimony. It has been very, very helpful. I know now
where to go for additional information, so we are grateful to all of
you.
Dr. Prothrow-Stith. Senator, may I say one other thing. I just
learned that the utilities pay for the monitoring system in Illinois.
The Chairman. I wonder where that little bit of information
came from. [Laughter.]
We have a final panel. We want to give them some attention.
We're going to proceed to that panel. We have been in session for
three hours. I want you to know this is a very important panel. We
put great emphasis on it. I would like to have about a 10-minute
recess, and then we're going to stay here as long as it takes to run
through the last panel. We want to give them our attention. We
have important questions, but we want to take our time with that
panel. They deserve attention.
You have been a very attentive audience. This has been a very
informative hearing. We have collected a great deal of information
and we're grateful to all of those who participated and helped us,
but since we have been in here for this period of time, we will have
a 10-minute recess. I know some people have to leave. We're grate-
ful to them for their presence, but I would hope as many as possi-
ble would stay. I think this will be an informative session with the
laist panel.
[Ten-minute recess.]
The Chairman. I ask that everybody rejoin us and take their
seats so we can give our full attention to the final panel. Again,
you've very attentive. We'll ask that people be kind enough to take
their seats.
First of all, we want to thank Nadine O'Neill, and I'm going to
ask all of you if you will join in giving our wonderful interpreter a
hand this evening.
[Applause.]
The Chairman. She's doing a magnificent job.
I shall ask our panelists if they will be kind enough to raise their
hands and do say if
[Witnesses sworn.]
The Chairman. We have a few housekeeping details, we have
statements from some of our colleagues. Representative Studds,
and Senator Kerry, and we will include their statements in the
record. I'll indicate to those whose testimony we have not been able
to receive in person, given the time that's been available to us,
we'll be glad to receive that testimony. I know that it won't be con-
sidered as sworn testimony, but nonetheless, it will be valuable to
us if it is informational, and we will instruct the staff to make that
part of the testimony which is relevant to this hearing a part of
the record and we'll leave the record open to the time that the
Congress comes back in, later in this month. So if there are those
who have opinions or who have views or who would take differing
views from what we have heard this evening, who would like to be
part of the record, they shall be.
[The statements referred to above follow:]
456
STATEMENT OF
THE HONORABLE GERHY E. STUDDS
BEFORE THE
SENATE COMMITTEE ON LABOR AND HUMAN RESOURCES
January 7, 1988
I first want to commend Senator Kennedy for holding today's hearing,
which will focu3 on health matters related to the reopening of Pilgrim
Nuclear Power Station and the associated issue of emergency evacuation
planning. I have received dozens of letters from constituents about
the plant, and it ia clear that these issues are of paramount concern.
The Pilgrim plant has been shut down since April 1986' because of
serious questions about safety and management. The Nuclear Regulatory
Commission's (NRC) most recent evaluation found the facility's
performance in five significant areas to be minimally satisfactory. In
addition, the Federal Emergency Management Agency (FEMA) has concluded
that existing emergency evacuation plans are Inadequate to protect the
public and could not be implemented until deficiencies were corrected.
State and local emergency planning officials are working with Boston
Edison to revise these plans, but this task will not be completed for
several more months.
Boston Edison officials have indicated that modifications to the plant
should be completed by the end of January, and they are expected to ask
the NRC for restart approval soon after. The agency will then have a
very important decision to make.
This determination will be made in the context of an evolving national
policy on emergency olanning. The critical need for state and local
government preparedness became obvious in the aftermath of the 1979
accident at Three Mile island, congress responded by directing the NRC
to deny a nuclear reactor operating license unless there was reasonable
assurance that adequate protective measures would be taken in the event
of an emergency. This past October, In an action with potential local
Implications, the NRC Issued a rule significantly weakening the
requirement for state and local participation in emergency planning.
457
It Is my view that the NRC would be ignoring its conqressional mandate
and would be making a grievous mistake if it allowed Pilgrim to resume
operations before an evacuation plan, acceptable to state and local
officials, is developed. The NPC commissioners cannot allow pilgrim to
reopen with a simple statement that they ace satisfied with the
progress of emergency planning. The citizens of Plymouth and the
surrounding area must be confident that when the plant's turbines start
to turn, their local officials will be able to protect their health and
safety in the event of an accident. Unless there is an approved plan
in place, they will not have such an assurance.
If an accident occurs, local emergency planning personnel must be able
to follow procedures that have been thoroughly and completely
discussed, reviewed and practiced. Evacuation planning activities, by
their very nature, cannot be carried out without the close Involvement
of community officials. Timely warning, effective traffic control,
evacuation assistance for special populations such as schoolchildren,
nursing home residents, or the disabled -- all these are essential
tasks that are uniquely and obviously the responsibility of local
qov«cnment. *" »
If the Plymouth plant had a longstandinq history of competent
management and a flawless operating record, perhaps the details of
emergency planning would not be so crucial. But Pilarim, characterized
by many years of mismanagement and numerous regulatory violations,
demands full attention to this aspect of its operation.
I want to join other Massachusetts officials in once again stating,
loudly and clearly, that Pilgrim Nuclear Power Station should not be
allowed to reopen unles=5 and until all emergency planning, management
and safety issues hav^ Uien sat i&f actorl jy addressed.
458
STATEMENT OF
SENATOR pHNF.iBRRY
BEFORE THE
SENATE LABOR AND HUMAN RESOURCES COMMITTEE
January?, 1988
Mr. Chairman, I would like to thank you and the other members of the
Senate Labor and Human Resources Committee for conducting this important
hearing tonight. Many of us in Massachusetts have been extremely
concerned about the safety of this plant and the health effects on the
surrounding communities around Pilgrim, and this hearing will play an
important role in the investigation into this problem.
It is especially important that the Chairman has chosen to conduct this
hearing, in light of the U.S. Nuclear Regulatory Commission's continued
refusal to open formal public hearings on the reopening of this plant. Since
September. Senator Kennedy, Congressman Studds. I and various elected
officials across the state have requested formal hearings from the N.R.C. on
the reopening of this plant, to give those who live near this plant an
opportunity to have their questions answer§d and their concerns raised.
Once again, in refusing to conduct these hearings, the N.R.C. has not fulfilled
its regulatory responsibility, and the Oiairman has provided a valuable
forum for these issues to be addressed.
The recent history of the Pilgrim Nuclear Power Plant Is one of failure
and neglert. Served with the largest penalty ever issued by the N.R.C, the
plant was closed In April. P"' because of repeated failures of its emergency
tquipmmni tnd for cferof' nagement proM'^ms. The Boston Edison
Company/ c^ ^^< f^^it year v.uu a j^gir, hBB.ii.iueriaken a managafflent and
459
safety review and upgrade program to address these problems. IhejiD
recent months have reloaded fuel, and hope to have permission to restart
the plant in the next few months. However, in November of 1987, the plant
was again beset with safety and health problems, as contaminated water
exposed workers to radioactive contamination and offsite generator power
problems occurred, which could have had grave consequences were the plant
on line at the time.
There are two fundamental questions that must be addressed before
this is plant should be allowed to restart: 1 ) are the evacuation plans for the
communities surrounding this plant adequate, regardless of safety
improvements that have been made on-site, and 2) is the Nuclear Regulatory
Commission in the best position to determine whether everything that can
be done, has in fact been done to improve safety at the plant?
First, it is my belief that the issue of adequate evacuation plans for the
communities within a ten mile radius of the plant is still outstanding, and
that no decision to restart the plant should be made until this issue has been
fully resolved. Not only have various community civil defense commitlies
found serious flaws in the plans that Boston Edison has on file, but the
Commonwealth of Massachusetts has also recently determined that these
plans are not viable in their current state. Unfortunately, the N.R.C. , in a
recent rule change, has eliminated the state's role in determining the
adequacy of evacuation plans, and will allow those plans that have not met
state criteria to be approved by the N.R.C. Although the Pilgrim Plant went
on line before the accident at Three Mile Island, and therefore was not
required to have approved evacuation plans before being granted an
operating license, the issue of adequate evacuation plans in the event of an
460
accident is no less critical. 1 strongly opposed the N.R.C. rule change, and vill
continue to fight in Congress for the state's role in determining the adequacy
of evacuation plans.
I am also seriously concerned about the N.R.C.'8 ability to determine if
this plant is safe to return to operation. Jhe^role of the U.S. N.R.C. as a
regulator of the nuclear industry has come under close scrutiny in Congress
recently, and has led to some disturbing conclusions about the Commission.
An Investigative Report issued in December, 1987 by the House
Subcommittee on General Oversight and Investigations concludes that the
N.R.C. has failed to maintain an arms length relationship with the industry,
stating that "Over the past several years, the Nuclear Regulatory Commission
has demonstrated an unhealthy empathy for the needs of the nuclear
Industry to the detrimp- * of the safety of the American people. " (p. ■41). One
of th» mott »er!ou -• - "-ised bv ♦h« report is th« so-called "backfit
rule", which has allowed the N.R.C, to evaluate safety improvements to plants
already in operation against the cost to the utility to implement them. In
1986. under the first full year under this rule, the N.R,C. did not impose a
single plant-specific backfit. and it required only one industry-wide backfit
which cost utilities less than $8,000 per plant. In opposition to the adoption
of this rule, former N.R.C. Commissioner James Asselstine concluded, The
consequence of this rule is to limit the NRC staff's and even the Commission's
ability to identify and correct safety weaknesses at the nuclear power plants
in operation and under construction in this country." This rule was struck
down last August by the U,S. Court of Appeals in D.C. and the N,R,C. issued a
new proposed rule which eliminates the cost/benefit analysis for those
improvements necessary for "adequate protection," However, this new rule
does little to address the problem of vagueness cited by the Court because it
still does not define "adequate protection," allowing the staff to determine
that all safety improvements eiceed the adequate protection level and
therefore can be evaluated in terms of cost to the utility.
461
The issue of the N.R.c;s coziness with the nuclear industry causes
serious concern with regard to the Pilgrim Plant, The N.R.C to date has not
issued any guidelines in determining whether sufficient safely
improvements have been made at the plant to allow it to restart. Further, in
light of the Commission's record on requiring safely improvements to be
made at any of the nation's nuclear plants, it is almost impossible to have
confidence in their ability to determine whether sufficient steps have been
taken. Finally, the N.R.C. has recently decided that, despite documented
flaws in the design of the Mark I containment vessel employed at Pilgrim,
they will determine whether Pilgrim should go back on-line without taking
into account the problem with the containment vessel. All of these decisions
by the N.R.C, indicate that the public can have little faith in the decision that
the Commission makes with regard to the Pilgrim Plant.
For the past two years, because of my concerns over both the
Seabrook and Pilgrim Nuclear Power plants, 1 and my colleagues in the
Massachusetts delegation have sought to bring greater accountability to the
Nuclear Regulatory Commission. The N.RL's tinwillingness to heed the
advice of the states regarding adequate evacuation plans, and their neglect
of needed safety improvements at plants currently in operation, have caused
serious concern in Congress. I will continue to use every opportunity to
Improve the public accountability of the N.R.C. and again, 1 thank Mr.
Chairman for conducting these important hearings on this issue. 1 know that
the testimony presented tonight from residents, state officials, and the N.R.C.
will add greatly to the debate In Con<?re88, and I look forward to reading the
testimony presentad here tonight.
462
HEALTH SURVEILLANCE OF THE
PLYMOUTH AREA
Massachusetts Department of Public Health
Center for Health Promotion and
Environmental Disease Prevention
March 16, 1987
463
TABLE OF CONTENTS
List of Figures i
Li St of Tab! es i i
Executive Summary iii
Scope of the Problem 1
Mortal ity Data 1
Incidence 3
Adverse Reproducti ve Outcomes 8
Environmental Data 9
Perspective of the Problem 11
Conclusion 15
Figures
Tables
Appendices
464
LIST OF FIGURES
Figure 1 Numbers of cases of leukemia, multiple myeloma, and other rare
cancers of the blood forming organs diagnosed in 1982-84 among the
residents of Plymouth, by census tract.
Figure 2 Numbers of cases of leukemia, multiple myeloma, and other rare
cancers of the blood forming organs diagnosed in 1982-84 among the
residents of Duxbury, Kingston, Marshfield, and Scituate, by census
tracts.
Figure 3 Infant mortality rate in Plymouth, Plymouth County, and
Massachusetts, 1969-84.
Figure 4 Percent of low birthweight in Plymouth, Plymouth County, and
Massachusetts, 1969-84.
465
LIST OF TABLES
Table 1 The numbers of observed and expected breast cancer deaths among
female residents of Plymouth, the five towns, and the remaining towns of
Plymouth County for two time periods.
Table 2 The numbers of observed and expected leukemia deaths among the
residents of Plymouth, the five coastal towns, and the remaining towns of
Plymouth County for two time periods.
Table 3 The numbers of observed and expected incident cases of cancers
of the hematopoietic and reticuloendothelial system diagnosed among the
residents of Plymouth and the five towns, 1982-84.
Table 4a The numbers of observed and expected incident cancers of the
hemtopoietic and reticuloendothelial system, excluding chronic lymphocytic
leukemia (CLL), diagnosed among the residents of the five towns, 1982-84.
Table 4b The numbers of observed and expected incident cases of leukemia,
all subtypes, diagnosed among the residents of the five towns, 1982-84.
Table 4c The numbers of observed and expected incident cases of leukemia,
excluding chronic lymphocytic leukemia (CLL), diagnosed among the
residents of the five towns, 1982-84.
Table 4d The numbers of observed and expected incident cases of
myelogenous leukemia diagnosed among the residents of the five towns,
1982-84.
ii
466
EXECUTIVE SUMMARY
Analyses of health data have been carried out to examine whether there is
excess risk of certain adverse health outcomes among residents in the
vicinity of the Pilgrim Nuclear Facility located in Plymouth. Five
communities were studied because of their proximity to the Pilgrim Plant,
area topography, and coastal meteorological conditions. These communities
were Duxbury, Kingston, Marshfield, Plymouth, and Scituate. The data
revealed no disturbing trends in either the patterns of cancer mortality
or in the expression of low birthweight and infant mortality. Radiation
monitoring records do not suggest any significant levels of radiation
off-site of the Pilgrim plant (the levels of radiation residents of the
surrounding communities are potentially exposed to). However, a
statistically significant increase in the incidence of cancers of the
blood forming organs, primarily leukemia, among males in the five coastal
towns has been identified. The number of leukemia cases diagnosed among
female residents of the five towns were also higher than expected.
This descriptive study, as the first step of an epidemiologic
investigation, has identified the existence of an apparent excess risk of
cancer of the blood forming organs, particularly leukemia, among the
residents of the five towns. Major gaps exist in our present
understanding of the relationship between the occurrence of leukemia and
the Pilgrim Nuclear Facility. The second step of an epidemiologic
investigation is to determine the likely cause(s) of the excess risk.
This data can only be reliably obtained from the cases themselves.
Additional resources would be required to collect this detailed
information.
i i i
467
This report presents a review of the health and environmental data for the
Plymouth area. The data were collected in response to citizen concerns
over possible health impacts from the operation of the Pilgrim Nuclear
Facility.
SCOPE OF THE PROBLEM
Three analyses have thus far been initiated by the Massachusetts
Department of Public Health (MDPH) to examine whether there is an unusual
occurrence of selected adverse health outcomes among the residents of five
towns - Duxbury, Kingston, Marshfield, Plymouth, and Scituate. These
communities were chosen because of their proximity to the Pilgrim Plant,
area topography, and coastal meteorological conditions.
Since the basic question related to the possible health effects from
ionizing radiation, the kind of radiation associated with x-rays and
radioactivity, two of our analyses focused on radiation induced cancers.
These cancers are leukemia, multiple myeloma, and cancers of the breast
and thyroid. The third analysis focused on adverse reproductive
outcomes. All of these health outcomes were chosen because of their known
or suspected relationship with exposure to low-dose ionizing radiation, as
reported in current medical literature. Information on these health
outcomes is routinely collected by MDPH.
Mortal itv Data
The first analysis reviewed mortality from leukemia and cancers of the
breast and thyroid during the period 1969 through 1983. The numbers of
468
deaths were determined for the five towns, as well as for Plymouth
County. The observed numbers of deaths in the five towns were compared to
the numbers expected based upon state mortality rates adjusted for age and
population differences.
Very few thyroid cancer deaths occurred in the five towns and so no
conclusions could be drawn from that data. Tables 1 and 2 show mortality
from breast cancer (table 1) and leukemia (table 2) among the residents of
Plymouth, the five coastal towns combined (Duxbury, Kingston, Marshfield,
Plymouth, and Scituate), and the remaining Plymouth County towns. These
data are given for two time periods, 1969-73 and 1979-83. These are the
years for which complete data on expected numbers of deaths in the five
towns are currently available. The first time period, 1969-73,
essentially represents the period before Pilgrim became operational. In
both time periods, there was a slightly higher number of breast cancer
deaths observed in the five towns than expected (table 1), but these
differences were small and statistically not significant. The observed
mortality from leukemia in both time periods was also slightly greater
than the expected number among the female population, particularly in the
town of Plymouth and the five coastal towns combined. Similar excess in
leukemia mortality was observed among male residents of the town of
Plymouth, but only during 1969-73. However, all these differences between
observed and expected mortality were small and statistically not
significant. Most importantly, the ratios of observed to expected numbers
of leukemia deaths are similar in both time periods. The ratios would be
expected to be greater in the later time period if suspected emissions
from Pilgrim were resulting in increased cancer mortality. Overall, it
appears that compared to the residents of Massachusetts as a whole.
469
individuals living in the five towns probably did not experience excessive
mortality from these cancers.
Appendix I shows the numbers of observed and expected deaths from leukemia
among the residents of all towns within approximately twenty miles of the
Pilgrim Facility during the two time periods. This data is presented to
illustrate the number of deaths for each town in the region. These towns
represent a large geographic area where the potential for exposure to
emissions from a point source such as Pilgrim would differ greatly among
the residents. Therefore, an analysis of the area as a whole to explore
any possible relationship with Pilgrim emissions would be inappropriate.
Incidence Data
Cancer incidence, newly diagnosed cases, was reviewed in the second
analysis. Incidence data were obtained from the Massachusetts Cancer
Registry, which has collected information on all cancers diagnosed in
Massachusetts since 1982. Computerized data were available for the years
1982-84 and all cases diagnosed- in those years were used in this
analysis. As in the first analysis, the numbers of observed cases were
compared with the corresponding numbers of expected cases. Cancer
incidence rates for the whole of Massachusetts were used to estimate the
expected numbers.
There was no statistically significant excess of breast or thyroid cancer
incidence among the residents. of Plymouth or of the five towns combined.
It should be noted, however, that an excess would not be expected from
1982-84 incidence data even if there was sufficient exposure from
radiation to cause cancer. This is because it is estimated that these two
-3-
470
cancers take approximately fifteen years to develop after they are
initiated by some causal factor like radiation. By 1984, the most recent
year for which cancer incidence data is currently available, the Pilgrim
Plant had been operational for less than twelve years. Therefore, it will
be at least three years, and likely longer, before MDPH will have the
cancer data to properly assess any possible relationship between Pilgrim
emissions and breast and thyroid cancer.
Because of reporting practices of the Cancer Registry, all cancers of the
hematopoietic and reticuloendothelial systems (cancers of the blood
forming organs), which include leukemia as well as multiple myeloma and
some very rare forms of cancer, were reviewed as part of the initial
incidence analysis. Table 3 shows the incidence of cancers of the blood
forming organs among the residents of Plymouth and the five coastal towns
combined, diagnosed between 1982 and 1984. The apparent excess in
observed incidence in Plymouth is statistically not significant. But when
the cancers are reviewed for the five towns combined, the number of new
cases diagnosed among males is significantly (statistically) greater than
expected based upon state rates. The number of these cancers among
females was also elevated, but the excess was not statistically
significant.
Figures 1 and 2 show the distribution of hematopoietic and
reticuloendothelial cancer incident cases (cancers of the blood forming
organs) diagnosed in 1982 through 1984 in the five towns. They appear to
be distributed throughout the census tracts within the towns.
As stated above, the cancers of the hematopoietic and reticuloendothelial
system are comprised of several types of related cancers. The two
-4-
471
principal types are leukemia and multiple myeloma. Leukemia itself is
characterized by several different subtypes. The major subtypes are
chronic lymphocytic, acute lymphocytic, acute nonlymphocytic, and chronic
myelogenous leukemias. Each of these cancer subtypes can be caused by
certain environmental exposures. But, not all of the same environmental
causes are related to each subtype of leukemia. For example, exposure to
ionizing radiation does not appear to be associated with chronic
lymphocytic leukemia (CLL) but is associated with the development of other
types of leukemia and of multiple myeloma. With this in mind, the
analysis of incidence was further focused to examine all hematopoietic and
reticuloendothelial cancers, excluding CLL. Results were analyzed only
for the five towns combined because of the small number of cases within
each town.
Table 4a illustrates the results of this analysis for the five towns
combined. The number of cases observed among males between 1982 and 1984
was again observed to be significantly (statistically) in excess over the
number expected in the five towns. The number of female cases was also
elevated but not statistically different from the number expected. In
other words, there is a reasonable probability that the differences
between observed and expected numbers among females are due to chance
alone.
Ta further refine the analysis, the latency periods was reviewed for each
of the cancer types and subtypes. Latency period is the length of time
between initial exposure to the potential cause(s) of the cancer and the
time when the cancer first becomes detectable (diagnosis). The latency of
multiple myeloma is at least 15 years. The subtypes of leukemia have
varying latent periods (2-20 years), frequently dependent upon age at
-5-
472
exposure. Since the latency of multiple myeloma iy likely greater* than
the ni^mber pf year,$^, Pilprim has been operatjional, leukemia is the
radiation-sensitive cancer outcome that would have the greatest
probability of showing an association, using current cancer statistics,
vHlth %ay..pj»st, Plljgrld ej^issions.. ;. Mj^elogenou.s .lewkeniia^. are. tlw . leukeratas.. .
most sensitive to induction by radiation.
Tables 4b through 4d show the number of observed and expected leukemias
for this more refined analysis. Ten hospitals have been identified as the
place of diagnosis for the 1982-84 leukemia cases. Four were in Boston
and the remaining six hospitals represent the major health care centers in
southeastern Massachusetts. Among males the incidence of each leukemia
group was consistently elevated. Each elevation is statistically
significant. The incidence of all leukemia and the subtype myelogenous
leukemia. among. females was slightly elevated, but. the numbers of observed
cases were not statistically different from the number expected based upon
State Incidence figures ► ,.,..../... : • . .-
One explanation for why the elevation is higher in males than females may
"•*Brtii«r(h^s •a^''it^9r4at?r >ntc-f6r«p^^^^
.leukemia in the five towns. Epldeiniolpgic research has shown that the
.; lOid^ctipiv of. Uukeniia-ha4..been, .fts^ofUted with ijkimb&cCQf different ....;..
• ■factors,' irtcfuding chemicals; certain m^^ aiid * ' '
,>> Jtt'* ■*,; '^\A''*^'. '];-^',-':-^'^ ;';''>'-'--*-/^;: ' v;:*^\'^; ;V "■•':■. V^'-'" >V-'^-^;; — ---'-"'^
|;Co e^me leiii^lay- «u<^ >':'
It ma^ bjfr that males in the iFive towns had a greater opportunity for these
.- rr ~"^' ' _i^_jz,.r."zr.'. -" " ^^.'7 " ~r — i" !"".'' •"";-^- yiiinriiiiipiiiih.-i^
occupational exposures, resulting in the higher elevations of leukemia.
, Another.expUnation may .be that males haid a greater potential for exposure ,
. to air emissions from Pilgrim because of the proximity to the • .
•• • ..-.6--. . .-, . .
473
plant of their residence or place of employment. Without in depth
knowledge of the type of work the cases performed, where they worked, and
where they lived, it is not possible to determine the differences in
potential for exposure between males and females to either occupational
... cisk. factors for le,ukemia or. air emissions from Pilgrini..
Leukemia mortality was not significantly different from that expected,
whereas leukemia incidence appears to be elevated, particularly among
males. There are several possible explanations for these inconsistent
findings.
One is that survival after the diagnosis of leukemia may be better in the
five town area than in the state as a whole. This may be due to earlier
diagnosis, better health care, or better utilization of health care
facilities. With early diagnosis and treatment, an individual's cancer
can frequently be controlled or cured. As a result, the individual may
ultimately die from some- cause unrelated to the cancer and thereby not be
recorded as a cancer mortality statistic. Incidence would reflect all the
cancers diagnosed but mortality, therefore, would reflect only those
''■ canetffr' for Which 'the '^caase of death* happenfed'to be cancer. '' " "-'---•-•
Another explanatioii may be that the increase in the risk <)f leukemia is
only recent and; therefore, would only be reflected in current incidence
' ■■ Istat'lsties. Most can'cfrr deaths occur s'ev^ratyfe^fs after* dfac(nosi s and so
'C '"igaS niortaTlty would, foV exaraple, incVude many caseSTikety diagnosed
before 1982, Incidence provides the best indication of current elevated
if*isks of cancer.
A third explanation may be that the apparent elevation in leukemia
-7-
474
incidence is due to a chance fluctuation in the observed numbers. Numbers
of observed cases characteristically increase and decrease from year to
year. Therefore, these fluctuations are possibly unrelated to any general
environmental exposures such as air pollution or contaminated drinking
water. Small numbers, in particular, are frequently susceptible to
significant fluctuations from year to year that can result in misleading
differences when compared with expected numbers which are based on larger,
more stable numbers.
Appendix II shows the numbers of incident cancers of the hematopoietic and
reticuloendothelial system (cancers of the blood forming organs) in towns
within twenty miles of the Pilgrim plant. As with the mortality data
shown in Appendix I, it would be inappropriate to analyze these towns as a
group because the potential for exposure to adverse environmental
exposures would vary greatly from town to town.
Adverse Reproductive Outcomes
The third analysis dealt with two adverse reproductive outcomes in the
Plymouth area, infant mortality and low birthweight. Adverse reproductive
outcomes often are sensitive though nonspecific indicators of
environmental problems. Figures 3 and 4 show annual infant mortality
rates and prevalence of low birthweight among live births in the town of
Plymouth, Plymouth County, and Massachusetts from 1969 to 1984. (Infant
mortality is defined as death within the first year of life; and low
birthweight is defined as birthweight below 2500 grams.) There was an
obvious, gradual decline in both infant mortality and low birthweight
rates in each of the three geographical areas before and after the Pilgrim
plant was operational. The year-to-year fluctuations in the rates,
-8-
475
particularly for (he town of Plymouth, show the susceptibility to
variation of rates derived from very small numbers of events. For
example, the 25 percent increase in infant mortality observed in the town
of Plymouth from 1981 to 1982 is accounted for by an increase in the
number of infant deaths from four to five. Without these short-term
fluctuations, the rates for Plymouth Town and Plymouth County appear to
have been lower than the rates for the State as a whole.
Environmental Data
In addition to health studies, MDPH has reviewed radiation data regarding
the Pilgrim Nuclear Facility. Monitoring of ionizing radiation in the
vicinity of the Pilgrim Facility has been ongoing since the plant first
became operational in 1972. This monitoring is carried out by MDPH and
the U.S. Nuclear Regulatory Commission (NRC), as well as Boston Edison.
Measurements in the town of Plymouth have been compared with measurements
from monitoring stations outside the Plymouth area, and suggest that
radiation levels off-site around the Pilgrim plant have been at or below
the levels measured elsewhere in the state.
Additionally, the U.S. Environmental Protection Agency (EPA) and the
International Atomic Energy Agency (IAEA) have reported on background
radiation levels for Massachusetts. Background radiation represents the
amount of ionizing radiation that is normally present in the environment.
The level for Massachusetts is reported as an average of approximately 13
microroentgens per hour. Except for one location on the Pilgrim site near
the stack, radiation levels in Plymouth have essentially been at or below
background levels for the state.
476
Additional environmental radiation data are currently under review by
MDPH. These include radiation measurement data from lake sediment,
pasteurized milk, and drinking water. Data from on-site radiation
monitoring (particularly emissions at the stack), will also be reviewed to
assess the levdls of on-site radiation emissions over time.
10-
477
PERSPECTIVE OF THE PROBLEM
Health data reviewed thus far indicate an elevation in the incidence of
cancers of the blood forming organs, particularly of leukemia, among the
residents of the five coastal communities studied. This elevation is
statistically significant among males. No elevation was found for cancers
of the breast and thyroid, though none would have been expected even if
there had been sufficient radiation exposure to induce these types of
cancer. This is because breast and thyroid cancers generally take more
years to develop after they are initiated by some causal factor like
radiation than the number of years the Pilgrim plant has been operational.
The biological significance of the incidence of leukemia in relation to
possible radiation emissions from the Pilgrim plant cannot be fully
determined from the available data. No clear pattern or gradient of
cancers around the plant is apparent. Generally, if some point source,
such as Pilgrim, is suspected of emitting pollutants then those at
greatest risk of exposure would be those living closest to the plant.
Those individuals with the greatest exposure would also be those with the
greatest risk of disease caused by that exposure. This is because as dose
of exposure increases, so usually does the frequency of disease
(dose-response relationship). Therefore, one might expect to see more
leukemia among those living closest to Pilgrim and less as the distance
from Pilgrim increases, if emissions are causing leukemia. This was not
observed. It should be noted, though, that many of the surrounding towns
are sparsely populated and, therefore, a gradient might be difficult to
identify. Furthermore, if the ability of radiation to induce leukemia is
-11-
478
approximately the same for widely differing doses of exposure, then a
gradient might again not be evident. Furthermore, the off-site radiation
measurement data reviewed so far (the levels of radiation residents of the
surrounding communities are exposed to) are not consistent with the
development of adverse health outcomes, based upon current medical
knowledge.
Interpretation of the health data currently known for the Plymouth area
requires a certain understanding of the limitations and value of the data
before definitive conclusions can be drawn. The Commonwealth has mandated
the reporting of all new cases of cancer since 1982. On the average,
there is a six month lag between diagnosis and the report arriving at the
Massachusetts Cancer Registry, located at and administered by MOPH. The
reporting hospital is required to report any changes made in the diagnosis
of cases previously reported to the Registry.
Additionally, the Cancer Registry regularly conducts quality control
checks. This process includes checks on the reported diagnosis, as well
as the completeness of case ascertainment. These quality control
procedures are in line with the procedures used by cancer registries in
other states and those supported by the National Cancer Institute, and
assure the validity of the cancer incidence data.
Any changes made in the Registry data as a result of these processes often
result in the revision of incidence rates for specific cancers and for
specific towns. This has occurred since August 1986 when the Registry
learned that a female leukemia case in Plymouth had mistakenly been
reported by a hospital as a male resident of Scituate. The correction of
this error altered the number of hematopoietic and reticuloendothelial
-12-
479
cancers in the five towns from 32 males and 20 females to 31 males and 21
females.
The Cancer Registry data are routinely used for the purpose of
surveillance. This involves comparing the incidence of specific cancer(s)
between communities or between communities and the state. The comparisons
are often complicated by year-to-year fluctuations in the rates due to the
small numbers of reported cases and the small population size of many
communities. Consequently, there is often little statistical confidence
in the observed differences between the incidence rates. Additionally,
current cancer incidence data are of limited use for assessing time trends
{to indicate increasing or decreasing incidence rates) in a particular
community or region because incidence data are presently available for
only three years (1982-1984).
Even with stable rates and large populations, descriptive analyses, such
as that presented in this report, only provide information as to the
possible existence of a problem and not to the cause(s) of the problem.
Regarding leukemia in the Plymouth area, a broad spectrum of risk factors
may have contributed to the observed incidence.
Occupational exposures, particularly among those who work in the rubber
and leather industries, have been implicated in epidemiologic research as
risk factors for leukemia. Exposure to benzene, for example, is a
documented risk factor for leukemia. Use of certain cytotoxic drugs such
as chloramphenicol, and radiation received in the course of diagnostic
tests or treatment are also considered as possible causes of leukemia.
The past residential histories of cancer cases is also of importance in
order to determine if there is a relationship between previous residence
-13-
480
of a case and proximity to the Pilgrim plant. Proximity to the Pilgrim
plant acts as a proxy measure of the potential for exposure and the
intensity of that exposure. That is, the closer an individual lives to
the plant, the greater the potential of exposure. Similarly, the length
of residence acts as a proxy measure for duration of exposure.
Available information on these important factors is presently limited or
nonexistent. It is, therefore, not yet possible to establish whether
there is a cause and effect relationship between the observed leukemia
incidence and exposure to possible radiation emissions from the Pilgrim
plant.
-14-
481
CONCLUSION
These analyses of health data have revealed no disturbing trends in either
the patterns of cancer mortality or in the expression of low birthweight
and Infant mortality. Presently, radiation monitoring records do not
suggest any significant levels of radiation off-site of the Pilgrim plant
(the levels of radiation residents of the surrounding communities are
potentially exposed to). However, a statistically significant increase in
the incidence of cancers of the blood forming organs, primarily leukemia,
among males in the five coastal towns has been identified. The number of
leukemia cases diagnosed among female residents of the five towns were
also higher but not significantly higher than expected.
This review has established that there is an apparent excess risk of
leukemia incidence in the five towns combined. But limitations in the
data available for this investigation preclude an assessment of the
magnitude of public risk from exposure to air emissions from the Pilgrim
Nuclear Facility. Major gaps exist in our present understanding of the
relationship of the nuclear facility with the health status of the
residents of Plymouth and surrounding communities. The major gaps include
a full characterization of occupational history, residential history, and
medical history concerning the leukemia cases.
In response to concerns regarding the elevated incidence in the
communities investigated, MDPH has considered several approaches to a
comprehensive study of the cancer incidence. The objective of the study
MDPH is committed to conduct will be to overcome the limitations of the
present health data. This would be accomplished through the collection of
-15-
482
information regarding possible causes of leukemia, including emissions
from the Pilgrim plant, by means of interviews with cases. The study will
be designed to include a sufficient number of cases and explore possible
causes of the observed excess of leukemia in these communities. Such a
study will require resources that are currently unavailable to MDPH.
b<>;
-16-
483
residents ot PiymouTn, Tiy census
tracts
484
3 cases
FIGURE 2
Number of cases of leukemia ,
multiple myeloma, and other
rare cancers of the blood
formins organs diagnosed in
1982-?4 among the residents
of Duxbury, Kingston,
Harshfield, and Scituate, by
census tracts
no cases
485
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487
TABLE 1
The numbers of observed and expected breast cancer deaths among female
residents of Plymouth, the five coastal towns, and the remaining towns of
Plymouth county for two time periods.
1969-1973 1979-1983
Observed/Expected Observed/Expected
Plymouth 15/21.5 29/33.2
Five Towns Combined 56/54.9 84/79.5
Rest of Plymouth
County 214/219.6 284/259.8
Source: Division of Health Statistics & Research, Massachusetts
Department of Public Health
488
TABLE 2
The numbers of observed and expected leukemia deaths among the residents
of Plymouth, the five coastal towns, and the remaining towns of Plymouth
county for two time periods.
1969-1973
Observed/Expected
1979-1983
Observed/Expected
Plymouth
Males
Females
6/4.3
5/3.6
5/6.9
7/5.9
Five Towns
Combined
Males
Females
8/11.7
12/9.4
16/16.3
16/13.8
Rest of
Plymouth County
Males
Females
43/47.3
47/37.4
44/54.7
43/47.1
\
Source: Division of Health Statistics & Research, Massachusetts
Department of Public Health
489
Table 3
The numbers of observed and expected incident cases of cancers of the
hematopoietic and reticuloendothelial system diagnosed among the residents
of Plymouth and the five coastal towns between 1982 and 1984.
Observed* Expected
Males 10 7.5
Plymouth
Females 7 6.6
Five Towns Males 31 18.1**
Combined
Females 21 15.2
* Observed numbers reflect corrections reported by hospitals since
August, 1986
** Statistically significant difference {p<.05)
Source: Division of Health Statistics & Research, Massachusetts
Department of Public Health
490
TABLE 4a
Observed
Expected
28
14.8*
17
12.6
TABLE
4b
The numbers of observed and expected incident cancers of the hematopoietic
and reticuloendothelial systems, excluding chronic lymphocytic leukemia
(CLL), diagnosed among the residents of the five coastal towns between
1982 and 1984.
Males
Females
The numbers of observed and expected incident cases of leukemia, all
subtypes, diagnosed among the residents of the five coastal towns between
1982 and 1984.
Males
Females
The numbers of observed and expected incident cases of leukemia, excluding
chronic lymphocytic leukemia (CLL), diagnosed among the residents of the
five coastal towns between 1982 and 1984.
Males
Females
The numbers of observed and expected incident cases of myelogenous
leukemia diagnosed among the residents of the five coastal towns between
1982 and 1984.
Males
Females
Observed
Expected
22
12.1*
12
9.3
TABLE
4c
Observed
Expected
19
9.4*
8
7.6
TABLE
4d
Observed
Expected
13
5.2*
6
4.8
* statistically significant difference (p<.05)
Source: Division of Health Statistics & Research, Massachusetts
Department of Public Health
491
Appendix I
Observed and expected numbers of deaths from leukemia among the residents
of selected towns in Southeastern Massachusetts, 1969-1973 and 1979-1983
1969 -
1973
1979 -
1983
Observed
Expected
Observed
Expected
Barnstable
Males
Females
3
3
4.9
3.8
11
12
8.0
7.0
Bourne
Males
Females
4
5
2.1
1.7
4
1
2.9
2.1
Bridgewater
Males
Females
2
0
2.2
1.4
0
0
2.6
2.1
Carver
Males
Females
0
1
0.5
0.3
2
1
1.1
0.7
Ouxbury
Males
Females
1
0
1.5
1.1
2
2
1.9
1.5
East Bridgewater
Males
Females
0
0
1.5
1.1
1
1
1.6
1.4
Halifax
Males
Females
0
0
0.5
0.4
1
1
1.1
0.8
Hanover
Males
Females
1
I
1.3
1.0
1
0
1.5
1.2
Hanson
Males
Females
0
1
1.2
0.8
0
2
1.3
1.0
Kingston
Males
Females
0
2
1.1
0.8
1
3
1.4
1.1
Marion
Males
Females
1 '
0
0.7
0.5
1
2
0.9
0.6
Marshfield
Males
Females
0
3
2.3
1.7
5
3
3.1
2.5
492
Appendix I (con't)
1969 -
1973
1979 -
1983
Observed
Expected
Observed
Expected
Mashpee
Males
Femal es
1
0
0.3
0.2
3
0
1.0
0.8
Middleborough
Males
Females
0
1
2.7
2.3
2
3
3.0
2.8
Norwell
Males
' Females
2
2
1.0
0.8
1
0
1.4
1.3
Pembroke
Males
Females
1
1
1.5
1.1
2
1
1.8
1.5
Plymouth
Males
Females
6
5
4.3
3.6
5
7
6.9
5.9
Plympton
Males
Females
0
0
0.2
0.1
0
0
0.3
0.2
Rochester
Males
Females
1
0
0.4
0.2
0
0
0.5
0.4
Rockland
Males
Females
1
4
2.6
2.1
2.6
2.3
Sandwich
Males
Females
0
0
1.0
0.7
1.9
1.4
Scituate
Males
Females
1
2
2.5
2.2
3.0
2.8
Wareham
Males
Females
2
5
2.7
1.9
4.4
3.5
Whitman
Males
Females
2
2
2.2
1.9
2.2
1.9
493
Appendix II
Observed and expected numbers of cancers of the blood forming organs
diagnosed among the residents of selected towns in Southeastern
Massachusetts, 1982-1984
Observed
Expected
Ma1e<
; Females
Males
Females
Barnstable
12
13
11.0
10.0
Bourne
6
2
3.8
3.5
Bridgewater
1
2
2.7
1.8
Carver
1
0
1.7
0.0
Duxbury
3
2
1.8
1.5 ■
East Bridgewater
2
2
1.9
1.6
Halifax
1
1
1.2
0.6
Hanover
2
1
1.5
1.6
Hanson
1
0
1.1
0.0
Kingston
3
2
1.3
1.2
Marion
1
2
1.3
0.6
Marshfield
10
5
4.3
2.6
494
Appendix II (con't)
Observed
Exoected
Male:
; Females
Males
Females
Mashpee
0
0
0.0
0.0
Middleborough
2
3
3.7
2.9
Norwel 1
3
1
1.2
1.3
Pembroke
1
2
1.3
1.4
Plymouth
10
7
7.2
6.8
Plympton
0
0
0.0
0.0
Rochester
0
1
0.0
0.4
Rockland
1
1
2.8
2.2
Sandwich
3
0
2.3
0.0
Scituate
5
5
3.4
3.1
Wareham
4
2
3.5
2.7
Whitman
7
4
2.5
1.7
495
COMMONWEALTH OF MASSACHUSETTS. JOINT COMMITTEE ON ENERGY
Testimony of Sidney Cobb MD , March 24, 1987
Last week I read a paper be-fore the American Epidemiologic
Society on behalf o-f my coauthors R. W. Clapp, C. K. Chan, h
Bail us Walter, Jr. In this paper I detailed the information
leadinq to the conclusion that there is an excess o-f leukemia
in the five coastal towns north -from Plymouth to Scituate.
this is now a well accepted conclusion and has been discussed
befort? this committee and in the newspapers. I will not bore
you with a repeat of the evidence, but I want to reemphasii-e
that the excess is very small when compared to the ordinary
hazards of life.
T warit to give 'you the reasons that I suspect this excess
leukemia might be attributable to airborne radioactive
effluents from the Pilgrim I nuclear powe»r plant.
1. A closer examination of the residential location of
the cases reveals that essentially all of the extra
cases live within four miles of the coast in a strip
about 20 miles long.
2. There are several factors which might tend to contain
the radioactive effluent from the plant in sucli a
narrow area. The first is the coastal circulation of
air that is depicted in figure 3. It is easy to
imagine how an injection of pollutants to the middle
of such a pattern might be contained and carried along
the coast. The second is the fact that two to four
miles inland the land rises rather sharply providing a
qeoqraphic containing wall '. The third is the fact
that coastal fogs are not uncommon in this AreA and
there is new information suggesting that fog can trap
residues from pesticide spraying. Perhaps it might
also trap radioactive materials.
3. Wo3 ha^e examined other possible explanations for this
very narrow band of excess leukemia and have found
none satisfactory. There does not seem to be any
clustering of cases by occupation, and the
distribution does not fit the distribution of any
water or milk supply nor is there a known coJ lection
of toxic waste dumps spread along this coast.
4. In Maine there is an outbreak of leukemia that is
similarly located in time and space with respect: to
the Maine Yankee plant at Wiscasset. This tic=<s as yet
not been thoroughly investigated because it was
overlooked by the group who made the original
496
investigation o-f leukemia in that sireA. It is,
howevG'r , quitt? str:iing £<ncl according to data from the
Maine cancer register appears to be continuing.
5. Ttiere was a particular peritjd in the early 1 i -f e of tha
plant during which the radioactive emmissions were
substantially greater than usual and on morF thari one
occasion e>;ceeded technical standards. I he worst
period was the 12 months -from last guarter o-f 19/4
through the third guarter o-f 1975. See tigure 1.
6. fhie increase in leukemia appears to have taken place
about -five years a-fter this period o-f extra emissions.
Five years is just about the expected incubation time
-for ra<Jiogenic leukemia.
7. I -f these releases in 1974--5 were su-f-ficient to
produce leukemia one would expect to see some adverse
reproductive outcomes appearing within a -few months o-f
the exposure. Assuming that the critical period to
examirie was 1975-6 we proceeded to rank the 26
health service areas in the state with respect to the
si^e o-f the bulge i ri that two year period when
compared with the two years be-fore and the two years
afterward. The ranking was done -first on infant
mortality rate (IMR) and second on congenital de-fects
reported on birth cer ti -f i cates (CDR) . The result is
shown in table 1 and the maps on the last page o-f the
handout. The top si;: in the IMR ranking contain the
top -five in the CDR ranking. All the selected areas
Sire either north along the coast or adjacent
to SireA 53 which contains the town o-f Plymouth. Thi«
distribution is highly unlikely to have occurred by
chance (P < 0.0002). This -finding clearly needs
-further exploration, but the hypothesis o-f radiogenic
health e-f-fects resulting -fro<n the extra emissions -from
Pilgrim .1 in 1974-5 is suppor-ted.
'ffc» »*e , the above evidence is quite suggestive enough to urge
Continuation oi the investigation. A causal relation is -far
f^-om proven, but the suggestion o-f possible causation should
receive serious -further consideration.
rf the investigations to date should be supported by -further
local research and by -further -findings around other coastal
rtuclear installations, we will be torced to conclude that m
the -future the standards must be set low enough to preclude
releases such as came -from the Pilgrim plant in the middle
seventies. This would be -facilitated by passage o-f House Bill
5lBa.
497
40 ..
30 ..
20..
a:
10
_ .j\\h-
MAIN STACK
All Isotopes
T-rr-*-!-*
a_
I I I I I I I II
150 1
100
50
I I I I I I I
REACTOR BUILDING VENT
All Isotopes
I I
_ wfk-rl
I I I I
fln_
150 ..
100
50 ..
I I I I I I I I I I
IODINE - 131
Main Stack and Reactor Bldg. Vent
n-h_r
171 172 |73 174 175 176 1 77 178 1791 80 1 811 82 1 831 84 1 851 861
YEARS
(by quarter)
Fig. 1 Airborne radioactive effluents from Pilgrim I nuclear reactor in
Plymouth. MA. by quarter. 1972-1986.
(Source: Boston Edison Semi-Annual Effluent Reports to USNRC)
498
FIGURE 3,
B
AIR COOLING
AND DESCENDING
^
t
-fr
^r"
WARM Ain,C.WP».
WATER l\l5ir<0
COOLER AIR OVER lArJr
MOVING Tc/'./aKU
dill
Land and sea breezes.
SOURCE: Field F: Dr. Frank Field's Weather Book. New York: G.P,
Putnam's Sons, 1981.
499
i-iuK 1 Ai . :l T y iiUu i:.orn,i.M t I hl uefeci ka icn
IWrnlJ I
KtiNl:.
I MR
L.liK
USA
RAI 11
5-3
I . /
5-6
1.6
5-2
1.4
6-1
1 . 2
6-3
1.2
6-5
1.2
HE,A
5 1
Kn r 1 (J
.1 . «
1 .;j
1 . B
1 . 6
1 . 6
1 . 5
'--■-i^i
r 1 Dure ^ r-lassAchusetts hedi tr-> service arcjae ahoMi mq ttioft
that *re in vol ved i n the 1975-7& "eoi domic " o* i nt a'tu
iTtortaiity. I fie areas Mere rar>l:ed bv their t'atio& o4 ii
(fiOf »:a 1 1 1 V rates *or l97ti-/«i ove?r the I r ratc-s for the Lwo ■,
;>rcrceedi riQ arid the tMO years toil owi no. The ai >; tOMns tha
a/-o si.iSdE-J are the top si « in thi s r,ani-i nn
riqure 3. Hassachuset ts health service areas showing those
that *re Involved in the 1973-76 "epidemic" o* conaenltai
defects reported on birth certificates. The areas were ranked
by their ratios of conqeni tal defects reported in 1975-76
over those reported for the two years preceedinq and the two
years .following. The five towns that are shaded are the top
five in this ranl-lng. (A» can readily be seen they »ro five
of the %in towns shaded on the previous map)
500
USA
L.i ve
BirthE.
ln+ ant
Observed
rl E? a t h s
F.:;pecte
d*
Ob
R
s/Ev;
at 1 □
P
N
E
D
umber
;;ces=i
eaths
5-3
3 . 668
60
34.9
1.7
25. 1
5-6
3 . 932
73
45.6
1.6
27 . 4
5 -2
5,536
92
64. 4
1.4
27 . 6
6-1
2, ;:iil
.'I
26. U
1.2
4. 2
6 - :•
2,973
39
33./
1 .2
5.3
6-5
3 , 45 .'
44
3 7.8
1.2
6 . 2
.; 1,772 3^9 24:...- 93.8
e,:pecterl number a+ infant deaths calculated by:
(1. ntant deaths in 1973.74,77,73)
(livp birttis in 1 973 , 74 , 77 , 7EW
* (live births in 1975, /6;
Per ki ns
30 March 19B7
Massdat a
501
CONGENITAL DEFECTS* - MASSACHUSETTS - 197b ?- 1976
R«nk HSA
Li ve
Births
Conqeni
Observe
tal
E
De-f ect
;;pecte
d
«-♦
ObB/E:;
fi: a t X o
P
Number
E;:cess
De+ects
2 , 20 1
29
1 6 . i;i
1.3
1 3 . 0
2,978
26
14. 2
l.B
1 1 .Q
5 , 536
55
31.5
1.7
23.5
3 , 668
42
25.8
1.6
16.2
3,457
35
22 . 0
1.6
1 3 . i:i
2,254
26
17. 4
1.5
8.6
■t, 6-5
6 5-1
Totals 20,094 213 126.9 86.1
♦ conaenital de-fects recorded on birth cer 1 1 -f i cate'i
»♦ expected number o-f congenital de-fects Ci^lcul<sted by:
tconq. defects in 1973,74,77,78)
e)!p « = ■ » (live births in 1975, 76j
(live births in 1973,74,77,78)
Pert 1 ns
30 March 1937
Massdata
502
BiFIVETOWN. CDR
INFANT MOFvTALITY AND COWGENI'
Z April 1937
-iL DEFECTS - FIVE COASTAL TOWNS - 1970-
TOWN/VEAR
Dux bury
Kinqston
Mar^h-f i el d
F'l ytnauth
Sc 1 tuat e
Totals
C DR
1970
1971
1972 1973 1974
Total Li ve Births
1975
1976
19B4
19 7 7
Du;;bury
124
109
131
123
124
114
104
125
l"-i ng^iton
135
106
1 11
112
1 1 1
93
101
9'^
Marsh fit?
Id
292
307
271
311
299
268
2/7
28o
PI yinauth
359
385
4u4
448
431
442
515
605
Sci tuate
248
200
178
193
161
18o
148
1-5
Totals
1 , 158
) , 1 u7
1 , 095
1 . 187
1 ,126
1 ,097
1 , 145
1 , 290
Conqeni tal De-fects*
0
0
2
1
0
'J
0
1
1
0
2
1
T,
2
1
4
0
1
7
4
6
8
5
1
0
1
4
'^
1
2
lo
8
14
15
a
=-,
9.
, 13
6.
74
12
.43
13
.6/
6.
,99
z-.au
Dux bury
2
0
2
Ki nqs ton
2
3
3
Marshf leld
0
-z.
2
Plymouth
T;
b
5
Sr.i 1 uate
4
jL
2
Totals
11
13
14
IMF<
9.
, 5».>
1 1 .74
12. /9
In-fe-nt deaths
1
7
0
1
6
1
3
6
17
12.64
15
13. lo
6.vg
congenital de-fects reported on birth certificates
503
1978 l'?79 198C.I 1981 1982 1983 19B4
130
126
147
140
161
lti5
155
97
94
97
97
117
103
112
299
309
327
303
32 1
304
329
551
590
594
552
588
558
575
175
182
194
IBO
2i;i9
201
"^"^. ■'.
1 , 252 1 , 30 1 1 , 359 1 , 277 1 , 396 1 , :..:. 1 1 , 4ij4
1
0
1
4
1
0
1
0
2
2
0
1
0
2
1
4
1
1
1
':?
3
3
2
6
1
4
1
7
1
. 0
1
1
■y
1.
3
6
8
11
7
9
4
16
4.
,79
6.
15
8.
09
=,,
.48
h.
,45
3.01
1 1 ,
. 40
0
1
0
1
1
O
ij
0
u
2
4
2
1
7
-T
4
3
O
0
0
5
lO
7
7"
■9
7.09
5.15
5.48
1
1
O 1 5
i i lO 14
7.a3 /.51 9.9 7
Perkins
Source: Mass DPH Annual Reports
504
HEALTH SERVICE AREA IV
'^£>' -^
JT^
505
HEALTH SERVICE AREA V"
*1NCLU)F.S ACTIVE AND INACTIVE SUBAREA COU:;cn,S.
171
506
HEALTH SERVICE AREA VI
'cp- -d
172
507
I CONOMIC
I'Kli >kll 11 S
NEWSLETTER""
December. 1986 CEP Publication N86 - 12
Public Health
Nuclear Emissions Take Their Toll
By Jay M. Gould with Brian Jacobs, Celia Chen and Steven Cea
Chernobyl has raised the universal question ot what
IS the true impact on public health of nuclear emis-
sions. This newsletter, the fifth in a series of reports and
publications by the Council on Economic Priorities on
the geographic dangers of toxic waste, will review some
of the evidence linking nuclear emissions in the US to
increases in mortality rates.
A state is often too crude a geographic unit for the
measurement of environmental dangers since these
dangers are generally local and seldom impact to the
same degree on all or most localities in a state . As a pre-
liminary effort, however, statewide and county varia-
tions in total infant and cancer mortality rates can be
used to appraise current regional variations in public
health.
Economy Determines Mortality
The advance of any modern industrial society can be
traced in terms of the systematic decline in its mortality
rates over time and the consequent increase in the lon-
gevity of its population. This is true of the US over the
past two hundred years or more, and certainly so in the
20th Century when the official mortality statistics
became representative of the total population. The US
total mortality rate stood at 17.2 deaths per 1.000 per-
sons in 1900 and declined at an average annual rate of
one percent to stand at 8.7 deaths per 1,000 persons in
1980. The annual decline in mortality rates can, of
course, be expected to slow as the population ages over
time. Thus the mortality rate, when adjusted fordiffer-
The Calculation of Excess Mortality
Insight into the probable consequences of the Chernobyl disaster can be gained through US Mortality data for areas
exposed to nuclear emissions, provided the toul volume of curies of radioactive materials released is known . This newslet-
ter explores the impact on public health of the release (routine and accidental) of some 35 million curies of all noble gases
and radioactive particulates emitted from all civilian nuclear power reactors in the US in the years 1974- 1981. as tracked by
ihe Brookhaven National laboratory. Our analysis indicates that such releases (detailed in Table 4) based on mortality data
for stales most directly affected by such emissions, are associated with nearly 9,000 excess deaths each year
Brookhaven emissions surveys are extremely conservative. They do not cover emissions from the plulonium producing
Hanford and Savannah River military reactors. The Atomic Energy Commission has been extremely sanguine about possi-
ble nuclear contamination of communities situated downwind from military reactors.
The Portland Oregonian (on May II and 12, 1986) revealed, on the basis of some 19,000 pages of classified data obtained
as Ihe result of FOIA, that the Hanford military reactors in Benton County, Washington, apparently released into the air
446.700 curies of radioactive Iodine-131 in the years 1945 to 1950, and an additional 7.616 curies in the years 1951-1961
This represents staggeringly high radiation levels— only 14 curies of radioactive Iodine were reported to have been released
by the Three Mile Island disaster in 1979. For example, in an experiment "related to the development of a monitoring
methodology for intelligence regarding the emerging Soviet nuclear program," Hanford purposely released 5000 curies of
radioactive Iodine on Dec. 2-3, 1949. One particular stretch of farmland, lying just downwind of Hanford. came to be
known as "Death Mile." Nine of its ten families have been stricken with cancer since 1950. The full impact of these emis-
sions on the area affected has never been estimated. It is time for private citizens in the US as well as the USSR and Europe
to demand official evaluations of the loss of life from nuclear emissions. It is CEP's hope thai the findings and methodology
offered in this newsletter receive the critical attention of radiation physicists, epidemiologists, and public health
officials. ■
I'." irMi'i; 1*1 .,,■ \i v ^.irl.
KHMl.i c:i.'i 4.
Ml-
508
Ciiniinued jrim paxe I
cnces due lo age. declined somewhat
more -from 178 in 1900 to S y deaths
fx.-r 1.000 in 1480
The inlant mortality rate (IMR)— de-
fined as the number of deaths within the
first year per 1,000 live births— does not
require age adjustment and has declined
much m.)re rapidly Overtime, the IMR
is very much affected by the change in
relative health standards of nonwhiles
since the IMR for nonwhites generally
has been about 50 percent higher than
the IMR for all babies. In 1915. the first
year in which the official Infant mortali-
ty rate was considered accurate, the
IMR was 998 The 1980 figure, at 12.6.
represents an average annual decline of
3.2 percent over a 65-year period The
average annual decline in the IMR usu-
ally ranged between two and four per-
cent in accordance with the degree to
which nonwhites and poor whites en-
joved better health and nutrition in peri-
ods of economic expansion
This fact IS indicated by Table 1 w hich
summarizes trends in infant mortality
by five-year periods since 1915. Annual
declines are seen to average below three
percent in depression years and over
four percent in the "prosperous" full
employment war years. In the decade
1955- 1964. the years when atmospheric
bomb testing produced peak fallout lev-
els, the average annual decline slowed to
one percent, however The signing of the
test ban treaty in 1963 saw fallout levels
dropping sharply, and the average rate ol
decline in the 1965-1979 period was
again well over four percent
I Cancer Rates i
i Steadily Increasing i
As the overall US mortality rate re-
, nects the gradual aging of Americans,
so does the cancer mortality rate— it has
been increasing for decades But the
cancer rate is increasing even after ad-
justment for age and now accounts for
I about 22 percent of all deaths. ,
These mortality rates, used to evalu-
ate public health standards, are closely
; intertwined. Historically, modern
industrial technology, along with ad-
vancing medical technology, has ele-
vated nutrition and health standards. It
has also contributed greatly to the sys-
tematic lowering of mortality rates But
1 over the past three decades, increasing
1 cancer rates, even after age adjustment .
represent the grim side of that equation.
' They reflect in large part the environ-
mental deterioration accompanying
modern industrial technology CEP is
I committed to the exploration of these
complex and often contradictory eco-
I nomic. environmental, and public
health issues
Infant Mortality
Linked To Fallout
! Of the three mortality rates, the IMR
1 is by far the most sensitive to both eco-
nomic and environmental change. It
can respond to a major environmental
change within months Let us again re-
fer to Table 1 that summarizes official
' US IMR data by five-year periods since
1915. The necessity of including nuclear
radiation in measures of environmental
degradation is indicated by the flatten-
TABLE 1:
INFANT MORTALITY RATES IN THE US, |
1915-1979
Annual % Rates 1
Year
A>
. # Deaths
per 1,000 Births
of Change |
period
All Babies
Nonwhite
All Babies
Nonwhite
1975-1979
144
22.1
-4,9
-4.6
1970-1974
184
276
-4 2
1965-1969
22.7
.165
1960-1964
25,3
41.6
■0 9
-1,0
I95S-195V
26.4
43,7
-13
•0 5
1950- 19S4
28,1
44,8
-36
-2,2
1945-1949
3.V5
498
-4,9
-6.2
1940^1944
42 6
67.2
-4 6
-3 9
1935-I9.19
53 2
81 3
■2 6
-3 9
I9.W-I934
f)04
986
-2,7
-14
19:5-1929
69 0
105 4
' -> T
-1.8
19211-19:4
76 7
115 3
-4 7
-5 ■(
1915-1919
Stturcc: tV/ti/ Slun.
95.7
1497
-
—
IKi oflhr U i
. 19X0. Viil 11, Mnruihn
Parr A. Setltnn 2
hifani Mnrlttht\.
piiv, 1
ingoutof the long secular decline in the
average annual IMR that occurred in the
bomb test years
When attention was first drawn to this
ominous change in the late sixties, pro-
nuclear proponents asserted this tlat-
tening out in the annual rate of the de-
clining IMR merely reflected the natu-
ral limits of medical technology and the
possible exhaustion of the powers of an-
tibiotics. This argument was called into
question after the ban on atmospheric
bomb testing by the immediate resump-
tion of the average annual four percent
decline in the US IMR, That there are
such cities as Amsterdam and Yokoha-
ma today w ith I M R rat los of t he orde r of
four or five, as against the current US
IMR of II. indicates we arc still far from
reaching any "natural" limit
A 1986 publication ol the ChildrcnV
Defense Fund has. however, jusi warned
that another ominous alteration in mtant
mortality rates has occurred in the peri-
od 1981 to 1984— when "the annual rate
of decline has slowed to approximately
three percent." In this period, the black
infant mortality rate was also iw ice that
of white infants, the greatest disparity in
23 years. (Table I shows that nonwhite
i.ifanl mortality rates have historically
been most responsive to both economic
and environmental changes Average
annual declines were close to SIX percent
in prosperous periods such as 1945-49
and average annual declines less than
one percent in the peak bomb lest years, )
The Children's Defense Fund offers
much evidence that these recent changes
can be attributed to cutbacks in Federal
health, nutrition, and service programs
The hypothesis that emissions from nu-
clear reactors are also adversely affect-
ing infant mortality rates for both white
and black babies shall be explored
below
Most of the nations civilian power re-
actors came on line in the seventies, par-
ticularly in 1974 and subsequent years.
Routine and accidental emissions from
these reactors have been tracked by the
Brookhaven National Laboratory
The following isa summary of the lat-
est Brookhaven Report:
Lmi&sions, All Nobte Gases,
Million Curies
Total
1974-1901
1970-1981
Riiiling Water
Reactors
li.m
40252
Pressurized
Water Reactors
rmals
11.687
J?.4rt
11.719
This newsletter investigates the .staiis-
Coniintietl i><i<!i' 4
509
TABLE 2: AVERAGE ANNUAL MORTALITY RATES, 1965^9 AND 1975-82
BY STATE AND REGION
> 1 • U 1 , IV!
t A ( ! '9
6 5
19 6 9
ANNUAL
A V ! t A 6
E 1 «
7 5
1 9 J ;
IIAIUS
l)E CHANCE
eiBIHS INFANT It!
•9f MAINS
Hi CANrm
cat
lltlNS INIANI
INl
Pof DiAHi
Nt
CAN[!R r«
I8R
HP
CNR
OiA-Ni
IIH)
OIAIHS
OIATHS
|TN>
(!A-H)
tAlli'
RAIIC
RAIIO
»3
:s'i'0'
03" 22 5
■'I.6A4 i«7n2;e
9 5
309907
157 4
11944)5
45'.6|
IS 4
2:i7''j
-'.1224
8 '
399011 179.7
0. 5-6
0 '15
1 141
Kill*
.'O.i ;
4045 i' 9
11329
II'I'.O
.0 4
20 '53
181 2
!5»02^
:;i8
II :
12375
1I0'43
9 n
25121 203 8
0 561
0 867
1 113
"ff
IW?
'i- H 0
'»4
I0«6«
II 0
HI'
184 9
15647
P5
9 .
!i;2
10)07
9 3
2745 201 8
0 51-
0 839
1 092
VK
:?l^?
:"41 > N
..-7
7260
10 5
12112
195 2
12589
116
9 2
eo.
7356
8 2
l66l 185 4
0 464
0 783
1 001
If
154 .' i
42!
IV.>
10 .
727
:'2 ^
'157
70
- 8
50!
4380
3 8
9|2 182 3
0 4-3
0 804
1 057
IM
,ii?-.
|1V 119
5408
5''J0A
n 0
10315
PO '
■|961
7-;
II 0
51)5
53481
* 3
120C1 208 5
0 553
0-84'
1.093
•N!
u»*;
141 20 .*
•III
.|9-,
10 •
1-78
197 3
11 '86
170
14 2
953
9221
9 7
2151 225 6
0 695
0 918
1 143
"CI
S01»
"S 1 H
2922
25915
8 )
4832
165 3
16685
435
II 9
1107
2599;
8 4
6152 198 0
0 598
0 943
1 197
mom! »iuHiir
J4H?
13720 .: 0
36746
179695
10 1
6 7948
184 9
48591-
6710
II 8
37008
1526 '9
9 5
'6'»e 207 5
0 62-
0.922
1 122
•HT
JkMS
'048 22 3
IF.064
187700
10 4
34171
189 2
238206
1446
14 5
177S6
167766
- 4
36670 206 5
0 650
0 90-
1 092
•iij
IIAUI
2402 20 9
6^78
65102
9 3
12405
177 8
9IS42
1129
12 3
'174
64995
9 8
1497' 203 1
0 390
0 945
1 143
•p>
in'e;
■r'o ?2 1
11704
126893
10 8
21372
182 6
156172
2134
13 '
11878
119917
0 1
25141 211 '
0 618
0.-51
1.159
CASr JtumH CEKIML
7i;9«S
15692 21 8
39166
371057
9 5
62907
160 6
632173
9464
13 4
4146'
358145
6 6
74396 |7» 4
0 613
0 -12
1 117
■OH
imti
3860 20 5
10503
99262
9 5
16931
161.2
163209
2124
13.0
10784
96324
0 9
20184 137 2
0.634
0-45
1 l6l
■ IN
'iiii
2050 21 •
SOIS
4'72B
"5
7800
155.4
64495
1066
12 6
543'
4'044
8.;
9520 175 1
0 575
0 -10
1-126
■11
\%i)'-
4-02 23 9
13870
108827
!0 0
18354
168.9
176708
2677
15 1
11407
100416
8 6
20-61 183 6
0 633
0 »'-
1 086
Wl
n2;o:
3585 22.0
8581
74845
8 '
12877
150 1
137566
1878
11 7
-I'l
74149
8 1
15421 168 1
0 620
3 926
1 120
■Wl
"ISA
1484 19.2
4194
40394
"*
6947
161 6
70205
719
10 2
4662
40210
9 6
6309 178 2
0 532
0 696
1 076
UE5I HUlilH CENTRAL
27«i60
5543 19.8
16008
163935
10 2
2680S
167.4
271081
3428
12.6
17063
157578
9 2
31462 194 5
0.636
0 -02
I 102
•HH
1.6301
1235 18 6
3629
33527
* 2
5762
158.9
63172
728
11 5
4029
33010
9.2
6791 168 5
0 619
0 ki:7
; 061
■l»
(i^o?
•43 l».3
2771
29521
10 '
4830
174 3
45090
507
113
2908
27040
■' 3
5518 189 7
0.594
0 875
1 068
H'J
W20
17S7 21.9
4575
52026
U 4
8171
178 6
'5737
1148
15 2
4830
49799 10 2
960- 201 0
0 692
0 697
1 125
HD
um
227 19 1
633
56)9
e 9
922
145 6
12347
162
13 1
651'
5664
8 7
1089 166 8
0 686
0.975
1 146
SB
12009
261 21 •
673
6509
9 7
1072
159 3
12219
151
12-4
688
6396
9 3
1212 176 1
0 56-
0 -61
1 106
■HI
251 'A
410 |6.3
1449
14898
10.3
2518
r; 7
2S871
323
12 5
1563
14546
9 3
2893 185 1
0 '68
0 9.15
1 066
IS
J5H«
710 20 2
2278
21814
9 6
3525
154 7
36645
40'
11 1
2542
21133
9 0
4170 178 0
0 550
0 942
1-151
sraiH (iiwiic
5A«05;
13976 25 5
29637
276055
g j
42176
142 3
520991
7919
15 2
36248
320918
8 9
65682 161.2
0 5-7
0 951
1 273
m
ID213
223 21 i
52)
4904
9 4
780
148 9
8961
118
13 1
596
5040
3.5
1116 167 5
0.603
0.-05
1 259
m
A2J92
1426 22.9
3660
31342
8 6
5565
152 0
51019
687
13.5
4214
32425
7 7
755! 1'9 2
0-569
0 899
1 179
■DC
28530
673 23 6
804
10513
i: 1
1480
184 1
18163
442
24 3
664
8715
15 1
1764 265 6
1 031
1 003
1 443
■v»
71611
1'6S 24,7
4547
373*6
8 2
5840
128 4
72964
1036
14 2
5285
40453
77
9381 158 6
0-576
0 951
1 235
yv
30526
752 24.6
1819
I960'
IC 8
2-50
|62 2
29080
426
14.6
1916
19440
10 1
3621 189 0
0-594
0 941
1.165
IKC
«!«58
260' 27 7
5068
43458
8 6
5804
114 5
93625
1307
15 6
5775
47644
8 3
'085 157 3
0.563
0 962
1 574
■sc
501 23
1398 !' 1
2634
22066
8 4
2919
110 8
48484
930
1' 1
3057
23853
7.8
4394 141 7
0 el4
0 931
1-297
•u
mil
2320 25 7
4510
39555
8 8
5423
120 2
8'79l
1294
14 7
5345
43667
8 2
7890 147 6
0.574
0-52
1 226
■fl
103316
2H2 25.3
6071
67215
11 1
11415
188 0
120994
1780
14 '
-3-6
99682
10 6
21679 232 9
0 582
0 958
1-258
!»s: SDum CEniiui
2A58I2
.768 27 5
12988
1261)4
9 7
17965
138 I
232995
3567
15 3
14405
132058
9 2
2499' 173 s
0 556
0 944
1 255
rt
5»0SA
:39| 23 6
3205
31989
10 0
4817
150 3
58376
727
12 5
3603
32962
9 1
6446 179 0
0 529
0 9|7
1 191
■ IN
73603
1858 25 2
39|9
38466
9 »
5439
138 8
6-524
1078
IS 5
4482
11673
9 3
7928 176.9
0 614
0.947
1.274
■»l
65319
1839 28. 2
3521
32S62
9 3
4584
130 2
59996
971
16.2
3833
34589
9 0
6567 171 3
0.575
0.967
1,516
NS
47836
1680 35.1
2343
22817
9 7
3126
133 4
45099
7-2
17 6
2487
22834
9 2
.1054 163 0
0 500
0 94)
1 222
NISI SOUIN CE«I««l
363118
8633 23 8
I90IO
165622
8.7
26363
138.9
415029
5753
13 9
23114
19037!
8 2
36606 158.4
0 585
0 945
1 141
■H
34128
758 22 7
1973
19848
10.1
2«0
151 5
34761
461
13 3
2241
21712
9 7
4226 188 6
0 596
0 963
1 245
l«
76263
2104 27 6
3663
33107
9 0
5094
139 1
76741
1234
16 1
4118
35235
8 6
6793 164 9
0 583
0 947
1 186
■It
40468
869 21 5
2514
24370
9 7
3995
158.6
47463
620
13 1
2958
27ylO
9 2
5297 179 1
0 608
0 9S2
1 129
TI
2I22S9
4902 23 1
10861
88297
8 1
14314
131 8
256062
1438
13 4
13797
106136
7 7
20291 147 1
0.581
0 946
1 116
HOUNUIH
155932
344 7 22 1
'ti46
63311
8 1
929'
lie 4
208613
2487
11 9
10917
•7254
7 1
14425 132 1
0 539
0 677
1 116
Nl
12346
269 21 8
699
6591
9 4
1004
143 6
13337
148
11 1
'80
6519
8 4
1227 157 4
0-510
0 887
1-096
IB
12'S2
251 19 6
705
5786
» 2
893
126 7
19511
167
' 0
-11
6362
7 0
1207 132.5
0 460
0 851
1 046
NT
5823
128 21 9
323
2822
8 7
393
121.7
8636
64
9 7
442
3033
6 9
530 119 8
0 445
0.786
0-64
CO
38034
dJN 22 0
2019
17256
8.5
2497
123.7
46947
560
11 9
2807
19034
6 8
3478 123 9
0 542
0 7-4
1 002
NH
21«33
557 25.4
1004
700'
7 0
985
99 1
24450
'J'4<i
12 2
1264
8441
6 7
1540 121 8
0 482
0 957
1 242
III
32610
«5 23.5
1634
13204
6.1
7043
125 0
4551-
614
1! b
2575
19985
7 6
4001 155.4
0.575
0 960
1 243
m
23661
432 18 2
1020
702)
6 9
939
92 1
39592
469
11 S
1791
i;217
5.9
1327 95 ;
0 649
0 856
1 034
HV
8744
207 23 7
4A2
3623
8 2
533
120 4
11622
147
12 6
745
5666
7 6
Ills 149 6
0 531
0 -29
1 ;<2
PICIEIC
43205"
«SS5 19 9
24114
206979
6 6
35682
148 0
47160-
5496
11 7
29 54-
231479
' 8
49515 l67 6
0 586
0 9|3
1 132
*NA
53940
if'i ;• •
31'0
2^404
9 2
4833
151 5
60195
731
12.1
3'4'
31298
7 9
6602 167 2
0 611
0 860
1 104
■l^
;3i:c
;3j;:
9 5
3126
:" !.
40104
194
12 '
2*2'
910"
■-■ 4
4^9* I'l 9
0 h-)?
n &'♦,
1 103
"C»
145019
,664 |i 9
1»'4I
158651
K 4
27724
146 4
371)10
4271
11 5
23028
179104
7 9
38528 166 9
0 578
0 927
1 141
■NWiEii smr;
INI INIANI NUIALIT
! SAI!
Hi
8U8IAL1II lAI!
cm
CANfEI NiiRlAllII RATE
irfAIHS/HlOii
• I8IH3I
ItlAIHS/I.OOO f!«).l"SI
■SIAIHS/IOO.OOO PEISONSI
510
lical relationship between the 35.4 mil-
ion curies emitted in the years 1974-
1981 and infant and other mortality rales
in the years 1975- 1982 in states most di-
rectly affected.
For the purpose of this inquiry, the
contiguous states (excluding Alaska and
Hawaii) are divided into two groups—
nuf/carwafe.s (those with power or mili-
tary reactors) and nonnuclear states
(those without). Actually, the geograph-
ic distribution of reactors In the US is so
wide that only 19 states can be regarded
nonnuclear. Small states, like the Dis-
trict of Columbia or Rhode Island, lying
directly downwind from reactors in ad-
joining states are included in the nuclear
group.
Our definition of nuclear states (des-
ignated by an asterisk i n Table 2 ) must of
necessity include Washington and South
Carolina, home of the Hanford and
Savannah River military reactors.
Emissions from these reactors are not
I reported by Brookhaven, and cannot be
I assumed to have reached peak levels in
the late seventies as is the ca.se of civilian
power reactors. Again, Brookhaven
does not report on emissions from the
hundreds of small experimental reac-
tors located at research institutes, uni-
versities, and large hospitals. Most of
these can be found in the stales desig-
nated in Table 2 as nuclear
The years 1965-69 were chosen as the
most suitable control lime period— radi-
ation from bomb test fallout was at very
low levels. Both Nevada and Utah,
which have no nuclear reactors, were in-
cluded in our nonnuclear states. Some
residents of both these states, however,
might have been affected by occasional
accidental emissions from underground
tests in the Nevada desert. These tests
continued without interruption after the
atmospheric test ban in 1963. In fact,
these tests are continued today with as
yet unknown public health consequences.
The average annual mortality rates
have been calculated in both lime peri-
ods for these two groups of slates The
results are summarized in Tables 3 and
4 The tables suggest that emissions
from nuclear reactors in the nuclear
states may have had a small but statisti-
cally significant adverse impact on mor-
tality rates in the 1975-1982 period,
when such emissions reached high
levels.
Thus, according to Table 3, which
summarizes the rale in the nuclear and
nonnuclear states, the infant mortality
rate in the nuclear states was 22.2 per
thousand births in the 1965-69 period,
somewhat lower than the national IMR
in those years of 22.5 (not a statistically
significant difference). In that same
period, however, the IMR for nonnu-
clear states was much higher than the
nuclear IMR, but ended somewhat
lower in the later period. Its decline,
over these years, was at the annual rale
of 0.89 percent, as against 0.83 percent
TABLE 3: SUMMARY OF CHANGES
for the nuclear slates.
While these differences appear small,
in Table 4 they translate Into disturb-
ingly large annual estimates of excess
IN MORTALITY RATES, 1965-69, 1975-82,
US, NUCLEAR AND NON-NUCLEAR STATES
deaths. This calculation yields what the
NUCLEAR NON-NUCLEAR |
observed deaths would have been in the
US
STATES STATES
nuclear states if they had had the same
percentage change in mortality rales ex-
1965-69
Total * Infant Deaths
401995
310289
91706
penenced by the nonnuclear slates.
Total * Live Birch.s
17858535
13989682
3868853
A surprisingly similar difference is
Average Annual IMR
22.510
22.180
23 704
arrived al between the two groups of
(Deaths Per 1000 Live Births)
states with respect to cancer mortality.
Total * of Deaths
9351192
7467466
1883726
While the cancer mortality rale in the
Average Annual Population
196844
155742
41103
nuclear stales was somewhat below that
Average Annual Mortality Rate
950. 1 1
95896
91660
of the nation in the early period, it was
(Deaths Per 100.000)
considerably higher in the later period.
Total * Cancer Deaths
1549534
1256809
292725
At first glance, this appears surpris-
.Average Annual Cancer Rate
157.44
161.40
142.44
ing because we would expect al least a
(Deaths Per 100,000)
five-year lag of cancer mortality from
1975-82
the year of exposure, suggesting that
Total * Infant Deaths
364490
270823
93667
emissions In the 1974-81 period should
Total * Live Births
27155479
20187695
6967784
lead to elevated cancer mortality levels
Average Annual IMR
13.422
13.415
13.443
In the eighties and nineties. The elevated
(Deaths Per 1000 Live Birlhs)
cancer rates In the late seventies may re-
Total * of Deaths
15449794
12157892
3291902
flect the much higher but earlier and yet
Average Annual Population
222093
172840
49253
unknown emission levels from military
Average Annual Mortality Rjlc
869 56
879.27
835 45
reactors. They may also reflect the
(Deaths Per 100.000)
emissions from some civilian reactors in
Total * Cancer Deaihs
3192087
2561141
630946
the 1970-74 years.
Average Annual Cancer Rate
179.66
185.22
160 13
Indeed the impact on public health of
(Deaths Per 100.000)
military reactor emissions deserves
Ratios of Change, 1975-82/ 1965-69
separate study (See front page box) both
Infani Mortality Rale
05963
06048
0 5671
because the lime period of operation
Total Mortality Rale
0.9152
09169
0 9115
spans several decades, and because the
cumulated volume of emissions may be
Cancer Mortality kale
1 141 1
1 1476
1,1242
Annual I^rcenl Rales of Change
higher than that of civilian reactors.
Infani Mortality Ralc
-4.04
-3.95
-4 33
However, so much Is not known about
Total Mortality Rale
Cancer Mortality Rate
-0.85
1 41
-083
1 48
-0 89
1 24
the treatment and disposal of the huge
stockpiles of military waste, we must
511
assume that the associated public
health problems may be ol the same
order of magnitude as those of the
civilian reactors.
Unlike mfant and total mortality rates
that are steadily declining, cancer mor
tality rates have been rising for several
decades The causes of this increase in-
volve a complex mix of environmental
and demographic factors for which total
cancer mortality rates, unadjusted for
sex, race, or age, require considerable
further research.
DifTerences in Mortality
What do these results signify? First,
the small differences between the mor-
tality changes of the two groups of states
cannot be attributed to chance. On the
other hand, can these differences be at-
tributed to different nuclear emissions
levels? There is no clearly defined ten-
dency evident in Table 2 among each of
the so-called nuclear states to have
increases in mortality that exceed those
of the nation This becomes evident by
considering the ratios ofchange for each
state for the three different mortality
rates shown in Table 2 It can be said that
a state does worse than the nation if the
decline in its infant or total mortality
rate was less than that of the nation or if
the gain in its cancer mortality rates was
greater than that of the nation Thus, the
30 nuclear states have 90 opportunities
to be measured against the national per-
formance, and the 19 nonnuclear states
have 57 such opportunities (As exam-
ples, the nuclear state of Connecticut
performed worse than the nation with
respect to all three mortality rates, and
the nonnuclear state of Wyoming per-
formed better on all three counts. )
But the nonnuclear states can be seen
to do better than the nation in only 54
percent of all cases, and the nuclear
states do better in about 52 percent of all
cases. Thus, it cannot be said that non-
nuclear states have a tendency to per-
form significantly better than nuclear
states How can these apparently con-
tradictory results be reconciled with the
results of Tables 3 and 4? Can it be that
the statistically significant differences
between the two groups of states shown
by Table 3 reflect factors other than nu-
clear emissions' There is a simple ex-
planation of this paradox.
There are a total of about 90 civilian
andmilitary reactors that released emis-
sions of varying volumes in the most re-
cent time period The effects of these
emissions will be primarily found in
residents of those relatively few coun-
TABLE 4: CALCULATION OF ANNUAL EXCESS
k
MORTALITY IN NUCLEAR STATES 1975-82
1
NtCLEAR
NON-NUCLEAR |
STATES
STATES
l%S-69
Average Annual IMR
22.18
23.70
(Deaths Per KXK) Live Births)
Average Annual Morlahu Rale
958.96
916.60
(Deaths Per 1(J0,0(X))
Average Annual Cancer Rate
161.40
142.44
(Deaths Per lOO.tXK)!
1975-82
Average Annual IMR
12 58
13.44
(Deaths Per 1000 Live Binhsl
Average Annual Moriaiuy Rale
874 09
835 45
181 45
160.10
(Deaths Per 100.000)
Average Annual Cancer Rate
(Deaths Per 100.000 1
Actual Avg Annual Infant Deaths
Actual Avg Annual Live Births
Actual Avg Annual Deaths
Actual Avg Annual Population
Actual Avg Annual Cancer Deaths
Estimated Avg Annual Infant Deaths
Estimated Avg, Annual Deaths
Estimated Avg Annual Cancer Deaths
Excess Annual infant Deaths
Excess Annual Total Deaths
Excess Annual Cancer Deaths
In ihts table we have calculated the "excess " in mortatitv in the nuclear states as the difference
in the number (if expected deaths if these states had the same change in morialin- since 1965-69 as
wflj experienced b\ the nonnuclear states These calculations are warranted by the fact that this
assumption \ields differences ihai are highly unlikelx ii> be alinhuted tn chance The standard
deviation ( a ) of the difference between the observed mortaltiy rate and an expected rate' is
given by the formula:
33853
11708
2523462
870973
1519737
411488
172840
49253
320143
78868
31740
_
1510780
—
313611
—
2113
_
8957
—
6532
—
Or.
= / ir.)ll-rj +
■J .V
Ir.ld-
where r, antt r,ure the chser^ed and expfcretl mortahlv rales expressed In \is dettmals on a per
capita basis, and N represents the number of deaths in the 1975-82 period The results can be
labulated as follo\cs:
IMR
I r, 01342
r, .01258
r..-r, .00084
Or.-r, 00031
Une 3/Line 4 2 72
Chance Pmbabilily 004
CMR
TMR
001852
.008793
001814
008741
000038
000052
.00003?
000037
1 01
1 38
156
084
Line 6 indicates the probabilities of securing the observed difference on line 3 purely bv chance
The difference in infant mortality rates is most significant . for the probability ofgeltinf; as targe a
difference as ^cis observed is ont\ four out of 1000 lA probability ratio of 50 times out of 1000 is
lenerulh taken as indicative of a highly improbable result of chance 1 The observed difference in
cancer mortalin rates lies at the borderline of chance The probability that both the observed
differences in the infant and cancer mortality could simultaneously be the result of chance could
be calculated by multiplying .004 by 156 to yield 0006. because these two mortality rates are
complelely independent The p value for total mortality— 084— lies at the borderline of chance
probability, but since total mortality includes both infant and cancer deaths (with a joint p of only
0006). It IS hard to believe that all other deaths would not be affected by the same extra force of
mortality that affected infants and t anier victims
ties most directly impacted by the re-
leases The vital statistics for these
counties should then shov^ up in these
counties and not in the far more numer-
ous remaining counties thul make up the
United States.
We do not have emissions data as yet
for military reactors, which, in any
case, were in continuous operation in
both the two time periods we are consid-
ering We can, however, attempt to de-
Ctmliiuieil piifte A
512
line a nuc/ear county for the SO civilian
power reactors for which we do have
emissions data for recent years.
Some 175 counties have been chosen
as a first step to defining a nuclear coun-
ty, one that would be more directly ex-
posed to recent radioactive emissions
from civilian reactors These include, in
addition to the county in which the reac-
tor is located . an average of two or three
counties lying within 25 or 30 miles
from the reactor Those adjacent coun-
ties lying to the north and east are fa-
vored in accordance with the prevailing
wind patterns in the US. (For example.
it has been suggested that such wind pat-
terns account for the severity of acid rain
in the Northeastern region of the US )
This too is a highly simplistic defini-
tion. Windbome emissions by no means
represent the most important way in
which nearby residents can be affected.
For example, rainfall affecting adjacent
counties probably determines the ulti-
TABLE 5: NUCLEAR COUNTIES: SUMMARY OF CHANGES
IN PUBLIC HEALTH MEASURES. 1965-69 AND 1975-82
NUCLEAR C 0 U H M E S
BOILING MAIER PRESSUIUZED yilER ALL REACTORS
MiNNUCLEAR COUNTIES
REACTORS
REACTORS
COUNTIES
1H5 h9
)tutti of CounliFS
mitt' o' lirin-,
NUltCf of infairl Hfdtti'.,
IHR ;D>>ilns per liioo Birttis)
NuaDcr if r^lil Deaths
fHR (Ofitn-, pef 1000 Births)
PofHiUtion. 1970
Kuilei of Deaths
NR lOealhs per 1000 Persofi'J
»ii»bti of Canter Oedhs
CNR (Deaths per 100,000 Persohs)
RATIOS OF CHANGE
IIIR
FfIR
HR
CNR
114
175
0.632
0.687
0.910
l.MO
0.599
0.653
0.974
1.230
0.613
0.669
0.942
1.187
2968
0.589
0.623
0.922
1.150
•fetal Death data relates to the period l'i75-ei. As of this witing, 1962 data are unavailahle
US luTALS
3143
M2574B
I49M74
2730406
IS258«55
17189341
.•0524
32060
60723
348023
«0a746
23.0
21 4
22.2
22 6
22.7
19185
21256
39226
23«246
276472
14.5
14.2
14.4
15.7
15.5
14552937
17508052
31072244
172232619
203304863
6'>3005
737496
1387643
6006837
9394680
9.5
8.4
6.9
9.3
9.2
117589
126722
237103
1316843
1553946
161 6
144.6
152.6
152.9
152.9
1975-82
Ih Curies Eiitted, 1974-91
2.37E»07
1.17E*07
3.54E«07
tiissioti Per Capita
1.563
0.577
1.035
Nutber of Births
1809862
2305116
3975794
23412534
27388326
Nutber of Infarit Deaths
26331
29542
54210
314397
368607
I1R (Deaths per 1000 Births)
14.5
12.8
13.6
13.4
13.5
•Nuiber of Births
1572114
1987858
3439066
20268725
23707791
•Nuifcer of Fetal Deaths
15645
18412
33071
196107
231178
•fNR (Deaths per 1000 Births)
10.0
9.3
9.6
9.8
9.6
Population, 1980
14975515
20212643
34166432
192359373
226545605
Nuiber of Deaths
1037764
1331493
2300973
13185191
15486164
NR (Deaths per 1000 Persons)
8.7
e.2
8.4
8.6
6.5
Nuiber of Cancer Deaths
220776
289143
495352
2707124
3202176
CHR (Deaths per 100,000 Persons)
184.3
178.1
181.1
175.9
176.7
0.592
0.630
0.925
1.156
513
mate destination of most emitted radio-
active particulates and effluents Near-
by residents can also be affected by the
possible contamination of water, milk,
and produce from counties even further
removed from the point source of the
emissions. Each reactor represents a
unique geographic situation that de-
serves a careful examination of wind,
precipitation and fresh food transporta-
tion patterns This examination will of-
fer a more complete definition of those
adjacent counties vulnerable to local
emissions.
Nevertheless, it turns out that even
with the admittedly restricted definition
of the 175 nuclear counties used here,
results indicate adverse impacts on mea-
sures of infant mortality, fetal mortality,
total mortality, and cancer mortality in
the late seventies as compared with the
earlier period. These results are sum-
marized in Table 5 which replicates the
methodology of Table 3. Now. however,
the change in mortality rates o( nuclear
counties are compared with nonnuclear
counties.
In addition, the nuclear counties are
separated inlotwo groups: thosecloseto
boiling water reactors and those close to
pressurized water reactors. For all nu-
clear and nonnuclear couMie^, the rales
for infant, fetal . and total mortality are
seen to decline over the selected time
period. It will be seen, however, that the
declines in nuc/ear counties ineachcase
fell short of the declines in nonnuclear
counties. With respect tocancer mortal-
ity, which has been rising over these
years, the 19 percent gain in nuclear
counties exceeded the IS percent gain in
nonnuclear counties.
Could such results be the product of
chance? If the answer is yes. then we
would expect a 50 percent probability
for each change in mortality in nuclear
counties to be worse than the change in
nonnuclear counties. The chance of
then getting four such results at the
same time would be equal to a coin loss-
er getting four heads in a row. i.e..
(.50)'= .0525. or about one in twenty.
Actually, the probability of obtaining all
four observed changes in mortality
rates by chance is less than 2 out of 100
as evident in the caption to Table 6.
Given the fact (demonstrated in the
caption to Table 6) that the difference in
the mortality experience of the two
groups of counties is significant, we can
speculate that there may be two ways to
increase the statistical significance of
our findings. The time periods studied
should be extended and additional nu-
TABLE 6: THE STATISTICAL SIGNIFICANCE OF
CHANGING MORTALITY RATES
IMR
FMR
TMR
CMR
1. Mortality Rate. Nuclear Counties
1965-69
2 Ratio of Change in Nonnuclear
Count les
3. Expected Mortality Rale, Nuclear
Counties, 1975-82(1x2)
4 Observed Mortalily Rate, Nuclear
Counues, 1975-82
5 Difference (4-3)
6 Standard Deviation of the Difference
7 5/6
8. Chance Probability
0 02224 0 014.366 0008933 0.001526
0.5888 0.62.34 0.9215 I 1504
0013095 0.008956 0 008232 0001756
0 013635 0 009616 0 008413 0 00181 1
0 000540 0.000660 0 000181 0.000055
0.000697 0000745 0 000084 0 IX)0084
0.77 0 89 2 14 0 65
0.2207 0 1867 0 0162 0 2579
In this table, we are testing the differences between a mortaliri' rale renistereii in the unnhineil
group of I ?5 nuclear utttnties in tV75-82 with wluil wiiuld have been expelled if these amniies
had the same change in inonaliry experienced b\ alt the nonnuclear t nunties H> kniiw from
Table 5 that these counties had a somewhat heller performance with respect to all (our nioittihn
rates
For the Mike of precision, we base expressed all rates im a per-capila husis lo six decimals
For example the IMR of the nuclear counties would have been Ol.iM.'- instead ol 01J6J5 if its
1^65-W rale had undergxtne the lame ratio of change (.38il3l repi'rled for the nonnuclear loiin-
lies. Is the difference between this 'expected ' ' rule and the observed actual rate 1 0(105 40t
significant? The answer is given by the formula for the standard deviation i a t of the
difference between two sample rales:
0 r,- r. =l(r,) II -r.) + (r.l 1 1 -~l
"in n
where r, is the expected rate, ri is the observed rate, and n is lite number of deaths involved in
the calculation of the monalitv rate
If'f see from rows 6, 7 and 8 above that the pntbabilirv of securing h\ chance alone a diver-
gence between the expected and observed IMR as great or greater than . 0(10540 is aboui 22
percent Bx' itself, this cannot be regarded as a significant divergence Similarlx . the ' i hance
probabilities of securing the obserx-ed divergences m the fetal and cancer morialilv ratcx are
respectively 19 percent and 26 percent, each being high enough to be regarded ax the pnssihle
product of chance But since each of these three rales are comfilciclx oulepeiidcni . wc can ask
what is the probabilitv thai all three divergences are simultaneously the product ofihuncc' The
answer, given bx multiplying the three independeill probabititiex tx .0106. which is about one
chance in one hundred.
This is in agreement with the vers low chance probability t.0162) of securing the ohserxed
divergence in the total monalirv rale, which of course includes infant, fetal, and cancer deaths
Thus, we haxe two pieces of evidence lo suggest thai there are less than two chancer out o( one
hundred for the following statement to be false In the period I97s~82 there txas xome exln. (one
of mortality present in the nuclear counties not opermmg m ihe ntinnuclcar * ouiilics
clear counties included. Extending the
definition of nuclear counties possibly
affected by radioactive rainfall might,
for example, double the number of
deaths involved. If Ihe divergence be-
tween observed and expected rales re-
mained the same, the significance of Ihe
results would be increased by 40 percent
(i.e.. by yi).
If the more current experience in Ihe
eighties is included, more significant di-
vergences in the cancer rales can be ex-
pected. Based on only a few years in the
early seventies, the cancer rale diver-
gence in Table 6 is seen to be the least
significant, if nuclear emissions in the
seventies do result in elevated cancer
rales, such effects will more likely be
seen in the next twenty years.
A more detailed, properly financed
study w(3uld, of course, try lo account
for other environmental factors and al-
low for adjustments for changes in age.
sex, and race required by proper bio.sta-
tistical procedures. These results, in
CEP's opinion, would illuminate the
main thrust of these findings.
It is clear that emissions in the nuclear
counties have had an adverse impact on
mortality, particularly on Ihe very
young and very old It will be noted that
Ihe total mortality rate (TMR) regis-
tered in the nuclear counties had the
smallest likelihood of boinp due to
chance. This rate mainly reflects the
deaths of persons over 65 years of age.
But infant and fetal deaths arc alinoM
Continued pane V
514
TABLE 7: REACTORS AND LOCATIONS
TOTAL
REAcroa
B/P EHISSIOHS
LOCATION
COUNTIES INCLUDED |
1974-61
lig Rock Point
B 3.34E»05
4 iiles NE of Charlevou, ni
HI;
CharlevoH, Chetoygan, Ettett
Iromi's Ferry
B 1.04E«06
10 iiles Ml of D«catur, Al
AL.
Laurence, Hadison, Horgan IN: Franklin, Lincoln
trunsvick
B 1.0«E«IK
20 iiles S of NiliinQton, NC
NC:
Duplin, Net Hanover, Onslot, Pender
Cooper
B 1.03£»05
70 iiles S of Ouha. NB
lA:
NI:
Fretont, Hills
Cass, 'Douglas, Lancaster, 'Sarpy, 'Nashington
Crnden 1,2(3
B 3.9;E»06
14 iiles SN of Joliet, IL
IL:
Cook, DuPage, lendall, Nill IN: Lake
Duane Arnold
B 2.42Et04
8 iiles NN of Cedar Rapids, U
lA:
Benton, Buchanan, Delanare, Dubuque, Linn
fdnin I. Hatch 1 1 2
B 7.47E»04
11 iiles N of lailey, U
GA:
Appling, Candler, latnall, Tootbs
Huiholdt Bay
B 9.62E«05
4 iiles SN of Eureka, CA
CA:
Del Norte, Hutboldt, Siskiyou, Trinity
Jttes 4. Fitipatrick
1 3.58E»05
U iiles N of Syracuse, NT
NT:
Jefferson, «Osiie90, St. Laurence
La Crosse
B 3.0IE«05
19 iiles S of La Crosse, NI
NI:
Buffalo, Jackson, La Crosse, Honroe, Tretpealeau
Hillstone 11 t 2
8/P 5.63E+06
3.2 iiles NSN Nea Lomton, CT
CI:
Ne« London RI: lent. Providence, Nashington
Honticello
B 1.7tf«06
23 iiles SE of St. Cloud, HN
NN:
letton, Isanti, Horrison, Sherburne
Nine Hile Point
B 2.04E«0«
8 iiles NE of Osvego, NY
NT:
Lenis, (Osiiego
Oyster Creek
B 2.92E«06
9 tiles S of Tois River, NJ
HJ:
Hiddlesei. Honiouth
Peach Bottot
B 5.S3E»05
17.9 iiles S of Lancaster, PA
PA:
lerkes, Lancaster, •Lebanon
Pilgrii
1 1.27E*06
25 iiles SE of Boston, NA
HA:
Norfolk, Suffolk
Quad Cities
B 1.24£»06
20 iiles NE of Noline, IL
IL:
Carroll, Nhiteside lA: Clinton
VerioDt Tankee
B 9.23E«04
5 iiles S of Brattleboro, VI
NH:
Cheshire, Sullivan VT: Nindhat
fort St. Vrain
B 2.2«E»02
35 iiles N of Denver, CO
CO:
Adots, Boulder, Denver
Arkansas 1 ( 2
P 9.68E*04
6 iiles WW lussellville, AR
AR:
Connay, Johnson, Neiiton, Pope, vjn Buren
6ea»er Valley
P 3.0«E»03
Shippingport, PA
PA:
Beaver, Butler, Laurence
Calvert Cliffs
P 8.24E»04
45 iiles SE of Nashinqton, DC
NH:
Cilvert, Charles, Dorchester, Prince Georges. St. Harys
Talbot
Crystal River
P 1.59E*05
70 iiles N of Taipa, fl
FL:
Alachua, Gilchrist, Narion, Putnat
Davis Besse
P 9.41E«03
21 iiles E of Toledo, OH
HI:
Honroe OH: Lucas, OttoKj
Donald C. Cook
P 7.34E»04
11 iiles SSN of St. Joseph, HI
IN:
La Porte, St. Joseph HI: Berrien, 'Van Buren
fort Calhoun
P 1.01E«04
19 iiles N of Oiaha, Nt
lA:
NB:
Harrison, Pottatattatie
•Douglas, 'Sarpy, Saunders, 'Nashington
H.B. Robinson
p i.mm
4.5 iiles NN of Hartsville, SC
NC:
Anson SC: Chesterfield, Darlington, Harlboro
Haddai Neck
f 1.62Et04
10 iiles SE of Hiddletovn, CT
CT:
Hiddlesei
Indian Point 1,243
P 9.l8Et04
3 iiles SN of Peekskill, Nr
NY:
Rockland, Nestchester
Josepti «. Farley
P 2.61E«04
Dothan, AL
AL:
Btrbour, Geneva, Henry, Houston GA: Early
leaaunee
P 1.05E»04
27 iiles ESE of Sreen Bay, NI
NI:
'Iroan, Door, 'Keaaunee
tUine rankee
r I. Him
3.9 iiles S of Nicassett, M
HE:
(ennebec, tnoi, Lincoln, Htldo
NcGuire
f O.OOEtOO
17 iiles N of Charlotte, KC
NC:
SC:
Cabarrus, Cataaaba, Gaston, Hecklenberg, Roaan, Union
York
North Anna
P 3.02E»04
40 iiles W of Richiond, VA
VA:
Caroline, Hanover, Henrico, (ing Nilliat
Oconee
P 2.41Et05
30 iiles N of Sreenville, SC
SC:
Greenville, Oconee, Pickens
Palisades
P 6.23Et03
5 iiles S of South Haven, HI
HI:
Allegan, Cass, (alatazoo, •Van Buren
Point leach
P 5.94E»04
IS iiles N of Hanitoaoc, NI
NI:
•Broan, •Keaaunee, Hanitoaac
Prairie Island
P 7.21E*03
2i iiles SE of ninneapolis, HN
NN:
NI:
Dakota, Goodhue, Hennepin, Ratsey, Scott, Nashington
Pierce, St. Croii
RE. Ginna
P 2.30E»04
16 iiles NE of Rochester, NT
NY:
Honroe, Nayne
Rancho Seco
P 2.11Et04
25 iiles SE of Sacraeento, CA
CA:
Aiador, El Dorado, Sacratento
Salei 1, 2
P 2.03Et03
20 iiles S of Hiliinqton, DE
DE:
Nea Castle HJ: Cuiterland, Salei
San Onofre
P 7.37E«03
2.5 iiles S of San detente, CA
CA:
Orange, Riverside
Sequoyah
P 1.20ft04
Diisr, TN
IN-
Hatilton, Heigs, Rhea
St. Lucie
P 1.04E«05
8 iiles S of Ft. Pierce, FL
FL:
Indian River, Okeechobee, St. Lucie
Surry
P 7.94E»04
19 tiles NN of He*port Nevs, VA
VA-
Charles City, Surry, York
Three Hile Island 1,2
P I.OIEW
10 tiles SE of Harrist-urg, PA
RA
SchuykiU, Dauphin, 'Lebanon, Nor thutber land
Frojan
P 6.52Et03
3S tiles NN of Portland, OR
OR
Coluibia, Hultanotah NA: Clark, Coaht;
Turkey Point
P 9.96Et04
10 tiles E of Florida City, FL
FL
Bronard, Dade
rankee Ro«
P 1.29E»03
20 iiles Ml of Eretnfield, HA
NA
franklin NH: 'Cheshire VT- 'Nindhat
Hon
P 3 12E«05
6 tiles H of Naukegan, IL
IL
lake NI: (enosha, Racine
•Counties close to tore
than one reactor.
515
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Council on Economic Priorities
NEWSLETTER
Edilar-ia-cM«f : Alice Tcpper Marlin
Editor: Paula Lippin
The Council on Economic Pnorilies is a non-profii organization established to disseminate unbiased
and detailed information on the practices of US. corporations. These practices have a profound im-
pact on the quality of American life. CEP was established so that the American public could become
■ware of this impact and work to ensure corporate social responsibility. CEP publishes i-^ Studies
and/or Reports per year, and a Monthly Newilelter. Memberships and contributions are lax-
deductible. Indexed in Public Affairs Information Service Bulletin. Excerpts welcomed. Please credit
the Council on Economic Priorities. 30 Irving Place. New YotL. New York 10003. and send us a
CODY ISSN 11-193-4066
For Further Reading
Quality Of Life In American Neighborhoods: Levels of Affluence, Toxic Waste
anil Cancer Mortality In Resitlenlial Zip Code Areas. Jay M. Gould. Westview
Press. 1986 See also CEP Newsletters "Toxic Waste and Cancer: The Link is Getting
Stronger." Sept. 1984; "Freedom of Information Acl: Breaking the Federal Barrier."
June 1985; "Toxic Waste tn Chesapeake Bay: Bad for People as Wfell as for Fish.'" Nov
I98.'i
Maternal and Child Health Data Book, Children's Defense Fund. Washington. DC.
1986.
Radioactive Materials Released From Nuclear Pliwer Plants, 1981, J Tichler and
C. Benkovitz. Brookhaven National Laboratory. 1984
Measurement of Low Levels of X-ray Mutagenesis in Relation to Human Disease,
C. Waldien. L Cortell. MA Sognier. T.T Puck, July. 1986, Proc US Natl Acad-
emy of Science The data obtained by these investigators, using a new laboratory
technique involving individual human chromosones implanted in animal cells, show
thai the effect of low dose radiation exposures is more than 2(X) times greater than had
previously been assumed on the basis of high dose studies.
This IS a pan of a rapidly growing body of clinical literature on ionizing radiation
effects which can be secured from the Health and Energy Institute in Washington.
DC The detailed annual mortality date for the 175 counties studied here can be
obtained on a personal compuler diskette Iroiii Public Data Access Inc., 30 Irving
Place, New York, NY 1(XX)3 (212-529-0890) PDA can assemble diskettes with
mortality rates for any desired group of states or counties in great detail, and in any
desired mode, such as Wordstar, Lotus, or DBase 111
ImiTiedialely responsive to the lethal ef-
fects of radioactive Iodine included in
the emissions Table 5 shows that the
greatest adverse change in the infant and
fetal mortality rates was registered by
those counties close to boiling water re-
actors These counties had emission
rales of 1.6 curies per capita as against
0.6 curies per capita for the pressurized
water reactor counties in the 1975-82
period
There is little point at this early stage
in the investigation to attempt to quanti-
fy the extent of the adverse impact since
we do not yet have a satisfactory delinea-
tion of all the nuclear counties affected
by both civilian and military reactors. In
Table 7, the 175 counties adjacent to each
civilian reactor which we have chosen as
nuc/ear counties for this Newsletter are
listed. Almost certainly, there are sev-
eral hundred more that could be includ-
ed among those directly or indirectly af-
fected by emissions from bolh civilian
and military reactors. It is CEP's hope
that environmental organizations
around each reactor will . on reading this
Newsletter, share with us their knowl-
edge or even suspicions about those
counties omitted from our preliminary
definitions. By adding counties with a
lesser impact, the average divergence in
mortality rates from those in nonnu-
cleariKis will be narrowed_The addi-
tional deaths, however, will make our
findings more significant statistically
and can lead to a more precise quantifi-
cation of the number of excess deaths lo
be attributed lo emissions. Until then,
the estimate of an excess 9000 deaths
per year derived from this analysis of
nuclear states can stand as a prelimir
nary overall estimate.
It is also clear that CEP's estimates of
the public health impact of radioactivity
and other environmental abuses such as
toxic waste can be made far more pre-
cise by allowing for differences due lo
age. sex, and race. Computer tapes
from the National Center for Health Sta-
tistics are now in CEP's possession.
From these tapes, the mortality rates for
each county, since 1968, for all white
and nonwhite males and females, by age
group and for several hundred detailed
causes of death can be calculated Use of
this extraordinary database, a tribute to
the work of statisticians and epidemiolo-
gists of the National Center, will make it
possible to pinpoint those groups in our
population bearing the brum of the
loss of lives from all environmental
abuses. ■
516
55b
(fi^e^</„c 0)
THE L-^NCET, .\UKCH 7, 1987
Letters to the Editor
CANCER NEAR NUCLEAR INSTALLATIONS
Sir. — Comprchoisivc inlbrmalion on the frequency- of cancer in
local authorip.' arrd^ in 'jie vicinity of fifrcen nuclear installauons m
England and \\'aie* has recently been made available to the public'
Ab you sav in \our n^-te last ucek (Feb 28, p 520) of particular
interest is the inciiience of leukaemia in 0-2-1-year-olds, since an
excess inadence r,2s been found near Scllafield in west Cumbria'
and near Dounreav '
STANDAlUMsa;' INCIDENCE .\ND MORTALITT R.\TIOS FOR
LEUKAEMIA AND ALL CANCERS IS PERSONS AGED 0-24 l^EARS IN
Locu- Atrnn'K; r^' areas in England .\nd wales tith at
LE.-<STOS"t-TH:BD OF THfclR POPULATION LIVING WITHIN 10
MILES OF NUCL£.\R INSTALLATIONS INCLLT)ED INOPCS REPORT
(LXCtI'I"SEU_\.'-!£La AND IN CONTROL AR£.\S FR0MT.\BLE2 IN-
OPCS RETORT
.'and number ol
cases;
foryeais:
—
|a95a-65t l«*-70
1971-75 ; 1976-60
All
Inci^iHC*
s
1
1
Leukaemia
I
All inslalbuonsi
"107 //// KH'l?-<.
112 ili- \ni'
■/W;
lll-fi5«;
Cintrol aras
w.»j 1 8<)-;';9
104'JJ«.| 97
;.W/
97 (501/
All cancers
1
All insullaiKms
iiy. 5;;.iio3'«;.'/
|1I0-.6J9 ;112-
(.71.
ioo 12122:
CuncrpI areu.
. .-.5 J-)/; :io2.«-'3.
100 • ■«« [ 103
fif.,
AW(j/t/v
i
1
Leukaemia
■' 1
'
All insutlations
<4 W: llW/J-f/
111 ;3S:l 96
W;
102 lilSi
Contrpl arou
■ iij./i(. «)•;;■"
,114 M/.ilOT
;;o.
]I06 isni
1 99 il42»i
Alt cincers
!
! i
All instalUions
tl'i^t. WXJ
101 Ji^'lOO
J9J,-
Control areas
"S i-'m 97 m
:iOI i-H 1 97
m.
1 9S itUti
•p<0l>5. ••p'--001
•;«M-r4:.M-urad<Rcc(lni tAll occpt Sdiandd
The accc>mp;iir:~^.£ uible r>ho«s for aJl ihe insuilaiions included
m the OPCS rrrcn. Except ScUafieid, and fur coirt-ipondLng
conu-ol areas the :cii! iT-ciJencc and mon2lir> ri::os tor leukaemia
and aJl cancers j: jge C^24 yezrs. The figures include die four time
penods for u h:ch doa were provided and all the arras sclcaed by
OPCS for study. O^Tthe whole study period there is a significant
excess incidence of liLtcaemia and of all cancers in areas in the
vicinit>' of the installations, but not in the control areas. The
exclusion of leukaemia from the all -cancer inadence figures for the
installations leav^ a sr^nificinily increased ratio of 107, based on
1862 registratiiTis. Considering each ame period separately,
leukaemia inadence is iigniiiczndy raised only m 1976~S0, and the
all-cancer inadence in WTl-TS and 197<>-S0. The number of
oncers near any one installauon is generally small and no
installation can be sinded out as diffchns signitlcandy from the
others. In contrast to the incidence daa, none of the mortality ratios
differs s:5ni:"icantly firom 100.
The disa-trar.c\' bet^veen lHc incidence and morrality findings is
importuiu. and the reasons for it will need to be clarified. Some
posiibilicics include; canoa retpsaraoon nught be more complete or
cancer survival bencr m the vicinir." of nuclear establishments than
elsewhere; there might be ditTcrenaat migranon away from nuclear
instjllauons once a child is diagnosed as having cancer; or the
increase in cancer inadence might be too recent to be reflected in
mortabry siadsr.cs. To establish which, if any, of these possible
explanauons is valid will require detailed investigation.
The estimated magnitude of the overaU risk is not largfr — an 1 1%
excess for leukaemia incidence and an 8% excess for all-cancer
incidence. The^e figures apply lo people living within roughly a 10
mile (16 km) radius of the installauons. The OPCS data provide
only crude infonmation on the reladon between nsk and distance
from the installations. This is because the smallest geographical unit
studied was the local authont\ area, whose breadth is often more
than 10 miles, especially in the njral distrias where most nuclear
installauons are located. For detailed assessment of risk in relation to
distance from the installations u will be necessar>- to study smaller
geographical areas, as has been done elsewhere.' ■*
The data in this report do not go beyond 1980, yet statistics for
later years should now be available. It is imponant to know whether
the findings noted here persist.
Epidcmiotugiol .Mi<ni(t.>rLnB Unit,
anJ Tropical .\l«licuic,
Loodw»ClE7MT
VaLEKIL BER.AL
I Ctv'V-MozalTan PJ, Vincent T, Fomun D, Ash^ood FL. .\ld«v« M. Cukct
incidence ami nv»T;i 1 1 r\' in ih^ t'iCTnic>*ornucl«iv LnitalUbori. EngLmd and Vt'jln,
1950-W> ;5(mJ .\I.-J Popi^ S:Ai no 51 ' London H.M Sucorer> OfTioe. I«R7
2. Invemgjnon of iheposwbk increased tnodenceofoncermwet Cumbria Repoaot
(he InJcpcnJcnt AJviion Grvup (chaimun, Sir Dc^gU» Black; Ijxidon. H.M
Suiioofp. OfTice, 19W
3 HcuiTun SW, Kemp IW, L'nquan JD, Black R. Ouldhood leuScacmta in noirhcm
Scodand. Umui 14&6i i: 266.
4. Roman E, BenI V, Carpcnier L, Wanon A, Banon C, R>der M, Aitgn OL.
Oiidhood Icukjcmia in (he Wcm Bcrk^hirr and the Basingstoke and North
Hampshue diMria health juthonne^ in felatjon lo nudnr oabUthmenti m the
\-iQnity. Bf SUdJ \.\i\ pteu)
517
SUMMARY OF ENVIRONMENTAL HEALTH EFFECTS
FROM NUCLEAR PLANTS
Leukemia Other In+ant Fetal Congenital Down Wind
Cancer Mortality Mortality Defects or Coastal
Windscale, Y N ? Y
Engl and
3 coastal Y ? Y
Scotland
San Onofre N? N? N? N
Calif.
Rocky Flats Y Y Y? Y? Y Y
Colorado
Hanford N? Y? Y
Wash.
T.M.I. ? Y? Y Y? Y
Penna.
All Plants Y Y
Wi sconsi n
Yankee Y Y
Mai ne
Pilgrim I Y Y
Mass.
Prepared 7/30/36 by Sidney Cobb MD , Pro-f Emeritus o-f Community Health
in Brown University Program in Medicine. The opinions expressed Are his
not necessarily those o-f the original authors. No claim to completeness is
made.
The tentative conclusion is that where there is so much smoke there must
be some fire. In other words it now seems quite likely that there is some
hazard to human health from living down wind of some nuclear plants. To
determine just how much of what conditions and under what circumstances
is the research task for the future.
518
AhreriB R, et al . Letter to the Editor. NEJM 5/22/ 1980; 302: 12U5-6
HariDi^tJ . Ivijffian E. F'lvder HM, Wstson A. Childhood leulemia in West
Berkshire., Lancet »1 983; 2: 1243-9.
ft X « » 1
BEIR III.' Ihe E-fi'ects o-f E;-cposure to Low Levels o-f lonizinq Radiation:
1980^ 1980. Wasl-i DC, Nat Acad Press.
bertell R, Jacobson N, Stoqre M. Environmental influence on survival of
low birthweiaht infan-t:.s in Wisconsin 1963-75. Internat Persp Pub Health
1984; l! 12- 24.
Bertell R. Handbook -for Estimating Health E-f-fects from Exposure to
lonizinq Rcsdiation. Aug 1934 Inst of Concern -for Pub Health lororrto
Canada.
» » * i
Ue/ea J. A Review o-f Dose A^isessments at i HI and Recommendations for
Future Research. 1984. Philadelphia. TMI Pub Health Fund.
*«-s tt
Black, Sir Uouglas, Investigation o-( the Possible Increased Incidence
of Cancer in West Cumbria. 1984. London, HHBO.
Brcsck HC, Edit. A Review o-f Radological Surveillance Reports o-f Wat,te
EF fluents in Marine Pathwavs at the Maine Yankee Atomic Power Company at
WiKcasset, Ha-i tie -- 1970-1984; An Annotated Bibliographv including data
■for r-eactor -der 1 ved isotopes characterizing high-level and transuranic
ij£i=tes. 1986 Hulls Cove, Maine. Pennvwheel Press.
Bunvard F' , Sear 1 e w. Ihe ef-fects o-f low dose rndiatiori. tcologist
1936; 16: 1/ J 81.
K-IC-S-K
Ounvar d P. Hie Sellafield Discharges. Lcclogist 1986; 1 6: i4/ 5) 182- 8.
»«)<*
Cannonsbui g PA This file contains an a-ftidavit bv JW Co-fman, 1983; an
Environmental Impact Statement. 1983; notes bv DW Boardinan . 1936; and
vai- i oils miscelaneous items and news clippings.
K It » s
Carlo G, Hogue Carol. Studv on -fetal mortality in Pope Co., Arkansas,
presumablv related to Nuclear Une. Report >-ias released by the Ark.Dopt.
of Healtki aboi.it Oct. 1979
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524
statement of Coimissioner James K. Asselstine
U.S. Nuclear Regulatory Conmission
before the
Subcommittee on Energy Conservation and Power
Committee on Energy and Conmerce
May 22, 1986
Mr. Chairman, I disagree in many respects with the Conmission' s testimony
on the impact of the Chernobyl accident. Now that the Chernobyl accident
has turned the spotlight onto the safety of the U.S. nuclear power
reactors, the Conmission would have the Congress and the public believe
that the U.S. plants may be five times safer than estimated just a few
months ago, that the U.S. plants are far safer than the Commission's
provisional safety goals, that the U.S. plants are much safer than believed
when the Conmission deemed the severe accident risks to be acceptable last
year, and that the consequences of a core meltdown in the U.S. are "very
different" than the consequences of a core meltdown in the Soviet Union.
Indeed, the Commission now seems to believe that the TMI inspired backfits,
which many argued before Chernobyl to have questionable if not negative
impacts on safety, have turned out to be very positive contributors to
safety. Before Chernobyl, those "undisciplined" TMI backfits served as
part of the basis for the promulgation of the Conmission's backfit
rule, which erects a substantial barrier against efforts to improve safety.
After Chernobyl, the Commission and the nuclear industry find that those
TMI backfits have provided substantial improvements in safety. Finally,
according to the Commission, apart from finding that the light water
reactors in the U.S. cannot have large graphite fires, it is premature to
525
draw conclusions regarding the ramifications of the Chernobyl accident for
our nuclear power program.
Mr. Chairman, by focusing on the design differences between the Soviet
plants and U.S. plants, the Commission misses the broader lessons of the
Chernobyl accident for nuclear safety in the United States. Those broader
lessons have to doj«1th the acceptability of core meltdown accidents and
the adequacy of our current efforts to prevent such accidents and to
minimize their consequences should one occur. I want to start with what I
think are three Inescapable conclusions regarding the risk of core meltdown
accidents In the United States.
n y First, unless further steps are taken to reduce substantially the likeli-
hood of a core meltdown accident, we can expect to see such an accident at
a U.S. plant within the next 20 years. This conclusion is supported by the
probabilistic risk assessments done for U.S. plants to date, by the
substantial uncertainties in those assessments. Including their limited
ability to account for human performance and external accident Initiators,
and by recent operating experience with the plants which shows that at
least some PRA assumptions are overly optimistic. As the Comnission's
chief safety officer noted recently, serious operating events illustrate
that In the real world, system and component reliabilities can degrade
below those we and the Industry routinely assume in estimating core melt
frequencies.
526
- 3 -
Second, as Is apparently the case with the Soviet reactors, our reactors
were not designed for large-scale core meltdown accidents. Because such
accidents were assumed to be so unlikely as to be incredible, they were
judged to be outside of the design basis for the plants. One consequence
of this assumption is that U.S. reactor containments were designed to
withstand the rupture of a large steam pipe but were not designed to
withstand large-scale core meltdowns.
i Third, although we believe that all of our reactors have some capability to
withstand severe core meltdown accidents, the extent to which they can
withstand such accidents depends upon the sequence of events during the
accident, the individual plant designs and the manner in which each plant
is operated and maintained. While we hope that their occurrence is
unlikely, there are accident sequences for U.S. plants that can lead to
rupture or bypassing of the containment in U.S. reactors which would result
In the off-site release of fission products comparable to or worse than the
releases estimated by the NRC staff to have taken place during the
Chernobyl accident. That is why the Conmisslon told the Congress recently
that It could not rule out a commercial nuclear power plant accident in the
United States resulting In tens of billions of dollars in property losses
and injuries to the public. The bottom line is that, given the present
level of safety being achieved by the operating nuclear power plants in
this country, we can expect to see a core meltdown accident within the next
20 years and it is possible that such an accident could result in off-site
releases of radiation which are as large as, or larger than, the releases
estimated to have occurred at Chernobyl.
V.
527
4 -
My point Is that large power reactors. In this country and abroad, are not
Inherently safe. Each design has Us own core meltdown vulnerabilities.
If nothing else Chernobyl should remind all of us that core meltdown
accidents can happen and, even assuming evacuation Is successful, that the
resulting releases can leave largetracts of land and buildings highly
contaminated.
To me, the lessons of Chernobyl are simple and straightforward. Given the
uncertainties in containment and plant performance, the occurrence of a
severe core meltdown accident over the next 20 years is unacceptable. That
was the judgment of the President's Commission on the Three Mile Island
Accident six years ago, and it is no less true today. We should return to
the safety philosophy espoused by the Kemeny Comnlssion at that time — to
pursue all practical measures both to prevent core meltdown accidents^rom
occurring and to minimize their consequences should one occur. This safety
philosophy is fundamentally at odds with the Commission's decision in the
Indian Point Special Proceeding, with the Severe Accident Policy Statement,
with the Commission's backfit rule and with the Conmisslon's provisional
safety goal. It is also at odds »(1th the passion for deregulation that has
been sweeping the nuclear Industry and the Conrilssion over the past two
years.
Many other countries have and are _tak1^ng U.S. -developed technology and
minimum safety standards, and building on them to have better nuclear
plants with greater defense-In-depth than that being achieved in this
country. These other countries have better designed plants that are
528
5 -
operated and maintained better than the U.S. plants and that are safer than \
the U.S. plants. They have achieved a far better state of affairs with
respect to reliability and safety of their plants than this country has.
And, they have accomplished this in a disciplined manner at reasonable
costs. While we are looking at foreign safety experience In the aftermath
of the Chernobyl accident, we should consider following their example.
Thank you.
J
529
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531
The Chairman. Our final panel this evening is comprised of the
people who make the decisions, Nuclear Regulatory Commission
and the Federal Emergency Management Agency. We heard a
great many serious concerns, voices, this evening about the way in
which the NRC and FEMA are regulating the Pilgrim plant, are
planning for emergency preparedness. Here this evening to respond
to these questions is Dr. Thomas Murley, director of the NEC's
Office of Nuclear Reactor Regulation. Along with Dr. Murley is Mr.
William Russell, NRC's regional administrator. Also on the panel
are the representatives from FEMA, Mr. Richard Krimm, the as-
sistant associate director of FEMA and Mr. Jack Dolan from
FEMA Region Number I. And I'm anxious to hear from you, gen-
tlemen, in response.
First of all, we'll hear from Mr. Krimm
STATEMENTS OF RICHARD KRIMM, ASSISTANT ASSOCIATE DI-
RECTOR OF FEMA; DR. THOMAS MURLEY, DIRECTOR OF THE
NCR'S OFFICE OF NUCLEAR REACTOR REGULATIONS; WILLIAM
RUSSELL, NCR'S REGIONAL ADMINISTRATOR, REGION I; AND
JACK DOLAND, FEMA REGION I
Mr. Krimm. Thank you very much.
The Chairman. They have been sworn in.
Mr. Krimm. My name is Richard Krimm. I'm the assistant asso-
ciate director of the Federal Emergency Management Agency re-
sponsible for the development and management of FEMA's pro-
gram related to technological and natural hazards. These programs
include radiological emergency planning [REP] around nuclear
powerplants, as well as planning for hazardous materials incidents,
earthquakes, dam safety and hurricanes. Accompanying me is Mr.
Jack Dolan, FEMA Region I, Boston, and Mr. George Watson, from
our Office of General Counsel.
The primary concern of FEMA's REP program is the health and
safety of the public around nuclear power plants. FEMA works to
achieve this goal through an evaluation of plans and preparedness
under the FEMA regulation. The evaluation process includes par-
ticipation by regional assistance committees, [RAC] chaired by
FEMA, and includes nine other Federal agencies.
The RAC reviews State and local plans against published crite-
ria, and agency representatives give advice on their particular area
of expertise. The published criteria were developed jointly by the
FEMA and the NRC with full public participation and contains all
the established Federal criteria for developing, reviewing and eval-
uating radiological emergency, planning and preparedness for com-
mercial nuclear powerplants.
Ultimately, the plans are reviewed and approved at FEMA head-
quarters. Following approval, FEMA notifies the NRC and the Gov-
ernor and publishes a notice in the Federal Register. This is done
only if a determination is made following appropriate plan exer-
cises that there is reasonable assurance that the public health and
safety can be protected in the event of a radiological emergency at
the plants.
Let me just briefly discuss Pilgrim. In a series of meetings with
the Commonwealth and the local communities in the spring of
532
1986, FEMA identified problems with the Commonwealth's emer-
gency response plan. Based on issues raised at these meetings and
information received subsequently, FEMA decided to conduct a
review of the emergency response plan and preparedness for the
Pilgrim nuclear power station, and so informed the Commonwealth
in a letter to the Massachusetts Civil Defense Agency on Septem-
ber 5, 1986.
On December 22, 1986, the Secretary of Public Safety, Charles
Barry, forwarded to FEMA a copy of the report to the Governor on
emergency preparedness for an accident at the Pilgrim Power Sta-
tion. This report stated that the Massachusetts plan and its pre-
paredness are inadequate to protect the health and safety of the
public in the event of an accident at the Pilgrim nuclear power sta-
tion. In the course of its self-initiated review, FEMA treated this
report as the authoritative and current position of Commonwealth.
On August 6, 1987, FEMA transmitted to the Commonwealth of
Massachusetts and the NRC its report entitled, "Self-Initiated
Review and Interim Finding for the Pilgrim Nuclear Power Sta-
tion." The report was provided to the Commonwealth and NRC
pursuant to the regulation and identified six areas of major con-
cern.
These are lack of reception centers for people evacuating to the
north; lack of evacuation plans for public and private schools and
day-care centers; and lack of identifiable public shelters for the
beach population; inadequate planning for the evacuation of the
special needs population; inadequate planning for evacuation of the
transport dependent population, and overall lack of progress in
planning in emergency preparedness.
Based on the Self-Initiated Review and Interim Finding, FEMA
concluded that Massachusetts offsite radiological emergency plan-
ning and preparedness was inadequate to protect the public health
and safety in the event of an accident at Pilgrim. The current
status of this when we translated the Self-Initiated Review to Mas-
sachusetts, we suggested that they work with us to develop a plan
and schedule to correct the inadequacies in their plan. The Com-
monwealth has not yet developed such a work plan as scheduled.
However, since the issuance of the new interim finding and the
publication of FEMA's Self-Initiated Review and Interim Finding
on Pilgrim, the Commonwealth of Massachusetts has taken action
to address some outstanding issues.
FEMA looks forward to working with the Commonwealth and af-
fected communities in order to achieve our common goal of protect-
ing the public health and safety.
We are prepared to respond to your questions, Senator Kennedy.
[The prepared statement of Mr. Krimm follows:]
533
STATEMENT BY RICHARD W- KRIMM
ASSISTANT ASSXIATE DIRECTOR
OFFICE OF NATURAL AND TECHNOLOGICAL HAZARDS PROGRAMS
STATE AND LXAL PROGRAMS AND SUPPORT DIRECTORATE
FEDERAL EMERGENCY MANAGEMENT AGENCY
BEFORE THE
COMMITTEE ON LABOR AND HUMWJ RESOURCES
U.S. SENATE
IN PLYMOUTH, MASSACHUSETTS
JANUARY 1, 1988
534
My name is Richard W. Krimm. I am Assistant Associate Director of
THE Federal [lmergency Management Agency (FEMA) responsible for the
DEVELOPMENT AND MANAGEMENT OF FEMA's PROGRAMS RELATED TO TECHNOLOGICAL
AND NATURAL HAZARDS- ThESE PROGRAMS INCLUDE RADIOLOGICAL EMERGENCY
PLANNING AROUND NUCLEAR POWER PLANTS, AS WELL AS PLANNING FOR HAZARDOUS
MATERIALS INCIDENTS, EARTHQUAKES, DAM SAFETY AND HURRICANES- AlSO, AS
office director, i chair the federal radiological preparedness coordinating
Committee (FRPCC) which includes officials from the Departments of Energy, .
Commerce, Health and Human Services, Transportation, Agriculture, Interior,
Defense, the Environmental Protection Agency and the Nuclear Regulatory
Commission- In addition, I co-chair with the Nuclear Regulatory Commission
(NKC) monthly meetings of the FEMA/NRC Steering Committee- These two
committees, at the National level, deal with policy matters related to
offsite planming and preparedness at commercial nuclear power plants
across the country-
i am pleased to appear before you to represent the federal emergency
Management Agency and to discuss the Radiological Emergency Preparedness
(rep) program, as it relates to offsite emergency planning in the plume
exposure emergency planning zone for the pilgrim nuclear power station-
Accompanying me is Mr- Jack Dolan, FEMA Region I, Boston and Mr- George
Watson from our Office of General Counsel-
Before discussing Pilgrim specifically, I would like to outline the context
OF PROGRAM PROCEDURES AND PHILOSOPHY IN WHICH THE PiLGRIM SITUATION HAS
unfolded- The primary concern of FEMA's REP program is the health and safety
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535
OF THE PUBLIC AROUND NUCLEAR POWER PLANTS- FEMA WORKS TO ACHIEVE THIS GOAL
THROUGH AN EVALUATION OF PLANS AND PREPAREDNESS UNDER THE FEMA REGULATION
44 CFR 350- This FEMA process, governed by the regulation, primarily involves
A FORMAL submission BY THE GOVERNOR. OR HIS/HER DESIGNEE. OF THE STATE AND
LOCAL PLANS FOR THE EMERGENCY PLANNING ZONE (EPZ) AROUND A SPECIFIC NUCLEAR
POWER PLANT. ThE EVALUATION PROCESS INCLUDES PARTICIPATION BY A REGIONAL
Assistance Committee (RAC). chaired by FEMA. which includes, at the Regional
LEVEL. THE SAME AGENCIES I MENTIONED AS BELONGING TO THE FRPCC
The RAC reviews the State and local plan, against published criteria (NUREG-0654/
FBIA-REP-l. Rev. 1). and agency representatives give advice on their particular
areas of expertise. The published criteria were developed jointly by FEMA and
NRC WITH FULL public PARTICIPATION AND CONTAINS ALL THE ESTABLISHED FEDERAL
CRITERIA FOR DEVELOPING. REVIEWING AND EVALUATING RADIOLOGICAL EMERGENCY
PLANNING AND PREPAREDNESS FOR A COMMERCIAL NUCLEAR POWER PLANT EMERGENCY.
The PUBLISHED CRITERIA CONTAIN 16 MAJOR PLANNING STANDARDS. WHICH ARE FURTHER
BROKEN DOWN INTO 196 EVALUATION CRITERIA ADDRESSING SUCH ELEMENTS AS EMERGENCY
COMMUNICATIONS. PUBLIC WARNING. AND PUBLIC EDUCATION AND INFORMATION.
The APPROPRIATE FEMA Regional Office coordinates the planning review and
ASSURES that AN EXERCISE IS CONDUCTED TO ADEQUATELY TEST THE PLANS. ThE
Regional Uffice or State also conducts a public meeting to inform interested
PARTIES of the CONTENT OF THE PLANS AND WHAT WOULD BE EXPECTED OF THE PUBLIC
IN THE EVENT OF AN EMERGENCY AT THE PLANT- FEMA. THROUGH THE PUBLIC MEETING
FORUM ENSURES THAT THE PUBLIC INPUT IS CONSIDERED AND INCORPORATED INTO THE
DESIGN OF THE PLANS. WHERE APPROPRIATE.
536
In addition, FEMA also provides technical assistance to State and local
governments to enhance the overall planning and preparedness effort. as an
example, FEMA has frequently provided technical assistance TO THE Commonwealth
IN THE development OF PLANS PURSUANT TO OUR REGULATIONS- ANOTHER EXAMPLE OF
this is our training program, which includes courses in radiological emergency
response planning and accident assessment at the fbia national emergency
Training Center in Emmitsburg, ^Vvryland, and a course to train Radiological
Emergency Response Teams at the Nevada Nuclear Test Site. These courses are
PRIMARILY for StATE AND LOCAL OFFICIALS-
Ultimately, the plans are reviewed and approved at FEMA Headquarters- Following
APPROVAL, FEMA notifies the NRG and the Governor and publishes a notice in the
Federal Register- This is done only if a determination is made, following
appropriate plan exercises, that there is reasonable assurance that the public
health and safety can be protected in the event of a radiological emergency
at the plant. However, the process does not end with the initial approval.
The State and the affected local governments must continue to keep plans
updated and they must also participate in periodic exercises with the utility
as a condition of continued FEMA approval.
FEMA AND NRC HAVE also signed a Memorandum of Understanding (MOU), most
recently revised in April, 1985- This MOU calls for FEMA to supply NRC with
advice on offsite preparedness issues. Typically, under the MOU, FEMA provides
"interim* offsite safety findings that are used in licensing decisions made
BY THE NRC. These "interim" findings are a snapshot in time of the preparedness
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537
POSTURE AT A GIVEN SITE- It IS IMPORTANT TO NOTE THAT FINDINGS MADE UNDER
OUR REGULATION (44 CFR 350) OR INTERIM FINDINGS UNDER THE MOD ARE MADE ON
THE SAME BASIS^ THAT IS, UNDER THE PUBLISHED CRITERIA-
PlLbKIM
In a SERIES OF MEETINGS WITH THE COMMONWEALTH AND LOCAL COMMUNITIES IN THE SPRING
of 1986, fel^a identified problems with the commonwealth's emergency response plans-
Based on issues raised at these meetings, and information received subsequently,
FEMA decided to conduct a review of the emergency response plans and preparedness
for the Pilgrim IJuclear Power Station and so informed the Commonwealth in a
letter to the Massachusetts Civil Defense Agency (MCUA) on September 5, 1986.
On December 22, 1986, the Secretary of Public Safety, Charles Barry, fowarded
TO FEMA A COPY OF the "Report to the Governor on Emergency Preparedness for
AN Accident at the Pilgrim Nuclear Power Station" (hereinafter called the
Barry Report). This report stated that the Massachusetts plan and its
preparedness are inadequate to protect the health and safety of the public in
THE event of an ACCIDENT AT THE PiLGRIM NuCLEAR PoWER STATION- FEMA WAS
subsequently informed that the governor and the director of the massachusetts
Civil Defense Agency had endorsed the Barry Report- In the course of its
self- initiated review, fema treated this report as the authoritative and
current POSITION OF THE COMMONWEALTH-
On August 6, 1987, FEMA transmitted to the Commonwealth of Massachusetts and
THE NRC its report entitled "Self-Initiated Review and Interim Finding
for the Pilgrim Nuclear Power Station"- The report was provided to the
Commonwealth and NRC pursuant to the regulation and identified six (6) areas
OF MAJOR concern;
538
- Lack of a reception center for people evacuating to the north.
- Lack of evacuation plans for public and private schools and daycare centers-
- Lack of identifiable public shelters for the beach population-
- Inadequate planning for the evacuation of the special needs population-
- Inadequate planning for evacuation of the transport dependent population-
- Overall lack of progress in planning and apparent diminution in emergency
preparedness-
Based on the Self-Initiated Review and Interim Finding, FEMA concluded that
Massachusetts offsite radiological emergency planning and preparedness was
inadequate to protect the public health and safety in the event of an accident
AT Pilgrim.
Shortly thereafter, NRC informed the Boston Edison Company of FEMA's finding-
They encouraged the utility to address the underlying issues in cooperation
WITH THE Commonwealth and stated that the status of all issues upon which
the finding was based would be taken into consideration in decisions about
the restart of the plant- NRC's prompt notification to the licensee about
the offsite problems at the site is consistent with the FEMA/NKC policy of
cooperative effort towards addressing issues of this serious nature-
Current Status
^EN we transmitted THE SELF" INITIATED REVIEW TO MASSACHUSETTS WE SUGGESTED
THAT THEY WORK WITH US TO DEVELOP A WORK PLAN AND SCHEDULE TO CORRECT THE
INADEQUACIES IN THEIR PLAN- ThE COMMONWEALTH HAS NOT YET DEVELOPED SUCH A
WORK PLAN OR SCHEDULE; HOWEVER, SINCE THE ISSUANCE OF THE NEW INTERIM FINDING
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539
AND THE PUBLICATION OF THE FEMA SeLF'In ITIATED REVIEW AND INTERIM FINDING
ON Pilgrim, the Commonwealth of Massachusetts has taken actions to address
outstanding issues:
° On December 17, 1987, in a letter from Governor Dukakis to our Regional
Director, Mr- Henry Vickers, the Commonwealth indicated that progress is
being made in several areas- for example, they indicated that draft revisions
TO THE LOCAL PLANS EXIST IN PART FOR EACH OF THE FIVE EPZ COMMUNITIES- In
SOME CASES THE DRAFT REVISIONS WERE INDICATED AS BEING UP TO SSI COMPLETE-
ThEY FURTHER STATED THAT WHEN OFFICIALS OF ALL OF THE COMMUNITIES AND
STAFF OF THE MASSACHUSETTS CiVIL DEFENSE AgENCY/OfF ICE OF EMERGENCY
Preparedness indicate that the initial drafts are completed, the drafts
WILL BE submitted TO FEMA FOR INFORMAL TECHNICAL REVIEW-
° The Massachusetts Bureau of Radiation Protection, which is part of the
Commonwealth of Massachusetts Department of Public Health, has submitted
TO FEMA A draft of their ingestion pathway plan which the RAC is reviewing
at this time and plans to complete by the end of January at which time
THE RAC's comments WILL BE FORWARDED TO THE COMMONWEALTH -
FEMA LOOKS FORWARD TO WORKING WITH THE COMMONWEALTH AND AFFECTED COMMUNITIES
IN ORDER TO ACHIEVE OUR COMMON GOAL OF PROTECTING THE PUBLIC HEALTH AND
SAFETY- We STAND READY TO PROVIDE TECHNICAL ASSISTANCE TO THE AFFECTED PARTIES
IN THE RESOLUTION OF OFFSITE ISSUES ASSOCIATED WITH THIS SITE-
We are PREPARED TO RESPOND TO YOUR QUESTIONS-
540
The Chairman. We'll hear from both the representatives of
FEMA.
Mr. DoLAN. I don't have a statement Senator.
The Chairman. I want to say first of all, how much we appreci-
ate your attendance here, Mr. Krimm. I understand that there
have been occasions when FEMA has not been so willing to attend
meetings. I also want to say that I regret FEMA's decision concern-
ing the participation of Mr. Ed Thomas. It is unfortunate that the
agency doesn't feel that this hearing was of sufficient importance
to warrant Mr. Thomas' presence.
I've had the opportunity to review the emergency preparedness
plan which was in place when FEMA published its interim finding,
that the plan offered reasonable assurance that the public could be
protected in the event of radiological emergency. I'd like for a
moment to present some excerpts from the FEMA's subsequent
self-initiated review of that plan.
I quote:
Existing local plans do not include a list of the resources the town plan used in
assisting mobility impaired people during evacuation. FEMA could no longer state
with confidence that the beach population can be protected; FEMA can no longer
state with confidence that a reasonable assurance exists that the health and safety
to transport the dependent population can be protected in the event of an accident.
These are just a few of the serious deficiencies quoted in FEMA's
own assessment.
I would like to know, Mr. Krimm, how a plan so obviously defi-
cient could possibly have received interim approval by FEMA?
Mr. Krimm. In early 1980, when we did give approval I think
that, number one, we were new in the game, as was the Common-
wealth of Massachusetts. We were really just starting out. We have
gotten more staff and we have become more expertise in reviewing
plans and making our findings to the NRC.
The Chairman. Well, it would seem you wouldn't need a lot of
experience in developing an evacuation plan if the plan didn't in-
clude a list of the resources to be used in assisting mobility im-
paired people; and it says that you can no longer state with confi-
dence that the beach population can be protected; and you can no
longer state with confidence that reasonable assurance exists that
the health and safety of the dependent population can be protected;
those are pretty basic and fundamental questions, I would think. I
mean, you don't have to be terribly new in the game to understand
if you can't find ways of evacuating people who are sick or infirm,
it would seem to me that that would pretty well jump out at you. I
mean, if you can't evacuate the people along the beach popula-
tion— those things would be pretty self-evident, it would seem to
me in terms of raising serious questions about the effectiveness and
the efficiency of such a plan.
Mr. Krimm. I believe that when Mr. Thomas and his staff re-
viewed the plans that they did assume that some of those things
were in order because they had been working with the Common-
wealth.
I don't know, Mr. Dolan, if you would like to make any further
comments at this time.
Mr. Dolan. I think at the time when I was there, we became
much more sophisticated with what we did. And when we started
541
with this work in 1982, it was in its infancy, and the other thing
that is an important factor is the fact that the population changed
dramatically in this area, and that had a profound effect on both
the identification of mobility impaired people, and, additionally,
the protection of the beach population.
The Chairman. Does the fact that FEMA missed the important
problems the first time around indicate that FEMA needs addition-
al staffing to evaluate emergency preparedness plan?
Mr. Krimm. Senator Kennedy, fortunately, in the past few years
that we have received additional staff from the Congress, and the
Congress in fiscal year 1988 appropriation budget, gave us 10 addi-
tional positions. Some of these additional positions will be put into
the Boston regional office.
The Chairman. Has there been an increase for Massachusetts,
for example?
Mr. Krimm. Yes, sir. We are increasing the staff
The Chairman. You are increasing. Has there been an increase
as of today?
Mr. Krimm. As of today, there are just six people allocated to us.
The Chairman. How many were there two years ago?
Mr. Krimm. I'm not sure how many.
Mr. Dolan. Eight. [Laughter.]
The Chairman. So there were eight people two years ago. That's
some arithmetic. Well
Mr. Krimm. It was the case, Senator Kennedy, people sometime
leave the agency.
The Chairman. Well, I know that. But I mean, that's a tough
way to try to explain to somebody about problems in evacuation
plans that you missed. I happen to be very sympathetic to agencies.
I wish they would come out and say, "we can't get the job done
unless you give us the personnel, and don't expect us to do it." You
know, I like to hear that. We're realistic and understand you have
to live with the rest of it, but there is no reason for professional
people to take that kind of abuse. If you haven't got the people,
then you can't do the job, and then you are doing them an enor-
mous disservice with the responsibility that you have. I think it's
unfair to you, and I think it's unfair in terms of trying to deal with
an issue that is so vital with respect to people's lives. I don't want
to belabor the point, but say we are talking about some matters af-
fecting very, very considerable public health and safety issues, and
the American people are certainly entitled to understanding these
things.
Let me quote from the FEMA's Self-Initiated Review during the
June 30, 1986, public meeting in the town of Plymouth, "the citizen
whose children attended private schools inquired about the plans
for their evacuation. FEMA promptly researched that and discov-
ered for the first time that private schools were not included in the
local plans."
Is that, Mr. Krimm, how FEMA usually assesses a plan— by
waiting for the local citizens to ask you whether their children are
protected? Why is it that people have to ask? Why is it that you
missed something that would probably be as basically fundamental
as that? You did miss that. Is the rest of the plan flawed?
542
Mr. Krimm. As a rule, Senator Kennedy, we do try to be very
thorough, but one of the purposes of having public meetings is to
allow the local citizens to bring to our attention things that my
have been overlooked, and that is a very important part, trying to
get public input into the
The Chairman. Well, if you believe that's the case, why doesn't
the NRC believe that's the case when they hear from local citizens?
Well, I'll have a chance to ask them.
Focusing on the issue of the Memorandum of Understanding be-
tween FEMA and the NRC, it is my understanding from the NRC
that FEMA serves as the offsite expert on emergency preparedness
plans, is that so?
Mr. Krimm. Yes
The Chairman. Yet the NRC also says that FEMA's advice is
nonbinding; that the NRC can accept or reject FEMA's findings; is
that so?
Mr. Krimm. Yes.
The Chairman. Does it not appear contradictory to you that the
NRC claims FEMA to have the expertise on emergency prepared-
ness, but reserves for itself the right to overrule your determina-
tion?
Mr. Krimm. Well, the NRC has the authority in the licensing in
making the determination
The Chairman. I understand
Mr. Krimm [continuing]. Excuse me. We do act as a consultant to
them. We provide the information to the NRC, and, of course, it is
their determination what they do with our information.
The Chairman. Well, I know what the law says, but, I mean, the
logic, the common sense; you are the expert, you make recommen-
dations they can ignore. What sense of confidence do you think
people ought to have in terms of that process and procedure? I
mean, it's
Mr. Krimm. Excuse me. I would say in many cases, Senator Ken-
nedy, that the NRC does take our advice and does consider our
findings. For example, in 1983, we made a negative finding at the
Indian Point power plant in New York State, and the NRC did
take action to issue, what is known as a 120-day clock, whereby
they advise the utility that they would close the plant.
The Chairman. Did they close it?
Mr. Krimm. No. Because the issues were cleared up. Governor
Cuomo developed an emergency plan for Rockland County which
was a nonparticipating county at that time
The Chairman. Well, wasn't a result of it that the NRC actually
overruled FEMA and allowed the Indian Point to restart?
Mr. Krimm. No, sir. The emergency plans were developed and
the deficiencies were cleared up.
The Chairman. And FEMA approved the final plans?
Mr. Krimm. We approved the final plans. The major deficiency
at Indian Point at that time was the failure of Rockland County to
participate and the State of New York cleared that up. And we
also worked with Westchester County on the bus issue, and with
some of the other counties with some of their problems
The Chairman. At the present time, the federal regulations re-
quire that an area encompassing a 10-mile radius of a nuclear
543
power plant have an evacuation plan. Did you know Cape Cod lies
just outside the 10-mile radius. It is my understanding that in the
event of a full-scale evacuation Sagamore Bridge would be closed to
off Cape traffic, and all residents seeking to leave the Cape would
be rerouted over Bourne Bridge.
Now, I don't know if you ever had the pleasure [laughter] of
trying to drive through the Cape at the end of a sunny, lovely
summer weekend, but I can assure you, as a resident, that the ex-
perience is not a pleasant one. It is not uncommon to experience
hours of traffic delays when both bridges are open for use, and I
cannot imagine the nightmare that would ensue if Cape Cod resi-
dents were asked to use only one of the bridges for emergency evac-
uation.
I would ask you, do you really feel that the residents are ade-
quately protected? Let me remind you that in the case of the Cher-
nobyl accident, significantly more than a 10-mile radius was evacu-
ated. In the case of Three Mile Island accident, over 100,000 people
left the area; in spite of the instructions that told them to stay.
Mr. Krimm. I'm very sorry that I'm not familiar with that par-
ticular area. I would like to ask Mr. Dolan to respond to that.
Mr. Dolan. Senator, in 1984, at the request of the NRC and as a
result of a petition, we did an extensive study of the traffic man-
agement in the area of^from the plant to the other side of the
bridge on the Cape Cod Canal. And the state participated in depth
in that study.
Our experts told us that the Cape could be evacuated using the
procedures set forth by the Massachusetts State Police and the
Massachusetts Department of Public Works. And currently, the
Commonwealth of Massachusetts has told us that they are again
taking a look at the situation with regard to that and they are con-
templating the expansion of the emergency planning zones of the
Pilgrim power plant to include the towns of Bourne, Wareham, and
the third escapes me, the towns in that area, and that's where it
stands right now.
The Chairman. Have you been down there recently?
Mr. Dolan. Oh, yes, sir. All my life.
The Chairman. Well, you can take some judicial notice, as they
say, of what those weekends are like and what just ordinary traffic
is like.
Mr. Dolan. Well, Senator, I believe it can be evacuated as long
as it can be managed properly. [Laughter.]
The Chairman. I don't know what's not managed properly on
just ordinary weekends, just ordinary traffic; and this is one of the
growth areas of the country, not only of our state, but of the coun-
try. And even if you left down that whole railroad bridge, and you
had people scampering across there. [Laughter.]
It really defies the common understanding.
As I understand it, Mr. Krimm, you are from the Washington
headquarters?
Mr. Krimm. Yes, sir.
The Chairman. Do you have any great knowledge of these evacu-
ation plans?
Mr. Krimm. Not specifically the area that you mention. I am fa-
miliar with certain evacuation plans throughout the country.
544
The Chairman. The area that I was just talking about, Cape Cod;
what about this area here?
Mr. Krimm. No, sir. I'm not.
The Chairman. Well, it would seem to me that someone of your
responsibility would have some information about one of the key
elements in terms of an evacuation plan. You've got major respon-
sibilities, as I understand, in making some judgments on this. And
it kind of appalls me that — I mean, I don't expect you to have the full
information, perhaps the detailed information that the people in the
locale have, but I would certainly hope that, given the kinds of
problems that have affected this particular plant and the signifi-
cance of the evacuation issue that s been very much a part of the
concern of everyone in this state, and I would think people around
the country, that you would have given it the kind of attention
that apparently you have given to some of the others.
In view of the fact that FEMA is unable to supercede the NRC's
decision on emergency preparedness, would FEMA support a con-
gressional requirement to give FEMA the authority to override the
NRC on issues of emergency preparedness?
Mr. Krimm. I listened very carefully when the Lt. Governor
brought that up. If I may submit something for the record, I would
like to think about it a little before. I would like to try to develop
the cons and pros for it, I would submit something for the record.
The Chairman. When you do, we'll make that available to the
citizens up here. But what I'm really interested in is FEMA's sup-
port for its having the final decision over whether a plant stays
open — if the public cannot be reasonably assured of evacuation pro-
tection; that would be the question I'm interested in your response
to.
[Response of Mr. Krimm to Senator Kennedy's question follows:]
Response to Previous Question
Answer. In response to your questions if the FEMA would support legislative
action to give the FEMA the authority to override the Nuclear Regulatory Commis-
sion (NRC) on issues of offsite emergency preparedness, the FEMA does not recom-
mend that it be given such authority, at this time, for the following reasons:
1. On the whole, the NRC has used and reflected FEMA's offsite findings and de-
terminations in all of its licensing decisions. This woudl indicate that the present
arrangements are satisfactory.
2. A change could bifurcate the current integrated licensing process resulting in
two separate licensing processes, onsite and offsite.
3. It is estimated that the FEMA would require an additional staff of 50 to 75 FTE
and an increased annual budget of $7 to $8 million dollars. The additional resources
are required for judicial reviews, hearings, public meetings and administrative re-
quirements needed for a regulatory activity.
The Chairman. One final question, you mentioned in your testi-
mony the report by Secretary Barry on the emergency prepared-
ness plan and the fact that the State has not yet submitted to you
all of its revision. I wonder if you can tell us how long it would
take FEMA to evaluate the plan after it's been submitted and how
long it would take FEMA to ultimately advise the NRC of the ac-
ceptability of a plan?
Mr. Krimm. Once the plan is submitted, of course, it will be re-
viewed by the Regional Assistance Committee, and depending on
the time and the problems, they should be able do it in about 30
days.
545
Mr. DoLAN. Three months.
Mr. Krimm. Ninety days.
The Chairman. Well, what assurance can you give us that Pil-
grim won't start before that time?
Mr. Krimm. That is not my decision. I can't give you any assur-
ances.
The Chairman. Whose decision is it?
Mr. Krimm. That's the Nuclear Regulatory Commission's deci-
sion.
The Chairman. Can you give us any assurance about that?
Mr. MuRLEY. I'll speak to that in my testimony, if I could.
The Chairman. We'll hear from Dr. Murley, who is the Director
of the Office of Nuclear Reactor Regulations at the Nuclear Regu-
latory Commission.
Mr. Murley. Thank you, Mr. Chairman. I'll summarize my re-
marks, which I provided to the committee in more detail.
First, I should say that we're not prepared at this time to recom-
mended restart of the Pilgrim plant nor do we have a schedule for
the restart for the plant.
The Chairman. Let me ask just before you move on. You say,
"we are not ready to recommend restart nor do we have a plan."
Can you indicate to us what would be the factors that you would
look for to determine whether you will have a plan or whether you
will permit restart? What are the events? What are the things that
have to happen?
Mr. Murley. What I
The Chairman. If you repeat them in your statement, I would
like to permit you the full opportunity to do that but, as you move
through the testimony, we're reaching the end of the hearing, so
I'm going to maintain a little more flexibility. If you have it later
on in your statement, just mention that to me, but if you don't, I
would appreciate if you would be responsive.
Mr. Murley. The major factors that we're going to look for are
the deficiencies in the plant equipment that we found through our
inspection; the deficiencies in the management of the plant and the
deficiencies in the emergency preparedness.
The Chairman. But again, can you indicate how long it will take
to look at plant management and evacuation? Do you have any
general ballpark figures? Mr. Doland indicated they thought
around 90 days. In each one, how long would that take.
Mr. Murley. After the Boston Edison Co. submits to us their in-
dication that they believe they are ready to restart, we think it will
take perhaps a month to 2 months, probably closer to 2 months by
the time we send our own team of inspectors in, to review and
come to our own conclusion.
The Chairman. When does Boston Edison indicate to you they
will submit their recommendations?
Mr. Murley. They have indicated, I think, informally to us, it
would probably be in late January or February.
The Chairman. On the question of the plant, you expect in late
January or February, to receive from Boston Edison the final plant
designs in terms of safety, and then it will take you approximately
30 days for you to send your people up there and conduct their
review, or does it take 30 days to get your people to get together?
546
Mr. MuRLEY. No, we would have our teams ready. It would take
probably 2 to 3 weeks at the plant. We would then have to collect
our information and pull it together, make our conclusions. That
would take another month, so altogether, perhaps 2 months.
The Chairman. So we are generally thinking sometime in early
March that you'll at least be able to make some judgment. I sup-
pose you may have to go back and get additional information. The
fastest track would be in March. What about with regards to man-
agement?
Mr. MuRLEY. With management, we're making continuous as-
sessments. What we will do, of course, is watch their performance
while they are getting the plant ready and also during the times
when they will be conducting what we call "hot functional tests."
The Chairman. What is a "hot functional test"? When do they
start?
Mr. MuRLEY. Well, they'll being doing some testing, not nuclear
testing, and we'll be watching and observing how the plant is being
operated.
The Chairman. What sort of testing do they do now?
Mr. MuRLEY. For example, I was in the plant all morning, and
they have a steam supply from a fossil-fired boiler to generate
steam to run steam turbines for the safety pumps. They will test
them and they will test the systems to see if there is leak. We
watch them carefully because it is a nuclear plant and there is ra-
diation in the plant. Even though this is a non nuclear test, we
watch them.
The Chairman. Have you reached any preliminary conclusions
that you want to share with us?
Mr. MuRLEY. No firm conclusions. I think we can say that they
made some significant management changes in the company that
we believe are improvements. Ralph Byrd, for example, was
brought in after years of experience in the nuclear navy, who was
an admiral. He, in turn, has brought in a number of capable
people. It remains to be seen whether they can gel as a team that
can really manage
The Chairman. How long does it take with respect to the evacu-
ation plan?
Mr. MuRLEY. We are reviewing the drafts as they are prepared
by the state and local authorities, and we expect that the state will
send those to FEMA. At that time, we'll have to come to a judg-
ment as to the status of those plans.
I say it in a little more structured way in the testimony, if I
could go through it, I would like to do that.
The Chairman. All right. Go ahead.
Mr. MuRLEY. With regard to the current status of the major NRC
activities concerning Pilgrim, the plant is shut down; the NEC has
met frequently with the Boston Edison Company, members of the
public and with the Commonwealth, as well as local officials, to dis-
cuss the issue regarding Pilgrim.
Boston Edison has developed a restart plan that describes their
programs and plans, but they have not reached a position where
they would request NRC to consider a restart decision. In addition,
as part of its safety enhancement program, Boston Edison has pro-
posed a number of modifications intended to improve plant per-
547
formance in the event of an accident at Pilgrim. These modifica-
tions are in consonance with the NRC's goals of enhancing contain-
ment performance under severe accident conditions.
We will conduct several public meetings to insure opportunity
for public participation and input to the assessment panel regard-
ing Boston Edison's restart plan. These meetings will be formal,
transcribed sessions in which the public's testimony will be heard
by NRC senior staff.
After the NRC staff has completed the restarts readiness assess-
ment, there will be a public meeting at NRC headquarters at which
the staff will inform the NRC commissioners on our findings and
recommendations, so that the Commission itself can make the final
restart decision.
The Chairman. Now, who is going to be able to appear at that
public meeting?
Mr. MuRLEY. Any interested citizen.
The Chairman. This is in Washington; is that correct?
Mr. MuRLEY. The meetings that we'll have will be here in the
Plymouth area to get concerned citizens' input on the plan itself
and our approach to the plan. The Commission meeting, if that's
what
The Chairman. Who will be at the meeting?
Mr. MuRLEY. It will be the senior staff from our headquarter and
from our regional office.
The Chairman. None of the Commissioners would come up to
that meeting?
Mr. MuRLEY. Probably not. It would not be an adjudicatory hear-
ing. It would be a more informal meeting. It will last as long as
people will be interested in talking.
The Chairman. You and I know that, quite frankly, there is a
difference if you have the staff hold the hearing or whether you
have the principals. With no disrespect, because I have an excel-
lent staff and am proud of them, as you know, and I know, there is
a quantum difference on those kinds of situations. People are busy,
and all the rest, but it is an unique set of circumstances.
You've got two situations. Pilgrim and Seabrook. You may have,
I don't know, half a dozen maybe— I don't know what the others
would be. I know one or two that are of such significance and im-
portance.
I find it difficult to understand what would be more important
than those fellows getting out in one of those Gulfstream planes
that the government has and spend a nice day up in the Plymouth
area and fly back so they could be back with their families at
nighttime. I really don't know what in the world is more important
than spending that particular day.
[Applause]
The Chairman. We'll request it nicely of them. Hopefully, they 11
be responsive, but whatever decision is going to be made, how im-
portant it is that people have an opportunity to be heard on these
issues; and I find having sat through the hearings tonight, that
these are well-thought out, well-considered, very well-studied testi-
monies. I mean all of us ought to be able to hear whatever people
we represent have on their minds in any event, but I think you
would agree that these are very impressive pieces of testimony that
548
people spent a lot of time on. Well, I urge you to give that consider-
ation. I will, and I'm sure I will be joined by my colleagues, but
let's go on with your testimony.
Mr. MuRLEY. Yes, Senator. I'll move on now to emergency pre-
paredness.
The Chairman. What page are you on?
Mr. MuRLEY. I'm sorry. I have a version that — when you asked
that we limit it to 3 minutes.
The Chairman. You can take a little longer time, if you'd like to.
I have the testimony which you submitted earlier where you said
on page 1, "that report brought into focus a number of problem
areas at Pilgrim, such as a shortage of licensed operators, a large
maintenance backlog, with a number of management vacancies in
the maintenance area, radiological protection program weaknesses;
emergency preparedness program weaknesses, and instances of
poor procedural adherence and administrative practices at the
plant." Have all of these been corrected?
Mr. MuRLEY. They have not yet been corrected. No, sir.
The Chairman. On the top of page 2, and then I'll let you contin-
ue, you report that "there are five areas that exhibited recurrent
program weaknesses. These are radiological controls, surveillance
of safety-related equipment, fire protection, physical security and
safeguards, and assurance of quality."
Now, have those been corrected yet?
Mr. MuRLEY. They have not been corrected. We have seen signs
of improvement, particularly in the radiological control area and
fire protection and assurance of quality, but we haven't — they
haven't been corrected.
The Chairman. Can you give us a rough idea? Ten is the stand-
ard in order to perfect. They ought to get your C grade. I mean
that's sort of minimum grade. Where are you on the radiological
controls? How close are they to being at minimum standards?
Mr. MuRLEY. I think I would say now that they do meet our min-
imum standards. It's difficult to give them a numerical grade, but I
can give you an idea of the action that we take when we think they
fall below standards in one of these areas. This was several years
ago in the radiological control area.
We felt if they fell below these standards, there were practices at
the plant that we thought were unacceptable, and we took an en-
forcement action by issuing them an order. An order is a formal
action that modifies a license, and we directed them to get an out-
side consultant to come in and help them formulate improvements
to the program, and we then made them implement those improve-
ments. It took a very long time for them to do it, and just recently
Mr. Russell closed out the order on the basis that we have seen im-
provements.
The Chairman. Well, when you found these deficiencies on radio-
logical controls — did you close down the plant?
Mr. MuRLEY. No, we didn't.
The Chairman. Why not?
Mr. MuRLEY. There are many areas that go into our judgment as
to the overall operation of the plant. Radiological control is one of
them. I said fire protection is another. If there's an area we judge
to be serious enough, we'll not hesitate to shut it down. We have
549
nine plants shut down in the United States today because we don't
think they are safe enough to operate; Pilgrim being one of them.
Regarding radiological control, what we did, we issued an en-
forcement order on their license.
The Chairman. Well, you know, I would think that after the
NRC identifies this plant as probably the least safe plant in the
country and you don't close it down, people are going to ask about
it, don't you think? What does it take? You've got nine down. You
say that this is one of the least safe plants in the country. Boston
Edison closes it down, but you people don't. What kind of assur-
ances can people have in terms
Mr. MuRLEY. Although we didn't issue a formal enforcement
order, we did, in fact, tell them to shut down the plant. This was in
April of 1986.
The Chairman. That's right. Well, in other circumstances, you
close them or do you ask the company to close them down?
Mr. MuRLEY. We ask the company to close them down. In the
case of the Peach Bottom plant, we ordered them to immediately
shut down. So in that case we issued an immediately effective
order.
The Chairman. All right. Let's just continue with your testimo-
ny.
Mr. MuRLEY. I'm now talking about
The Chairman. Let's go down— we've had a long evening, but
I'm not in any hurry right now. If we could go down to the bottom
of 2. You say, "Let me summarize the current status of major
Boston Edison and NRC activities regarding the Pilgrim facility."
Let's pick up there. Have you got your copy?
Mr. MuRLEY. Yes, sir. The facility remained shut down. The NRC
has met frequently with Boston Edison, members of the public and
with the Commonwealth as well as with local officials.
The Chairman. Who of the public have you met with? Do you
know?
Mr. MuRLEY. Yes. I have met several times with the Selectmen. I
have spent an evening in this very auditorium with the Selectmen
and with several other people, probably until past midnight, an-
swering questions. My staff and Mr. Russell's staff have met in
Duxbury with similar groups. I would guess there have been prob-
ably, all in all, half a dozen or more meetings with people in this
area.
The Chairman. Continue.
Mr. MuRLEY. Boston Edison has developed a restart plan that de-
scribes the program plans, actions considered necessary by the
company to restart and safely operate the company. Although
Boston Edison has not reached a position where it could request of
NRC to consider a restart decision, the utility has completed a
number of plant improvements.
The reactor was refueled in October and several major system
tests on the reactor cooling system and containment structure have
been completed. As part of its safety enhancement program, Boston
Edison has proposed a number of modification intended to improve
plant performance in the event of an accident at Pilgrim.
550
The NRC staff reviewed these modifications in August of 1987,
and concluded that many of the modifications were appropriate for
implementation.
The Chairman. Does that suggest anything to you? It says
Boston Edison proposed a number of modifications to improve
plant performance in the event of an accident at Pilgrim. Does that
suggest anything to you? Did we draw any conclusions about the
considerations as to the safety?
Mr. MuRLEY. Yes. We have underway, Senator, a generic study.
It is a research study on how we can make these containments
even safer. As you know, the issue was raised earlier this evening
about the safety of the BWR Mark I containment of the type that
Pilgrim has. There are, I believe, 24 such reactors.
NRC believes that they are being safely operated today, but we
have research programs to see if we can make them safer. Boston
Edison knows the kinds of things that are being considered. They,
presumably on their own, assumed that the NEC is coming out
with new requirements. We haven't done that, but we are sched-
uled to go to the Commission this summer and make our recom-
mendations.
The Chairman. Well, then you wouldn't bring this on-line before
then, would you, if you were going to make specific recommenda-
tions this summer regarding safety. It wouldn't make any sense,
would it, to try to do this prior to that time?
Mr. Murley. There are really two answers. Senator. One is that
many of the types of things that we're looking at generically, are
the very things that Boston Edison has done on their own to im-
prove the plant; and second, if the Commission decides to do even
more, we would make at that time, no matter when that is, we
would make Boston Edison backfit any additional requirements.
The Chairman. Can you be just more specific? Does that include
the torus vent improvement?
Mr. Murley. In our review of that proposed modification, we
asked them a number of questions; in particular when they would
use it and when they wouldn't. They still owe us a reply on that.
The Chairman. You are familiar with the technology?
Mr. Murley. Yes.
The Chairman. I mean, do you think that that is a large addi-
tional safety factor or is not?
Mr. Murley. It does if it is used correctly.
The Chairman. Let's assume that they use it correctly. I mean, if
they are not going to use it correctly, then nothing makes any
sense at all. [Laughter.]
Mr. Murley. Sir, I wish things were always that clear. Our ques-
tions will elicit that very information; namely, have they studied
all the cases where it could help and where it could hurt to operate
the torus vent.
The Chairman. What was your impression?
Mr. Murley. The containment is a very important structure in
the plant. Chernobyl did not have such a containment. The con-
tainment that was designed has been required by the NRC on these
reactors to contain any radioactivity and fission products.
One does not lightly change the design to deliberately open the
containment unless one really knows what is right, and under the
551
right circumstances. And that's why we're being very cautious on
this.
The Chairman. Does your report reach any conclusion about
whether it will be successful or fail?
Mr. MuRLEY. There is a report from some of our laboratory ex-
perts. They have been looking at the behavior of these Mark I con-
tainments under very severe accidents, very unlikely core melt-
down accidents. I have not read the report myself, but the indica-
tions I have is they concluded that under these very severe condi-
tions, the containment could fail when molten fuel contacts the
steel liner parts.
[The report referred to above follows:]
552
REVIEW OF THE STATUS OF THE MARK 1 BUR LINER MEUT-THKOUCH ISSUE
by
C. A. Greene
Brookh«vcn National Laboratory
Experlaental Modeling Croup
Uptoo, NT 11973
1. INTRODUCTION
The interaction of core debris with the Hark I drywell pressure boundary
hat recently been the object of intense scrutiny as a result of the HKC's re-
astessnent of risk under severe core daaage accident conditions [1]. Tradi-
tional concainaent failure analyses have assuaed that the Hark I drywell would
fail by overpressurization at the drywell knuckle-weld position at a pressure
of 132 psla 12] . This pressure aay be generated as a result of non-
condensable gases accuaulated in the drywell ataosphere due to a aolten core-
concrete interaction (MCCI) and soae analyses have indicated that this failure
eode could be delayed for as long as several hours after pressure vessel fail-
ure [3]. Other study group activities have examined the leak-bef ore-failure
aodc of cont.^lnoent failure due to high drywell ataosphere teaperature as an
alternative to gross overpressure failure (4). However, the Containaent Per-
formance Working Croup (CPWC) results siailarly indicate a delay of one to
several hours between vessel failure and the onset of leakage. The principle
driver for both cases, high drywell pressure and teaperature, would be a MCCI
or. the drywell floor. During the activities of the Containaent Loads Working
Croup (CLU'C), a third aechanlsn for failure of the drywell pressure boundary
was proposed. ..celt-through of the steel shell by direct contact with core
deans. A series of calculations were performed to »ste»t the liner response
over a range of paraoetric variations employed for the overpressure calcula-
tions. Tne series of analyses were consistent in so far as they employed
self-consistent initial and boundary conditions, and coupled the results .of
MCCI analyses with the CORCON code 15] into hand calcul
13,61 indicated that containment failure by liner aelt
under a wide range of parametric conditions within minu
contact. Reterence 6 is attached as Appendix A. The conclusion was developed
that, for a ilark I BUR, liner failure, given that core debris is expelled from
the reactor pressure vessel, is a highly probable aechanism of early contain-
nen: failure. Tne liner failure issue was addressed by the containaent loads
review panel for the t.i;?.ZC-ll50 analyses. An average of the eight SARRP ~1
analysts' estimates of the probability of liner failure upon contact with core >
deDTls was approxinately Ti'i. When factored into the NURXC-U50 analyses for
tne Mari; I B"T< cases, liner nelt-through was singularly responsible for in-
creasing the ?rooablli:y of early containment failure from the 5-101 range to
the SO-90;. range. I: is clear that the effectiveness of any accident aanage-
nen: strategy developed to mitigate fission product release and off-site con-
secuences will depend upor. recoEnlcion of this containment vulnerability and
ln:egration of liner ii-.ljTt in;o tne strategy.
supled the results .of .
Lations. The results'^*
-through was possible J
jtcs of debris-liner/
553
- 2
2. MARK I LINER RESPONSE: NUREC-1079 ANALYSIS
During th« analytical «xercl»ei of the CLWG with rtapact to th« Mark I
BWR, para»«trlc calcuiatlona aa oppoaad to b«st-*stlMte calculation* were
p«rfotB«d to lnv«atl(at« the lapact of than-poorly understood variables upon
Cha contalnnant raipona* to a MCCI In the drywell. One auch paraaetrlc varia-
tion waa tht radial spreading of dabrls on the drywell floor, tihlch was
Inttndad to examine the effect of surface area. The radius of spreading was
varied fro* 3 to S aeters; the 3 aeter case represented holding the debris
iaslds cha reactor pedestal, while the 5 meter case represented spreading the
debris evenly over the In-pedestal floor and 1/2 the ex-pedestal floor area.
Id order to cause such spreading, It was recognised that the debris would not
only have to be aolten but would, by definition, have z.o flow up against the
•teel contalnaent liner which constitutes the drywell pressure boundary in
order to be deflected to spread evenly across half the ex-pedestal floor area.
This contact between core debris and the ateel liner is subject to vanishlngly
saall uncertainty. The typical drywell floor area is 132 a^; allowing for
floor aounted equipaent and blockages, floor coverage of U2 a waa chosen,
equivalent to a circular radius of 6 aeters, for the series of paraaetrlc
debris-liner aelt-through calculations. It should be aentloned that this
acalysis, by retaining 7 a^ of debris in the in-p«destal siaps (eollapaed
debris voluBC - suap voluae) and evenly spreading the rest of Che debris over
all available floor area results in the ainiaua possible debris depth on the
drywell floor and up against the steel shell. The variables that were chosen
<or Che paraaetrlc analyses were concrete type (baaalt or liaestone) , initial
coriua temperature (1775, 1900, 2550 K), and percent of core debris in drywell
(60 or BOS).
It was considered vital that the analyses performed for the liner aelt-
througn assessaent be dependent on reasonable and technically defensible
assiaptions, and that the analyses be consistent and coapatlble with contempo-
rary severe accident analyses. This, unfortunately, haa not been the caae
with other analyses and this will be delineated In subsequent sections. The
explicit assumptions concerning concrete type, coriua teaperature, coapocl-
tlon, and inventory, aa well as other Initial and boundary, conditions and con-
tainaent conditions required to Initlallie the CORCON code were chosen to be
coapatlble with the saae conditioos for the CLWG calculations. These condi-
tions were the subject of extensive review by the CLWG participants and were
all assessed as reasonable.
In the formulation of the problem, several Implicit aasuaptions were
invoked, aaong these were the following:
- melt spreadabllity
- liner back-side thermal boundary condition
- effect of overlying water.
These will be briefly discussed.
554
3 -
The first concern w«« whether the fluid dynaaict of the melt exiting the
pedjstal needed to be aodeled or if the spreading would be so quiclt that it
could be assuaed to arrive at the liner almost isMdiately. The physical
properties of the coriun, especially the viscosity of the molten metal and
oxide phases , w«re found to b« conducive to rapid flow of dabrls out of the
pedestal. This, coupled to the absence of floor-mouated obstacles, was taken
a.< sufficient Justification for neglecting the dynamics of malt spreading in
favor of the assumption of Immediate contact. In assuming Imncdiate contact,
whe debris was similarly spread over all available floor space, preventing
local pile-up and neglecting transient surge effects which might otherwise
present a more serious local threat to Che liner.
The thermal boundary condition on the back-side of Che liner facing the
concrete shield wall was the second concern. The 2-lnch gap between the
shield wall and the liner was found co be full of flbreglass insulation.
Furthermore, results of a structural analysis of Che Peach Bottom plant indi-
cated that, in spite of radial outward expansion of Che sceel liner toward the
concrete shield wall, this gap would remain open for most of the time of che
analysis and, in fact, at or near the point-of-imbedment with the drywell
floor, the gap would always remain open [7). Assuming grey body radiation
across an air gap to the concrete, it was found that only It of the decay heat
could initially be transferred from the steel shell at 1750K Co concrete at
373K. Furthermore, the concrete would rapidly heat up, ahutclng off che tem-
perature difference for heat transfer and rapidly approaching a nearly adla-
batic condition. Coupled with the realization that the gap is full of fibre-
glass insulation which would further impede heat tranafer, it was decided Co
invoke an adiabatic boundary condition. In this way, anomolous numerical
effects due co nodalization problems or contact heat transfer and temperature
effects which could erroneously bias the results could be avoided.
The third major problem to be considered was the absence or presence of
an overlying water pool and its ability to transfer heat from the debris.
Much credit has been given to the ability of water to mitigate the effects of
cevere core danage accidents. Most of this credit is based upon the assump-
tion thac an overlying water pool will boil at the critical heat flux and
"quench" the debris into cold, coolable rocks [8). Unfortunately, this as-
sumption is not supported by the prevailing and well-docianented data base
which indicates that boiling of water over molten core debris would be a film-
boiling process 1^,10). Since the accident analysis code CORCON did not have
a coolant boiling model at the time of these analyses, it was decided to eval-
uate the effect of watef in film boiling vs. convection and radiation heat
transfer. Assuaing that a means of continuously. injecting water into the dry-
well exists, a film boiling heat flux of approximately 5 x lO** W/m is reason-
able (this corresponds to a mass flux of water of 325 Ibm/min) . CORCON, in
the absence of water, would calculate natural convection and radiation heat
fluxes from this debris of approximately 2.0 x lO** W/ra^ and 2.9 x lO" W/m ,
respectively; this would be a total heat flux by radiation and convection of
i.9 X lO"* W/a^, not nuch different from the boiling flux assumed. Although
555
Che nagnlcude of these ombers could be easily challenged, the agreenent Is
supported by the widely recognized fact that flla boiling Is an Inefficient
heat transfer aachanlsa and supports the substitution of water in flla boiling
by natural convection and radiative heat transfer. In the assessnent of the
effect of water boiling over core debris, the possibility of a surface crust
on the core debris was neglected. Such crusts have been observed in the
Sandla SWISS tests [10], and were found to llait Che heat transfer to overly-
ing wacer pools by imposing a conducclon heac Cranafer resiscance becwcen che
■elt and Che wacer. In none of Che Cases done Co dace was ic found that wacer
pools would benignly quench siaulated core debris. For a aorc detailed dis-
cussion of Che calculadons and asstapcions, che reader is dirccccd co Refer-
ence 6 which is accached as Appendix A.
The analyses presenced in Appendix A 13,6) represent a consistent treat-
ment of Initial and boundary conditions in the drywell, coupled to a aechanis-
cic concalnaent analysis and a mechanistic HCCI analysis through hand calcula-
dons. To date, it is che only known analysis co be driven by and conslscent
with a mechanistic MCCI analysis. Arbitrary assumptions have been avoided
wherever possible and all assumptions made have been carefully documented.
The results of the liner melt-through analyses, over a reasonable range of
parametric variations indicate that, given a core-on-the-floor scenario, it is
nearly impossible co conceive of conditions chac will not fail the drywell
pressure boundary. Reasonable and mechanistic analyses demonstrate that con-
pletc local ablation of che drywell shell may occur as soon as several minutes
after contact with debris. These analyses neglect such cranslenc effects as
initial hydrodynamic surge across the floor and up the liner, radiation from
debris to the liner, uneven pile-up of debris along the liner, energetic melt-
water interactions which might splash large amounts of melt onto the liner,
and structural deformation of the' liner due to reduced strength at elevated
temperature when in contact with debris. Given that only 9Z of the total core
debris is required to fill the drywell sumps (boilup to 40: void fraction) ,
and that debris will flow at depths of 6 cm or less, che drywell shell Is
vulnerable to even the most optimistic assumptions of in-vessel meltdown and
transient oelc ejection from the failed reactor vessel. The only question
chat reaains is "when will che steel drywell wall fail.'
3. KARK I LINXR RESPONSE; A CRITICAL REVIEW OF THE IDCOR MODEL
It is the stated objective of che IDCOR-IPE program and che IIRC Severe
Accident Policy Statement to ascertain if chere are any poccntial risk out-
liers with respect co -core-melt frequency or unusual containment vulnerabili-
ties. One such containment vulnerability has been identified for the Mark I
BWR containment steel liner. Primarily on the basis of Reference 3, the fail-
ure of the Mark I liner when contacted by core debris following vessel failure
was included by the SARRP program in the NUREC-USO source term analyses HI.
An average of the eight SARRP analysts' estimates of liner failure probability
upon contact with core debris, when factored into the analyses in Reference 1,
resulted in the probability of early containment failure for Mark I BWRs in
the 80-90i range.
556
The IBCOR analysis In the draft report 'Approximate Source Term Method-
ology for Boiling Water Reactors" (81 recognised thlt potential containment
failure mode and reexamined the liner vulnerability or survivability In a
separate analysis. In what was characterized to be a "conservative" analysis,
the report Indicated that the steel containment liner would not fail under
any of the postulated conditions. This conclusion is In disagreement with the
analyses presented in Reference 3, as well as with the containment event tree
issues in SARItP for the Mark I containment analyses. As such, the models and
assumptions Inherent in the IDCOR analyses will be assessed. The section of
Reference 8 that Includes the IDCOR liner analyses is attached as Appendix B.
The IDCOR analysis of the behavior of the Mark I containment shell was
based upon numerous asstaptlons and Judgements. It Is on the basis of these
assumptions and judgements that the initial and boundary conditions, physical
properties, and phenonenological models were developed. Those assumptions and
Judgments that could be identified from the text In Reference 8 are discussed
below. The IDCOR model assumes that:
(a) The core debris that escapes the pedestal region of the drywell is
assumed to be in a thin layer 6-12 cm deep and to be, by definition,
solidified (Ul. This debris, for the purpose of the analysis in Refer-
ence 8, is assumed to consist only of uranium oxide fuel. There is no
netal phase present.
(b) Heat transfer within the core debris is asstned to be by conduction
only. There is no provision for Internal convectlve processes due to
bubbling or concrete decomposition gases.
(c) Heat generation within the core debris is by decay power heating. There
are no. provisions for the chemical energy source resulting from metal-gas
phase reactions between concrete decomposition gases and metallic core
debris.
(d) A pool of water overlying the core debris is assumed to boil at the cri-
tical heat flux. The film boiling regime is not modeled, and the exten-
sive data base tor aelt-water interactions is neglected.
(e) The steel liner is modeled to transfer heat from its outer surface by
thermal radiation to the surrounding concrete shield wall as well as by .
convection to the gas in the gap. Both the concrete shield wall and the
gas in the gap appear to be infinite heat sinks at a constant low temper-
ature. All emisslvities are apparently equal to 1.
(f) The area of the steel liner that is in contact with the overlying water
pool is assumed to transfer heat to the water at a rate specified by an
arbitrary heat transfer coefficient, h^. It is assumed to represent nu-
cleate boiling.
557
(g) The core debris, consisting of UO2. Is assumed tO' be at a cemperacure of
only 1800 C and less than 12 ca deep. An unspecified "protective layer
on the Inner steel shell surface" is postulated.
(h) The core debris transfers heat to underlying concrete by conduction.
However, Che baaeoat concrete is not allowed to outgas (i.e., dehydrate
and dccarboxylate) or to ablate. This prevents concrete dccoaposltlon
gases froa entering the debris from below and rules out eonveccive heat
transfer and esothenalc chealcal reacciona froa occurring in the «elt.
Once again, Che concrete is a passive heat sink.
There aay be other fundamencal assvapclons inherenc in che nodel for
liner response when concacted by core debris. However, aasumpclons (a) - (h)
were chose Chat could be readily identified from Reference 8. Nevertheless,
Chese eighc cacegories of assumptions appear to form the basis for the IDCOR
approach to the problem; each will be addressed in the following discussion
and compared to representative BNL positions or assumptions.
IDCOR assumption (a) assumes chat the debris is solidified, and consists
of UO2 fuel only. Since the debris is assuned to be pure UO;. its thermal
conductivity Is only 3 W/mK. However, IDCOR' s own core-concrete interaction
model, DCCOMP, is inconsistent with these conditions. OECOMP assumes that the
ex-v4ssel debris is a homogeneous mixture of oxide and metallic core debris
phases, not Just oxide fuel. This results in a debris pool with a lower melt-
ing temperature that can be molten, a more fluid pool of debris, and a higher
deDrls thermal conductivity, in che range df 10-20 W/mK. BNL analyses rely
upon the CORCON code. These analyses allow the debris co be molten or solid,
depending upon the calculated conditions, not only assvnptlon. The molten
oxide and metallic phases solidify in a mechanistic framework in a manner con-
sistent with prevailing thermal hydraulic conditions in the melt and che
boundary conditions experienced by Che melc. These analyses show chat the -
liner may be contacted by a deeper pool of core debris (> 25 cm) than assumed
by Reference 8. Also, this pool can be molten and have a considerable quan-
tity of molten metal phase present, wlch a thermal conductivity as great as 47
W/mK or more.
IDCOR assumption (b) assumes categorically that the UO; core debris is a
solidified mass. This precludes internal eonveccive processes froc transfer-
ring heat to boundaries, especially to che basemat concrete and che steel
liner. In deeper pools, this has been shown noc co be che case, ar.d rhe NRG,'
FRC, and EPRI prescndy have reaccor macerials experlmencal programs in pro-
gress to examine the molten stage of debrls-concrece inceracclons. In all che
tests to date, the molten atcacic on concrete was easily sustained.
IDCOR assumption (c) allows for internal heat generation in the solidified
fuel by decay heating only. However, reactor materials experiments and code
analyses have shown that, especially for BUR cases which may have a large
analyses have shown that, especially for BUR cases which may have a large in-...,,^
ventory of unoxidized Zr in che raelt, the internal heat source due Co mscal- lA
gas phase chemical reactions will in general exceed the decay heac generation /
by a large margin, in oosc cases representing the driving heat source for che |
il exceed the decay heac generation 1
.ng the driving heat source for the |
aggressive melt-concrete interaction stage.
558
IDCOR assumption (d) considers a pool of water over the debris, boiling
At the critical heat flux. At the tenperature apecified for the debris, 2100
k, clearly this boiling regiae would aost appropriately be reprecented by film
boiling. For moat caaea of Intereat in the NUR£C-U50 analyaes there would be
no water present since containment sprays are aaamed to not be available.
The availability of fire aprays must be evaluated on a plant-specific basis.
Regardleaa, the data baae conclusively demonstrates that the appropriate
boiling regime Is film boiling.
IDCOR asaumptlon («) modela heat cranafer from the outer surface of the
liner by radiation to the concrete ahield wall and by convection to the gas in
the narrow gap. The concrete and gaa appear to be laothermal heat sinks at
350-400 K and the emisslvlclea representative of blaekbody radiation. How-
ever, the gap between the liner and concrete shield wall, at least for the
Browns Ferry Nuclear Power Station analyaes reported in Reference 6, is not
empty but full of flbreglass and polyester foam. Over the time intervals re-
ported in Reference 6 for liner failure, this would be sufficient to insure an
adlabatlc boundary condition on the outside surface of the liner, not a radia-
tion-convection boundary condition. Also, the concrete would quickly heat up,
effectively terminating heat transfer.
IDCOR assumption (f) assumes that an overlying pool of water exists over
the core debris and that it cools the exposed surface of the liner with an ef-
fective heat transfer coefficient hv. In most Mark I BWR drywells, the down-
comer vents to the torus are only two feet above the drywell floor. If core
debris were tis accumulate to this depth, the overlying water pool would simply
overflow into the suppression pool. This would prevent the water heat rejec-
tion mechanisms proposed, both for the liner and melt (debris) surface, and ^
expose the liner to direct radiant heat transfer from the high temperature J'
debris. In fact, molten core debris could easily overflow into the vencs .0^
itself.
IDCOR assumption (g) proposes a debris temperature of 1800 C and a debris
depth of, at most, 12 cm. For similar low temperature cases studied in Refer-
ence 6, the steel liner was sometimes calculated to aurvive nelt-through.
However, the steel was calculated to be at a high enough temperature so as to
have greatly reduced mechanical strength, and failure by mechanical deforma-
tion would be likely. Furthermore, a simple examination of the ex-vessel de-
bris inventories calculated in recent studies such as BMI-2104, NUR£C-1079, .
KUREG-0956, and MJR5G-1150 indicate that debris depths (assuming uniform
spreading over the entire drywell floor to minimite the depth) will exceed one
foot.
Finally, IDCOR assumption (h) allows for heat transfer to underlying dry-
well concrete from the core debris by conduction only. By assumption, the
concrete is not allowed to decompose or ablate. This is in spite of the fact
that concrete needs only to be heated to 100 C to start boiling the free water
In the asgregatt uatrlx. By not accounting for debris-concrete Interactions,
559
- 8 -
the gates (H2O, CO2) which would bubble up through the debris and rwact with
■et«Hlc tpecle* (if there were any) are ellolnated, thua erroneously preclud-
ing the poasiblllty of exothermic cheoical reactions in the aelt. There Is
nothing In the exlatlng data base to support the position that concrete
behaves as a passive heat sink.
Other issues that aay be iabedded in the IDCOR assunptions la Reference
8 but were not apparent to this asaessaent arc the. concepts that (1) water
overlying molten core debris qucnchas that debris and (2) water on the floor
presents an obstacle to the migration of high temperature melts across the
floor. Data from ongoing experimental programs at SNL and BNL exist which
contradict these concepts. Instead it is found that water overlying melts en-
gages in file boiling and that melts flow through or under water obstacles as
long as the debris is molten. Neither of these two concepts presents a con-
vincing case to argue that core debris cannot flow to the containment liner
and still be molten.
It is clear that there are major differences between the assumptions in
the IDCOR analyses |8] and the BNL analyses [6] for the Hark I BWR containnent
liner response to contact with core debris. There are also major inconsisten-
cies In the IDCOR model, particularly with respect to melt temperature and
composition, boiling, concrete behavior, and llncr-shlcld wall boundary condi-
tions. The IDCOR analyses pertain only to a very limited, optimistic set of
assumed accident conditions and arc not generally applicable to a wide range
of accident conditions such as those addressed in Reference 1. The lOCOR
analyses specifically are not applicable under the conditions that (1) the
debris pool is hot, molten, and deep, (2) the debris has a significant metal-
lic component, (3) the debris is attacking the diywell basemac concrete, and
(4) there are exotherslc chemical reactions in the melt. In addition, some of
the IDCOR BOdels are suspect and should be reevaluated. In particular, (5)
the heat transfer from the outer surface of the steel liner, (6) the existence
of an overlying pool of water over the debris when containment sprays are not
available, and (7) the mode of boiling of an overlying pool of water when
water is available. Some of IDCOR assumptions with respect to physical prop-
erties should be reconsidered, specifically (8) radiative eaissivitles of
steel, core debris, and concrete, and (9) the debris thermal conductivity.
Convection and radiation from the backside of the steel liner to the
shield wall is to a constant temperature, infinite heat sink. This results in
an increasing heat transfer with time as the liner heats up, instead of a
decreasing heat transfer in time as the shield wall concrete heats up. No
attempt to include the shield wall concrete in the analyses was aade. This is
puzzling since basemat concrete was explicitly Included in the numerical
model. It is not immediately apparent what the effect of this omission had on
the numerical results. However, it is clearly in favor of liner survivabil-
ity. It would be recommended that the shield wall be nodalized and Bore nodes
enployed in the steel liner. It is expected that implementation of these
cnanges, along with relaxation of the previously listed objections, would
560
result in liner failure In the IDCOR analyses. A cooparative assessoer.:: of
both the IDCOR and NRC analysis approaches has revealed dramatic differences
in several key feature*. These Include:
- underlying assumptions
- Initial condition*
- boundary conditions
- phyaical properties
- thermal-hydraulic model* of key phenomena.
It is the opinion of the author that the exi*ting data base (upports the as-
sumption* and approach used in the BNL analyses (Ref. 3,6) and not the IDCOR
analyses (Ref. 8). Within the context of this asse**ment, there appears to be_
no defensible technical basis to support the IDCOR conclusions. "
it is once again concluded that the drywell liner is highly vulnerable to
attack by ex-vessel core debris and that containment failure
is a highly probable mechanism of early containment failure.
lere appears to be
is. As a result , ~ 1
vulnerable to I
by melt-tnrough I
U. ANALYSIS OF MARK I LIKER RESPONSE TO CONTACT WITH SOLIDIFIED COR£ DEBRIS
WITH TKE TAC-2D COMPUTER CODE
^eaff of the NIJKEG-nSO Reassessment Program repeated the IDCOR liner
analysis, relaxing certain questionable IDCOR assumptions/ uncertainties , in
order to determine if there was any merit to the IDCOR position.
The differences between the TAC-2D calculation and the IDCOR calculation
were as follows:
TAC-2D used a finer nodalization in the steel liner to better repre-
sent thermal gradients. It is believed IDCOR used 3 radial 'lodes.
TAC-2D allowed for a metallic component in the debris as opposed to
oxide fuel only. However, the debris was still all solid.
TAC-2D did not have an overlying water layer. However, as discussed
in Section 2, radiation and convection from the debris which was
modeled in the TAC-2D calculation should be representative of heat
fluxes expected by film boiling.
The TAC-2D calculation replaced convection and radiation across the
liner-shield wall gap by direct-contact conduction. The assumption
made was that there was no resistance to heat transfer across the
gap; but the TAC-2D calculation allowed for heat-up of the shield
wall concrete as opposed to the IDCOR assumption that the shield
wall was an infinite isothermal heat sink.
561
10
The tlnllarlcles between the TAC-2D calculation and the lOCOR calculation
vere strllclng. This was due, of course, Co the Intention to reproduce the
IDCOR analysis with a verified numerical tool with apparently defensible
boundary conditions. Briefly, the similarities are as follows:
Heat generation was at a level dictated. In both Che oxide and metal
layers, by decay heat.
The analysis was a conduction analysis; no melt convection was
allowed.
There was no direct coupling to • HCCI analysis. In fact, concrete
was created as a passive heat sink. Concrete was not modeled to
oucgas, thus prevendog axochermic metal-gas chemicitl reactions.
- The cheraal loading on the steel liner could melt the steel, but the
melted steel remained in place (not ablated).
The results of the SNl. TAC-2D analysis did not indicate complete melt-
through of tne liner, however partial melting was observed in some calcula-
tions within 200 seconds of contact. The results indicated that peak tempera-
tures in the carbon steel liner rapidly approached 1740K for the base case
analysis, but minor increases in initial debris temperature resulted in sub-
stantial local melting. The preliminary conclusion was offered by the analyst
that "reduced strength (of the steel liner) at elevated temperatures and slg-
nliicant melting calculated from small parametric variations strongly support
the position that containment Integrity is Indeed compromised."
Thus, even with a conduction analysis, the TAC-2D calculations resulted
in liner failure with minor changes from the IDCOR analysis.
It should be pointed out that the TAC-2D calculations allowed direct
llner-snield wall contact. This would result, even with concrete melting, in
a calculated outside liner boundary condition, biased towards the concrete
ablation tenperature,. below the melting temperature of steel. It is the
author's belief that inclusion of a minor heat transfer resistance between the
liner and shield wall would have resulted in total melting of the liner in the
TaC-20 calculations.
A series of TAC-2D calculations are presently being repeated with more
parameters and reasonable assumptions, and the results will be available in
the near future. At that tine, the speculation concerning the effects of the
parameters that have Just been discussed may be relaxed.
562
5. CONCLUSIONS
There have been three nuoerlcal analyses performed to investigate the
thermal response of the Mark I BWR dryvell pressure boundary (a. It. a. steel
liner, ateel ihell) to direct contact with core debris under severe accident
conditions. Each of the three analyses, the BNL analysis (Ref. 3,6), the
IDCOR analysis (Ref. 8), and the SKL analysis (unreferenced), has been de-
scribed and critically reviewed. The bases for aach analysis as well as the
underlying assunptlons have been discussed and examined for consistency and
technical defenslblllty. A thorough review of the supporting data base has
not been perforaed, however, where appropriate, experimental evidence which
supports the positions developed in this report has been cited. For each
analysis, the initial and boundary conditions, thermal hydraulic models, and
physical properties have been discussed.
It was found that the BNL and SNL analyses resulted in rapid failure of
Che drywell pressure boundary, while the IDCOR analysis resulted in survival
of the drywell pressure boundary. When the models and parameters of the IDCOR
model which resulted in liner survival were reviewed, they were found to be
Inconsistent, and not supported by the data base. The SNL analysis, which
relaxed only a few of the objectionable IDCOR assumptions and models while
retaining the fundamental approach (i.e., conduction analysis), resulted In
rapid failure of the steel containment. Inherent drywell design features were
found to offer little or no support to the liner's ability to survive beyond
Che time of vessel failure. It is concluded that the drywell pressure bound-
ary (steel liner) Is vulnerable to even the most optimlscic assumptions of In-
vessel seltdown and transient melt ejection from the failed reactor vessel,
and that priaary concainnent failure by melt-through is a highly probable
mechanisn of earlv containment failure.
563
REFERENCES
1. Remccor Risk Reference Docuaenc, NUREG-llSO, Draft for Coaoent (February
1987).
2. Crieaann, L.C., Faaous, F., Wold-Tlnsai , A., Katalaar, D., U.n, T.,
Kluln, D. . 'Reliability Analysis of Steel Contalnacnt Strength,* NUREG/
CR-2A42 (1984).
3. Spels, T.P., ct al., "Eatlaatea of Early Centaioicnt Loads froa Core Melt
Accidents,* NUREC-1079, Draft (July 1985).
U. Containment PcrforiMnce Woriclng Group, "Contalnacnt Leak Rate Estlaates,*
lJUREC-1037 Draft 4 (April 1984).
5. Huir, J.F., Cole, R.K., Corradlni, M.L., and Ellis, N.A., *C0RC0N-M0D1 : •
An laproved Model for Molten Core-Concrete Interactions," SAND 80-2415
(1981).
6. Greene, G.A., Ferklns, K.R., and Hodge, S.A., *Hark I Containment Dry-
well: Impacc of Core-Concrete Interactions on Containment Integrity and
Failure of the Drywell Liner," Proceedings of the International Syaposius
on Source Term Evaluation for Accident Conditions, IAEA (October 1985).
7. Mokhtarian, K. , et al., "Hark I Containment Severe Accident Analysis,*
CBI Report (April 1987).
8. "Approximate Source Term Methodology for Boiling Water Reactors," FAI/
86-1 (Decetaber 1986).
9a. Greene, C.A., "Gas Bubbling-Enhanced Film Boiling of Freon-11 on Liquid
Metal Pools," Trans. Am. Nucl. Soc, 49 (June 1985).
9b. Greene, G.A., and Irvine, T.F., Jr., "Film Boiling of Rl 1 on Liquid Metal
Surfaces," Eignth International Heat Transfer Conference, 86-IHTC-305,
San Francisco, CA (July 1986).
9c. Greene, C.A., Flnfrock, C, and Burson, S.B., "The Effects of Water in
Film Boiling Over Liquid Metal Melts," Trans. Aa. Nucl. Soc, 53
(Novenber 1986).
10. Blose, R.E., Gronager, J.E., Suo-Antilla, A.J., and Brockaann, J.E.,
'SWISS: Sustained Heated Metallic Melt/Concrete Interactions with Over-
lying Uater Pools," NUREG/ CR-4727 (July 1987).
11. Plys. M.C., Gabor, J.R,, and Henry, R.E., "Ex-Vessel Source Term Contri-
bution for a 3WK Mark I," Proceedings of the International .VNS/ENS Topi-
cal Meeting on Thermal Reactor Safety, San Diego, CA (February 1986).
564
APP-^NDtX A: MARK 'l CONTAINMENT DRWELL: IMPACT OF CORE-CONCFIETE INTERACTIONS
ON CONTAIfWENT INTEGRITY AND FAILURE OF THE DRYWELL LINER
(REFERENCE 6).
FOR ACCIDENT CONDITIONS
INTERN. lONAL ATOMIC ENERGY AGc->iC y BNL-NUREC- 3 7131
« CSS^ V IMTERNATICNAL SYMPOSIUM ON SOURCE TERM
^V li^ M EVALUATION FOF
Columbus. Ohio, USA, 28 October-! November 1985
IAEA-SM-281/35
IMPACT OF COP.E-COMCP.ETE INTEaACTIOIIS
IN THE MARK I CONTAINMENT DRYWELL
ON COriTAINMENT INTEGRITY AND
FAILURE OF THE DRYUELL LIME?.
G. A. Greene and K. R. Perkins
Brsok-^aven National Laboratory
Uct:n. New York USA 11573
and
S. A. Hocce
CaK Sices 'Jstional Laboratory
Oct; Ricce. Tennessee USA 37S3C
Tn,» .» 3 3re;nn: ci j o»o»' munoM 'O' D'tifnijuon 3\ » ici»nii1.c m«ing S«CJui« o( irf o'Ov.nonji naiun 01 r:5
oonien: ino •.■nta cnanefi o' luntmet O' reio.i mjv njv« lo ot nvioe oefoft DuaNcjtion. ine o'tS""' " "»o« J«3'iJ3't on t^»
unet'ttano.r!) :ijt ■! m.n not 3* c>:ca •" in« i^ie'iiufe o» in any nay Of lesfooucta m us ofei«"i 'or" The ».»Kyi racrora jr-
trit Jtjitt^en;j rrj;, '«-o.n tn» '««oon«i0.l.tv Ot tn« fnm»o juinordl. me vi«m 00 noi ofcefjr.iy ffdec: inoie ot ;r.« ;o«»'r'-
m«ni o( int cts^njnn; Mem3«r SlJt«l«' O' of m. ctJ.jnjUfifl orginuanonlj) , /n 0<a/Ci//*r, nf.inf "T '-*-•* "«" '"" 0'"?'
orytrujuon'or coox locic-no rn.i m*rr.«» ejn Bt nna rneom.oi* lo' tnr mt,,,,,, r,3,„„^.,a "< ir.t 0'ts"r>! ^
565
IAEA-SM-281/36
Impact of Core-Concrete Interactions'
in the Mark I Containment Drywell
on Containment Integrity and
Failure of the Drywell Liner
ABSTRACT
Previous containment analyses of the Mark I BWR have con-
sidered the Y-mode of containment failure as the dominant mode.
The Y-mode is over-pressure failure of the drywell liner result-
ing in release of fission products and aerosols directly into
tne reactor building. The failure pressure for this event has
been estinoted at 132 psia. However, results frcn the SASA p.-o-
crar, analyses of the Mark I BWR have indicated that high tenper-
et'jres in tne drywell during ex-vessel core-concrete interac-
tions nay result in containment failure due to seal degradation
prior to cross failure due to over-pressurization. It has
bsco-.e evicen: that a third mooe of arywell failure must be con-
s::2'=c urcer these specified acciaent conditions, in adcition
t: t'-e cress over-pressure failure and the leak-before-fai lure
roces. 'This third node of failure is local ablation of the
stee- drywell liner due to contact with the molten cerium. In
crce- to' assess the drywell liner response to heat transfer frcn
a pool of molten core debris during a core-concrete interaction,
a Celculetional procedure consisting of both code calculations
anc hanc calculations was develcpea. The general methocolocy
was to calculate tne melting attacx on tne steel liner by moiten
core ceo'is that is' simultaneously attacking the drywell con-
crete floor.
A ccmoarison of the results of the calculations inoicates
t^.at all tnree containrrent failure modes need to be considered
sirr.ul tanecusly in oroer to accurately predict the pressure-
ter-erature h'i story in a Mark I BWS drywell. Lea^cage through
drywell seals, as well as through local breaches in the liner
due to netting, must be considered when estimating the struc-
tural resDcnse of tne drywell. Tne transport of fission prod-
ucts and aerosols will also be affected by the location and tim-
ing of cor.tainrient failure, as well as mode of failure, leakage
area, and flow rate through the leakage area.
1. ir.'TP.CD'JCTION
The potential for coniainnent failure fron core rrelt acci-
dents ha been unce*- review by the Nuclear Regulatory Conr.lssion
(N^C) for sore tire. Tne possoiHty of early failure witn tne
•"•:-'. p5-:cr-ec unoe' tne ajsoices of me U.S. *L:l52r
P.e'tul story Cc.--iS5:on,
566
potential for a large release of radioactivity (aerosol concen-
tration is higher early in the accident) is the principle reason
for this attention. Containment loads that might lead to such
failure can result from severe accidents not normally considered
In the design basis of nuclear povver plants. In order to assess
the inherent capability of various containment designs to miti-
gate the effects of a broad range of severe accidents, the ISC
formed the Containment Loads Working Group (CLWG) with the ob-
jective of developing an updated evaluation of containment loads
(temperature and pressure history) and associated challenges to
containment integrity.
The overall approach was based on a standard problem meth-
odology. The CLWG management team selected a specific reactor
to represent each of the six containment designs deployed in the
U.S. These were chosen to overlap with previous probabilistic
risi< assess.T.ents in order to provide a basis for evaluating pro-
gress in ur.derstanoing severe accicent phenomena.
This paoer is an outgrowth of the SM and 0?.M oarticipa-
ticn in t.ie CLWG and specifically deals witn the likely failure
mec.-.a.nisr.s for Stanoard Proalem 4 (S?-4).
Tne Containment Loads Working Group (CL'.iG) Standard Prosle.i
C is a TC'JV-type accident secuence in a Mark I BW?. contair.r.ent
in wnicn all coolant injection fa'ils at the time of reactor
SC^a:-' frcr. 100% power. Witnout coolant injection, the core
uncsve'S wuJ'.in 30 minutes and since the ADS is assumea net
activatsc, tne primary system rerains at high pressure. Short-
ly, tne uncovered core of tne reactor begins to melt, slurcs
in:: tre ?.?'.' lower plenum, and eventually causss the reactor
lowe" he>c to fail at. approximately three hours after accicent
in:f, 2ticr.. The molten corium is assumed to be displaced onto
the re»;t:r containment drywell floor immeaiately and to begin
to i'.'.iZK tne drywell concrete.
The Mark I containment consists of the drywell, pressure
sup:re£sicn pool, downcomer vents connecting the drywell and
suppression pool, a containment cooling system, isolation
valves, etc. The drywell is a steel pressure vessel, cylindr-'-
cal at the top and spherical at the bottom. The vent systen to
the wet.^eH has eight circular downcomer pipes which penetrate
the steel crywell liner, terminating in the pressure suppression
pool. Tr.e pool is a toroidal steel pressure vessel which con-,
tains suoccoled water for condensing primary system steam during
ncrrial transients.
The c2-tic'jlar contairr.ent design chosen for Standard Prow-
ler ^ wjs tne: of me Brovns Ferry Nuclear Power Station, In
tms ccr.tiin-o"^: , tr.e nolten core debris, consisting of approxi-
ratr'/ cC cf tne c:re invertory. is ass'jned to fill downward
ir:c tre reactor peces:^! racicn for-riny a aeep pool, fillm?
tr.e ;»o c:**. ainrer.: su-ps. a^c *^cn flowing outwar- tnroucn tne
dco'-iv eve- tne anrjlar cy-el' floor area. The suro voli;~es
567
are approximately 3.8 m^. Subtracting this from the initial
corium" inventory of 32.3 m^ leaves 28.5 m^ to be spread over a
total of 132 m- of floor area. Assuming an even spread of all
the debris over the entire floor results in a corium pool deptn
of 22 cm. Although this spreading is not mechanistically calcu-
lated, it is considered reasonable for the limiting high temper-
ature debris case since pathways through the. many obstructions
are available, and there is empirical evidence that corium will
flow at depths characteristic of this calculation [1]. For the
high temperature limiting case, it is assumed that the debris
will spread up to the steel containment liner Itself.
Previous containment analyses of the Mark I BWR [2] have
considered the -r-ffiode of containment failure as the dominant
mode. The -r-mode is over-pressure failure of the drywell liner
resulting in release of fission products and aerosols directly
into the reactor building. The failure pressure for this event
hcs been estimated at 132 psia [3]. However, recent results
frcn the SASA program analyses of the Marie I BUS have incicatec
that hicn te-peratures in tne drywell during ex-vessel core-
ccr.crete interactions may result in containment failure due ts
sesl ceoraaation prior to gross failure due to over-
prassurization [^,5,6]. Recent efforts ty the Containment Per-
formance norKing Group (CPWG) have concentrated on determininc
the prosaoility and timing of over-tamperature failure of these
penetratioos, ana the rate of leakace into the reactor byildinc
[7].
It has beccne evident that a tnird trode of drywell failure
rust be considered under these specifiec accident conditions in
acc:tion to the gross over-pressure failure and the lea^-^efore-
fci'ure modes. This thiro mode of failure is local aslation of
the steel drywell liner due to contact with the molten coriun.
Since patnways througn the obstructions on the drywell floor are
cvcilable, molten core debris is assuned to flow outward from
tr.e peaestal region and contact the drywell liner. As lone as
tne coriun is at a temperature greater tnan the steel melting
te-serature, it will present a threat to the containment integ-
r:'.y due to local melt-through. Should this occur, a flow path
to the reactor building and standby gas treatment system, by-
passing the wetwell, will be availaole for blowdown of tne high
temperature concrete decomposition gases from the ex-vessel
core-concrete interaction, aerosols, and volatile fission prod-
ucts. Although some of the gap between the drywell liner and
t^e concrete is filled with fiberglass and polyester foam (see
FiC'jre 1), it is dcuDtful that they will present a sicmficant
ODStacle to tne flow of these high temperature gases from the
dry we 1 1 .
The cDjectives of this study are to:
(1) Develc? a netiodd c;:y to calcLlate the attack of mol-
te" cere ce^ns or tie dryweil line--,
568
(2) Parametrically study the impact of corium temperature,
concrete composition, and fraction of core in corium
on liner melt-through, and
(3) Compare the results to over-pressure and over-
temperature failure times for a Mark I BWR.
2. PROBLEM SPECIFICATIONS FOR SENSITIVITY STUDIES
The CLWG Standard Problem 4 addresses the timing of the
failure of the drywell due to over-temperature soaliing of pene-
tration seals (leak-before-fail) versus gross over-pressure
failure of the steel liner (t-mode failure). For S?-4, the core
debris temperature and composition, the concrete composition,
and the fraction of the core released were specified [8,9]. The
specifications of the corium and concrete compositions as well
as a sur^ary of the sensitivity calculation specifications for
S?-l are listed in Tables 1 and 2, respectively.
The asoroach taicen in tne local liner failure calculations
was sc-rewnat different than for the S?-4 calculations reocrted
in tne CLWG report [10]. For S?--, radiative heat transfer frzn
tne surface of the csriun debris to the drywell contain-ent
structures and atr;osphere was eliminated. All the sensible
■f^trz/ in tne debris was tnus forced into ablation of concrete,
maxirizinc tne concrete ercsicn rate and the generation of con-
crete de:cr.2osition cases. For the local liner failure calcula-
tior.s, however, radiative hej* transfer from the cori-jm debris
surface was r:oceled. Tnis enabled a more accurate calculation
of tne transient corium ter-.rerature, the cost Important variaole
in the calculation of the liner ablation rate. Tne concretes
tnat were used in the calculations were a basalt- and a
1 irestcne-type, identical in composition to those specified for
%?.£., The actual concrete conoosition at Browns Ferry is
a;orcxir.a:ely an average of tnese two generic concretes (see
Tarle 1). Three core debris tenperatures were assumed: 2550 K,
19CC K, 1775 K. Mechanistically, the low temperature debris
case is inappropriate since the debris probably would not be
able to flow to the liner prior to solidifying. The radius of
spreadinc of the debris on tne drywell floor was assumeo to be
apprsximately 7 meters and the depth of the debris was held uni-
form. The debris required to fill the drywell sumps was sub-
tracted frcn tne aeoris inventory in order to calculate the cor-
iun deptr. The radiative emissivity of the corium was given d
constant value of 0.5. The fraction of the core that was
allowoi to participate in tne core/concrete interaction was
assur^ed to be SO" or eCi.
Altrcjc- f^e TCUV acticent sequence is a hich pressure
secuente wi:- faili^re o' tie AOS, tms was assuned to have no
iT2:t c*^ t"e cis;cs:f!cr o: tre coriun in trie drywell upon
fs"'j'"e c' tne ?.?'.'. In o:ner worcs, tne debris was allowed to
s;resc unforn'iy ar.d hcnc-?neously across- tne floor; hig.^i
presur; jet;:ng. ir.pactioi cn tr.e Steel liner, and direct
569
atnospneric heating were neglected. Although nodeling of these
phencrnena nay be desirable, they were neglected since they were
beyond the scope of this study. A conplete Itst of the paranet-
ric calculations chosen for. the local liner melt-through evalua-
tions is shown in Table 3.
3. CALCULATIONAL MODEL
In order to assess the drywell liner response to heat trans-
fer frotTi a pool of molten core debris during a core-concrete
interaction, a calculational procedure consisting of both code
calculations and hand calculations was developed. The general
met^.odolocy was to calculate the nelting attack on the steel
liner by molten core debris that is simultaneously attacicing the
dryweil concrete floor. The calculational tool that was used to
analyze tr^.e attack of molten core debris on the drywell concrete
floor was a rodified version of the CORCON-MODi conoutar coce
L •• - J •
CC?^C:^-••001 is a general model describing the the— .al and
cr.s-.:c2: interactions between molten core deons ana strjctjrjl .
C3r;-s:s. Tne major components o: tne system are tne ccncreir
cir.ij, tne r.clten deoris pool, and tne gas atnospr.ere anc su'"-
r:,--;c:-cs asove the pool. The geo-etry of the system is forr.'j-
latec as a two-dimensional, axisymetrical cavity, altno-jcn sse-
ci'";: tsc-ztries not availaole as. coae-sup?l iea opf.or.s may be
us = ---.-.?ut.
"r:r- t-e res j Its of tne CC'.CC". c-ue calculations, tr.s naxi-
r-_- s"::r.-.i':s heat transfer coe^'^'icier^t across the gas film to
t-.r e2". sti". concrete, h^ , was calculated at eacn tTme step as
H
h.
1
^conv ^rad
interface ' abl .concrete
w-5'? Oc-'^v 2nd Urii are the convective and radiative cor;i-
pc.ents 6: neat transfer per unit area across the gas film, ar:i
'i-.te^fjce *"^ ''^abl .concrete *'*s ^^^ melt-gas filn inter-
fsciai tr-.;erature ano tne concrete ablation temperature,
respectively. Tnis neat transrer coefficient was then used as
ir.-j*. for tne calculation of the transient heat-up anc ablation
o' tr.e steel liner. Tne neat transfer from tne molten ccrvj-i to
t.-.r steei line'" was modelec as one-ciinensioral transient convec-
t-c". fozr. sensiole and laten: hea: transfer. The transient
nest-'jj o' tne liner frcn its initial temperature to the steel
rrif.r; te-:er>tjr? was calcjlate- as
570
(pel , V —iliii . n.(T, - T , ,)k
^'^ '^steel ^^ 11 steel
subject to the initial condition
Tsteel(t-O) « To " 300 K
where e is the steel density, c Is the specific heat, V is the
liner volune, and A is the contact area of the liner with the
molten core debris. Note that V/A is the liner thickness, 6.
Once the liner is calculated to have heated to Its melting tei^i-
perature of 1750 K, the rate of melting of the steel liner is
calculated until the calculational procedure is termin?ted. Tne
nelt rate of the liner is calculated as follows:
"steel^fs, steel ct ' ^i^"^! ' "^ablate^
su3:ect to the initial concition
6(t « to; » 3 cr.
whe-e hfs is the latent he2t of tne steel, T^tjia^a is the
strr* asiation terioerature, anc tj is the tine at"the start of
tne aslation calculation.
The calculation proceecs unti'. one of three criteria are
scfisfieo. First, the calcjlotion is terminated wnen tne tn-ick-
ness of steel ablatec exceecs the initial liner thicsness. Tm s
tire, tjjia-a, indicates the containment failure time at wnich
tir.e fissicn'prooucts ano aerosols would flow into the ga? be-
fween the liner and shield wall, eventually finding their way
into tne reactor building. The second criterion, wnich will ter-
minate tne calculation is when the dov/nward erosion deptn into
tne concrete exceeds the bubbled-up depth of the corium against
the steel liner. Once the erosion depth exceeds the corium pool
deptn, it is assumed that contact o: the corium witn tnc steel
is ended and the threat to tne liner is over. If the liner is
not penetrates at this time, it is not estimated tc fail by
mel t-tnroucn. The tnird criterion for termination of the calcu-
lation is wnen tne calculated conu-i-steel interfacial lempe-a-
ture falls below the steel melting t?noerature. Once this oc-
curs, melting of tne liner enos ana failure by mel t-tnrouijn is
avoided. Sere of tne pnysicil properties and physical constants
usee in tne calculations to oe flisc.:s5d are listed below:
571
Psteel " yoOO kg/n^
f'fs. steel ' 2.7 x 10^ J/kg,
Cpsteel ' 500 J/kg K.
6wail « 3 en .
4. RESULTS CF PARAMETRIC CALCULATIONS
The results of the calculations that were perforaed for the
local liner failure proolen are indicated in Table 4. Indicatea
on the table are the concrete type, coriun temperature, percent
of core participating in the interaction, total tine to fail
liner, total downward erosion at end of calculation, and thick-
ness of liner ablated. It is clear from the table that in most
cases studied, the steel liner was calculated to fail by abla-
tion very rapidly, in one case as rapidly as 3-1/2 minutes after
contact with the molten core aebris. In two of tne eicnt cases
st'jaieG, it was calculated that the liner would not fail by
local raelt-tnrougn'at all. Tnis occurred for tne 177 5 K and
1903 K corv.-i tenperature cases on the basaltic concrete. Due
to t-s low ablation te~De-sture ass'jne^ for tne basaltic con-
crete cases (-i-iSOK), tne corTun tenperatjre tro^^ei quicicly
utcn contact since tne baso'.tic concrete acts as a raoidly
fOlctinc, low tenoerature heat sink. As a result, the coriun
cerris fell very rapioly below the steel ablation te-oerature,
'1":j '<, enc'.nc tne aolation of the liner early. If at tnis tire
tne line- nac no: been calculated to have been- penetrated, it
was assurec tr.at no fu-tner tnreat :>y local melt-tr.rcjg'^^ v.ou'c
ccfjr anc tr.e calculation was ter-inated. The only basalt ccn-
crets cases in wnicr. tne crywell liner failed by nelt-thrguch
we*"? for tr.e nicr coriun tenoerature cases of 2550 '<. For tr.ese
two cases, it too< only 5-1/2 nir.utes to ablate the lire- ana
fell the crywell .
For all tne lir.estone concrete cases studied, the steel
drywe'i line;- was calculated to nelt tnrouon rapidly. The tir.e
to r.sit tnrcjcn varied fron 3-1/2 minutes for the 2550 K coriun
cases to 45 ninutes for the 1775 K coriun case. Once again as
for tne 2550 K basalt cases, varying the percent of tne core
fron 8C.% to 6:*; hao little impact on the failure times. Since
tne aolaticn ttnperoture of tne limestone-type concrete was
assuned to be 1750 K, the same as tne melting temperature of the
steel line*-, tne debris renained slightly above this temperature
lone enouon to insure tne eventual melt-througn failure of the
crywell liner, even for tne case tna; the debris initial tenper-
atjre was 1775 K,
It IS apparent fron tnese results tnat variation of the
fraction of core m the core-concrete interaction hiC no impact
en tne ablit'.cn rate for botn tne m.jn deons temperature 1 ine-
stone anc oasalt concrete cases. In none of the calculations
ci: tne corvjn cebris penetrjte deeo encuon into tne concre:e to
'. ?'n: .-. .it 2 tne C3l oj'' i' ions .
572
It is not clear if assigning the same ablation temperature
to both the limestone concrete and the Steel liner had any
impact on the results of the low te-nperature limestone concrets-
liner failure calculations. It v/ould be desirable to lower the
concrete ablation temperature by 25 K to determine if it would
lower the debris temperature below the steel ablation tempera-
ture in time to prevent failure of the drywell by melt-throusn,
in much the same way the basalt concrete calculations behave-i.
It is clear, however, that the only cases that liner failure by
melt-through was avoided were those for which the corium debris
tenperature fell below 1750 K prior to liner melt-through.
5. DISCUSSION OF RESULTS
Until recently, the most likely modes of containment fail-
ure in a Mar* I BWR were corsicereo to be over-pressuriiition of
tns drywell and structural failure of the drywell liner or far, -
ure of sealing materials due to decrjdation at elevated tsrnce-'a-
t'jres ans leaicsge through these decr»ied seals into tne reictor
buil cine.
It is now apparent that if the Hark I containment is c;ir,c
to fail uncsr the threat presentee ry an ex-vessel core-concrete
interaction, it nay occur early in t.ne interaction due to meU-
thrcucn of tne Steel drywell liner if the core debris is able to
fic^ to anc aolate tne liner. In scie cases, the dryv/oll line-
wes calcjlatei to fail witmn five r.inutes of contact wit- r.ol-
tr". core ceoris, taking as Icn: as -5 minutes in one case. 1"
0""y f..3 cases, witn relatively low temperature deoris ir,te'"£Ct-
ir.c'wit-. a hicr.ly basiitic concrete, was the liner calc-late: to
S'jrvive. •
A cc-sarison of calculated o' estimated drywell failure
tires (time after RPV failure) for tnese three failure mooes
discjssec is presented in Taoie 5. Tne calculations are for c
TC-'V occioent sequence in a 3rowns Ferry-type Mark I containr.e-'.t
witn no CSC flow. In these calculations, tne containment
response calculations were perfor-e: witn the f-tARCH I.IB com-
puter coce [12] developed at ORNL, \»nich contains sone modeling
chances specific to the Hark I not available in MARCH 1.1 [13].
Tne containment failure results v.?ii;h are presented employeo
CC?.:0*;-:'.CD1 calculations whicr. were input to MARCH 1.13 in tabu-
lar forr, bypassing the INTER mooel [K] in MARCH, whicn has
bee': snown to overpredict concrete erosion rates and gas genera-
tion rates during core-concrete inte!-3Ctions.
Tne cortiinner.t 1ea<ace t::^es cuoted in Table 3 are esti-
mated from Re:'erenc2 [7] usmo tne jressure-tenperature histo'-
les from Rcfe'-ence [101. Usmy tne rediui pre-existiny leak
area results for etnylene propylene sail r.a:e'"i2l at 500 ', tns
sei" soar-, ti-e to im t^ ate. lei'-a :e li 13 nnutes and tne r»ro
f.-r to totally Ge;i"30-2 tne seil -.ite'ir.l is 15 minutes. Tne
o.e'-:5-;e':: j'e fo^'ji"? f.-es liste: I'o-.c^te tne sj-. o' I'o
573
tines to achieve "aOO F in the drywell atnosohere , js an addi-
tional 34 minutes. All times listed in Table 5 are "time after
RPV failure."
Note that the over-pressuri ration failure times vary from
over two hours for CLWG Case 1 to over eight hours for Cases 2
and 3. Case 4, with an extrapolated over-pressure failure tine
of 16 hours, is considered highly unlikely to actually fail the
containment at all on pressure. The over-temperature failure
times from the CPWG criteria are significantly shorter, varying
from one hour for Case 1 to 3-1/2 hours for Case 2. Cases 3 and
4 are not calculated to fail at all on over-temperature. How-
ever, the local liner melt-througn calculations indicate that
failure may be expected as early as 3-1/2 to 5-1/2 minutes after
the initiation of ex-vessel core-concrete interactions for Cases
1 and 5, to as much as 45 minutes for Case 2. These tines are
r.uc?. less than the failure tines for eitr.e- of the other two
failure noces. Case - was not calculated to r.elt tnrouuh the
1 iner.
U'nat is evident from tnis conpirison is tnat all ihrez con-
tainrr.ent fa-.ljre ncces need to Be ccnsicc'sc si-ult2neously in
cr:e- to accurately predict tne pressure-teiperature history in
a i'.2r< I oWR dryweli. Lea^o'je through dryweil seals as well as
throucn local ireacnes in tr.e liner cue to r.eltino must be con-
siderec wnen estir.ati.-.g the strutfjral respcrse of tne drywe'il.
Tne trar.soort of fiss'.on procucts ana aerosols [15] will also be
ef:e:: = : oy tne locition ani f.nnc of cc.t/.inTent failure, as
ws:l as -oce o: fail -re, les^ace area, arc flow rate tnrouon t-e
les-:ace iret.
574
REFESENCcS
[1] POUESS, D., Personal Comunication, April 1984.
[2] Reactor Safety Study, "An Assessment of Accident Risks in
U.S. Conmercial Nuclear Power Plants," WASH-1400, 1975.
[3] GRIEMANN, L.G.. FAflOUS, F., WOLO-TINSAI, A., KETALAAR, D. ,
LIN, T., BLUHM, D.. "Reliability Analysis of Steel
Containnent Strength," NUREG/CR2-142, 1984.
[J] YUE, D.D., COLE, T.E., "BV/R 4/;iARK I Accident Sequence
Assessment," NUREG/CR-2S25, November 1982.
[5] COOK, D.H. et al., "Station Blackout at Brown's Ferry Unit
One - Accident Sequence Analysis," NUSEG/CS-2132, Novenoer
19S1.
[5] CC::-:, C.H. et al., "Loss of DH?. Sequence at Brown's Ferry
Uni: Qr.i - Accicen: Sequence AnalvsTS," NUREG/CR-29T3, f.av
19S3.
[7" Ccr.tainnenz Pe-formance Vicr'<irc Grouo, "Contiinnent Le2<
R2te Estimates," NUREG-1037 (for corments). Draft 4, April
4, 19S;.
[21 3!L=;=.E'=.3, (•".., "Phencmenoloc.ical Standard Prcole-is for
Dt*.. ^ f .1.. V ..^...«jr C>l«iMtif wC«7w -IW*. -WC* Wf ^^ ^^ m
[ = : S:'.= !=:!^3, M. , "Ccroletion cf E.;^ XA?.?: I, K.;.-:k II Stan- .
care ='-021 ers," NnC Ilenorancu-, Datea Januarv 20, 153-.
[1:3 S=-!S, T.P., et al., "Estimates of Early Continmen*. Loa:s
from Cere r.elt Accidents," NU?.£3/107?, Draft (July 19E5;.
[11: r-Vj:=, J.F., COLE, R.K., CCRRADINI. M.L., ELLIS, n.A.,
"C3=C3:;-"0D1:. An Inorovec Model for J'olten Core-Concrete
Interactions," SAND 80-2^15, 19S1.
[12" HAkRirJGTCN, R.?-'.., OTT, L.J., "l-'.ASCh i.i Code Inorovements
for B',;= Decradeo Core- Stuaies," Appenoix 8 of NUSEG/C-.-
317 9, Septemoer 1983.
[131 W'JOT:-;, R.C., Ave:. H.I., "MA;?CH (r^el-.do-.-n Accident
Rrs:c-:s= CHsractenstics) Code Desc-ioticn ard User's
TTanje: ," Tr.-.IG/:?-17:i. E-'.:-2'J-:^, Cc-=oe- 1930.
[1-j V.'JP.F*.-;, U.ri., "A Pre', ir.inary I'oael fcr Core/:oncrg:e
In:5';;:ions ," SA:.3-77/u37'j, Aj-jus: 1977.
[: = : g:££I-'.i, J. a.. cy'^'jls-'.:£. ?.. D£:.-.:-;g, r.s., kuhl'-^am,
V..?... L££ . K,.«.. "Kic'.or..: ': : je ^eleise i/i:-e- ipeci^'ic L'...R
Acci-e"*. Cone. *. TJ"i: Vo'.-"e I! - o.i'. ."Kir-, I Cesicn,"
3'» ■ ■7- - • •.'-.. 1 r. J ■!
575
?OLy£ST£R FOAM
BE RC LASS
ASS LAMINATS FORM
Ficure 1 C-y-'eli Lir^e' - Ccn:-.= :e 'Sir 5 ; >; U3I1 Gap Gec-^:
576
TABLE I
SPECIF ICATIOr.' OF CORIUM AND CONCRETE
.CO:;c?.£T£
LIMESTONE
BASALT
erC'.;:js fe^ky
WEIGHT
F?.ACTIONS:
CcCO,
0.30
0.01
0.^5
Cc;oh:.
O.IS
0.13
0.07
S:3-
0.01
0.57
0.3=
Free H,0
0.03
0.0-
O.C:
AUO,
0.01
0.20
0.0-
C-.^.l'JM
r
uo.
IZrCCO k:
•
ZrOj
91:J '^v
reO
12250 kc
Fe
41r20 i^C
7..
453S0 kt
1
M
4^50 kc
Cr
8C00 kc
577
TABLE II
SUMMARY OF SENSITIVITY CALCULATION
SP^tlf ICaI iU-tb F0« SP-4
Case Nunbei-
1
la
2
3
3a
4
Coriu- Soresi (r\)
5
5
3
5
5
3
Dssris TerDe-i^'j-e (K)
25:0
2:: J
17 = 5
25 = 0
2==:
T::
Ccr.crsta Tvu'S
L
L
L
B
E
3
Frss --J (•,)
3
6
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A
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581
APPENDIX B: APPROXIMATE SOURCE TERM METHODOLOGY FOR BOILING WATER REACTORS,
FAI/86-i (REFERENCE 8).
DRAFT
FAI/86-1
APPROXIMATE SOURCE TERM
METHODOLOGY TOR
BOILING WATER REACTORS
Fa'iske & Associates, inc.
16W070 West 83rd Street
Burr Ridge, Illinois 60521
(312) 323-8750
DECEMBER. 1986
582
APPENDIX D
Estimates of the Containment Ultimate
Pressure Caoacitv and the Failure Modes
The assessment of containment ultimate pressure has two different
purposes depending upon whether procedures for a sufficient containment vent
have been implemented for the various accident classes. For those designs
with containment venting procedures implemented, the assessment for contain-
ment integrity 1$ directed toward assuring that the containment integrity
would be assured until the venting pressure is achieved. For such cases, a
sorhisticated calculation for the ultimate capacity of the containment
liner, rebar and/or tendons is not required. The user can use the con-
cl'jsions drawn 'ror IDCCP "ask 10 report (0-1) which concluded that the
ultimate contairrent caoacity is at least twice the design value and usually
atS'--* 2.: tires the des'iir :-essjre. A rore sochisticated aralysis wojIs
cr.ly be recuired if the oressjre for iri.tiatinc containr«rt ventinc is
'^i""er 'r.ir. f..i;s t*"S cc*tj*r~5*" ces'tr cessure.
'"Cv.evs', icc't" c'.i" S'.i'.cticrs S-C'j'c be ci''r*ec cut tc irj.'s
tna- -.-e-e a"-" no ccv:c-s recior.s associated with the ccrtai r.rer.t oere:'?-
t'zr.i tr.a: wcjli 'ai' before the ccntainrent venting cressurs wcu'c ;e
rei:-e:. Areas wr.icn have been identified in the oast which snoul: se
surveyec tc ins'jre that such failures would not be anticipatei are liste: '.r
Table C.l. This provides a checklist for the various areas tc be sjrveye:
is induced as a guide for the user.
For those designs or scsc'fic seouercss w*<e-e cchtairreht ve't'*:
rray not be available, the assessment of containment ultimate caoacity snclc
include an evaluation of the containment ultimate oressure incluCin: t-.e
penetrations, to evaluate both the timing and the location of the ootertis':
failure. For Mark I and Mark II systems, this assessrent should ir.cluce the
structural caoadty of the dr^/well and the wetwell while also assessor; t-.e
cctential failure at penetrations in each of these regions when the contain-
ment IS strained close to the uUirate failure coni:tTons. Table C.2 lists
the assessrerts whic*- s-O'jli acccroany the vulnerjsil •: ty evaluatior 'c-
583
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containment failure. These should use the analyses in IDCOR Task 10 for
guidance. The Hark III containment systems need only evaluate the potential
for failing btlow the suppression pool water line in comparison to failures
above this location since a failure above the suppression pool water line
wouTd allow the fission products to be scrubbed through the suppression pool
tvtn after containment failure and a detailed assessment of such source
terms Is unnecessary.
TWEWUl RESPONSE OP TVg STEEL COWTAIWWEfIT SHELL
The response of the Mark I steel contalranent shell following release of core
material fron the rvactor vessel is dependent upon (1) the mass of core
material involved, (2) the temperature of the debris and the presence of
water in close proximity to the debris and the steel shell. To analyze the
shell transient response, a finite difference model wis constructed repre-
senting the tM-dimensional conduction within the ste«l shell and the
supportive concrete inside and outside the shell. Since the large differ-
ences in the thermal properties between the carbon steel and the oxide fuel
greatly favor the steel, core debris would be frozen upon contact witn tne
shell. As a result, the regions dose to the steel responsible for local-
ized heating, would be the frozen cnjst and the molten mit«ria1 next t: the
crust, with the major energy transfer process being conduction controlled in
the debris crust. This has 5een demonstrated experimentally in Re'eretce
(1). Thus, the core material was also nodal ized such that tne twc-
cTmensional csncuction process into the shell ane the concrete floor ccul2
be represented. Ouenching of the debris, wnich would occur witn an overiy-
inc water pool, was also represented in the model. Figure 1- Illustrates :re
general nooalizatlon scheme used, with the major processes being two-
dimensional conduction in the debris, and the steel shell as well as euencn-
ing with the overlying water pool.
Upon contact with the steel shell, the interface between the debris anc the
steel will establish an initial temperature (T.) given by
T, • T 1, (1)
where T. is the initial core debris temperature, T- Is the initial tem-
peratur^Sf the steel shell, o, c and k are the density, specific heat and
thermal conductivity of the core debris (subscript F) and steel (subscript
S). This temperature would remain constant until the thermal *«ve pene-
trated either the steel shell or the debris configuration, whichever oc-
curred first. In the nodal ization scheme, this temperature is used t:
central the heat flux into the inside surface node of the st«el sfe^l <jn*''1
the first nodal temperature achieves a temperature such that the interfica'
586
teinperaturt 1$ best described by the equal flux gradients between the steel
and fuel hodes. This condition 1$ given by
T^ - (kpTp^ ♦ ks^SJ^/e^F ^ '^S^ ■ (2)
when T,. 1$ the temperature of debris node i and T.. is the temperature of
stMl nbit j. dj .
Nedalitition
The finitt difftrtnce model used the nodtllzatlen seh«w shown in Figure 1,
with three Mjor regions to describe the containment shell, two regions for
the concrete and one for the core debris. Containment shell regions include
that part which is in direct contact with the debris, the region above the
contact zone and the region imbedded in the concrete. The two concrete
regions modeled are: (1) the inside of the shell which Is also in contact
with the debris and (2) the outside of the containment shell. Each of the
six major regions issubnodalized as illustrated in Figure 2, which allows
the two-dimensional temperature profiles in each region to be calculated.
The nodalization scheme is established in the upper and lower steel nodes
for a length eoual to three times the debris depth and in the concrete nodes'
to a length of three times the shell thickness in a direction orthogonal to
the shel'l . This is sufficient such that the most remote nodes can be^
assured to have adiabatic cuter surfaces without influencing the calcule-'
tlon. As stated above, the core debris region considers that a layer cf
water may cover the detris, whicn could quench the ovemeated debris frcr
aoove. 'in this recerc, it Is imscrtart that the debris be nodal ized ir e
two-dimensional manner since the debris Is close to the containment shell
would experience an Initial theraal transient due to direct contact with the'
shell. As a result, this region could quench faster since the localizes
stored energy would be suostantially less than that originally contained in
the debris.
In addition, the upper steel node above that portion in direct contact with
the core material should csnsider convective energy losses to the overlying
water pool as well as convective and radiation losses off of the outer
containment shell surface. Sioce the carton steel containment shell has a
high thermal conductivity, the regions above and below that in contact witn
the debris would be effective fins to conduct away much of the imposed heat
transfer. This 1$ particularly true when there is an overlying water pocl
since the upwerd conduction length would be very short with convective
(boiling) h«at losses to the water pool.
The calculations were checked in two ways. The first was to oerforr a
global energy balance on the three steel shell and two concrete regions
given the imposed heat flux from the overheated core debris and the heat
losses at all of the available surfaces. The second was to perform a alccal
energy balance on the core debris given the heat flux to the steel and
concrete regions as well as the internal heat generation due to decay hest
and tne Quenching of material by overlying water. For both energy balances,
the Integrated energy transfer to and from the regions were comoared to :re
587
sutratlon of th« stored energy In ill jubnodes and the energy excess or
decrement «n.th resMct to the Inltlil condition. Both showed good •greement
through th« entire transient evaluated.
Results
Using tht model t the wall thermal response for conditions when wttcr would,
end would not be available, were analyzed to show the thermal response of
the drywell shell. One of the variables controlling the shell thermal
response Is the depth of the core material in Intimate contact with the
shell. Other features analyzed using the model are the Influence of Initial
debris tcinoerature, which should also be Included In the decision making,
the extent of the nodal Ization the Influence of an overlying weter pool and
the Influence of a protective layer on the inner steel shell surface.
Figure 3 lllustrites the thermal response of the hottest steel shell node
for Initial conditions of 2100'K debris temperature, 0.12 n debris depth,
which represents approximately SOS of the core material discharged from the
reactor vessel at vessel failure, and no overlying water pool. As Illus-
trated, the tamoerature Increases over approximately 200 seconds to a value
of about SOO'K (980*F). Figure 3 also Illustrates the response of the
hottest steel node for the same Initial conditions except with water avalU
able. As Shown, the original temperature Increase for this node Is essen-
tially the same as that calculated without water but after about 200 sec-
onds. Quenching of the core material occurs and tne temperature 1s drsmat*
ically reduced. Figure 3 also illustrates the thermal resccnse witn water
available and an Increased oressure In the containment as a result of tr«e
accident scenario. In particular, the figure considers cases In wnicn the
containment pressure is 0.1 MPs (1 atm), 0.3 MPa (3 afn) and 0.5 MPa (;
acn). As snown, the" Increased drywell pressure, which provides for an
Increased cuenching rate, significantly effects the containment shell
thermal resoonse because the higher quenching rate cools the debris suffi-
ciently rapidly that the steel nodes do not achieve the peak temoerat-jre.
This is a particularly Informative result since the threat to containirent
Integrity would only arise from a substantial pressure difference across the
containment shell and this pressure difference would also mean that a
significant Increase in the quenching rate would be available. Conseouent-
ly. It is Important to consider the containment shell integrity in terms .of
both the stress applied to the shell by the internal pressure as well as the
Influence on tht debris quenching rate. In this regard, the presence of
drywell sprtyt would provide the quenching capability and at the same time
would reduce the dr>we11 pressure through condensing steam and cooling the
noncondensable gases. Both of these act to protect the shell Integrity.
These analyses Illustrate several key features pertinent to the evaluation
of the containment shell response.
0 First, they Illustrate that the thermal Inertia of the shell is
very significant and that the initial thermal transient bet>*«en
high temperature core debris and the carbon steel shell would
be strongly weighted in favor of the shell. This means that
the thermal transient would be much greater in the low tner-il
588
conductivity core MtcrUl t)un In the conulranent shell.
Constqutntly, direct contact by tht core dtbrls «ou1d not
dlnctlx fill the conulnment shell but would provide for t
thick crust formitlon of core MterUI that could further
insulate the steel shell. This crust formation would occur
virtually Instantaneously because of the large differences In
the thermal conductivity (k -w 3.3 «/«»K for debHs and 66 M/m»t
for carbon steel).
0 Secondly, the peak steel tmptrature Is not achieved until
about 100 seconds of direct contact. This Inplles that the
dynamics of the core material discharge process, which would
take place over a few seconds to a f w tens of seconds would be
relatively unimportant. Consequently, the appropriate modeling
configuration Is one In which the debris has settled against
the containment shell.
0 Thirdly, since the aoorooriau debris configuration Is one
which has settled, regions which were exposed to high temoera-
ture core deons as a result of the dyn«n1cs of the debris
distribution orocess and caused a localized frozen crust to be
formea on various structures Including the conulnwnt shell,
would not be exoosed to continued heating by molten core
material since this would drain to a lower portion of the
drywell. As a result, the frozen crust would be the only heat
generetinc xatenal wMcn could increase the temoerstures of
the local strjcfjres enc this would be a negligible ere-tv
source ccrrarsc :: :ne energy dissioatlon caoaoilitles o^ tiie
hicr. ccr.c-^ctivuy s:eel structure.
0 Fourthly, the settled debris configuration could be that due to
molten care rater:8l or solidified debris. For molten irate-
rial, the aoorooriate death of material Is represented oy
unifcrr. distribution ana the Initial temperature should «e tnat
representative of the debris discharged from the reactor
vessel. Deeoer debris depths would only be possible witn
solidified material which would have a substantially lo**--
temoerature. Therefore, In dealing with the peak temperatures
of the steel structure', the depth of core material cannot be
considered to be Indeoendent of the Initial temperature.
Figure 4 illustrates the thermal, history of the hottest shell
node for different debris depths. As shown, the deoth chances
the t«B>erature at 20C seconds by about ISO'C when quencning'is
not considered. For accumulations which would be anticipated
under severe accident conditions at Pilgrim, the peak wall
temperature would be about 700*K (800'F).
Another aspect of these analyses Is the strong temperature gradients oevel-
oped along the length of the steel shell. The highly nodalizea moael snows
that there is little terr.oerature difference through the steel shell, cut tne
upward heat losses to an overlying water pool aod the conduction losses to
tne steel imbedded in corcrete cause a strong axial temperature variation.
As a result, the region which is overneated is less than one haU c' tne
debris depth. I.e. at -cs: a few centlreters. As a result, this region
589
would exp«r1«nc« $ob« deformation, but would receive subJtantI*! jtnjctural
support froB colder regions above and below the high temperature zone.
Analyses *«rt tlso p«rfomed for a 1 on thick concrtte barrier on the inside
of the conttlnaent shell. As shown In Figure 5, this decreases the thermal
transient by •bout 150'C (250*F). A major consideration for the barrier
would be ttie mthod of anchoring the liter concrete in the presence of the
dense core debris. It should also be noted that the presence of a debris
barrier does not titer the conclusion that water should be added to quench
the debris end prevent concrete attack.
In simMry, the analyses assumed a conservative condition of debris coming
Into direct contact with the containment shell. No early failures of the
shell would be expected as a result of this eonUct and water has been
denonstnted to quickly quench the debris. It should also be noted that
water (drywell spnys for example) would tend to Inhibit or prohibit such
direct pontect from occurring.
Reference
(1) M. Epstein, et'al., "Transient Freezing of a Flowing Ceramic Fuel
Steel Channel", Nuc. Sci. and Eno.. 61^, 1976, pp. 310-323.
R£M:jaD
in
590
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595
The Chairman. That's 80 or 90 percent of the time, as I under-
stand?
Mr. MuRLEY. Again, the understanding that I have, under these
very unlikely conditions, is that it could fail, yes.
The Chairman. We'll put the entire report in the record. I'll
read two excerpts. First, "the probability of early containment fail-
ure for Mark I [boiling water reactors is] in the 80- or 90-percent
range," and second, "containment failure by melt-through is a
highly probable mechanism of early containment failure."
What Brookhaven has said is that Mark I reactors are highly
likely to rupture, release high amounts of radiation into the envi-
ronment.
Am I to understand that the NRC is permitting nuclear plants to
rely on the Mark I system to continue to operate?
Mr. MuRLEY. Yes. As I said, I think I need to say this because
people are concerned. The NRC believes that the Mark I plants are
operated safely today. We have research programs that are looking
for ways to make them safer.
The Chairman. I don't want
Mr. Murley. I don't want to leave the impression that these
plants are like Chernobyl. I think that would be a disservice, be-
cause they are not. These containments, we think, will function
and do their job in most accidents. It is only the very severe and
very unlikely accidents that we are talking about where they could
fail early.
The Chairman. That ought to be reassuring. [Laughter.]
Mr. Murley. We are looking for ways that can improve even in
those severe accidents.
The Chairman. I think that the problem that you have is that —
here you have a study that is done for your own commission that
draws this kind of a conclusion, which I have just read, and then
you respond there really isn't a problem. What are people suppose
to assume on that? You have a study for your commission which
reached one conclusion and then you comment and testify that
there is nothing really to worry about.
Mr. Murley. I didn't quite say that, sir.
The Chairman. All right. There is something to worry about?
Mr. Murley. In the sense, under very severe accident conditions,
these containments could fail, and we are looking at that. We're
looking to see what improvements can be made to reduce that fail-
ure problem.
The Chairman. Let's continue.
Mr. Murley. Questions have been raised regarding the Mark 1
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 condition. During staff review of this
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 has made a
number of changes that we believe are improvements. In early
1987, Mr. Ralph Bird was hired as the senior vice president of Nu-
596
clear. He has extensive nuclear navy and management experience.
Changes have been made in the on-site organization, additional
personnel have been hired and programs for improvement are
being implemented. The NRC staff has a special programmatic ap-
proach for assessing the Boston Edison progress at Pilgrim. Our ac-
tivities are being coordinated by an assessment panel that is
chaired by the senior staff members from Region 1, and includes
representative from the region and from NRC 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
then will assess restart readiness. It's assessment will be a compre-
hensive evaluation that considers the general readiness of the
plant and personnel to resume safe operation and will include a
comprehensive on-site team inspection.
In addition, as we indicated to you, Senator Kennedy, and to
Congressman Studds in Chairman Zech's letters of November 20,
1987, we will conduct several public meetings to insure opportunity
for public participation and input to the assessment panel regard-
ing the Boston Edison restart plan. These meetings will be formal,
transcribed sessions at which the public's testimony will be heard
by NRC senior staff. After the NRC staff has completed the restart
readiness assessment, there will be a public meeting at NRC head-
quarters at which the staff will brief the NRC Commissioners on
our findings and recommendation so that the Commission itself can
make the ultimate decision.
The Chairman. That's part of the problem. I mean with all re-
spect to your dedication and service, you hear the testimony; you
make the recommendation; then they, the Commissioners, can
either take it or not take it. There is no opportunity — perhaps you
can reach one kind of conclusion. As I understand the proceeding,
there is not much opportunity for those who differ with you,
whether they are for or against, to be able to make presentations.
The Commissioner can either take or not take your recommenda-
tions. And that, I think, is the reason or part of the reason why
people want to have an adjudicatory hearing.
Now, as I understand — would you answer this? How many of
those section 2.206 petitions for adjudicatory hearings have been
filed with the NRC?
Mr. MuRLEY. I'll have to provide you the exact number for the
record.
The Chairman. Do you know how many have been granted?
Mr. Murley. I don't know that.
The Chairman. As I understand it, one has been, and only once
did the NRC grant a special one as a result of a petition. Do you
know any reason why they don't grant any more of these hearings?
Mr. Murley. I think it is probably more than one, but we'll get
you the correct number for the record. Frequently, the petitions
that we receive are asking us to reconsider a licensing action that
we've already taken.
The Chairman. What if it comes before you make a judgment? If
we make that petition, will you support that for us?
Mr. Murley. I'm sorry
The Chairman. If we make that petition for an adjudicatory
hearing prior to the time that there is the decision; would you sup-
597
port that, given the fact that you have been here this evening, and
the type of witnesses that we have heard tonight?
Mr. MuRLEY. We already responded to that, Senator, and the
answer is that we agreed that we should get the views of the public
and we think that there are several opportunities. I've mentioned
several of them. Adjudicatory hearing rights are triggered really by
NRC licensing action, which in this case would be an action against
Boston Edison's license, which would be an enforcement matter.
Boston Edison would be the one to have the hearing rights.
The Chairman. As I understand it, it can be granted on a discre-
tionary basis. We can get the standard out, but the law, as I under-
stand it, provides it can also be done on a discretionary basis.
Mr. MuRLEY. Yes. There can be hearing rights, adjudicatory
hearing rights, granted on a discretionary basis but the Commis-
sioners have done that very infrequently.
The Chairman. But you will support our petition, Mr. Murley,
[laughter] while you're in front of all these nice people here.
Mr. Murley. I absolutely support the need to get the views of
the public and I have done that myself. I work for the Commission-
ers and I have to get their approval.
The Chairman. Let me move on to another subject. As I under-
stand, the hearing petitions filed by the utilities were granted. We
find that in terms of the discretionary power of the NRC, when
their petitions have come from them there was only one instance —
of a denial how do you think people will react to that? What the
companies want, they get; and if the people want it, they give it a
lot of thoughtful consideration. What is the perception? What do
you think people believe when the system is kind of rigged like
that? I don t mean to say rigged all the time, but when it is rigged
like that?
Mr. Murley. I understand your concern and the public's con-
cern. We do have to follow our administrative procedures. We're
professionals. We're trying to regulate in an area that is highly
controversial.
The Chairman. Order. We want to give the witness full attention
and full courtesy this evening. We still have to get additional testi-
mony and I would ask him to proceed.
Mr. Murley. I'll continue with my prepared testimony. If restart
is authorized, NRC would increase its inspection coverage for the
restart program by round-the-clock coverage in startup on-site ac-
tivity. A number of hold points would be instituted and Boston
Edison would not be permitted to proceed without NRC authoriza-
tion. These decisions would be based on the on-site inspection
team's evaluation of the Pilgrim operation.
In addition of the areas previously discussed, a number of emer-
gency preparedness concerns have been raised at Pilgrim since the
Confirmatory Action Letter was issued in April 1986. Mr. Krimm
has already testified of the FEMA findings.
On August 18, 1987, the NRC transmitted the FEMA report to
Boston Edison and requested that the utility provide us an action
plan and a schedule for assisting the Common./ealth of Massachu-
setts 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 Edi-
598
son's plans to assist the Commonwealth 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 con-
siderable resources and efforts toward resolving these concerns.
The current status, as we understand, is as follows: Drafts of local
plans were completed 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 com-
plete 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 Emergen-
cy Preparedness for an Accident at Pilgrim Nuclear Power Plant
from the Commonwealth. NRC and FEMA will consider this report
in their ongoing review. Additionally, Boston Edison submitted an
exemption request to NRC on the requirement 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 thrn June 30, 1988.
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 needed to take enforcement action regarding emergen-
cy 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 improved evacuation plans for school
and day care centers, as well as improved evacuation plans for spe-
cial needs and transportation-dependent population in the 10-mile
emergency planning zone. We will require some demonstration of
the critical aspects of these evacuation plans before we can decide
if 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
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 action and
progress toward correction of the deficiency. For Pilgrim, this deci-
sion will be made ultimately by the commission itself.
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 improvement. This approach in-
cludes opportunities for public input to the process. I want to
Eissure the committee that Pilgrim will not be permitted to restart
until the NRC staff has reviewed carefully the plant improve-
ments, the management improvements and the offsite emergency
599
preparedness improvements and has concluded that the plant will
be operated safely.
Thank you, Senator. That concludes my testimony.
[The prepared statement of Mr. Murley follows:]
600
TESTIMONY BEFORE THE SENATE
LABOR AND HUMAN RESOURCES COMMITTEE
REGARDING TttE PILGRIM NUCLEAR POWER STATION
DR. THOMAS MURLEY, DIRECTOR
OFFICE OF NUCLEAR REACTOR REGULATION
U. S. NUCLEAR REGULATORY COMMISSION
PLYMOUTH, MASSACHUSETTS
JANUARY 7, 1988
601
Thank you, Mr. Chairman, in response to the request of the Committee, 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
Licensee Performance (SALP). In early 1986 the NRC staff issued a SALP report
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 backlog with a number of
management vacancies in the maintenance area; radiological protection program
weaknesses; emergency preparedness program weaknesses; and instances of poor
procedural adherence and administrative practices at the plant. These problems
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 summer of 1986, I
revised and extended the Confirmatory Action Letter to confirm that Boston Edison
would keep Pilgrim shut down until resolution of those management deficiencies
identified in the SALP report and by the special team inspections.
602
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 committed 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
Coimonwealth 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.
603
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 at 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
emergency diesel generator, modifications 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, however, 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 review 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 has made a number of changes that
we believe are improvements. In early 1987 Mr. Ralph Bird was hired as the
604
-4-
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 for 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 programmatic 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 MRC 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
onsite team inspection.
In addition, as we indicated to Senator Kennedy and Congressman Studds 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 heard by 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 Comnissi oners on our findings and recommendations so that the Commission
itself can make the ultimate restart decision.
605
-5-
If restart is authorized, MRC 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 NRC authorization. These decisions
would be based on the on-site inspection team's evaluation of Pilgrim
operation.
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 ana
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
overall state of emergency preparedness at Pilgrim Station. FEMA subsequently
committed 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-Imtiated
606
Review and Interim Finding for the Pilgrim Nuclear Power Station, Plymouth,
Massachusetts." In this report, FEMA listed the following six areas of concern
in the Coirrionwealth of Massachusetts emergency plans for the ten-mile emergency
planning zone surrounding Pilgrim:
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.
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
requested that the utility provide an action plan and schedule for assisting the
Cotimonwealth 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 Commonwealth of Massachusetts and local governments, as well as
describing resources and a schedule for completion.
Over the past few months, Boston Edison, the Coitmonwealth, and the local
607
-7-
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 NRG received the "Report on Emergency
Preparedness for an Accident at Pilgrim Nuclear Power Station," from
the Cormionwealth of Massachusetts. NRC and FEMA will consider this
report in their ongoing reviews.
608
Additionally, Boston Edison submitted an exemption request to NRC on the
requirements for conducting its Biennial Full Participation txercise. 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.
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 neeaed to take 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
improved 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 Coimiission itself.
609
-9-
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 Conmittee that Pilgrim will not be permitted to
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
questions.
610
The Chairman. Do you know what I think is almost as much of a
problem as some of the technical issues, some of which we have
gone over— we'll have time to go over some more— but there is a
problem, I think, in the tone of your testimony, which seems to run
throughout the statement, seems to lean towards restart. It leaves
the impression that the issues have already been decided, almost as
if the NRC has already decided that the burden is on those who
believe Pilgrim should not be allowed to restart. It seems to me to
lean toward restart. Leaves the impression that the issues have al-
ready been decided. Isn't that backwards?
Mr. MuRLEY. I am the one who decided in April of 1986, that the
plant ought to stay shut down. I'm the one who told them that
there are some additional things that need to be corrected and
NRC is keeping it shut down. There is not a presumption that the
plant can restart. They have to convince us that they have made
these corrections.
The Chairman. At the bottom of page 8 of your statement, you
start off, "However, it may be that restart can be authorized with
some emergency planning issues not fully resolved."
Now, that's really reassuring, I would expect, to a lot of people.
Mr. MuRLEY. May I explain that?
The Chairman. Sure. Why can't they just maintain that they
can't restart until the State of Massachusetts is satisfied that they
have in place a more effective emergency plan.
Mr. MuRLEY. I don't mean that to be a pugnacious staternent, but
I have to explain that emergency preparedness is a changing proc-
ess. Mr. Krimm mentioned earlier that things change around the
site: population changes, new schools come in. That's why we re-
quire regular exercise of these plans. It is not uncommon to find
deficiencies in emergency plans and we don't generally require
that a plant be shut down while these deficiencies are corrected.
The defense in-depth philosophy has guided the nuclear regulation
over the years, which is an area that relies on several levels of pro-
tection. Therefore, we don't necessarily have to shut plants down
while deficiencies are corrected. Nonetheless, with Pilgrim, we
agreed that these deficiencies are quite serious and that they must
take corrective action before we allow them to restart.
The Chairman. Wouldn't you agree with me, Dr. Murley, that
there is a considerable question in the minds of many when prob-
lems which you identified, which you have gone through on the
first page of your testimony and we reviewed briefly during the
course of your oral presentation, that they would have some seri-
ous problems in knowing whether they were resolved unless— with-
out your performing another SALP prior to restart? Don't you be-
lieve that the NRC should conduct another SALP?
Mr. Murley. We are going to do a comprehensive evaluation, in-
cluding an around-the-clock inspection. I'll let Mr. Russell, who's
responsible for the SALP Report to respond to that.
Mr. Russell. Senator Kennedy, I would like to add two points to
the record as it relates to evaluation by the staff of the items which
are identified.
First, during the public hearing that we proposed to hold, the
first one was to gather concerns. We agreed to come back and hold
611
a second meeting to identify the resolution of those concerns, at
least to the staffs standards of what is required.
We have also indicated that we will conduct a detailed team in-
spection to address both the management issues and whether the
program can be put into place effectively. We have indicated to the
State of Massachusetts that they may have an observer to observe
that inspection as it is conducted by the NRC, such that they would
be in a position to see how that process is conducted.
We will also have self assessment performed by the utility them-
selves, which would be the equivalent of the utility SALP report
and the staff will be there to evaluate their performance. The pur-
pose is to compare the two results and see if the utility is able to
critically evaluate their own performance. Those are the
The Chairman. How will that differ from a SALP report?
Mr. Russell. A SALP report, if I can call it, Mini-SALP. This has
been done for two facilities recently in Region 1 for Beaver Valley
Unit 2 during their startup program and for a Nine Mile Point
unit 2 from the power ascension to actually evaluate the perform-
ance of the company in critical
The Chairman. I hear your words. I was just trying to under-
stand how a Mini-SALP is different from a full SALP?
Mr. Russell. The difference is that we specify particular areas to
be evaluated of concerns that are associated with operation.
The Chairman. Do they cover the other areas as well? Do they
have special emphasis in the areas of radiological monitoring or
the other areas that you identified for weaknesses?
Mr. Russell. We will specifically address each of the areas of the
five areas that have been identified as being marginal perform-
ance; radiological monitoring, security surveillance. Those areas I
indicated each will be addressed in detail.
The Chairman. And the other parts that are included in the
evaluation in the SALP report will also be included?
Mr. Russell. Yes, sir. We will reach a conclusion. The format
will be somewhat different. I will be issuing a readiness for oper-
ation report that will go to the Dr. Murley as a part of the delib-
erations. That will be a process
The Chairman. Excuse me for interrupting, but the hour is late.
As I understand what you say when I asked about whether you
would have a SALP report, you say there are many SALPs. You'll
look at and evaluate the critical areas which have been identified
as trouble areas and get a full report on that, and then the other
areas which you would normally do in a SALP report will also be
covered. Is that your
Mr. Russell. That is correct. They are in different documents.
The SALP report is
The Chairman. But even if they are in different documents, they
are collected at the same time. Would there be one particular place
that someone can
Mr. Murley. There is no doubt that we'll have a written report
of all those deficiencies that we found and the circumstances.
The Chairman. That will be done before there is obvious
Mr. Murley. Yes. Absolutely.
The Chairman. There is no way of knowing exactly when this is
going to be ready; is that correct?
612
Mr. MuRLEY. No. It will be well before any recommendation is
made.
The Chairman. I suppose this is important, obviously, in terms
of your own review. It is important as well that people have at
least a reasonable chance to review it and to get some recommen-
dation or reaction. Can you give us any assurances about that?
Mr. MuRLEY. I don't know that we have talked about that. I
think it is a good idea, so I will commit that we will do it.
The Chairman. You will commit to reviewing it
Mr. MuRLEY. Yes.
The Chairman [continuing]. In a reasonable time?
Mr. MuRLEY. Yes.
Mr. Russell. Senator Kennedy, I have committed to coming back
to this area to review those results following the team inspections.
The Chairman. It would be marvelous to get our commissioners,
once — well, let us try and work on that.
I may have other questions which I would like to submit to you
both. I will make those a part of the record. I will welcome your
responses. I want to thank you very much for coming up here. I
will excuse you.
[Additional material supplied for the record follows:]
613
EDWARD M. KENNEDY
MASSACHUSETTS
^niteb i^tates; i^enate
WASHINGTON, DC 20610
March 8, 1988
Dr. Thomas E. Murley
Director
Office of Nuclear Reactor Regulation
U.S. Nuclear Regulatory Commission
Mail Stop 12-G-18
Washington, D.C. 20555
Dear Dr. Murley:
First, I want to express to you my appreciation for your
participation in the Senate Labor and Human Resources Committee
hearing on the proposed restart of the Pilgrim Nuclear Power
Station in Plymouth. Massachusetts.
Since the hearing ran later than expected, there were a
number of questions which I did not have an opportunity to
ask you. At this time, I would like to request that you respond
to the attached list of questions. Your answers will be
included in the hearing record.
Again, I appreciate your assist^n^ce and look forward to
your timely response.
enclosure
614
1. There remains a great deal of uncertainty as to how the NRC
will evaluate whether lihe Pilgrim reactor is ready for restart.
As you know, I fully support the adjudicatory hearing process
and hope that the NRC will agree that an adjudicatory hearing
is the proper way to proceed. I am aware that there has been
one public meeting in Plymouth and that another meeting is
contemplated. Would you provide me with a schedule of planned
or proposed future meetings, including the location of the
meetings, who will attend from the NRC, and what public
involvement there will be at the meetings. I am also interested
in learning if a final decision has been made on Governor
Dukakis' and Attorney General Shannon's petition for an
adjudicatory hearing. If a decision has not yet been made,
when will it be made''
2. During your testimony, you mentioned that the NRC had asked
Boston Edison a series of questions relating to direct
torus venting. Specifically, Edison was asked when and under
what conditions they would utilize a direct torus vent. At
the time of the hearing, Boston Edison had not yet responded
to the NRC's questions. You indicated that a response would
be necessary before the NRC could proceed with considering
whether the installation of a direct torus vent was warranted
at Pilgrim. Has Edison responded to the NRC's questions?
If so, has the NRC made a decision on whether it will permit
the licensee to make the direct torus vent improvement?
3. During the hearing, I asked you how many times the NRC has
been formally requested to hold an adjudicatory hearing in
relation, to restarting or licensing a nuclear reactor. I
would be interested in learning who made the requests
(i.e., whether they came from the licensee, from a State
government, or elsewhere), and whether the NRC acted
favorably or unfavorably on the requests (and/or petitions)?
setts State Legislature
s
5. In your prepared statement you said, "The NRC will not
permit the facility (Pilgrim) to resume operation until
corrective actions satisfactory to the NRC have been taken
to address the Emergency Planning deficiencies identified
by FEMA" . Have those corrective actions been taken?
You also indicated that the NRC would allow the plant to
restart without the resolution of all Emergency Planning
deficiencies. What deficiencies would the NRC allow to
be left unresolved at restart?
6. You said in your testimony that a detailed team inspection
will be performed at Pilgrim prior to a restart decision.
Has that inspection commenced? When will it conclude? How
long will the public have to review the NRC's findings
relative to the inspection and prior to a restart decision?
615
7. A great deal of public concern has focused on a release
of radioactive resin which occurred at Pilgrim in the
summer of 1982. It is my understanding that radioactive
resin was found on the rooftops of buildings owned by
Boston Edison. Would you please provide all the data the
NRC has on file (including on-site and off-site readings,
dosimeter readings and stack readings) indicating what the
level of radioactivity had been in the period of time when
the resin was released.
8. In recent years ,^ Boston Edison has had unsatisfactory ratings
in the area of fire protection. 1 would like to know if
Pilgrim is now in full compliance with fire protection
requirements? Are all barriers, fire doors and penetration
seals repaired and capable of passing required testing? Are
fire watches still required in certain areas of the plant?
How many fire watches are still needed? Will the NRC
require Edison to complete the upgrading of the entire
fire protection system prior to allowing restart? How many
maintenance requests are still outstanding in the area of
fire protection? Please also comment on the condition of the
halon system in the computer room at the plant and the smoke
detectors over the spent fuel pool.
9. How many automatic and manual scrams have occurred at Pilgrim
since the plant became operational? What is the annual
industry-wide average?
10. How many "unusual events" and how many "alerts" have been
declared at Pilgrim since 1972? Please describe and give
the date of each report. How does this compare to the
industry-wide average?
11. How many violations of NRC regulations have occurred at
Pilgrim since it began operation? What is the industry-wide
average?
12. There have been a number of allegations concerning the
illegal dumping of radioactive waste on Boston Edison
property. Concerns have also been raised over Edison's
use of the town dump for disposal of radioactive material.
Would you please describe what monitoring the NRC conducts
or requires on materials and waste leaving the Pilgrim site.
Has the NRC or the licensee performed tests on Edison property
and at the town dump to ensure that there are no elevated
levels of radiation at areas suspected of containing
radioactive waste? Where and when were tests conducted?
What were the results?
13. Has Pilgrim ever violated established radiation emission
levels i.e., have there been any releases from the plant
which exceeded standards set by the NRC?
616
it--" "»'.,
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON, D. C 20556
April 29, 1988
The Honorable Edward M. Kennedy
United States Senate
Washington, D. C. 20510
Dear Senator Kennedy:
Enclosed are responses to questions forwarded with your March 8, 1988 letter
10 Thomas E. f-'urley, who testified for the Nuclear Regulatory Commission at
the Senate labor and Hudian Resources Committee hearing on the proposed restart
of the Pi Igrim plant.
A cupy cf these responses has been sent to Boston Edison Company, the licensee
for P-i Igrim, for verification of the accuracy and ccnipleteness of certain
infori.iotion. Vie expect their comments within two weeks. If any corrections
or addit-ons to the enclosed responses are necessary as a result of the
licensee's rtjview, we will provide you a revised version of our submittal.
Sincerejy, / ,,y
'^'jfchtrC. Bradburne
^_ fongressiona 1 Affairs Director
Office of Governmental and Public Affairs
Enclosure :
As stated
617
QUESTION 1. There remains a great deal of uncertainty as to how the NRC
will evaluate whether the Pilgrim reactor is ready to restart.
As you know, I fully support the adjudicatory hearing process
and hope that the NRC will agree that an adjudicatory hearing
is the proper way to proceed. I am aware that there has been
one public meeting in Plymouth and that another meeting is
contemplated. Would you provide me with a schedule of planned
or proposed future meetings, including the location of the
meetings, who will attend from the NRC, and what public
involvement there will be at the meetings, I am also
interested in learning if a final decision has been made on
Governor Dukakis' and Attorney General Shannon's petition for
an adjudicatory hearing. If a decision has not yet been made,
when will it be made?
ANSWER.
The NRC staff and local officials in Massachusetts have engaged in a continuing
dialogue on the Pilgrim situation. This dialogue has included public meetings
with the Plymouth Board of Selectmen and Chamber of Commerce, the Duxbury Board
of Selectmen, the Massachusetts Joint Comr.iittee on Energy, the Massachusetts
Legislative Committee on the Investigation and Study of the Pilgrim Station,
the Town of Plymouth Advisory Committee on Nuclear Matters, and others. The
NRC staff also participated in a public forum on the Pilgrim situation at the
618
QUESTION 1. (Continued) 2
Duxbury High School on October 29, 1987. This meeting was sponsored by the
Duxbury Board of Selectmen. Representatives from some of these groups also have
participated in NRC Region I management meetings dealing with the Pilgrim
facility, including the Systematic Assessment of Licensee Performance (SALP)
meeting held on May 7, 1987. On October 8, 1987, the NRC met with representa-
tives of the Commonwealth of Massachusetts in our Region I office. This meeting,
which was open to the public, was held to discuss agenda items proposed by the
Commonwealth, including emergency preparedness issues, the status of various NRC
technical reviews, and inspection activities expected in the next few months.
Subsequently, other meetings have been held with representatives of the
Commonwealth discussing the same topics.
The most recent meeting, which was coordinated with the Commonwealth and was
open to participation by interested members of the public, was held in Plymouth
on February 18, 1988. The purpose of this meeting was to receive comments on
the Pilgrim Nuclear Station Restart Plan.
The following is the projected schedule, location, and expected participation
for future meetings which are currently planned. The schedules are subject to
change depending on several of the integrated activities being conducted by both
the licensee and NRC staff.
1. Public meeting(s) will be held in the Plymouth area, currently projected
for late April or early May, to discuss the disposition of comments and
619
QUESTION 1. (Continued) 3
concerns raised in the February 18, 1988 public meeting. The meetino(s)
will be chaired by NRC senior staff members and members of the public will
will be invited to participate.
2. A Commission meeting, currently projected for June 1988, will be conducted
to brief the Commission on the status of licensee activities relating to plant
restart and the NRC staff's plans and schedule for completing their readiness
review. This will be a public meeting held in the Washington, D.C. area.
3. A meeting will be conducted by the N'RC staff in the Plymouth area to discuss
with interested members of the public the results of NRC's team inspection
cf the readiness of the plant, and licensee management preparations to
support the restart and safe operation of the plant. This meeting is
tentatively scheduled for July or August 1988.
4. A meeting, currently projected for July or August 1988, will be held in
the Plymouth area with State Senator William Golden and the other
petitioners who submitted the July 1986 Petition, under 10 CFR Part 2.206,
if the petitioners desire a meeting. Senior NRC staff members wi''! aiscuss
emergency preparedness, management, and plant readiness issues with the
Petitions and answer any questions they may have. Members of the public
will be invited to participate. This meeting may be coordinated with the
meeting addressed in number 3 above.
620
QUESTION 1. (Continued) 4
5. The Commission will hold an additional public meeting at NRC Headquarters
prior to making any decisions regarding the readiness of Pilgrim to
resume operations. The licensee will provide a full accounting of its
readiness to restart the Pilgrim station during this meeting. The staff
will also brief the Commission on the results of its independent inspection
and review of licensee activities.
ether public meetings, including those with Boston Edison, will be held as
circumstances warrant. These meetings will be announced pursuant to NRC staff
policy on open meetings (43 FR 28058 which is enclosed).
A final decision has not been made on Governor Dukakis' and Attorney General
Shannon's petition for an adjudicatory hearing. The petitioners were notified
by letter dated November 13, 1987 that the Petition would be treated as a
request for action under 10 CFR Part 2.206 of the Commission's regulations.
The staff is nearing completion of its evaluation of the petition, and expects
to render a decision in the near future. We will advise you as soon as we make
a decision on the petition.
Enclosure:
43 FR 28058
621
UNITED STATES NUCLEAR REGULATORY COMMISSION ^^^lo^^^^ ^0
RULES and REGULATIONS Question 1
TfTU 10, CHAPTER 1. CODE OF FEDERAL REOULATIONS-ENEROY
Conduct of Proceedings
COMMISSION NOTICES
POLICY STATEMENTS
43 FR ?e05fi
P\,t>/(*^— d 6/28/78
COM£ST< LfCtNSE AfPUCATlONS
Cf>«« M*
The Nuclear R«ru'»tory Commls-
tkm'i <NnC"s) regulfttioni In 10 CFR
2-102 cxrmJt applica-nU to conJcr in-
forciAlly »Uh the NRG techiilcAj stxff
durlJ3< reviews of domestic Dccnse or
perniri applications. TT.ese meetings
Kave served as an esienllal means for
Lhe eachange of te<lTj\lcaJ Lnformallon
and ricws necrssiry for the Lechrucal
reyUrw of appllcatlona. For several
yean other parlies or potential parUcs
Xo dooicstlc UcensLn* proce^<lLngx. as
vtU %s mexbers of the general public,
have, upon request, been perraitt^ to
attend applicant-NRC technical sUff
n>e<lln^ as obscr\ers. However, the
CDmrrilsslon'i regulatJona do not re-
quire that others be perroltted to
attend «uch LnformaJ meetlng3 be-
twcec applicant and »taTf. and Ihc
gcnermJ practice being rolJo»ed In this
regard has never been formally anlcu-
lited- This statement Is Intended to
prov-,<ie such articulation. It Is also
Doted thai this matter Is related to the
prT:\-.sion for Lncreaied public parllci-
patJoo which was approved by the
Ccm=iIssion during Its consideration
of SVREG 0192 (Denton Report).
As a genera] matter, the Commission
ar>d ciAlf try to Involve concerned cill-
rens In any Commission activity In
whuiii they have eiprcs^ed an Interest.
All oeettngs conducted by the KRC
techr_ic*l staff as part of Its review of
a particular domestic license or permit
appb<=atlon (Including an application
for aji amendment to a license or
perm-T; > will be open to attendance by
aE pa_-^les or petitioners for leave to
tntenene In the case. These meetings
axe tnUnded by the NRC technlcai
rtaif to faclLtate an exchaxige of Infor-
maticM^ between the applicant and the
r-aiL It Is expected that the NRC
tec.^nicAl staff and the applicant will
artiveJy participate In the meeting.
Others may attend as observers Like-
w-tse. when meetings aje scheduled be-
tweera the staff and other parties or
petltA^ners. applicants would be per-
mitted to attend only as observers.
The general policy of open meetln*^
descr;"bed above will admit of only a
few exceptions, which must be ap-
proved by the Director of the relevant
d:%-Lsion. For example, some persons
ir-ay not be permitted to attend meet-
ings where classified or proprietary In-
JorTTL-ation (including sensitive sale-
rua.-ds Information) is to be discussed.
The NRC staff will prepare a written
•ummary of the unclassified and non-
propneta.''> portlorj of sjch meetings
and for\*.ard the summary to interest-
ed persons unable to attend so that
they will be Inr^rmed of uhat tran-
opired ai the merting How.ever. at-
tendance ftill not be limited solely be-
cause p'-elLmir.ary opinions, recora-
tnendatlcns. or adUce ulll be offered
on the merits of the applications
during the meeting.
When a par'.y or petitioner for leave
to Lnterxene requests, reasonable ef-
forts u U: be made b> the NRC slaff to
Inform the parly or peliiioner of
forthcoming meetings conducted by
the NRC technical staff so that appro-
priate arrangements for attendance
can be made. It is recognized that In
some cases the need for a prompt
meeting may make It Lmpossible or Im-
practicable to notify all parties and pe-
titioners The policy described above
also CAJuiot practicably be applied to
chance encounters belaeen NRC tech-
nical slaff personnel and other parties
or petitioners but such chance encoun-
ters will not be permitted to serve as a
source of Information for the conduct
of licensing reviews.
46 FR 28533
Publ.thad S/27/81
StTlement of Poflcy on Conduct «
Licensing ProcMdln^ /
L Backsrouod /
The CommisBion has reviewed the
docket of the Atonuc Safety ind
Ljceosmg Board Pane! (ASi^P) and ibt
current statuj of proceedy(gi before lt«
individual boardB Id a *^nei of pubUc
rreeri.ngs, the Comzmsa^n h3i examined
at length all .-najor clafaentt \n Its
licensing procedurey4t Is clear that a
niimber of difK mi I Problems face the
agency as It ende^on to meet lU
respoQsibLlitie* in the licensing area.
TbiA i> e^peoalif tk« eas* vt^h repaid to
rt-^ejie<i. for aTp^cxheo* for oaciear-
pow«r pUW Of tratjij uceoaeab
tiiatcc^aiily. VRC operBtfos ticesmo^
reviewaJiai* been com p^edsnid tb*
IlccnsA^asued fay th« thzn tba Budaav
plaotA ready to opesfttaLyGM^fiartb*
D • tba b eaungi rm a txuztcef of
I licraa ap^jUcatioca maty oat
^coochided beforv cmotriKitiDa te
Jeted. Thia ai^iatioa is •
/conser^.-FTvy of the Threa Liile laUnd
(TMI} aeodant. whrdb required a.
reexamurat^on of the entirt regniAlo
)L-ucrure. Aiter TMl, for oref a year i
a ball, lhe ConmssaraDt attsabtTO i
resource* were focu5#d on pliQia wb
were sLready Lceoaed lo operatj i
the pre*«rauoo of ao Kboa pJ*i i
fpecified chac^e« oecraajy for r
a« • result of lhe acck^m
Although ilaff review of f
\kxTaB applkatli?B» was deU j
this period. QtlHtiea which had)
cocsa"uct:cn3 penmU conthmra to boikl
the authortied pTaatA. 7ht ataJi la as
expediting ilj renew of tht crpiicati
aod aa unprecedented (mrnhfet of
heanng» are ichedaJed in iJjfe ncoa 2
moDlhs. Majiy of iheie pn
concern appUcaUons tor oAeratizif
license*. If theae proceeding* «r« aot
ccocKided prior lo the cocipIebaB ci
cocstTJCtJoa the coil ofiuch delay
couid reach Whons of doUara. The
ComEasioD will scei so avoid or reifuct
juch de!ay» wbeoeverAneajurct a/»
a> aiable that do not LD^proniute ihs
Comjiuiiioii'* fuDdadbectaJ conmntmanl
to a fair and ihorouyi Ijeanng pfoceaa.
Therefore, the CopniissioQ it laauii^
thif pobcy ttilemepi od the need for tfaa
ba'-Anced ari eSJaent conduct of aU
phase* of the hearing procesa, Tha
Comnisiion sppreaatei lhe many
<iLlTiciJtlea facea by It* boarda In
cooducUng ibeae coclentlou* and
complex proceeding*. By and larga. tiM
board* have fterforxed very welL iTiia
document i* litended to deal with
problem* nof prtmanJy of the boards'
own malcma However, the board* will
play an usFcbnaot rolt m resolving »«cli
dJTicultjea/
Lndivid-Jal adjudicatory board* art
encouraged to expedite the heanag
prc-:^-5* ay -daLiig ihoee mana^emaoj
me'Jiod* aLready axuaajed ji Pvi I of
lhe Coi^jmssioo * Rule* axul
Pe^.'apons. The O;mnij3iion wisbaa to
er^ph/sjie LSough that, in expedjtuig tba
he*n/gs. lhe board *>iouM eniura that
the 'wanngs are fair, and produce a
frd vsihich !«»d» to high qualify
dei^sjoD* L^at ade^^uately prefect iba
puhiic health and tal^ty aad lb*
|\iionAeDL
/VLrtoaDyaH of lh« procecinrfti davtca*
I jn this Si^tesaefii are cuowkdjp
t«iri^»avplo7ed by «ttlcg board* to
/varyiz^g degree*. 'nkeCoaun»a>«La'fr
r ree.:it^k^sj« of iha s3« of SMcb taoU is
u>i£iMJ*d to reduca iha [imft (or
complattag Ucanaic^ proceedJji^ Tb*
guidehfta&a«4CaftKbekwar«DO< t« b*
PS-CN-1
December 31, 1985 freset)
622
QUESTION 2. During your testimony, you mentioned that the NRC had asked
Boston Edison a series of questions relating to direct torus
venting. Specifically, Edison was asked when and under what
conditions they would utilize a direct torus vent. At the time
of the hearing, Boston Edison had not yet responded to the
NRC's questions. You indicated that a response would be
necessary before the NRC could proceed with considering whether
the installation of a direct torus vent was warranted at
Pilgrim. Has Edison responded to the NRC's questions? If so,
has the NRC made a decision on whether it will permit the
licensee to make the direct torus vent improvement?
ANSWER.
The Boston Edison Company (BECo) has not yet responded to the questions we posed
on August 21, 1987 concerning BECo's submittal of a design for a direct torus
vent (DTV). As stated in the testimony, the questions must be resolved before
the system is placed into service. The DTV, a hard pipe designed to be capable
of providing a path that could withstand high pressures from the containment
torus structure to the plant stack, has been installed but with a physical block
(blank flanges) to prevent flow and isolate it from the low pressure path. The
piping, supports, and blank flange were installed by BECo pursuant to provisions
of 10 CFR Part 50.59.
623
QUESTION 2. (Continued) 2
10 CFR Part 50.59 allows licensees to niake changes to their facility as
described in the safety analysis report without prior Comniission approval, if
the proposed change does not involve a change in the technical specifications
incorporated in the license or an unreviewed safety question.
An inspection team was sent to the Pilgrim site during the first week of March
to review the blanked off vent line. The objective of the inspection was to
verify the adequacy of the plant modification and associated licensee safety
evaluations. Although the vent line is not operational, we chose to confirm that
the plant modification (including the installation of the piping, supports and
blank flange) does not adversely affect the function of the other plant systems,
structures or the plant response under accident conditions. The inspection team
concluded that the plant modification was adequately evaluated by the licensee
and the design change had been made with no adverse impact on plant safety. The
conclusion was based on a system walkdown, inspection of the supporting documen-
tation, and interviews with utility personnel. At this tine the NRC has not
made a decision on allowing the completion of the installation or operation of a
direct torus vent system.
624
CI'ESTION 3. During the hearing, I asked you how many times the NRC has been
formally requested to hold adjudicatory hearings in relation to
restarting or licensing a nuclear reactor. I would be interested
in learning who made the requests (i.e., whether they came from
the licensee, from a State government, or elsewhere), and whether
the NRC acted favorably or unfavorably on the reouests (and/or
petitions)?
ANSWER.
There have been contested operating licensing proceedings for most operating
nuclear power plants. Our log shows some 80 proceedings. There have also
been some 70 proceedings involving amendments to power plants' operating
licenses. Many amendment proceedings could affect continued reactor operation.
We have identified 6 proceedings directly Involving power plant restarts:
Browns Ferry - 1975; Changes involving startup a^ter fire;
Intervener B. Garner. Commission authorized operation,
Humboldt Bay - 1977; Request to delete seismic upgrade requirements allowing
startup of the facility; Intervenor Sierra Club, Friends of the Earth.
Proceedings terminated after licensee notified NRC of intent to decommission
the facility.
625
QUESTION 3. (Continued) 2
Trojan - 1978; Proceedings on Commission Order requiring modifications to
Control Building; Interveners D. McCoy, C. Parson, N.Bell, E.Rosolie,
S.Willingham, Coalition for Safe Power, Columbia Environmental Council,
Bonneville Power Authority, State of Oregon. Commission authorized operation.
Rancho Seco - 1979; Proceeding to permit operation after post-TMI shutdown
Order; Licensee requested hearing; Intervener California Energy Commission
et.al. Commission authorized operation.
Three Mile Island 1 - 1979; Proceedings to permit operation after post-TMI
shutdown Order; Interveners Commonwealth of Pennsylvania, UCS, TMI Alert,
Mr.S Mrs. Aamodt. Commission authorized operation.
San Onofre Unit 1 - 1984; Seismic shutdown Order recission; Hearing requested
by Sierra Club et.al. Commission denied request for hearing and authorized
operation.
We also looked at 81 published Director's Decisions issued since February, 1979
that relate to power reactors. In 30 of those cases, petitioners made requests
under 10 CFR § 2.206 that could fairly be construed as requests for adjudicatory
hearings. (Petitioners rarely used the word "adjudicatory".)
A brief explanation of the process associated with petitions filed under
10 CFR § 2.206 is called for. Under 10 CFR 2. 206, any person may file a request
with an NRC director "...to institute a proceeding pursuant to § 2.202 [Orders
to Show Cause] to modify, suspend or revoke a license, or for such other action
626
QUESTION 3. (Continued) 3
as may be proper." There is no requirement for the petitioner to demonstrate
a legal interest in the matters raised in the petition.
Only rf the flRC institutes a proceeding in response to the 2. 206 petition,
will members of the public be given an opportunity to request a hearing and
demonstrate the requisite legal interest in the proceeding so as to be allowed
to intervene. The demonstration of requisite interest is not affected by the
fact that the petitioner to intervene had filed a 2.206 petit'on; it is an
independent requirement.
Thus, granting an adjudicatory hearing directly in response to a 2.206 petition
would be legally inappropriate. The reason is that a 2.206 petitioner has no
right to a hearing. Illinois v. NRC, 591 F.2d 12, 14 (7th Cir. 1979). For
this reason, the NRC has never granted an adjudicatory hearing in direct
response to the request of a 2.206 petitioner.
Nevertheless, in two instances, requests by petitioners did indirectly result
in adjudicatory hearings. In one case, an Order to Show Cause issued in response
to a petition resulted in a proceeding. See Dairyland Pcv/er Cooperative
(Lacrosse Boiling Water Reactor), DD80-9, 11 NRC 392 (1980). In a second
case the Commission decided to hold a discretionary adjudication to resolve
safety issues raised by a petition and Director's Decision responding to the
petition. See Consolidated Edison Co. of New York Inc. (Indian Point Unit
No. 3), DD-80-55, 11 NRC 351 (1980). See also Consolidated Edison Co. of
New York Inc. (Indian Point Unit No. 3), CLI-81-1, 13 NRC 1 (1981).
627
QUESTION 4. You may be aware that the Massachusetts State Legislature is
considering a bill which would expand the Emergency Planning
Zone around nuclear power plants in Massachusetts to 50 miles.
Would the NRC support this initiative?
ANSWER.
It is the NRC view that the current detailed planning requirements for the
10-mile plume exposure pathway EPZ and 50-mile ingestion exposure pathway EPZ are
adequate to assure that prompt and effective actions can be taken to protect the
public in the event of an accident. We do not believe there is a need from a
public health and safety standpoint to expand the 10-mile plume exposure pathway
EPZ around nuclear power plants to 50 miles. However, this does not preclude a
State and utility from working together to develop supplemental planning for the
plume exposure pathway for a'-eas beyond 10 miles if they so desire.
628
QUESTION 5. In your prepared statement you said, "The NRC will not permit
the facility (Pilgrim) to resume operation until corrective
actions satisfactory to the NRC have been taken to address the
Emergency Planning deficiencies identified by FEMA". Have those
corrective actions been taken? You also indicated that the NRC
would allow the plant to restart without the resolution of all
Emergency Planning deficiencies. What deficiencies would the
NRC allow to be left unresolved at restart?
',NSWER.
Progress has been made to date toward improving the offsite emergency prepared-
ness programs at Pilgrim and correcting the emergency planning deficiencies
identified by FEMA. Drafts of the local emergency plans have been completed and
six of these plans have been forwarded by the Commonwealth to FEMA for informal
technical review. The draft Massachusetts Civil Defense Agency Area II p'lan has
essentially been completed and is being reviewed by the Commonwealth. The
draft of the Commonwealth plan for Pilgrim is nearing completion.
As indicated in the testimony, the NRC may authorize restart with some planning
issues not fully resolved. In reaching this decision, the NRC will examine
each planning deficiency and weigh the significance of the deficiency, the
nature of any compensatory actions, and the progress being n:ade by the Common-
wealth, local governments and the licensee toward correction of the deficiency.
Our apporach to these issues is not unique to the Pilgrim facility. A similiar
process occurs at all operating nuclear plant sites in the
629
QUESTION 5. (Continued) 2
United States because of the dynamic nature of the emergency planning process.
In practice, we expect that emergency response plans will be revised and
improved on a continual basis. Deficiencies identified during the ongoing
review process and in biennial exercises at each of these sites are assessed for
significance and plants may be allowed to operate while the deficiencies are
being corrected. Given the progress to date at Pilgrim, it is premature at
this time to attempt to determine which, if any, deficiencies will remain when
restart decisions are to be made. However, the NRC will give special attention
to the corrective actions involving the emergency response plans for schools and
day care centers as well as the emergency response plans for special-needs and
transport-dependent populations in the plume exposure pathway emergency planning
zone.
630
QUESTION 6. You said in your testimony that a detailed team inspection
win be performed at Pilgrim prior to a restart decision.
Has that inspection commenced? When will it conclude? How
long will the public have to review the flRC's findings relative
to the inspection and prior to a restart decision?
ANSWER.
Prior to consideration of Pilgrim plant restart, the NRC will conduct an
Integrated Assessment Team Inspection (lATI) at Pilgrim to review and evaluate
the effectiveness of licensee corrective action programs in order to determine
the readiness of the plant and licensee personnel to support the restart and
safe operation of Pilgrim. The inspection will encompass a three week period
and is tentatively scheduled for June 1988, based on a projection of licensee
activities. It is expected that the report documenting the findings of the
team will be issued approximately one month prior to the planned public
Commission meeting to consider a restart decision. As noted in our response
to question 1, the NRC will hold a public meeting in the Plymouth area in
July or August 1988 on the findings of the inspection team.
631
QUESTION 7. A great deal of public concern has focused on a release of
radioactive resin which occurred at Pilgrim in the summer of
1982, It is my understanding that radioactive resin was found
on the rooftops of buildings owned by Boston Edison. Would you
please provide all the data the NRC has on file (including
onsite and offsite readings, dosimeter readings and stack
readings) indicating what the level of radioactivity had been
in the period of time when the resin was released.
ANSWER.
In response to your request, we have made a comprehensive search of our files
regarding information on the radioactive resin release at the Pilgrim Station.
Enclosed are all the documents which were found as a result of this search.
Enclosures 1 and 3 provide the most detail concerning the event itself. Figure 1
of Enclosure 1 indicates the extent of the contamination by the resin found on
June 11, 1982. All contamination found was within the site boundary. Figure 1
of Enclosure 1 provides a detailed map, but basically contamination was found as
follows:
C'.ESTION 7. (Continued)
632
.ocation
Activity in disintegrations
per minute (CFM)*
Aocinstration Building Roof
Turbine Building
AOG Building
Retube Building
Main Transformer Area
Pavement curb near Retube Building
Pavement curb near Administration
Building
100,000 - 200,000 DPM
100,000 DPM
200,000 DPM
200,000 DPM
1,000 - 25,000 DPM
20,000 - 80,000 DPM
100,000 - 200,000 DPM
Enclosures:
1. Inspection Report No. 50-293/82-20, dated August 5, 1982.
2. Letter from R. W. Starostecki, NRC, to W. D. Harrington, BECo, dated
June 16, 1982.
3. Letter from J. E. Howard, BECo, to R. W. Starostecki, NRC, dated
July 15, 1982.
4. NUREG-0837, "NRC TLD Direct Radiation Monitoring Network," Progress Reports
for January through September 1982, Vol. 2 Nos. 1, 2, and 3.
5. Memorandum from R. J. Mattson, NRC, to H, R. Denton, NRC, "Generic Implica-
tions of the Release of Spent Demineralizer Resins from Pilgrim,
Unit No. 1," dated July 8, 1982.
*In discrete small piles of resin of several grams.
633
QUESTION 7. (Continued) 3
6. Memorandum from J, L. Pellet, NRC, to K. V. Seyfrit, NRC, "Technical Review
Report on Pilgrim 1 Resin Migration," dated April 19, 1983.
7. Event Evaluation Sheet, "Spent Resin Release," dated June 14, 1982.
8. IE Information Notice No. 82-43, "Deficiencies in LWR Air
Filtration/Ventilation Systems," dated November 16, 1982.
9. Pilgrim Nuclear Power Station, "Radioactive Effluent and Waste Disposal
Report Including Radiological Impact on Humans," January 1 through
June 30, 1982, dated September 1, 1982,
10. Pilgrim Nuclear Power Station, "Radioactive Effluent and Waste Disposal
Report Including Radiological Impact on Humans," July 1 through
December 30, 1982, dated March 1, 1983.
634
EIJCLOSURl 1
to QUESTION 7
Report No. 50-293/82-20
Docket No. 50-293
License No. DPR-35 Priority — Category_
Licensee: Boston Edison Company
800 Boylston Street
Boston, Massachusetts 02199
Facility Name: Pilgrim Nuclear Power Station
Inspection At: Plymouth, Massachusetts
Inspection Conducted: June 11-13, 1982
In-.pectors: R- L NJ \aw^ Sisl ft"
R. L. Nimitz, Radiat'fon Specialist date
g/?/e-4t
Approved by:
M. H. MbBr'ide, Ph.D., Radiation Specialist date
J. J. Kottan, RadiatHin Laboratory date
Special i st
E. G. Greenman, Acting Chief, Facilities date
Radiation Protection Section
Inspection Summary:
Inspection on June 11-13, 1982 (Inspection Report No. 50-293/82-20)
Areas Inspected: Special, announced inspection of initial licensee actions after
spent resin was found on roof-tops and pavement within the protected area of the
Pilgrim Station on June 11, 1982. Areas inspected included: initial contam-
ination identification, contamination surveys, posting and barricading, resin
removal, resin source determination, notifications and initial and long term
planned corrective actions. Upon arrival at the site at 10:30 p.m. on June 11,
1982, the inspectors toured the site to review the extent and control of the resin
contamination. The inspection involved 33 inspector-hours onsite by three
region-based inspectors.
Results: No violations were identified.
635
DETAILS
1. Persons Contacted
W. Armstrong, Deputy Manager, Nuclear Operations
W. Anderson, Watch Engineer
J. Bunning, HVAC Supervisor, Johnson Controls
L. Dooley, Health Physics Engineer
B. Elderidge, Senior Radiological Engineer
J. Frazer, Instrumentation and Control Supervisor
*R. Machon, Nuclear Operations Manager
*C. Mathis, Deputy - Nuclear Operations Manager
A. Richards, Health Physics Engineer
K. Roberts, Chief Maintenance Engineer
J. Smallwood, Chemical Engineer
*P. Smith, Chief Technical Engineer
V. Stagliola, Senior Waste Management Engineer
'denotes those persons attending the exit interview on June 13, 1982
The inspector also contacted other licensee personnel during the inspection.
Purpose
The purpose of this special inspection was to review the licensee's
actions after spent resin was found on roof-tops and pavement within the
Protected Area of the Pilgrim Station on June 11, 1982.
Description of Identification
During a tour of the Retube Building Roof (see Figure 1) at about 1:00
p.m. on June 11, 1982, a Radiation Protection Technician saw resin in the
building's rain gutters. Subsequent contamination surveys of small piles
of the resin (about several grams) indicated activity levels of 100-200,000
disintegrations per minute (DPM).
Inspector Review
The inspectors reviewed the following licensee actions taken after identi-
fication of the spent resin.
4.1 Contamination Surveys
The review of this area indicated that, when the resin was found the
licensee immediately pertormed surveys of the entire Protected Area
and selected areas of the Licensee Controlled Area. The surveys
were completed within about 2 hours of initial identification of the
resin.
Areas surveyed included: roof-tops of other buildings, pavement
areas, storm drains, security access area, parking lots, automobiles
and the shore front area.
636
The licensee identified resin contamination on the Reactor, Turbine,
Administration, and Augmented Off-Gas Buildings. Resin was. also
identified on two areas of pavement (see Figure 1).
No resin contamination was found off site or in the storm drains/
3ased on this review, the licensee performed adequate initial contamina-
tion surveys to define the extent of resin contamination.
No violations were identified.
4.2 Personnel Contamination Surveys
The licensee's normal personnel contamination survey requirements
includes the requirement that personnel exiting the Controlled Area
perform a complete whole body frisk. In addition, personnel are
required to pass through high sensitivity portal monitors at the
security access/egress area.
Subsequent to the resin identification, the licensee initiated a
requirement that all personnel exiting the security access/egress area
perform contamination surveys of their shoes with a thin window detector.
The requirement to perform the additional surveys was implemented
within about two hours after the initial identification.
No shoe contamination was identified.
No violations were identified.
4.3 Posting and Barricading
The review of the posting and barricading of selected contaminated
areas, indicated the licensee had posted and barricaded the areas in
an expeditious manner and in accordance with station procedures.
No violations were identified.
4.4 Spent Resin Removal
The review of this area indicated the licensee initiated vacuuming of
the resin from the contaminated areas and from the Reactor Building
Contaminated Ventilation Exhaust System in an expeditious manner.
To further expedite the clean-up operation, the licensee ordered
additional vacuum cleaners. These vacuum cleaners were to be flown in
by airplane.
During removal of resins from the pavement and roof-top areas, the
licensee also collected airborne radioactivity samples. No airborne
radioactivity was identified.
637
4.5 Source Identification/Initial Corrective Action
The inspectors' review of licensee actions taken following identi-
fication of the spent resin indicated that the licensee immediately
initiated an investigation to determine the source of the resin contami-
nation.
The licensee's initial findings indicated the resin was entering the
ventilation system during resin cleaning operations. The licensee
subsequently suspended all operations which could result in further
resin releases to ventilation system duct work. Figure 2 provides the
apparent resin contamination/release pathway.
The inspector's discussions with licensee representatives regarding
the initial identification of spent resin in the ventilation system
showed that spent resin had been identified in the ventilation system
prior to the identification of the resin on roof-tops. The inspector
also noted that dry radioactive resin was found in the "B" Stand By
Gas Treatment (SBGT) System on September 27, 1981. (Inspection
Report 50-293/82-01).
The SBGT System exhausts air from contaminated ventilation systems In
the Reactor Building as does the Reactor Building Contaminated Area
Exhaust System. Consequently, the inspector noted the identification
of spent resin in the SBGT System would serve as an indication of
possible resin contamination of the Reactor Building Contaminated Area
Exhaust System. The latter system vents to atmosphere via the Reactor
Building Vent Stack.
Licensee representatives stated that in September 1981, the Reactor
Building Contaminated Area Exhaust Filters were found to be by-
passing, apparently due to improper filter fit and degradation and
were subsequently replaced. The licensee representatives stated that
the contamination most likely exited the plant vent via the by-pass
prior to the repair of the filters.
The Inspector indicated that circumstances surrounding the initial
ventilation system contamination and the licensee's actions taken
would be reviewed further during a subsequent inspection.
(50-293/82-20-01)
4.6 Notifications
The inspectors reviewed the identification of the spent resin event
with respect to the requirements of 10 CFR 50.72, "Notification of
significant events." Upon evaluation it was determined that the
detection of the contamination did not constitute a significant event
as described in 10 CFR 50.72.
638
Inspector discussions with the Pilgrim Station Senior Resident Inspector
indicated that he noted additional personnel activity (about one hour
after the licensee's initial discovery) and questioned licensee representatives
regarding this activity. Licensee representatives stated that the additional
activity was the result of resin identification on roof-tops.
The Senior Resident Inspector subsequently notified NRC Region I. The
licensee also notified the NRC Operations Center of the resin contamination.
No violations were identified.
Long Term Corrective Action
The inspector met with licensee representatives on June 12, 1982 to
discuss the licensee's plans for long term corrective actions.
As a result of these discussions and a followup telephone conversation on
June 15, 1982 between the Director, Division of Project and Resident
Programs, NRC Region I and the licensee, a Confirmatory Action Letter
(No. CAL 82-19) dated June 16, 1982, was sent to the licensee to document
the NRC's understanding of planned actions.
The letter stated the NRC understanding that the licensee would undertake
and complete the following actions:
Discontinue back flushing, regenerating or ultrasonical ly cleaning
condensate demineral izer spent resins until the source of the resin
contamination of ventilation systems is identified and corrective
actions taken for its cause. In the event long term plant design
changes are needed to correct the cause of the resin release to the
ventilation system, resin cleaning operations may be performed
provided that: a) appropriate procedure revisions and other admini-
strative controls are established to prevent further resin releases
to the ventilation system; b) a test of the adequacy of the procedure
revisions and other administrative controls is performed using clean
resin and; c) the integrity of the Contaminated Exhaust Ventilation
filters has been verified by DOP testing.
Inspect or test all potentially effected safety-related ventilation
system co.nponents (e.g. Secondary Containment Isolation Dampers) to
verify their operability and the absence of resin. In the event
resin cortamination is identified, the resin will be removed. The
results of this inspection shall be documented for subsequent NRC
rev i ew .
Inspect clean air intake ventilation filters or ducts for all potentially
effected station structures to verify absence of resin. In the
event resin contamination is identified, the resin will be removed.
The results of this inspection shall be documented for subsequent
NRC review.
639
Inspect the Reactor Building plant vent monitor to verify its opera-
bility and the absence of resin in the sampling system. The results
of this inspection shall be documented for subsequent NRC review.
Establish a surveillance and preventative maintenance program for
contaminated ventilation exhaust systems to ensure exhaust filter
integrity. This program will also include provisions for system
inspection to identify resin accumulation.
Provide to the NRC Region I office by July 15, 1982 a report detailing
the history and extent of the duct contamination, i^s causes, and
the circumstances surrounding the release of radioactive material.
This report will also describe the corrective actions taken and the
additional management oversight initiated to prevent recurrence.
The licensee provided the requested report in a letter dated July 15,
1982. The licensee's implementation of the remaining NRC understanding
will be reviewed during a subsequent inspection (50-293/82-20-02).
6. Exit Interview
The inspector met with licensee representatives (denoted in Section 1 of
this report) on June 13, 1982. The inspector summarized the scope and
findings of the inspection.
640
FIGURE 1
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641
FIGURE 2
SPENT RESIN CONTAMINATION/RELEASE
PATHWAY
Reactor Building Vent
To Main Stack
Standby Gas
Treatment System
imTT
1
six Condensate
Demlnerallzer
Vent Valves
Reactor Building
Contaminated Area
Exhaust Filters and Fans
:rp
Gas
Scrubber
Vent from
Cation Regeneration
Tank
Vent from
Resin storage
Tank
1. Possible source prior to repair.
2. Apparent source during backwashlng.
3. Possible source during resin transfer
4. Filters found to be by-passing about September 1981.
Docket No. 50-293
CAL No. 82-19
642
^^ ENCLOSURE 2
ije Jl"* ^°^ ^0 QUESTION 7
Boston Edison Company M/C Nuclear
ATTN: Mr. Wnilam D. Harrington
Senior Vice President, Nuclear
25 Bralntree Hill Office Park
Bralntree, Massachusetts 02184
Gentlemen:
This refers to our telephone conversation on June 15, 1982 regarding the
Identification of spent resin on roof-tops and pavement within the protected
area of the Pilgrim Station on June 11, 1982.
With regard to the matters discussed, we understand that you have undertaken
or will undertake and complete the following actions:
1. Discontinue back flushing, regenerating or ul trasonlcal ly cleaning condensate
demineral 1zer spent resins until the source of the resin contamination of
ventilation systems Is Identified and corrective actions taken for its
cause. In the event long term plant design changes are needed to correct
the cause of the resin release to the ventilation system, resin cleaning
operations may be performed provided that: a) appropriate procedure
revisions and other administrative controls are established to prevent
further resin releases to the ventilation system; b) a test of the adequacy
of the procedure revisions and other administrative controls 1s performed
using clean resin and; c) the Integrity of the Contaminated Exhaust
Ventilation filters has been verified by DOP testing.
2. Inspect or test all potentially effected safety related ventilation
system components (e.g. Secondary Containment Isolation Dampers) to
verify their operablllty and the absence of resin. The results of the
inspections/tests shall be documented for subsequent NRC review.
3. Inspect clean air intake ventilation filters or ducts for all potentially
effected station structures to verify absence of resin. In the event
rosin contamination is identified, the resin will be removed. The results
of this Inspection shall be documented for subsequent NRC review.
4. Inspect the Reactor Building Plant vent monitor to verify its operability
and the absence of resin In the sampling system. The results of this
inspection shall be documented for subsequent NRC review.
OFFICIAL RECORD COPY
B206220151 B206 16
PDR ADOCK 05000293
643
16
Boston Edison Company M/C Nuclear
5. Establish a surveillance and preventative maintenance program for contaminate
ventilation exhaust systems to ensure exhaust filter Integrity. This
program will also Include provisions for system Inspection to Identify
resin accumulation.
6. Provide to this office by July 15, 1982 a report detailing the history
and extent of the duct contamination, Its causes, the circumstances
surrounding the release of the resin, and the amount and extent of onsite
and offslle releases of radioactive material. This report will also
describe the corrective actions taken and the additional management
oversight Initiated to prevent recurrence.
The response directed by this letter Is not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork Reduction
Act of 1980, PL 96-511.
If our understanding of your planned actions described above Is not In accordance
with your actual plans and actions being Implemented, please notify this
office by telephone within 24 hours of your receipt of this letter.
Your cooperation with us in this matter is appreciated.
Sincerely,
Starosteckl , Di rector
Di('vUion of Project and Resident
Programs
cc w/encl :
A. V. Morisi, Manager, Nuclear Operations Support
R. D. Machon, Nuclear Operations Manager - Pilgrim Station
Public Document Room (POR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
Commonwealth of Massachusetts (2)
NRC Resident Inspector
bcc w/encl :
Region I Docket Room (with concurrences)
R. Carlson
E. Brunner
E. Greenman
T. Mjrtin
R. Haynes
644
MftR -22 '88 11:04 PILGRIM NRC RESIDENT
BubiON CoiBON CowrANV
VOO auTLVTON StRcrr
BDSTON, MikCBACHU'COS 03t99
ENCLOSURE 3
TO OIJESTIOr 7
C p^-e-o-*-»,
July 15, 1982
BEOo. Ltr. #82-194
Mr. Richarf K. StaroBti=s;ki , Dijrector
Division ol Project and Resident Proyrans
Ricl eai" negulatory Carmission
631 Park Avenue
King of Prussia, PA. 19406
License No. DPR-35
Docket No. 50-293
Res^junae to CAL » 82-19
Reference
(A) MFC letter (R. Starostecki) to
BECo (W. Harrington), CAL « 82-19,
dated June 16, 1982
Dear Sir:
Tnis letter provides our response to Reference (A) , Iten 6, regarding the
identification of spent resin on roof tops and pavanent within the protected
area of Pilgriro Nuclear Power -Station on June 11, 1982.
Response
.. History, ai
■^.••^,
ind
O
Causes
TtK Cordensate Demineralizer System has been identified as the source of the
resin contamination found in the ductwork. More specifically, the processes
associate with condensate dcmineralizGr resin backwash/transfer have been
deternuji«3 as the causal factors as discussod belcw:
During resin txansfer opcffations into a condensate dardjieralizer , the vent
valve is open to allow proper resin sluicing and subsequent filling wit}.
water. Condensate demineralizer venting occurs sequentially via 1) camcri
vent teader, 2) gas scr\ibber, 3) reactor building contaminated exhaust system
and 4) standby gas treatnent s>'StaT>. (Attachnents A i E)
For the fill stcpT gas .scrubber readings are utilized by the orerator for
indication of a "rull" demineralizer. Jtawe-v/er, because of excess water carry-
over into the scrubber &nd beyond, v^-ater could flood through the scrubber and
into the ventilaticn ductwDrk an El. 23' of the reactor building, depositing
any entrained resin in the ductv,"ork and ultimately, after drying, in the
Standby Gas Ti-eatment System.
645
MfiR 22 '88 11:04 PILGRIM NRC RESIDENT P03
Li t z,^ CO"'"''**'*
w luevauiS K. Starostecki, Director
Xiy 15. 19B2
Daring resin bacVcwash operations, the "Cation" or "Storage" tank, by systen
design (Attachment B) , varrant the respective vent valve to be in the open
position for venting throiigh the upstream gcis scrubber. Swall amounts of
resin are sonietijDes entraijied in the air and water sluice, wiuch could gain
access to the cxsnta-ninated exhaust vent plenun as discussed above.
2. Extent of Duct Contamination
Attachment D shou-s the extent of duct contaniriation frcm the sources (Conden-
sate Danineralizers) to the Rector Ifjilding Vent Stack. 1-t also shews the
aTDunt of resin collected fron June 12, 1982 to July 13, 1982.
Since the contaminated exhaust filters were found to be degraded and replaced
on .'•■jarch 15, 1982, and since the analysis of the resin indicated that it was
at least a year old, it was concluded that the Ttost likely pathway of the
resin-was frcrn the condensate danineralizer vent to the contaminated exhaust
plenum, throug^i the contaminated exhaust fOters euid out the Keactor Bjilding
Vent Stack.
3. Circunstances Surrounding Release of Resins
The circumstances surrounding the release of resin can be attributed to
several factors. As mentioned earlier, condensate demineralizer backwash
operations and problenvs with the condensate derdneralizer systen vents were
primary factors.
In order to mainti^in condensate demineralizers operating within lo* differ-
ential values, so as to attain Tr^axiTnum filter capabilities vrfiile minimizinfj
crud loadir^ of the reactor vessel and attendant radiation exposures, numerous
backwashes of the condensate danineralizer beds were required durinq the
ascension to power frcm extended refuel outages. "Hie resin beads that had
accunulated in the vent ducting ewer the y^irs were hastened in their miaratiun
b^' the repeated venting operations and by virtue of SGTS testing using a camon
ventilation plenum allowing the entrained resin beads to pass into t)ie
Reactor Building Ventilation.
The initial identification of the release was observed by a health physics
technician on June 11, 1982 while collecting randon samples on top of the
Condenser Retube Building, as lart of a general site survey.
4. Amount and Extent of CTisite and Offsite Releases
An extensive survey was oor»3ucted both cnsite and offsite. Sirall quantities of
resins were detected on sectiais within the protected area to the south and
west of the plant. Attachment C shorfs cnsite areas where resin was disco^'ered,
Ihe total anount of resin fo-ir^ outside the process twildings was less than one
cubic foot. Health physics technicians i:urveyed end checked personnel and
646
MfiR 22 '88 11:05 PILGRIM NRC RESIDENT P04
'\ u: 60W COMPACT
^
«
w RichArtJ W. Starostea^i, Direi--toi
>^jy 15. 1982
page 3
vehicles in the parking lot with no measurable results. "Hie storm drain
outlet to the Discheirge Canal was checked with no measurable results. A
fine mesh screen was affixed to all storm drains to oontaiji resin within the
protected area. In situ soil analyses conducted in selected areas outside
the Protected Area resulted in no detectable activity' above historic levels.
TTie shorefront area and the main stack area were also checked which resulted
in no activity above background. A oonplete list of sanples taken including
jsotopic analyses is available for revie\*.
In total, less than one (1) cubic foot of resin was found inside the protected
area fencir^ and less than (70) cubic feet was found and reiroved frcm inside
the ventilation systan. (Attachment D)
Corrective Actions Takgi
Our iitmediabe corrective actions were to conduct an extensive survey of
affected areas, ixiiiience cleanup operations, and identify and secure the
resin source. The Condensate Danineralizer Systen was identified as the
resin source and was secured to preclude further backwashing or venting
activities until procedures and/or tonporary nodifications could be imple-
mented to ensure that no more resin vrouid be admitted to the ventilation
dueling.
Ihe vent to the ducting was blanked off linder Temporary Modification "Si 82-39
and a Tgnporary Procedure IV 82-44 was written to address the operational as-
pects necessary to prevent carryover of resins. The Tanporary Procedure was
finalised utilizing a clean (new) charge of resin before condensate darvinier-
alizer operation was alleged again.
Ttie integrity of the contaminated exhaust ventilation filters was verified loy
DCy testing (procedure «7,].30), on June 14, 1982 and found to be 99.95%
particulate efficient for both banks. Potentially affected safet>'-related
ventilation systan ccrponents were inspecusd or tested to verify their
operability and the absence of resin. Clean air intake filters and ducts were
inspected to verify absence of resin. Tnt Reactor Building Vent monitor was
inspected to verify operability. The inspection found the systan to be operable.
■Die long term corrective actions to prevent recurrence currently in place or
under oonsideration are: ])' ciianges to the operating procedure, i.e.
restricting times and flCTws during boc)washeS and transfers to minimze
resin volume with the cation tank; 2) a plajTt design change to the existing
gas scrubber so as to provide a larger volume, two levels of fhase separation
and a final stage screen to trap the resin; and 3) the condensate danineralizer
vent systan will loe vented to the TIP Itoatn rather than dircsctly to the ventila-
'tion ducting.
In additioi, a ventilation systan inspection piugian has been established to
identify and rcove any ranaining resin from the ventilation systffn. Ihe
integrity of the contaminated exhaust filters will be verified by visual in-
sf>ecticn on a six month basis.
647
MflR 22 '88 11:06 PILGRIM NRC RESIDENT PQS
Mr Ric*»rd W. St-aiostecki, Director
juiy 15, 1982
rage 4
We believe these actions to be prudent and effective rieasures to assure
t>»t the condensate demineralizer resins will not be entrained in the
plant ventilation systans in the future.
6. ftidltional Managefflent CVersight Initiated
Boston Edison Qxpany, in response to an Order irodifying our License, has
cuiiidtted to improve the Corrective Action Prograin through a Perfoniiance
Inprovanent Program (PIP). In Sections I1I.1.C.3 and III.1.C.4 of the PIP,
we have made ctiiinitments to identify weaknesses and determine alternatives
for impruvoTxints. This deterrvination will include 1) Managenent Systans
involved in Corrective Action Program, 2) Forms and Reports including Status
Reports, 3) Latest Trend Analysis, 4) Infonnational sources and 5) Evaluation
of cotrnuni cation methods and uses.
In addition, revision to the Corrective Action Systar) design will be de-
veloped around a "universal carrier form" on v^ich to identify report
problems/events. The use of this report/follow-up jnechanian will be pro-
cedurally addressed. The origin of seme of the elai^ents \*iich will re\'ise
the Corrective Action Systan are based on our recent Joiou-ledge of a Corrective
Action System used by another Utility, currently under review bj' Boston Edison
Cbnpany. ^
l-te believe this information adequately addresses the Reference A concerns; ho^vever,
should you have additional questions on this subject, please do not hesitate to
contact us.
Very truly yours,
Attachments
',
(A) P«D «M-213
(B) P4ID *M-214
(C) location of onsite Resin Discoveries
(D) Sketdi of Resin Disccveries in Ventilation Systero
(E) P41D «M-294
YiS^^'y^
648
I inr. i.i
649
flHr ii
h r xi_'jr. ii 1
650
651
MfiR 22 '88 11:09 PILGRIM NRC RESIDENT i-u?
mm
ATTACH MF NT
JULY 13, 1982
2.5 FT _
%14CK'
£^ol FT "TOTAL ...
E3c<F0R RxBLDG
652
653
NHR . 22- ' SS 1 1 : 1 6 PI LbR I PI nF.l. kto i uui [ mi
.j.%'' '^•"''U UNITtD STATES
.f*C \ NUCLEAR REGULATORY COMMISSION
Kf ClON I
'Ji^^^rrnr^^V * *'* »a«k avcmuc
I^ING OF vnus&IA. ^fvNSv-LVAhlA 1 •40t
Docket No. 50-293
CAL No. 82-:9
Boston Edison Company r,/C Nuclear r.ECilVl?
ATTN: Mr. WiTliam D. Harrington
Senior Vice President, Nuclear 'c? J")> l\ ■;;-; 10 tg
25 Braintree Hill Office Park
Sralntrte, Massachusetts C2184
ri;,CRi:.f ST;.:;:;;
Gentlemen: l.jj.EAP, r.ECDrCi CiNTI?.
This refe-s tc our telephone conversation on June 15, 1952 regarding ^he
identification of spent resin on roof-tops and piveraent within the p-ctected
area of the Pilsrim Station on June 11, 1962.
With regard to the matters discussed, we understand that you have undertaken
or will unaertake and complete the following actions:
1. Discontinue back flushing, regenerating or ultrasonically cleaning condensate
demineral i:er spent resins until the source of the resin contamination cf
ventilation systems is identified and corrective actions taken for its
cause. In the event long term plant design changes are neaded to correct
the cause of the resin release to the ventilation system, resin cleaning
operations may be performed provided that: a) appropriate procedure
revisions and other administrative controls are established to prevent
further resin releases to the ventilation system; b) a test of the adequacy
of the procedure revisions and other administrative controls Is performed
using clean re$1n and; c) the Integrity of the Contaminated txhaust
Ventilation filters has been verified by OOP testing.
2. Inspect or test all potentially effected safety related ventilation
system components (e.g. Secondary Containment Isolation Dampers) to
verify their operability and the absence of resin. The re.sults of the
Inspections/tests shall be documented for subsequent NRC review.
3. Inspect clean air intake ventilation filters or ducts for all potentially
effected station structures to verify absence of resin. In the event
resin contamination 1$ identified, the resin will be removed. The results
of this inspection shall be documented for subsequent NRC review.
«. Inspect the Reactor Building Plant vent monitor to verify Its operability
end the absence of resin In the sampling system. The results of this
Inspection shall be documented for subsequent NRC review.
I
654
MflR 22 '88 li:ll PILGRIM HRC RESIDENT PI 2
' 16 Mi '=■"
Boston Edison Compiny M/C Nuc1««r 2
5. Establish i survelTlinct and preventative maintenance prosram for contaminated
ventilation exhaust systems to ensure exhaust filter Integrity. This
program will also include provisions for system inspection to identify
resin accumulation.
6. Provide to this office by July 15, 1982 a report detailing the histo-v
and ««tent pf '^r riii(;t contami nati an . Its causej , the circumstances
surrounding the release cf the resJn. and tfTii amount and *<tent of ensile
and pTTSTte releases of raoioactive matprial Th1 s report wi I I a i so
ggscribp "the ;orrectiv^ actions taJiefi—and the additional management
ov_ers_1ght initiated to prevent recurrence. _
The response directed by this letcer is not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork Reduction
Act of 1980. PL 96-511.
If our understanding of your planned actions described above is not in accordance
with your actual plans and actions being implemented, please notify this
office by telephone within 24 hours of your receipt of this letter.
Your cooperation with us in this matter Is appreciated.
Sincerely,
I— 1^^/
ro-n. Starostecki , Director
v/sion of Project and Resident
rogramj
cc w/enci :
A. V. Morisi, Manager, Nudtir Operations Support
R. D. Machon, Nuclear Operations Manager - Pilgrim Station
Public Documtnt Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
Connonwealth of Massachusetts (2)
NRC Resident Inspector
655
'iHrs. ^^- oo iiJli rii_ij)r.ii'i Hr.'. KtciL-'cn i n-j
PlLOwiM Nu:lC*.i« Powell Station
PLTMoutM. MA>k«.er<uscTT» czabo
(^-t^*-
l«. D. M*C"P*-
f* •*»*>••
July 9. 19B2
EECo Ur. /'E2-1B8
Pr-
Roaald. C. Haynes
Regional Accinistraior , Regies I
C. S. Suclear Regularerj' Comclssloo
631 Park Avenue
Ring cf ?rusEia. TA 19406
Leer Sir:
^ Z ' / ^ 2_
Docket Kufflber 50-293
License D?R-35
The atiached llccr.see Even: Repcrt E2-O19/03I-0. "A" Standby Gas Treatoent
Svsteit", is hereby submitted in eccordence v-ith the requirements of ?il£Tta
Nuclear ?over Station Technical Specif icatioa 6.9.B.2.b.
If there are ir.y cuesrlonf on this subject, pleese contact us.
R. D. Kacbon
Nuclear Operations Msnaser
PtlBrim Stetion
CSV : cp
Inclosure: LiR 62-019/03L-O
cc: Document Control Desk
V. £. Kuclear Regulatory Co=Lissien
■U'athlnston, D.C. 20555
Standard BtCo LSR Distribution
656
MflR 22- '88 11:12 PILGRIM NRC RESIDENT P14
l^tEASt »«1KT 0« TVPS ALL REOUIKCO •NfOKMATlOM
' coK-Twom.o;<: ] I ! I II \(T)
ID I'XI Ai p|p| s|-i|(T)|oio|-|o|o|o|o|D I- |o|o l(T)H Mini h 1(^1 I i O)
• » l.<Cf Ntt( coot " '» V.ICIMIC •.««»!» M M tlClNSE Tv»i M ii tiki m ^^
EV€n"T OtSC^lTtON *N3 •'HOBfcBLE CONSeO«iNCE» ^o)
7T1 I Oa June'M. 1962. th« "A" Standby Cas Tret;=er.t Svyiem ves declared inoperanTy
J
73*^ ) based oo lo« *lo^" test data per procedure £.7.2. fc. crl:.erlB. The recunder.t |
TTI I sysiea vas tested satlsf aetcrlly to allow continued reactor operatlcn as recuirec I
if) I by Techaical Sptclllcation6.3.7.E. 1 .c. The "A" SGTS vas rtturned to sen.'lce vithia |
7?") I the allowable liaits. I
m L
lTJ L
m
coot
Cl-USf
CODI
CAUSI
tuacooe
COMrONCNT coot
COm». VALVf
•u*e09( SutCDOl
LSJ_CJ0 ^@ LiJ® I 2| Z| Z| 21 Z] ZlfT) LiJ© |_2J0
13 13
KOUiK'TISL
>i la
OCCUKKtNCE ftirOOT
A-^ LlH/HO r*^*""'""*" «t'0«T«C. cool TV»I NS.
©jj:??; 1 81 zi L=J 1 oi ii 9i Ld ipi ?j yj brJ uj
uxa> ^^j, » M M it 11 ■« 3« S3 31 35
♦CTIOX H/TUKI
TAKIN ACTION
(FFICT IHUTOOWN
on ft*«T MrrHOO_
MOunS (t2) SlAMITTfD '0*M>ul. surrLitK
eOM'OHfXT
MAHUFACTUntn
•• iiJOLU® LLJ® Ui© I 01 01 01 01 LU© LL)© UJ© I zi 9I 9! 9
CAUSE DESCRirTlON AND CORniCTIVC ACTIONS 'Q^
I 0 I I The cause has been detercined to be i^legged fllrers dv-g ra r>«''Ti bead« fT" -v»
TT) I ccpdensatc daaiiierallzer avttaa veats clerer'lTig i-nrr th* t^nrr vo-v ^f »v» tCTC
TTI I The dettlaerallzer sTtten vas tagged out and_eZ«anpt> cf SGTS started. Procedure
TsH I ehaaees and a tesporar^' aediflcatlon vere cade atid » lor.B-tera fix to urecluee retur-
TTI I recce Initiated. Please refer ic the attached event ceacrlption
»»eii.iTY ■ /aS) utTMos e»
STituI %POWi» otmikstatus vc?
H] IXl® I 01 71 5l(S)| KA
OlfCOVtSV
Di»eow(«T pcsoirriOK (22)
J I E 1(3^1 S-jrvelllance Test
ACTlvi-nr eOWTIWT
^MLIAttOCr «ILIAS(
3 UJ © UJ©L
ikMOLIKT O' ACTIVITY (JjJ
KA
LOCATlOK'Or K{ LEASE '
.M.
• f '0 n
Kwuil* ,-» Tv»t oitcKOTioK wS;
ID I 0 10 I 0 1^1 2 1^1
S • 11 1J >3
rIAtOMNll IKJUIIitt y^
NUMM* o«e«i'Tio«l*y
ZI I 0 I 0 I 0 lgS)l
KA
KA
« t 11 i>
t.o» o> on OA>u,ce TO FACaiTv /^
1T>I _^ DEtSni^TION >Ci'
Zl UJ©L
t ■' ie
13 1JLI0I
t t 1ft
KA
KA
N«C USE ONtV
J I I I I I I I I I I I '
657
I'lHK 22 '88 11 J 1^ l-iLbKif'l NKL- r-.toiL-'t.Hl rij
• , .. ?ii.zT.iy. NUC1E.OI rov-ix station
y. ' • DOCKTT KO. S0-??3
/.ttteh.Te-; te IlP E2-019/03L-6
On June 11, :S£2 during steady state reactor operation, vhlle ceniucting a
surveillance test ^8.7.2.6, cf the Standby Gas Treetaent System (SGTS) , the
'A' SCTS train was declsrei inoperable due to the inability to etteic sulfi-
cient llou as defined by the test criteria. The redundant sy«te= vas then
successfully tested as required by Technical Specifications 3.7.E.1.C end an
investigation vas conducted to detertlne ceuse.
The invesllESt-on detemined the cause to be carryover of resin beads fron
Che condensate deitinerellzer vent systesc, into the conratinated exhaust vent
^ and to the sets. The resultant re£ln ttigrEtion via the reactor building vent
i was reported to the 1>"RC as a separate issue via the ENS line per 1-0 QTK 50.72.
The condensate deiiineraliser systea vas secured end cleanup and corrective
measures initiated. Procedure charges and e tespcrary modification vcre cace
to allow interiB operation, vhiie for long tern corrective actions, a nev
operating procedure and design chinge vill be made.
This entire event is the subject of a report to be sent to KRC Region 1 as a
reply to CAL 1?£2-19. A sj-nopsls cf this report is as follows:
EsckvEshing of dcEineralizer beds, by design, removes resin fines aDd
particuletes. It is expected that sone vhole lesin beads vill also be
entrained.
During inltl&l sCEZtup operations, s ges scrubber vas designed and in-
stalled to minimize this cntra.innent. ' Since 'the time the 6crubber_was_
installed, the svstem has suffered from component breskdovn vhleh
resulted in resin being found in the reevasie and veotllaticn ___>
systems. ,■
la order to maintain condensate deTiinerelliers operating vlthin lev
differential values,, so as to m&lntain ma>d.Dum filter capabilities to
Eicicise crud loading of the reactor vessel and attendant radiation
eirposures, ouatrous bacKvashes of tne condensate denineralizer beds :.
were required during the ascension to power subsequent to extended
■ refuel outages. The resin beads that had accumulated in the vent
ducting over the years were hastened in their tigration by the repeated
venting operations and by virtue of SGTS testing using a coEacn ventile-
' tion plenua alloving the entrained resin beads to pass into the SSTS.
The resin release outside the process buildings has been secured. Off-
site stcpling found no measurable amounts of resin released to the
surrounding environs. Less then one-half of a cubic foot of resin beads
vas found inside the protected area fencing. Less than seventy cu';lc
feet was found and removed from inside the ventilation systes.
658
HhR 22 '88 li:i3 PIu3KlM NkC REilDtHT P16
4. FoUowup of June IT. 1982 Identification of Spent Resin
The Inspectors reviewed the licensee's actions with regard to the June 11,
1982 Identification of spent resin on roof tops and pavements and the NRC
Confirmatory Action Letter (CAL) No. 82-19 dated June 16, 1982. No further
condensate demlnerallzer system backwash evolutions were performed until the
licensee took actions to prevent recurrence. A temporary modification was made
to the vent system by blanking off the outlet of the gas scrubber to the Con-
taminated Exhaust System. The licensee made use of the dump valve off of the
gas scrubber to vent the deminerallzers/cati on/storage tanks to the Reactor
Building equipment sump In the HPCI quadrant.
A trial run was made with clean resin and resulted In no further Increase
of resin Into the ventilation system. Inspections were made of the ventila-
tion system (dampers and plenums) and removal of any previously deposited
resin was performed. Procedure changes were made to ensure that backwashing
evolutions were compatible with the new vent path. The licensee also Initiated
actions to prepare the Ultrasonic Resin Cleaner (URC) for future use In an
attempt to reduce the need for some future backwashing evolutions.
On June 22, 1982, at about 12:50 pm, (while touring the condensate demlnerallier
area of the Turbine Building as part of a review of procedure TP-82-44, Test
Program for Developing an Alternate Venting Pathway for Condensate Demlnerallzers)
the Inspector noted the existence of a resin slurry on the floor near the con-
densate pumps.
The Inspector determined that the spill of resin was caused by a failed check
valve In the condensate transfer system and allowed clean and spent resin to
exit an open flow meter at panel C127 which was being cleaned as part of the
URC system maintenance. No violations of equipment control tagging or radiation
protection procedures were Identified.
The inspector noted the existence of an out of calibration (due April 10, 1982)
survey meter In the area under a table. This meter was Imnedlately removed
from the area by the licensee, and the Inspector verified, through a review
of radiation survey records, that the out of calibration meter had not been
used following the due date.
No violations were identified during this followup. The Inspectors will con-
tinue to review condensate demlnerallzer operations during routine Inspections
of the facility.
659
MflR 22- '88 11:13 PILGRIM NRC RESIDENT Pi;
7»i<» pr«!lr<fi»ry rcVlflCiHon cc'.illtjtes t^RL> ra-.icf c' t.er-.; c' » wM : ". : -. ^ • c ; / —
fiiSl^c 'ntfesi J>SM f ^»*1C*. The inforrri". icri 1$ «< irifilly rf.;.,i»,c -i-.-i vi' •.-
c«i<on or tv4lu4t*on. md 1i b«$1c>11y ill ihat. is kno.n by ite Rejiir ; i-.b'f c •'•
Pllnrln Nuclear Power Sutlon
*^«cilUy: Plyroulh. M4iS«chusetts Licensee En-ergeney ClassiflciiL ;
DN SO-293 Noiiflceiion of U'uiu*! fvent.
Alert
Site Area Eirergency
General Eme'gency
> Not Applicable
Subject: «EUAS£ Of SPEMT RESIH
At approKfaitely 1900 on June 11. 1982 spent resin was found on the ground near the
Twrbtne Butldlitf. SObseouent surveys Identified contamination of the roofs of the
T«rt1w» KMctor, Off-G«s *nd Re-Tube Buildings. Contamination was also found on the
flr««M«1tfelA Xht site ccntrolltd «rv«s. Conttmlnatlon levels ranged from 20-30,000
^^/IBO aS^ m\tk Mxlw* omtMriMtlon of up to 100.000 dpo/lOO cnf-. Ganre Isotopic
«mIkU of tlie min ItfMttfled priabrlly long lived r«d1onuc11des (Co-60. Cs-137,
to csaUBtMtiM MS Idefltlfled off-site or In stor« drains. All personnel are being
fHflHi prior to cittfug ttic site «nd no personnel contAminatlon has been identified.
rMla mtf tmm btm releosed throu^ the rMctor building vent duct which exhaust!
tk» ataxylicw «t «n sltvatfon of Approxlwteljr 100 ft. The licensee has found
■itiljr 10 ft' «f r*s<« in tht Standby Gas Treatmnt System inlet plenur. The
•f tte rtstn f s k«tot Investlgtttd. Three radiation specialists have been
; 4Ns9«t8b«f it tlie sit* Is tvalutte the radiological Aspects of the occurrence.
' IMfi liitemt <s ci9ceto4 4ue to pAllc Interest In the facility. The license? is
tmaittrtttg fssartng • press relMS*. 11w MC does not plan to Issue a press releasp
fe«t trill i\spowi to ■e<H« (nqulrics. The CooRMtMcalth of Massachusetts has been
Ihls M is arrent as of 4:4S P.M.. June 11. 1982.
CCMTACT: Cisasser Bnmter
48&-123S 4B8-122S ^««(4ir
rX$T«BUTI»: ^ ♦* ^'^
«. Si. trvgB P-MlVps y'/^ E w _ wiT.r.e ".I'V Aoy.rv^
Cha1rea«« Pan*£lnc EX fc^R a/«\i :E " WSS ■"" cr.'rir;
6«Hi«»lLy PA 0:A res
AhM<^i« r:>A AEOD
•a(.«ns ELD
Acts A'r ft-chil IKK
SKY sp nsa:
CA
»CT R«;ic-a*. C"'ce» *•'; :.«*:»". 5-r:^':r. f r I i/j/^i.
k\ Hn'3»ft ?f**ce X'*"*./.
^ i!i-, «-, ice'i-e:
660
MflR 22 '88 ll:14 PILGRIM HRC RESIDENT P18
Cut-' ^ ' ■. > i I k, J '. ■ . " . a 1-- ' i I ; •- ■ c a i ' > i
MKri-, Nuclfdr fihff Mation
is >
.•see £;>.•; ■'• ' ■
NoVi- •- lo-i v'
Alert
Site Area [p*-; r -.
Generil Lirtr c- ■ cy
» Not Applicable
Jjbjecf '*^'-r*5E OF SPENT RtSIN (UPDATE PNO-I-82-42)
Surveys of ihc entire sUe within the nrotected area and surveys of seicc.vd fca'. a' :••
IUense« controlled *rca were made within 3 hours of the identification of the spent > i . -.r.
release. The licensee's onslte Surveys Identified two contaminated pavement areas *• ' '
irfre- barricaded and posted. Surveys confirmed contamination of the Turbine. fidrini«.* ■ ,:
fcuqmented 0ff-6«s and Re-Tube Building roofs. The Reactor Bulldlno Poof was found ti bi
fre« of conumlnatlon. The licensee's offslte survey Included surveys of cei:, nartin'
lots, shorefront. and security access areas. No contamination was identified. Rnutirt
tnvlrotwiental air samples covering the period June 1-15, 1982 were counted. Sothinc
wnusual was identified. Because of the size and weight of the resins, no offsite airi.crt,^
release of the beads appears to have occurred. This was conflmed by air samcles coHcctt-d
during clean-up of the contaminated pavenent areas which when counted indicated boc* .'(.jrc'
•nd the Identification of resins only on roof-tops under the Reactor Buldino Vent. Prrlr *r
try samples of storw drain residue have been counted with no contamination identified.
Ml contaminated ventilation ducts have been vacuumed clean. A duct surveillance proure:
Has been established to Identify any additional resin accuculatlon.
*^e licensee believes the resin entered the ventilation ducts from the condensate de^iricr-
llizer systen taring resin backwashinq via the Cation Regeneration Tank Vent. In aaaitirr,,
resin fron defective condensate deminerallzer vent valves ray have also been rrlr.isKi
prior to their repair during the September 1981 -March 1982 refueling outaoe. Thr '^■,^■.
appears to have been released from the Reactor Building Ventilation Pxhaust Systf' '■' •
vents above the reactor building roof, trior to the repair of defective filters in iti-
tystetn in Septeinber 1981,
The licensee has suspended all transfer operations which could result in further . (.. t.
releases to ventilation ducts and has Initiated additional enviromental sanitilir.n. 'ri-
licensee's actions were monitored by three Region 1 Radiation Snecialists thrfn.nhr.jt !■•
treekend. Region I will Issue a Confirmatory Action Letter to address nlannrtl luct''.
corrective actions. The licensee Is continuing to review the source ?nd causr u .;er: .•.
what permanent corrective action will be needed. The Resident Insnectors tri il"..;iv
following licensee actions concerning this event.
■0f'
j^di* interest has occurred. The licensee has responded to media Inouirirs hot mrv •'•
■.■p\*r\ to issue a press release. The NRG will respond to media inruiries tit >■'"•'
;'ts ItSHe a oress release.
This ''N is current as of 11:0(1 a.r\., June 1«, 198?.
H. . .:•/.•
"Nr"- : H.- J. .. . , i,
Keg 'on 1 fc-* B3
661
MfiR 22 'SS 11:10 rii_or.iM ,ir... r.c.
SEP 2 5 1986
MEMORANDUM FOR: William F. Kane, Director, Division of Reactor Projects
THROUGH: .Harry B. Kister, Chief, Reactor Projects Branch No. 1, ORP
JJack. Strosnider, Chief, Reactor Projects Section No. IB, DRP
FROM: iRoy L. Fuhrmelster, Reactor Engineer, RPB No. 1, DRP
SUBJECT: PILGRIM RESIN RELEASE IN JUNE 1982
During recent public meetings In the vicinity of Plymouth, Massachusetts there
have been numerous references to the resin release at Pilgrim in June of 1982.
These references have most often been made by Mr. Abbott of the Plymouth County
Nuclear Information Group in the manner of "the accident in 1982". A great
deal has been made of the increased dose measured on a particular Thermo-Luml-
nescent Dosimeter (TLD) during the summer and autumn of that year. In order to
determine if there was any credence to the claims that the Pllgriin resin release
contaminated the environment as far away as New Hampshire, a number of TLD data
points were extracted from the NUREG 0837 series and plotted on a common time
line. An explanation of the data points selected from random plants, a tabula-
tion of the data, and a plot on the common time axis are attached.
It 1s interesting to not* that during the first half of 1984, while the plant
was shut down, TLD 1 from Pilgrim showed striking increases in the dose. Also
of note 1s the fact the TLD 49 from Pilgrim, located 1n Weymouth, Massachusetts,
shows a consistently higher dose than TLD 13, which is only 0.7 miles from the
plant.
As a check on TLD 1, the plant operation time-line and quarterly release data
are also included 1n the figure. No correlation with plant activities Is readily
apparent. In fact, the high reading in early 1984, with the plant shut down and
no releases being made 1$ inconsistent with Mr. Abbott's contentions.
Ir conclusion. It can b* seen that the off-site dose In the vicinity of Pilgrim
Nuclear Power Station followed the general trend of the other sites in the
Northeastern United States. This trend includes a significant drop in doses
during the first quarter of 1982. This drop. If narrowly construed, could lead
one to the conclusion that the second quarter 1982 dose was significantly higher.
This would be an erroneous conclusion, since second quarter 1982 dose is lower
than the fourth quarter 1981 dose. In general. It appears that from mid-1981 to
mid-1983. Eastern Massachusetts dose data followed the decreasing trend evidenced
across th* Northeast United States. In fact the doses In Eastern Massachusetts,
Including those measured around the Pilgrim site (with the exception of TLD No. 1
which Is exposed to turbine "shine"), were on the order of 70% of expected natural
background throughout the period. First quarter 1983 doses show a dramatic drop
In Eastern Massachusetts, despite a major release from Pilgrim during that time
period (13,200 c1 , higher than the 1982 release). It Is also worthy of note
that with the exception of the third quarter 1981, Weymouth, Massachusetts doses
662
I inr. ^^
were hightr than those recorded only 0.7 miles from the site. This suggests
factors other than operation of and releases from Pilgrim ire affecting the
results of the environmental monitoring program. This also shows that the
1982 resin release and higher dose readings are strictly coincidental.
The dose readings on TLD 1 are In the range of 1 to 3 times the expected back-
ground levels for the area. The cause of the elevated readings was originally
thought to be "turbine shine". The 1984 data do not support that conclusion,
and further Information on plant activities In 1984 is being developed. Parti-
cular interest is being paid to temporary on-site storage of materials removed
during the recirculation piping changeout.
Attachment 6 shows typical expected doses.
Roy L. Fuhrmelster
Reactor Engineer, RPS IB
DRP
Attachments:
1. Exi^lanation of Data Points
2. Tabulation of Data
3. Plot of TLD Exposure Data 1981-1984
4. PNC- 1-82-42
5. PN0-I-82-42a
6. Extract from Health Physics >nd
Radiological Health Handbook
cc:
H. Kilter
J. Strosnider
L. Dotrflein
■M. MtBrlde
663
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666
MflR 22 '88 11:17 PILGRIM NRC RESIDENT P24
?cr o^ n.ii f>?cSv;i-?r DflTrt Ft« 1^8/-!^ SI
r, .1 \
I
667
mR 22 '8S li:lS PILGRin NRC RESIDENT
''■•4 r'f ' T ir*"-) rr- " rat'p- cr-sfij'.es '»'.•
Cation or tv<iu«ticn. «ic iv &«S'Cal1y « i °. -.r..-.
Pilqrlm Huctetr Power Station
Pljraouth, K«&i«cnusett&
W 50-W3
«L0tsc or van ksin
iJCiViUf,
Net ' 'tea: • r* •' 'i-„
_ S1t» Art* En-e'qp'jv
G«ne''«l Emergency
' Not *pplll:«Ol^
•pyrMtaitcly 1300 on June H, 1982 spent resin was found on th- - rour.d net' t
Itw ■Hllitaf. StMtOMMt twntyi tdenttfied contimination of tnc roofs r * ti
»tat. RMCttr, Off-tet Md Re-Tube Buildings. Conuminttion hi also four
fTMHi Mitkli; tlic site controlled areas. Contamination level- ranged fr-.,-
#1^100 of Vlth MxiMi
contamination of up to 100,000 dpm/lui
Car
«M|ntt ttf UM rMta l^mtlffcd priibrllv lona lived radionucltdt^s (Lo-t;
Ci-W mi l»-M).
to CMUvtaotton «n ftfentified off>stt« or In ttorm drams. All p«r$nn'.
ffHtka4 prtor to •kU4i»9 the tit* «nd no personnel contaminaKun t\i% txc
1m rvstn mtt tave Men rtl«*s«d tlirou^ tr>e reactor building vent duct ..'
»^m0mr» •! an •tcwtlon of approxfaatcly 100 ft. The licensee has fou^ci
Iwtlljr 10 ft^ of rtsln In the Standby Gas Irtatnent Syster tnlet plcnu .
•f tk» resin 4s feting tn««stl9ated. Three radiation special ist<. have- bee
#ltfatdM4 t» tke site to evaluate the radiological aspects of the occurnr.L- .
Ito^la Interest is ci^ected *• to ptAlic Interest In the facility. Tii. Hcf--
CMHttferlaf ItSMtng a |»«ss release. The HkC does not plan to issue a press r> i( •
teatiflll rtMond to aetfla InqHirtct. The CoMKmwealth of Massachusetts tjs bc.--
CAT
msTUBtrriok:
CKal'rar Ti ■*;— c rr?
t as nf 4:4S ».N., J^ne U, 1982.
Cisasser
-123&
I SErr
f r*
Af»ta"e
tDt.jrts
PA
•'•-A
liZ
Brunner
t-r'tif:'* r ,_ W'-s:e
■ 1 •
i'.":
668
DCS Nc "0293-820611 '' '
Oa*.e: --"e 1«, 1982
PRELIMINARY NQTIflCATION OF EVENT OR UNUSUAL OCCURRENCE— PN0-I-82-42A
' This preliminary notification constitutes EARLY notice of •venti of POSSIBLE wfety or
public interest significance. The Information 1$ as Initially received without verifi-
cation or evaluation, and is basically all that Is known by the Region I staff on
this date.
Pilgrim Nuclear Power Station
Facility: Plymouth, Massachusetts Licensee Emergency Classification:
ON 50-293 Notification of Unusual Event
Alert
^____ Site Area Emergency
_____ General Emergency
X Not Applicable
Subject- '^^^^^^ 0"^ SPENT RESIN (UPDATE PNO-I-82-42)
Surveys of the entire site within the orotected area and surveys of selected areas of the
licensee controlled area were made within 3 hours of the identification of the spent resin
release. The licensee's onslte surveys Identified two contaminated pavement areas which
were barricaded and posted. Surveys confirmed contamination of the Turbine, Administration
Augmented Off-Gas and Re-Tube Building roofs. The Reactor Building Roof was found to be
free of contamination. The licensee's offsite survey included surveys of cars, parking
lots, shorefront, and security access areas. No contamination was identified. Routine
environmental air samples covering the period June 1-15, 1982 were counted. Nothing
unusual was identified. Because of the size and weight of the resins, no offsite airborne
release of the beads appears to have occurred. This was confirmed by air samples collected
during clean-up of the contaminated pavement areas which when counted indicated background
and the identification of resins only on roof-tops under the Reactor Buiding Vent. Prelimii
ary samples of storm drain residue have been counted with no contamination identified.
All contaminated ventilation ducts have been vacuumed clean. A duct surveillance program
has been established to identify any additional resin accumulation.
The licensee believes the resin entered the ventilation ducts from the condensate deminer-
alizer system during resin backwashing via the Cation Regeneration Tank Vent. In addition,
resin from defective condensate deminerallzer vent valves may have also been released
prior to their repair during the September 1981 -March 1982 refueling outage. The resin
appears to have been released from the Reactor Building Ventilation Exhaust System which
vents above the reactor building roof, prior to the repair of defective filters in this
system in September 1981.
The licensee has suspended all transfer operations which could result in further resin
releases to ventilation ducts and has initiated additional environmental sampling. The
licensee's actions were monitored by three Region I Radiation Specialists throughout the
weekend. Region I will issue a Confirmatory Action Letter to address planned licensee
corrective actions. The licensee Is continuing to review the source and cause to determine
what permanent corrective action will be needed. The Resident Inspectors are closely
following licensee actions concerning this event.
Media interest has occurred. The licensee has responded to media inouirles but does not
plan to Issue a press release. The NRC will respond to media inouirles but does not plan
to issue a press release.
This PN 1$ current as of 11:00 a.m., ^June 14, 1982.
Region I Form 83 -^'iV'
(Rev. March, 1982) ^
669
.MfiR 22 '88 11:19 PILGRIM NRC RESIDENT P27
The Health Physics and
Radiological Health
Handbook
Kti'^
Compiled and Edited by
Bernard Shleien, Pharm. D., Certified Health Physicist, ABHP and
Michael S. Terpilak, Ceitified Health Physicist, ABHP
u.s.f.vi:f.::r
UBPAr.V
WASMlNGTCft, D.C. ii-w
Nudecm '^'"^
Lectern
Associates
Copyright ® I9B4 Nuclcon Lectern Aisodues, Inc.
670
MflR 22 '88 11:20 PILGRIM NRC RESIDENT
■zo
Table 1.5. Summary of average annual per capita
doges CO whole U.S. popolatlon
Source
Ave. per capita dose (mren/year)
Natural background
Cosmic
Terrestrial
Tech. inhanced
Sub-total
Man-sade
Medical
X-ray
Nuc. Med.
Sub-total
Nuclear weapons
Nuclear power
Consumer products
Sub-total
Total
31
68
4
103
77
14
4-5
« I
0.5-1.5
91
- 8
200
Table 1.6. U.S. general population collective dose
estimates - 1978
(From Biologic Effects of lonirlng Radiation. Report of
the Science Work Croup of the Interagency Task
Force on Radiation, Department of Health, Education and
Welfare. June, 1979)
Source
Person-reois per year
(in thousands)
Natural background
Technologically enhanced
Healing arts
Nuclear weapons
Fallout
Weapons development, testing
and production
Nuclear power
Conaumar products
20.000
1.000
16,000
1,000-1,600
0.165
56
6
671
I'lrtr /-
Co 1 i i i-H.' riL.ar-.iii Mr.'.- r.ci' it-cm ri?
Tabl* 1.7. Annual per capita doa« from natural radioactivity
Sourct
Variability
Doaa (araa/ycar)
Cosnlc
Avcraga
31
Rock Bountaln
■tataa
60 >80
Jat flight -
continantal
trans
2.5/Trlp
Tarreatrlal (txteraal)
Average*
40
Colorado
75-1*0
(intarnal)
Averaga" (gonads)
28
Lung
100-450
T«ch. tnhanced
Averaga*
4
Total
103
Average whole-body dose to the whole population.
Uncorrected for shielding of structures (reduce eosaic by lOZ
and terrestrial by 20Z). Self-shielding by body further
reduces doee.
Table 1.8. Radiation dosee from aedical radlatioo*
Source
Mean active
bone-aarrow dose
Ave.
per capita dose
■rea/exaa
(area/year)
Diagnostic z-rays
Cheat K-ray
10
Upper CI
300
tower 61
900
Skull
80
Full aouth (dental)
9
Sub-total
77«
Radio pharaaceudcals Dose (area) to organ
Specified/4
133
l"^ (function)
Tc
99H
Thyroid
Whole body
Whole body
5000
30
180
133
Xe
Total
Whole body 5
Whole-body equivalent to
whole population 14
91
*I>oasD't include therapy
Baaed en whole population (exposed and unexfoaad)
'gSO la 20 area/year (CSD is the Genetically Scientific Dose)
672
ENCLOSURE 4
TO QUESTION 7
NUREG-0837
Vol. 2, No. 3
NRC TLD Direct Radiation
Monitoring Network
Progress Report
July-September 1982
U.S. Nuclear Regulatory
Commission
NRC Region I
F. Costello, T. Thompson, L. Cohen
673
PILGRIM
TLD DIRECT RflDIflTION ENV I RONMENTflL MONITORING
FOR THE PERIOD 820630-821008 101 DAYS
FIELD TIME 820707-821005 91 DAYS
NRC
LOCATION
GROSS
EXPOSURE
RATE
STATION
AZIMUTH-
'DIST
EXPOSURE<mR>
mR/Std. Qtr.
(.deg. )
(mi.)
■f- Sid.
Dew.
+- Sid.
Dev.
001
288
0. 10
52. 1
+ -
1.3
46.4
+ -
1. 1
002
310
0.20
19.6
+ -
1. 1
17.5
+ -
.9
005
289
0.70
19.4
•f-
.2
17.3
+ -
.2
006
261
1.70
17,9
+ -
.9
15.9
+ -
.8
007
270
0.50
19.4
+ -
.0
17.3
•♦•-
.0
008
247
0.30
19.2
■f-
.3
17. 1
+ -
.3
009
224
0.30
17.6
♦ -
.3
15.7
+ -
.2
010
205
0.30
27. 1
+ -
1.2
24.1
♦ -
1. 1
011
184
0.03
22.2
+ -
.3
19.8
♦ -
.2
012
159
0.40
23.2
■♦■-
.5
28.6
+ -
.4
013
146
0.70
15.8
+ -
.5
14. 1
■♦•-
.4
014
155
1.00
17.4
+•-
.8
15.5
+ -
.8
016
136
1.30
20.3
+ -
.2
18. 1
■f-
.2
018
212
0.80
19.7
+ -
.0
17.6
+ -
.0
019
232
1.00
14.6
+ -
.3
13.0
+ -
.3
021
256
1 .60
16.8
+ -
. 1
15.0
+ -
. 1
022
130
2.50
15.4
+ -
.5
13.7
+ -
.5
023
146
3.40
15.3
+ -
.8
13.6
+ -
.7
025
168
1.50
15.6
+ -
.3
13.9
+ -
.2
026
180
1.30
14.9
+ -
.2
13.3
+ -
.2
674
PILGRIM
TLD DIRECT PflDIflTIOH EHV I POHMENTflL MONITORING
FOR THE PERIOD S20t;3o-82 1 008 101 DAYS
FIELD TIME 8207Q7-82 1 005 91 DAYS
NRC LOCATION GROSS EXPOSURE RRTE
STftTIOH RZIMUTH'DIST EXPOSURE<mR' rnR/Std.Qir.
(deg. > (mi.) +- Std. Dew. +- Std. Dev.
027
231
1.80 .
16. 3
+ -
. 7
14.5
+ -
-»
030
153
2.20
17. 1
+ —
. 1
15. 2
■f-
. 1
031
179
2.50
15.2
+ -
.0
13.5
+ —
.0
032
217
2. 60
13.9
+ -
. 4
12.4
+ -
. 4
033
234
2.50
16.0
•f -
.2
14.2
+ -
. 1
037
264
4.20
17.9
+ -
. 1
15.9
a. —
. 1
039
155
5.30
13.3
+ -
.2
11.9
+ -
.2
040
272
4.60
16.2
+ -
. 1
14.5
■f -
. 1
043
291
5.80
18.2
+ -
.6
16.2
+ -
.5
045
-
-
13.9
+ -
.0
12. 3
+ -
.0
047
301
26.2
18.0
+ -
.0
16.0
+ -
.0
048
301
26.2
17.7
+ -
.2
15.8
•t--
. 1
049
301
26.2
17.2
+ -
. 1
15.3
+ -
. 1
COMMENTS:
BTRTrON_]_ IB ON LICEINBEE PROPERTY iPILGRIM OVERLOOK FIRER)
RCCESS'IS CONTROLLED
675
PILGRIM
FOR THE PERIOD 820630-321068 101 DAYS
TLD DIRECT RflDIflTION ENVIRONMENTAL MONITORING
RZIMUTH (dig.)
AVER. EXPOSURE +- Std.Oev.
CmR/Std.Citr. )
* IN GROUP
348.75-11.25 (N)
NO DHTR<-NO DflTR
0
11.25-33.75 (NNEi
NO DRTftf-NO DflTR
0
33.75-56.25 (NE>
NO DRTfif- NO '^TR
0
56.25-78.75 (ENEl
NO DRTR-H-NO DHTR
0
-■'8.75-191.25 (E)
NO DRTR+-NO DRTR
0
101 . 25-123. 75(ESEj
NO DRTH-H-NO DRTR
0
123. 75-146. 251SE'
14.9 +- 2.2
4
M6. 25-168. 75(S5Ei
15. ■I +- 3.3
5
16B. 75-191.25(5)
15.5 +- 3.7
3
191 . 25-213. 751S5WJ
20.9 +- 4,7
2
ai3.75-23G.25(SU.'
14.0 +- 1.3
5
236 aS-25e.75(W5Wi
16. D +- 1.5
2
256 75-261. 25iHi
15.9 +- 1.2
4
291 25-303. 75CHNHi
26.7 +- 17.1
3
303 75-326. 25(NWj
17.5 +- Q.Q
1
326. 25-348. 75(NNWj
NO DRTR+-NO DRTR
0
DISTRNCEU, 1 FROM THE RERCTOR
RVER. EXPO SURE t- 3-ld.Dcv.
(niR/5td,Qtr. J
♦IN GROUP
B-2
IB. 3 +- 7.4
19
2-5
14. 1 -t- 1 1
a
>5
14. 1 +- 3.1
£
UPWIND CONTROL DRTR
15.7 +- .3
3
I
676
NUREG-0837
Vol. 2, No. 1
NRC TLD Direct Radiation
Monitoring Network
Progress Report
January - March 1982
U.S. Nuclear Regulatory
Commission
F. Costello, T. Thompson, L. Cohen
>\
677
PILGPIH
FOR THE PEPICiD -91 i::;;-S2Ci415 115 DFlYS
TLD rilRECT |:ftDIi=lTIuN EHV IPOHnEHTftL MONITORIHi:
RIIfUJTH i.:iBg. )
flVEP. EXPOSURE +- Std.D©...
(mP- £td .(Jtr. i
* :u GPouF
34S.75-ll.35 iNi
Q.ia +- (3.D
0
11.25-53.75 .NHE'i
Q.Q +- a.D
a
33. 75-56. £5 .HE-
o.a +- Q.B
a
56.25-7S.75 lENE'i
e.a +- a.0
a
■'§.75-101.35 lE'
e.Q +- a.D
a
101 . £5-125. 751ESE
e.a +- a.D
a
123,75-14iE..25i-3E''
15.3 +- 2.3
4
H6. 25-168. 75i'55Ei
15.3 4- 2.9
6
168.75-191.35(5:'
M.a 4- 1.3
3
igi .25-2 13.75IS5WI
18. a +- .9
2
ai9.75-i3b.55C5W.
13. B 4- .7
5
336 2S-2Sb.75(USUi
15.9 +- . B
2
3SB :'S-2ei.25.W.
15.8 +- 1.3
5
3a 1 25-3103. 75 (WNUi
la.Q 4- 5.9
6
3Q3 75-32b.25iNW-
le.B 4- Q.lJ
1
326. 25-343. 75 (NNHi
Q.a +- a.D
a
DISTANCE (m, J rpOM THE RERCTOR
RVEP. EXPO SURE t- a-td.Dc. .
(mR'Std.Otr. 1
+ IN i^PDUP
0-2
16.9 4- 3.7
19
3-5
IS.B 4- 1.6
IQ
:S
14.7 +- 1.4
5
678
PILGRIM
JLI' 5i^EC 7 PhDImT: jN Eri' IFuHriENTHL MOH I -^OP I HG
FuP THE PEPIuD >: 1 I _>.^ - -:in4 1 =; lis Dh'. -■
FIELD TIME SJ0l0'"--ln4u;-, --.:-- l,f^y --,-
HFC LOChTIijM
iTHTIOr; mZIMUTH DIET
INTEGPhTED
e::pu:UPE' r.ip
+ - ■-.■■> d. Ds"
E::pn:'jPE Pf
'iP z-f '3 . C't r .
+ - ■:. ' d . ri « ■ ■ ,
o^r
2 3 1
1 . 3:0
18.2
+ -
. J
14.3 + -
. 3
0 J 0
153
2 . 2 0
20.5
+ -
■ J
16.1 +-
. 4
y ? 1
17?
2 . f 0
1 ~* '-'
+ —
. 1
13.9 + -
. 1
0 52
217
2 . r: 0
1 6 . s
+ -
. 1
13.1 +-
. 1
y j 2
2 34
2 . 5 0
17.:-!
+ -
. 3
14.0 + -
• i!
0 5 T
264
4.20
20. 1
+ -
. 0
15. 7 +-
. 0
0 3 ¥
152
3 . 5 0
24. 1
+ —
. 3
1 :3 . 9 + -
. ^
0 3?
155
5. 30
1 c- . 3:
+ -
. 1
12.3 + -
. 1
«40
272
4 . r: 0
13.5
+ -
. 13
14.5 +-
Cj
04 2
281
4 . <-: 0
13.8
+ -
, if.
14.7 +-
c-
04]:
291
5 . :3 0
21.0
+ -
. 1
16.4 +-
. 1
045
-
-
15. ■?
+ -
. 4
12.4 + -
. 3
047
301
^ r . r
17.8
+ -
. 0
13.9 + -
. 0
048
301
w' 1- • ^'
1 '? . ■?
+ -
. 4
15.6 + -
"I
049
301
^ '!■ . ^'
19.0
+ -
. 7
14.9 + -
. 6
050
CTL
TLD
17. 1
+ -
. 0
13.3 +-
. 0
COMMErn:E.:
§IdII'-'f'_i ^~- •-''■* LlGErJSEE PPOPEPTv iPrLuFItl r.VEPLOrjl- flPEH'i
FICCE5S IS COrJTROLLED
679
FiLGRIM
TLB DIPECT PhDIhTIO'I EMV I = UMMEHThL MOM I TOP iriG
FOP THE PEPIOD ■illL^L-iL^AlZ liZ DHVi
FIELD TIME 820 1 u5-:5;04Ui:". 9^ DHV'i
Hpr LOlPiTION
•; T H T I ij n H r I M ij T H v: IT
• dig, > ' tu 1 .
INTEGPhTED
E ■ s F Ij •: IJ P E • m P
+- itd. D«"
E::POiUPE p'
rii P ■=■ t ij . Ij f r
+ - itd. He
001
238
0 . 1 0
3S.2
•f -
. o
29.9
+ —
6
002
310
0. 20
21.5
+ -
_ 7
16,8
+ -
6
005
289
0 . 7 0
21.9
+ -
. 3
17.2
+ -
-1
eoc:
261
1 . ro
20. li
+ -
. 1
16. 1
+ — ,
1
00?
270
0 . 5 0
2.1:. r
+ -
. 4
17. 7
♦ -
5
00S
247
0. 30
20.9
+ -
• £.
16.4
+ -
1
009
224
0. 30
18.9
+ -
. 1
14.3
+•-
1
010
205
0 . 3 0
24.8
+■-
.0
19, 4
■f -
0
01 1
184
0 . 0 3
21.0
♦ -
. 1
16,4
+ -
1
012
159
0. 40
26. 1
♦ -
.4
20.4
+ -
3
013
146
0 . r 0
17,3
♦ -
.2
1 3.6
+ -
014
155
1 . 00
19.3
♦ -
.5
15.5
♦ -
.4
01t.
136
1 . 30
2 3.8
+ -
.0
18.6
+ -
0
018
212
0 . 8 0
2 3.2
•f -
1.0
13, 1
+ -
. 8
Oli*
232
1 . 00
16.6
♦ -
3
13.0
+ -
■:.
021
256
1 . to
19.8
+ -
. 1
15,5
♦ -
. 1
022
130
2.50
19. 1
+ -
.0
14. 9
+ -
. 0
02 3
146
3.40
17.8
+ -
. 6
13,9
+ -
.5
025
168
1.50
17.8
+ -
. 6
13.9
♦ -
, 4
026
180
1 . 30
18.3
♦ -
. 3
14,3
♦ -
, 3
680
NUREG-0837
Vol. 2, No. 2
NRC TLD Direct Radiation
Monitoring Network
Progress Report
April-June 1982
U.S. Nuclear Regulatory
Commission
NRC Region I
F. Costello, T. Thompson, L. Cohen
681
PILGRIM
FOR THE PERIOn S;0 3i5-S207 1 2 UO DAYS
TLD riPECT RfllilfiTION EHVI PONMEHTHL MONITORIHG
RZIMUTH (deg. i
flVEP. EXPOSURE +- St.:i.D*..'.
I mR £td .Otr. )
♦ in 'iPOUP
348.75-11.25 (N>
0.0 -f- a.D
a
n. 25-33. 75 (NNE'i
0.3 +- a.B
a
33.75-56.25 (HZj
0.a +- a.B
a
56.25-78.75 (ENEJ
0.a +- a.B
a
78.75-181.25 i E )
0.a +- a.B
a
101 . 25-123. 75(ESE)
0.Q -►- a.B
a
123. 75-146. a5l3E)
16.B +- 1. 1
4
M6.25-iee.75iS5E)
17.3 +- -f.B
5
168.75-191.25(5)
18. -1 +- 5.8
3
191 . 25-213. 75(SSW)
18. g -t- 2.9
2
a 13. 75-236. 25 (9W)
16. E +- 2.2
5
236 25-2Sa.75(HSWJ
17.3 +- 1.4
2
258 75-2ai.25<Wj
17.3 -t- 3.4
5
281 25-303. 75 (HNW)
26.5 +- 13.e
3
303. 75-326. 25(NWi
18. B +- ia.0
1
326. 25-348. 75(NNM)
0.a +- a.B
a
DISTANCE ( m i ) FROM THE REfiCTOR
fiVER. EXPO SURE t- Std.D=v.
(mR'Std.Qtr. )
* IN CROUP
B-2
19.5 +- 6.4
19
2-5
16.4 +- 1.6
9
>5
16.3 +- 3.3
2
UPWIND CONTROL DRTR
17. B +- .4
5
682
PILGRIM
JLD DIPElT PhDIRTIuN ENV I POHMENThL MOM I TOR INC
^9^, I"l,£i'^J'-"^ yi:0325-S20712 110 DAYS
FIELD TIME «2m40i:"-32u707 '^3 DhYS
MRC LOCfiTION
■5TRTI0H RZIMUTH DIST
■' d€-g. ; ' rn i . •
026 180 1 . S>j
027 231 1.80
031 179 2.50
032 217 2.i;0
033 234 2.50
037 264 4.20
033 152 3.50
•3 39 155 5.30
040 272 4.60
042 281 4.60
043 291 5.30
347 301 26.2
043 301 26.2
049 301 26.2
:OMMENT:;
GROSS
EXPOSURE
PhTE
EXPOSURE
aiiR>
mR Std. ui
f- .
+- Std. Dffv.
+- Std. D
e <-' .
18.2 +-
.5
14.9 ♦-
.4
19.4 +-
.3
15.9 +-
.3
18. 7 +-
■ ^
15.3 ♦-
.2
24.5 +-
. 1
20.0 +-
. 1
13.9 + -
.6
15.5 ♦-
.5
21.3 +-
.5
17.4 ♦-
. 4
19.1 +-
.5
15.6 +-
. 4
17.0 +-
. 1
13.9 +-
. 1
19.8 +-
.3
16.2 +-
. 3
18.4 +-
.4
15. 1 ♦-
.3
22.7 +-
.2
18.6 +-
, 2
20.3 +-
. 1
16.6 +-
. 1
20.9 +-
.5
17. 1 +-
. 4
21.3 +-
.4
17.4 +-
3
§I0IIO(j_i IB or J LICENSEE PROPERTY .■PILCPIM OVEPLOuK flPERl
RCCE53 IS CONTROLLED
683
PILGRIM
TLD DIRECT PRDIhTIOH EHV I PuNMEHTRL tlONITORim:
FOP THE PERIOD SZ6i2Z-SI:(l7 12 118 DfHYS
FIELD TIME 32O4O.£-32u707 93 DAYS
NRC LOCRTION
STflTIOH AZIMUTH DI3T
( d e g . > < nn . >
GROSS
EXPOSURE' niR
+- Sid. Dey,
EXPOSURE PfiTE
riiR S» d. Qt r- .
+- S»d. Dev.
001
288
0.10
51.9
+ -
.5
42.5
+ -
. 4
002
310
0. 20
22.0
+ -
. 1
13.0
+ -
. 1
005
289
0.70
22.5
+ -
.6
13. 4
+ -
.5
00b
261
1.70
21.0
+ -
. 1
17. 1
+ -
1
007
270
0.50
29.0
+ -
. 3
23. 3
+ -
. 2
008
247
0. 30
22.4
+ -
.0
13.3
+ -
0
009
224
0. 30
21 .0
+ -
. 6
17.2
+ -
5
010
205
0. 30
25. 7
+ -
. 4
21 .0
•f -
3
0U
184
0.03
30.7
+ -
.9
25. 1
+ -
7
012
159
0. 40
23. 1
+ -
.2
23.0
+ -
-^
013
146
0. 70
18.6
+ -
.3
15.2
+ -
2
014
155
1 . 00
26. 1
+ -
.0
21. 4
+ -
0
016
136
1 . 30
20.0
+ -
. 4
16.4
+ -
3
018
212
0.S0
20.6
+ -
m ^
16.9
♦ -
1
019
232
1 .00
17.5
+ -
1 . 1
14.4
■f -
9
021
256
1.60
19.9
+ -
.3
16.3
+ -
2
022
130
2.50
8.4
+ -
.2
15. 1
+ -
023
146
3. 40
21.2
+ -
. 1
17.3
+ -
1
025
168
1 .50
19. 1
+ -
. 1
15.6
+ -
0
I
684
-'' -.v - ,;r *"" NUCLEAR REGULATORY COMMISSION ENCLOSURES
-. ■ fe;^^-'' I WASHINGTON, D.C.205S5 TO QUESTION 7
»
Docket No. 50-293 JUL f fi82
MEMORANDUM FOR: H. R. Denton, Director, ONRR
FROM: R. J. Mattson, Director, DSI/ONRR
SUBJECT: GENERIC IMPLICATIONS OF THE RELEASE OF SPENT DEMINERALIZER
RESINS FROM PILGRIM, UNIT NO. 1
Reference: PN0-I-82-42/42A
The release of radioactive spent resins from the Pilgrim Power Station,
reported in PNO-I-82-42, June 11, 1982, has been reviewed for generic
implications in accordance with your request. Based on information in
the PN and its update of June 14, 1982, on information in the docket file, and
on information obtained in telephone discussions with Region I representatives,
a licensee representative, and the Operating Project Manager (DL), it
is our conclusion that there are -=veral related factors in this incident which
have both generic and licensee - specific implications. These are discussed in
items (1) through (5) below.
(1) It is probable that the resins observed and reported in the PN
originally escaped from operations involved in a resin cleaning
operation for condensate demineralizer resins. Resins were
apparently forced up a vent pipe into a ventilation exhaust duct,
from which the resins were transported by ventilation air flow. Vent
pipes are designed to maintain tank pressure close to atmospheric as
tank levels fluctuate and gases evolve from tank contents. Such a
design provides a controlled exhaust system rather than a discharge
into the building atmosphere; many such vents are present in plant
designs. While it is considered good design practice to install
screens or filters in such vent lines, there were apparently no such
devices in the Pilgrim vents. The Standard Review Plans 11.2
(Liquid Waste Management Systems) and 11.3 (Gaseous Waste Management
Systems) and Regulatory Guide 1.143 (Radwaste System Design Guidance)
do not specifically address such a design criterion.
(2) It is probable that water entered the ventilation exhaust ducts along
with the resins noted in (1), above. While it is not known if this
water was significantly radioactive, the presence of the water may
have been a factor in the deterioration of filters and filter frames
(see (3), below). Vent lines serving liquid systems should be
designed to incorporate a device or mechanism, such as a water trap,
to prevent the flow of liquids into vent pipes discharging to ventilation
exhaust ducts. Neither the applicable Standard Review Plans nor the
applicable Regulatory Guide address such a design feature.
685
H. R. Denton - 2 -
JUL t 1982
(3) The licensee considers the most probable source of the discharge of
radioactively contaminated resins to the roof and ground' areas
of the plant to be the reactor building ventilation exhaust duct.
Based on the dispersal pattern of the resins, we arrived at the
same conclusion. As noted in (1) and (2), above, resins are presumed
to have entered tank vent pipes leading to ventilation ducts, probably
in the form of a slurry. The continuous flow of warm dry air would
cause the resin to dry out, leaving a residue of small beads or
particles of low density, which can be carried along the duct by
the ventilation exhaust air current. In the filtration plenum, air
from the ventilation exhaust ducts is passed first through a
fiberglass prefilter media and then through a HEPA (High Efficiency
Particulate Air) filter. Air flow through the filters is horizontal
and there is about a four-foot space (measured horizontally) between
the prefilter banks and HEPA filter banks. Linear face flow velocity
(design) of the prefilters is about 250 linear feet per minute, or
about 3 mph. Each HEPA filter module has a dimensional cross-section
of about 4 ft' and has a rated capacity, when new, of 1,000 cfm at a
1" (water) pressure drop; the face velocity for a HEPA filter is also
about 250 linear feet per minute or about 3 mph.
An IE Health Physics appraisal team visited Pilgrim in January and
February, 1980. The team's report, dated July, 1980, noted that the
prefilters were "disintegrating in place" (Section 4.2.3.2, page 55)
but that no damage to the HEPA filters could be observed by visual
inspection. This situation was apparently not corrected until the
refueling outage which began in September, 1981. In fairness to the
licensee, though, it should be noted that the prefilter disintegration
was not included as a "significant finding" by the NRC in the appraisal.
While there may be extenuating circumstances which are not apparent
from the IE appraisal, there appear to be no reasons why these
non ESF systems could not have been taken out of service for replacement
or repair in a more expeditious manner.
686
H. R. Denton - 3 -
JJL 8 1532
While we have not been able to determine the exact condition of the
HEPA filters at the time of their replacement in September, 1981,
licensee representatives did state many of the HEPA filters
were found to be damaged. It should be pointed out that no release
of resins had been identified at that time and no tests were performed
to determine the nature or extent of leakage or damage. The staff
considers that the Pilgrim occurrence has no direct implications as
to the integrity of adequately tested and maintained HEPA filters in
ESF filter systems but, rather, emphasizes the need for regular testing
and surveillance where a specified level of performance is to be achieved
and maintained. The occurence is, however, a clear demonstration that
plant operators cannot neglect HEPA filter systems indefinitely and
then expect them to perform as designed.
We note, however, that in the present regulatory climate, licensees,
in general, have no compelling motivation to perform surveillance which
is not formally required of them, especially when inoperability of a
system will not lead to noncompliance. The fact that deteriorating
prefilters were observed during the Pilgrim Health Physics appraisal
and that radioactive resins were found to be present in the
ventilation exhaust ducts was not evidence that Technical Specification
release limits or Appendix I criteria were being exceeded and, there-
fore, there was no violation of regulatory requirements to initiate
corrective action. The periodic testing, or replacement of non-ESF
filtration system components represents an expenditure of money and
manpower with little tangible benefit when only routine normal
operation is considered; in an era of tight money and budgetary
restraints, plant managers may be hard-pressed to justify to upper levels
of utility management the expenditure of even a few thousands of dollars
at a very high cost-benefit ratio.
(4) Technical Specifications require periodic testing of ESF filter systems
at nearly all plants, as well as surveillance of parameters such as
pressure drop, which are indicative of system condition and performance.
Normal ventilation exhaust air filter systems are not ESF systems and,
therefore, are not subject to Technical Specification requirements for
testing and surveillance. Non-ESF ventilation exhaust filter systems
are Installed in nuclear power plant buildings to reduce releases of
airborne material to levels that satisfy the criteria of Appendix I to
10 CFR Part 50; Pilgrim, Unit 1, is only one of many plants which do
not regularly inspect, check, or test their non-ESF filter systems.
687
H. R. Denton - 4 - Jl"- « 1S82
While the failure or procrastination on the part of operating plants
to regularly test and assure the proper functioning of these systems
may be interpreted by some parties as failing to provide maximum
protection to the environment, making such testing a firm comitment
would necessitate a substantial revision in the basic NRC philosophy
of plant safety and environmental protection. Commitments made by
applicants in their FSAR to Regulatory Guide 1.140, "Design, Testing,
and Maintenance Criteria for Normal Ventilation Exhaust System Air
Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power
Plants," is the method currently used by NRR to implement design
guidance and testing programs for non-ESF filter systems. Such
criteria had not been established by the NRC when Pilgrim 1 was
licensed in 1972, so it is likely that no commitment was ever made by
Boston Edison to provide surveillance testing of the non-ESF filters
at Pilgrim 1.
(5) The Licensee and IE (reference IE Health Physics Appraisal Report
for Pilgrim, dated June 22, 1980, page 54) have been aware for over
two years that radioactive resin beads and fines were present in
Pilgrim ventilation exhaust ducts. The same appraisal report,
page 55 notes serious deficiencies in the condition of ventilation
exhaust prefi Iters and the presence of approximately six inches of
spilled radioactive (2R/hr) resins on the floor of a room in the
Radwaste Building (p. 48), as well as loose contamination up to
90 mrads/hr on the floor immediately outside that room. In view
of the unique and highly visible nature of resin beads, the rather
high radioactive contamination levels associated with the resin, and
the knowledge that resins had been a problem In several areas of the
plant for over two years, the Licensee's statement (PN Update
June 14, 1982) that the resins had probably been released prior to
September 1981 seems to indicate, at best, an absence of recognition
of potential problems on the part of plant management. To admit that
external plant contamination of this ijrder of magnitude had gone
unnoticed and undetected for over eight months would seem to admit to
the existence of Inadequacies in the Health Physics program.
IE COORDINATION
Our review has been coordinated with IE personnel at Bethesda, Region I,
and the Resident Inspectors' office. The Radiological Safety Branch
(IE) is currently reviewing completed Health Physics appraisal reports
for other plants to identify any similar circumstances -to confirm the
generic nature of the Pilgrim incident and support the need for issuance o
688
H. R. Denton - 5 -
JUL « 1982
guidance to licensees; this review has not been. completed but
will be made available at a later date.
SUMMftRY
AS the result of our review of the Pilgrim, Unit 1, PNO of June 11, 1982
(PMO-I-82-42), the staff suggests the following:
(1) As a short-term action, recommend to IE that an information notice
be issued to all operating reactors whic^ (a) describes the Pilgrim
1 resin dispersal event, (b) requests plants to voluntarily institute
a surveillance program for existing non-ESF filtration systems if
one does not exist and (c) requests that tank vent designs be reviewed
and that, if appropriate and feasible, modifications be made to prevent
inadvertent release of resins or liquids to the ventilation system.
NRR staff is available to provide assistance to IE in the preparation
of such a circular.
(2) As a longer term action, revise Regulatory Guide 1.143, "Design Guidance
for Radioactive Waste Management Systems, Structures, and Components
Installed in Light-Water-Cooled Wuclear Power Plants," and Standard
Review Plan 11.2, "Liquid Waste Management Systems," to Include design
guidance and acceptance criteria which address (a) the incorporation
of filters or screens in the design of vents from tanks which may
contain resins, and (b) the incorporation of provisions Into the vent
design such as filters traps or check valves to prevent or minimize J
the flow of liquids through vent lines while permitting pressure equallz- J
ation within the tank.
R. J. MattsM, Diredtor
Division of Systems integration
Office of Nuclear Reactor Regulation
cc:
E.
Case
D.
Eisenhut
S.
Hanauer
G.
Laines
T.
Novak
W.
Houston
W.
Garnmill
D.
Vassallo
F.
Congel
L.
Hulman
R.
Bangart
C.
Willis
R.
Capra
L.
Cunningham
K.
Eccleston
P.
Stoddart
689
6 -
JUL 8 19S2
690
.,.>*»""%,
UNITED STATES
NUCLEAR REGULATORY COMMISSION
WASHINGTON. O. C. 20S5S
ENCLOSURE 6
TO OIIESTTON 7
APR 1 9 1383
KEMORAKDUH FOR:
THRU:
FROM:
SUBJECT:
Karl V. Seyfrit, Chief AE0D/T307
Reactor Operations Analysis Branch
Office for Analysis and Evaluation
of Operational Data
Stuart D. Rubin, Lead Engineer
Reactor Systems 4
Reactor Operations Analysis Branch
John L. Pellet
Reactor Systems 4
Reactor Operations Analysis Branch
TECHNICAL REVIEW REPORT ON PILGRIM 1 RESIN MIGRATION
Enclosed find the technical review report titled'Condensate Deminerelizer
Resin Migration Through the Plant Vent and Standby Gas Treatnent System."
This report concludes that no additional AEOD/ROAS involvement is necessary
for this event.
a
^^G^-^nn"
John L. Pellet
Reactor Systems 4
Reactor Operations Analysis Branch
691
AEOD TECHNICAL REVIEW REPORT*
UNIT: Pilgriin 1 " TR REPORT NO. : AE0D/T3n7
DOCKET: 50-293 DATE: April 19. 1983 "
LICENSEE: Boston Edison Company EVALUATOR/CONTACT: 0. Pellet
NSSS/AE: General Electric/Bechtel
SUBJECT: CONDENSATE DEMINERALIZER RESIN MIGRATION THROUGH THE PLANT VENT
AND THE STANDBY GAS TREATMENT SYSTEM
EVENT DATE: June 11, 1982
SUMMARY
This report reviews the safety significance of the June 1982 discovery at
Pilgrim that demineralizer resins had migrated throughout the plant contam-
inated exhaust vent to external plant areas inside the protected area fenc-
ing. Also, sufficient resin had migrated through the reactor building
ventilation system to block proper operation of 'the Stendby Gas Treatment
System (SBGTS). References are cited which show that resin migration into
the ventilation system and SBGTS had occurred at least three years previously.
This report finds that the event was of minimal safety significance and con-
cludes that current NRC efforts are adequate without additional AEOD involve- -
ment.
DISCUSSION
Plant & Status
Pilgrim 1 was in steady state power operation on June 11, 1982 while performing
a surveillance instruction {SI) on the SBGTS.
Occurrence-Cause & Ef f ect ^
The SBGTS failed its routine SI due to low flow. The low flow was caused
by carryover of. resin beads from the condensate demineralizer vent piping
to the reactor building ventilation system and contaminated exhaust vent
and from there to the SBGTS. This carryover occurred during backv/ashing of
the demineralizer. Backv,'2shing with air and water resulted in resin fines,
particulates, and some resin beads being entrained in the air/water backwash.
An air scrubber was installed during initial startup to prevent resin migration
i-nto the ventilation system. However, it did not perfora as expected since
installation. As a result, substantial resin migrated to the radwaste and
ventilation systems over a considerable time period.
After this event, contaminated resin beads were discovered outside of the
plant buildings (but not offsite) as well as inside the vent system. Less
than 70 cubic feet of resin v/as removed from the ventilation system and less
than 1/2 of a cubic foot was found inside the protected area. Root cause of
the substantial resin migration appears to be inedecuate design of the scrubber
intended to preclude -such migration. ' ;
"ihis document supports ongoing. AEOD and NRC activities and does not
represent the position or requirements of the responsible NRC program
692
- 2 -
History
At least two cases of resin intrusion into the SBGTS have been previously
reported*^'^ since June, 1979. This indicates that resin intrusion into
the ventilation system and SBGTS has been a recognized problem at Pilgrim
for several years without adequate resolution. However, prior to the
June 11, 1982 event there was no evidence of contanii nation outside of
the plant buildings.
Consequences
The consequences of this event may be broken down into three categories:
1) off site release, 2) personnel exposure, and (3) system performance or
availability. The resin migration problem produced no evidence of offsite
release during this review. However, the resin migration clearly has
resulted in added equipment contamination and substantial cleanup efforts
by plant personnel over a perit)d of several years, but this review found no
indication of unacceptable personnel exposure. From a system viewpoint,
this event demonstrates the potential for failure in a nonsafety system to
act as a common cause initiator affecting multiple trains of a safety system
(in this case SBGTS). This potential is mitigated because failure is as a
. result of flow restriction due to resin buildup and is therefore very slow
with respect to the test interval (i.e., only two failures over the last
three years). Also, even thougli one train of SBGTS was inoperable due to
low air flow, the train was capable of performing at a reduced level.
In summary, the resin migration produced minimal actual consequences in
the three areas of concern.
Corrective Actions
The licensee actions to preclude further resin migration into the vent
system may be divided into short-term and long-term efforts. The
inmediate actions by the licensee to remove existing resin and preclude
additional migration were set out in Confirmative Action Letter No. 82-19 ,
Additionally, the licensee disconnected the ventilation system from the
poorly functioning gas scrubber and rerouted the scrubber discharge
(liquid, cir, and resin) to the Reactor Building Equip:nent Sump. However,
the equipment sump was not intended for eitner the quantity of air/water
mixture or the entrained resins produced by demineral izer backwashing.
This resulted in sump discharge to the KPCI room during demineral izer
backwash. Due to a loose cap on a floor drain, approximately 12 inches
of wcter accumulated in the B RKR pump room as well ai in the HPCI room.
Resin contamination was also evident in the HPCI room^. The licensee
corrected this problem by securing the leaking floor drain and admin-
istratively requiring low sur.p level prior to oeTiineralizer backv/ash.
The above details introduce considerable uncertainty as to the long-term
efficacy of the corrective actions impleniented by the licensee thus far.
The licensee is currently studying potential long-terr, corrective actions
and can be expected to ir.pl enent such actions v.he-. they are detgrr.ined.
The K'RC Resident Inspector is follov/ing this subject and can b^^expected
to require an adequate resolution based on his past efforts.
693
FIIJDIK'GS
Findings for this investigation were:
1) Resin migration through the ventilation systea can produce a common
mode failure of both trains of SBGTS.
2) The safety significance of this event is minimal due to the slow
propogation rate and limited actual consequences of the resin
migration.
3) Corrective actions by. the licensee are adequate at present.
CONCLUSIONS
The safety significance of this event is relatively minor given the radio-
logical release and system performance effects previously discussed. The
personnel exposure effects may be more significant, especially since this
has evidently been a problem for over three years. However, this review
produced no evidence of excess personnel exposure. Given the limited signi-
ficance discussed above, followup and resolution of this event by the resident
inspector appears to be adequate. At present there is no need for. additional
AEOD involvement on this event. Hov/ever, this type of common mode failure is
potentially generic, depending on plant specific arrangement of demineralizer
vents, SBGTS, and reactor building ventilation.
REFERENCES
i: LER 82-019/03L-0 on Pilgrim unit 1.
2. LER 79-020/03L-0 on Pilgrim Unit 1.
3.. IE Inspection No. 50-293/82-20
4. Confirmative Action Letter 82-19
5. IE Inspection (Jo. 50-293/82-30
I
694
Event Evaluation Sheet
EfJCLOSURE 7
TO QUESTION 7
Information
Initial Receiver Date Source Subject
Licensee/Facil ity Type/location • Regional Contact
Event Summary; (-/^/sz^ Sf^t^r a^o^:^ ^L'^^-^^ ^ .x^^jZ^ ^^^^ ^^,^_^^
^r>>~C.
/ TSection Chief)
Further Actior Assigned to l^i^^'-T-.'^
"equired
1^^ No (Assign Code #)*
Followup Actions/Results
Lfobx ^Uto ^/^ l/'^'^ /3-L,.n-. i/Aivt^ c^^
^-
^L C<:"-'' ''•' -f ■■•■;■■ f, ■
J -
Item Closed by/Date
Concurrence/ Date
(Sect. Chief)
695
OCS No: 5029J-820611
Date: June H. 1982
i'5L'lliti}_J!;]lL-iJ.5i ^^ .':VE4T OR ONJSLAL CCCURR£f!C£--P!<0-I-32-42 . .. .. ..
Iht: pellt.1 li ry /-otillct Ion csnitVuta* £.Kklr notice if events of POSSIBLE safety or
f u<' t; liitrisi.t :• jn*fi:^rzM The liifonsation is as inftiaUy received wiihout verlfi-
taton ar <vj' uji^ofl, a.vl Is bas'fca;'/ all th.at Is Known by the Region I staff on this fte.
Pi'irim Nuclei'.r 'ower Station _.
fa:'ll y PI;/iiO(th. Ka^Racnusetts Licensee Emergency Classification:
ON 50-293 Notification of Unusual Event
ATert
Site Area Emergency
__ General L-sergency
\ Mot Applicable
SJ*J^.-l: /lELfASE OF S,?EKT REStN
A. 3,; ro'*ma\el; l^^C or Jine 11, 1982 sp.irt resin was found en the ground j^ear the
T obire Ji'i!«;li'i. ::Lbsi.>qutint airveys identified conti-mi nation of the robfs'of the
Tjibii.e, Fear.tor, ^f-j/s -md Re-Tnte Puildlngs. Contamination was also found on the
g-taivJ .« ItiUx fit i ta jo.TtroTltd areas, fontamiration levels ranged from 20-30,000
dx/U-C Ji.- »-1ti) iTiixinij. C'"r.tain1na".1on of up tc lCO,iX;0 dpm/iCO cm^. Gamma isotopic
«>«lri.i» cf v.he res'r. iiincified primarily long lived radionuclides (Co-60. Cs-137,
C.-ljy jnc /*-54;.
1; csi.tjir.inavijn wis iJtntJfled off-site or In stem orains. All personnel are being
f 'IsmJ ,u1jr to e.Klt1i< tlife s'^te and no personnel contaminaticn has been identified.
Ti. (stii :i\ii i-ve ban released through ':he reactor building vent duct which exhausts
t- tie ijin;|.h2rt \z a-1 eluvaticn of arproxinately 100 ft. The licensee has found
a f->; 1-a.tciy li: fc-* >>t r«s1n in the Standby Gas Treatment System inlet plenum. The
Sjtrct ■)' tie. r^ii^ is taiHc investigated. Three radiation specialists have been
d'jpivcarc '.(• tl.t s-'te to «'va1uate the radiologic?! aspects of the occurrgnce..
H cii in-:erv-tt s •?;.pe.lei CU2 to public interest in tho facility. The licensse is
orsicirng "ssi.i.ij a ;nejri release. The KP.C docs not >jlan to issue a press release
btl <«ill re.>(-on)^ t:> (nsJia rqulrl^s. Ihs Conso.iwealth of Massachusetts has been
lii1o"i<isi.
Iltlj J'N ''S -ir^nt
bS
of * 45 P.M.,
June 11. 1982.
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488-11-2S
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int Office
RI Reside
Licensee;
(keactor licensees)
ligiun • F)i« U3
.•Re; «.-.> •fS2:,
696
(I
I
i
^.WAi HflrriflCATIOK -f a&T OR IWUSUAL oicURR0i3~PW-Ii82-«A
wtlJitlon. ariUi 3*»1c«ny «n th*t 1» Jwb»h hy th« lUglon I sUff on
iSiii ef«>1rn»ry notlficatiicn «n«t1tut«« EARLY notldt of •v«nts of POSSIBLE safaty or
aiblic -Jtsrtit s1dPlf'ca<^t. Th» Inforwtlon^U MjliJItuny rw:«1»«d wUhoutytrltl-
Ktloe o»
?ngr-iii Nuclear Po^ir Station
Rrtllity; P^Jjaouth. Massa-^setts
iti 50-293
Li
JCS.Ite:5O??3-^06U
},»«: Jitne 14. 1982
««• EflMrgancy Classification:
Notification of Unusual Evaat
Alart
Sit* Ar«a Eoergency
Qatwral Eawrgsncy
Mot Applicable
surveys of selected areas of the
Identification of the spent resin
ti.*.^ VXlfiSi Of SPENT RESIN (OPOATE PNO-I-82-42)
■jijrveys t'f ♦>« entire uitn wltMn the orotected ar«a ^nf
!ic8v«M caitnlled arw v«re «B<te v#ith1n 3 hours of th<
r»1e4se. T)« Ifcensess qnslte surveys Identified tW9 i ontawlnated pavanent areas t«n1ch
ine tarrl'-adel a-vl posted. Surveys eon-'IriKd contant™ tlon of the Turbine, Adnrlnlstratlon,
itak-ftei. (>'f-'ies and Ra-Xbe eulldlnfl roofs. The Reac or Building. Roof wis fpund.to be
ffte of con-a«l nation. Tffe licensee's yffslte survey 1i eluded surveys of cars, parking
lots, ihtrr'rort, and security access areas. No contain' nation was Identified. Routine
ilTvl'tfBtnftil air saou'.esjcovering the oerlod June l-JS 1382 were counted. Nothing
4KKa1 was IdJTftl-'leJ. ifccause of the size and weight. of the resins, no offslte airborne
KlaAre (f "te beads ippeirs to have ocoirretl. This was confirmed by air sairoles collected
d'^rlK cle^n-uJ of the corka.^irated pavement areas whIcS when counted Indicated background
aic tfe ideiitl Mca-lon of jres^ns only on roof-«pp$ undef the Reactor Bulding Vent. Prellnrtn-
!•> i*q>1es of ftorw -Ira I?* retldue have been counted with no contamination Identified.
%\\ .-.tnt^l»1Ilat.1c 'unti''atan ducts have been vwcuuned -clean. A duct surveillance progran
feat bten esrabltsnnd to Itkntlfy aiqr additional reslH^«*cunii1at1on.
T^4 llcwiSje b-jflives the resin wtered the ventnat1on|ducts_from tfte.iffndensate demlner-
.l2ur jiStMT .icring TSlrj backwashlnfl via the Cation Regeneration Tank Vent. In addition.
r.sate iffniiierallzer vunt valves may have also been released
, the Septaaber 1981 -Iterch 1982 refueling outage. The resin
se-l frjm the Reactor BoildlnglVentllatlon Exhaust Syst««i which
111 jing roof, arlor to the repair of defective filters In this
iln frca defecttve ct-nl
lor to their repair {"ur
pears to f.avi: bmtsn re Is
Hnfi abcv) the rsiictor b
^:4ta« in Septoiter 10f<l
^w 11c<rfiS»e has wsper-d
relsBsas to ventilation di
all transfer operations whie* could result In further resin
,..^., ,_., _^tj an<1 has Initiate* additional environmental sampling. The
Viceittee's tctlcns wer* nrtnltored by three Region I Radiation Soeclallsts throughout the
wteki-nd. Region I will 1*us a Confinatory Action latier to address planned licensee
CLrr-Kt^e #ctiens. T^e ^cersee Is contlnolna to revltw the source and cause to determine
i«hat fe-iiaxnt corrective [action will be needed. The .Resident Inspectors are closely
iA»11uii1<% licamitt action* concerning this event. : .
'itedia lute 1st has oci:urr«id. The license* has responded to media Inoulrles but does not
IP an TO Isjce a prtss rel^se. TTie NRC will respond to'madia Inoulrles but does not plan
JtD 1:iSu« a pr«5e I'elease. i ....
This PN is current at of il:0O a.m.. dtnt 14, 1962. -
IU(l9c. I Form S3
^(•v. March. 19821
697
tiJCLQSURE 3
Tn nMF<:TTnM 7
SSINS No.: 6835
IN 82-43
UNITED STATES
NUCLEAR REGULATORY COftllSSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON. D. C. 20555
Noveinber 16, 1982
IE INFORh-JMION NOTICE NO. 82-43: DEFICIENCIES IN LWR AIR FILTRATION/
VENTILATION SYSTEMS
Addressees:
All nuclear power reactor facilities holding an operatlnr license (OL) or
construction pemit (CP).
Purpose:
This information notice Is provided as notification of events that had actual
or potential radiological Impact on the plant environs. It Is expected that
recipients will review the Information for applicability to their facilities.
No specific action or response Is required.
Description of Circumstances:
Within the past 2-1/2 years, air filtration/ventilation systems at five
facilities were found to have serious deficiencies, ranging from overloaded
prefilters to evidence of a wetted high-efficiency particulate air (HEPA)
filter bank, to penetration of HEPA filter banks by substantive quantities of
radioactive resin beads. Deficiencies occurred In both safety-related and
non-safety-related systems.
In June 1982, radioactive spent resin was found on the grounds and roof areas
at Pilgrim 1. Principal radionuclides were Co-60, Cs-137, Cs-134, and Mn-54;
contamination ranged from 20,000 dpm/lOO an» to 100,000 dpm/lOO cm^ . The
contamination penetrated damaged filters In a non-safety-grade HEPA filter
plenum. The degraded condition of these filters was not detected in a timely
manner because of a lack of surveillance or testing of the filtration system.
The HEPA filter failure occurred possibly as an end result of a combination of
high dust loadings and mechanical damage resulting from the Impact of
disintegrating prefilters, as well as the probable warping or distortion of
HEPA filter frames under prolonged exposure to water and high humidity.
In December 1980, the SGTS trains at Brunswick 1 were found to be operating at
close to loot humidity, and condensation was observed on the interior walls.
Regulatory Guide 1.52 recomnends operation at humidity of 70X or less;
operation at high humidity Is known to cause substantial degradation of the
Iodine-retention capacity of charcoal adsorbers. Also, In December 1980, both
filter trains In the turbine building filter system at Brunswick were found to
be operating with the upstream HEPA differential pressure gauges off scale
high. Also, in the turbine building filter system, 43X of the upstream HEPA
filters were improperly installed.
82081 90248
698
IN 82-43
November 16, 1982
Page 2 of 2
In August 1980, filters and charcoal adsorbers In the Surry 1 process vent
exhaust air treatment system were determined to have been half submerged In
water, and the HEPA filters were caked with dust. No pressure drop Instru-
fientatlon was provided across the filter banks to ascertain their state
of loading. Also, In August 1980, pressure drop gauges across the HEPA filter
banks In the ventilation exhaust treatment system of the auxiliary building at
Surry 1 exceeded 5 Inches, which Is offscale high; this condition had existed
since May 1980.
In May 1980. the normal containment building exhaust filters at Turkey Point
were found to be overloaded with dust to such an extent that the filter medium
was separated from its frame in aore than 50% of the filters. This apparently
allowed radioactive contamination resulting from explosive plugging of steam
generator tubes to be transported to the southeast sector of the plant site.
In March 1980, it was determined that HEPA filters in the Big Rock Point offgas
and chemistry laboratory exhaust trea'tment systems were not being tested for
leakage in place. No records were maintained of pressure differential across
the laboratory HEPA filters which had not been replaced for at least five years.
In each case described above, licensees initiated programs and procedures to
correct the deficiencies and to prevent or minimize their potential for
reoccurrence.
Air treatment systems which Incorporate filtration or adsorption media are
provided to reduce the potential release of radioactive materials to the
environs. In order to function as designed, such systems should be installed,
tested, and maintained to a degree consistent with their intended function.
Guidance on installation, maintenance, and testing programs, of a degree and
nature which have been demonstrated to ensure proper system functioning. Is
provided In Regulatory Guides 1.52 and 1.140.
No written response to this information notice is required. If you need addi-
tional information about this wtter, please contact the Regional Administrator
of the appropriate NRC Regional Office or this office.
^A
Edward L. Jordan, Director
Division of Engineering and
Quality Assurance
Office of Inspection and Enforcement
Technical Contacts: L. J. Cunningham, IE
301-492-8073
P. G. Stoddart, NRR
301-492-7633
699
TO QUESTION 7
Pilgrim Nuclear Power Station
Radioactive Effluent and
Waste Disposal Report
including
Radiological Impact on Humans
January 1 through June 30, 1982
By: Nuclear Operations Support Department
Environmental and Radiological
Health and Safety Group
Date: September 1, 1982
BoFton Edison Company
8209160303 320831
PDR ADOCH 05000293 ^C
^ PDR -^^'
700
PILGRIM NUaEAR POWER STATION
RADIOACTIVE EFFLUENT AND HASTE DISPOSAL REPORT
INCLUDING RADIOLOGICAL IMPACT ON HUMANS
JANUARY 1 THROUGH JUNE 30. 1982
Prepared
by: d3^»3^^yJ^->«^>»«*» i
Christine E. Bowman
Sr. Radiological Engineer
Approved by:
Thomas L. Sowdon
Environmental and Radiological Health
and Safety Group Leader
Date of Submittal: September 1, 1982
701
Sec
on
TABLE OF CONTENTS
Introduction and Sumary
Effluent. Waste Disposal and Wind Data
Off-Site Doses Resulting from Radioactive Liquid Effluents
Off-Site Doses Resulting from Radioactive Gaseous Effluents
Off-Site Doses from Direct Radiation
Page
1
1
41
46
67
Table
lA
1B
IC
2A
2B
3
LIST OF TABLES
Supplemental Information
Gaseous Effluents - Surnnation of All Releases
Gaseous Effluents - Elevated Release
Gaseous Effluents -Ground Level Release
Liquid Effluents - Sunmation of All Releases
Liquid Effluents
Solid Waste and Irradiated Fuel Shipments
4A-1 Distribution of Wind Directions and Speeds - 33 Ft. Level
of 160Ft. Tower
4A-2 Distribution of Wind Directions and Speeds - 160 Ft. Level
of 160 Ft. Tower
3.2-1 January-June 1982 Liquid Release Maximun Individual Doses
from all Pathways for Adults (MREM)
3.2-2 January-June 1982 Liquid Release Maximun Individual Doses
from all Pathways for Teenagers (MREM)
3.2-3 January-June 1982 Liquid Release Maximum Individual Doses
from all Pathways for Children (MREM)
3.3-1 Population Doses Resulting from the January-June 1982
Liquid Effluents
Page
2
3
4
5
6
7
8
9
25
42
43
44
45
11i
702
Table LIST OF TABLES (Cont.) Page
4.1-1 Undepleated Relat-ive Concentraffon per Unit Emission for 47
Reactor Building Vent for January-Karch 1982
4.-1-2 Depleted Relative Concentrations per Unit Emission for 48
Reactor Building Vent for January-March 1982
4.1-3 Relative Deposition Concentrations per Unit Emission for 49
Reactor Building Vent for January-March 1982
4.1-4 Undepleted Relative Concentrations per Unit Emission for 50
Main Stack for January-March 1982
4.1-5 Depleted Relative Concentrations per Unit Emission for 51
Main Stack for January-March 1982
4.1-6 Relative Desposition Concentrations per Unit Emission for 52
Main Stack for January-March 1982
4.1-7 Undepleted Relative Concentrations per Unit Emission for 53
Reactor Building Vent for April -June 1982
4.1-8 Depleted Relative Concentration per Unit Emission for 54
Reactor Building Vent for April -June 1982
4.1-9 Relative Deposition Concentrations per Unit Emission for 55
Reactor Building Vent for April-June 1982
4.1-10 Undepleted Relative Concentrations per Unit Emission for 56
Main Stack for April -June 1982
4.1-11 Depleted Relative Concentrations per Unit Emission for 57
Main Stack for April -June 1982
4.1-12 Relative Deposition Concentrations per Unit Emission for 58
Main Stack for April-June 1982
4.2-1 Maximixn Individual Locations and Pathways 59
4.2-2 January-June 1982 Gaseous Release Maximun Individual Doses 60
from all Pathways for Adults (MREM)
4.2-3 January-June 1982 Gaseous Release Maximum Individual Doses 61
from all Pathways for Teenagers (WIEM)
4.2-4 January-June 1982 Gaseous Release Maximun Individual Doses 62
from all Pathways for Children (MREM)
4.2-5 January-June 1982 Gaseous Release Maximun Individual Doses 63
from all Pathways for Infants (MREM)
iv
703
Table LIST OF TABLES (Cont.) Page
4.2-6 January-June 1982 Gaseous Release Haximun Individual Doses 64
0.5 Miles SE
4.3-1 Population Distribution 65
4.3-2 Population Doses Via Major Pathways Resulting from Gaseous 66
Effluents during January- June 1982
»
704
1. INTRODUCTION AND SUWARY
This report Is issued for the period January-June 1982 in accordance
with NRC Regulatory Guide 1.21 "Measuring, Evaluating and Reporting
Radioactivity in Solid Wastes and Releases of Radioactive Materials
in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power
Plants" (Rev. 1). The information supplied Includes actual effluent
releases, radioactive waste and meteorological data; doses from
liquid releases, doses from gaseous releases and direct gamma radia-
tion doses.
2. EFRUENT. WASTE DISPOSAL AND WIND DATA
Radioactive liquid and gaseous releases, wind speed data together with
reasurement errors and solid waste disposal information are given in
Tables lA. IB, 1C, 2A. 2B. 3. 4A-1. 4A-2. and supplemental information
section in the standard Regulatory Guide 1.21 format.
705
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT
Supptemanul Information
January - June 1982
, Padlltv WgiM NmIw Per— Sartoa liiwi DTK-M
1. Rcfuliiary Luaiu
1. Foiun aid tctmiHin (am - ^ '
0.25/f oTtO/E
h. i«idifi«2C1 /Quarter
c. PariK-ulain. half-livei >K <bvs 1 3( 1 . 8E4Qs-*-1 .8E5Qv}^ 1
d. uquidtiDurnu: loci /Quarter
2. MiUffluiii ftnniaiUt Concmimioa
PiiivMlr ih( MPTt lord in deirrmininf ilkiwiblfrHraK rainur Limcrniraiioni.
i. Fau>n «nd Kiivaiiim pics \ 10 CTK 30
b. Iiidinct: > Apptsdii •
c. hnmbin. hair-lnviX dayt ' TtM* II
<i. LjquHl rrnutnit. H- 3 ■ I X lOr* ICUmU iS rau, lOCFR 10, AppmdU ■. TiMt n
3. Anfttfi Eatf|^
Frnvidt ilv iwrjcr enrn)' <tl oi ihf radioniiL-liiJr mixiuir in iHeii«> m fiUKin jnj iH.iivaiiufi uvs. ii aoolitable
MS»O.324:RBV-0r503
4. McaMrtmcnis tnd Approkimaiiom of Telal lUdioKlivily
Pvonde Iht methiidl MCd to mcjwrr m apt>riiitinuic ihc liHal iadKia.'ii«it> mefniienuand ihr m(th(«ii uitd i»
dtierminr radHinu>.'lidr urnifmutHin.
a. Fasiun and a^iiwinai pstt: \ q,|j
ti. lodinn: I ^^
d. Uquid einurnii:
■web Hilfti
hi>«idr tte fulluwinr mformaiMin icbioif in batch fcleaKt ul radwaciiw maienals in liquid jnd fHcous erfluenii.
■■
I. Numbrriirtamdirfltain 121
1. TtNal iimr ptriod (tw hairii rdcan: 192.92hrS
.1. Maximum iimt pmud Titr a taidi iekat< - 7 . 75hrS
4. Awfaff liriK ptrmd tur taali.1i >*kaKi 1.59hrS
5. Mnimum iiim pemid f.H a haiehirloif - 0.25hrs , onrj-CCOM
6. A»(rafr uitam flim dunn(p(nodiuricteaic orernucni Mi»a fVtwinf tiitam I .TUt'^Surn
«<« AwlcaMa)
«. AkMTi^ Ukmm
k. None
706
TABLE 1A
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT
GASEOUS EFFLUENTS - SUMMATION OF ALL RELEASES
January - June 1982
Unit
Ejt. Toni
Error, X
A. Fiaion and ictiTition gnet
1. ToUl release
a
-
3.55E+3
2.50E+1
2. Average release rate for period
tiCi/sec
-
4.52E+2
3. Percent of Technical Specification limit
%
-
6.92E-2
B. lodiiMi
1. Tot*l iodine-131
Ci
-
3.97E-3
2.54E+1
2. Average release rate for period
«Ci/iec
-
5.05E-4
3. Percent of Technical Specification limit
%
-
1.99E-1
C. Particulatci
1. Particulates with half -lives > 8 days
a
<3.68E-4
4.26E-3
3.05E*1
2. Average release rate for period
uCiltc
<4.73E-5
5.42E-4
3. Percent of Technical Specification limit
%
<8.39E-3
6.98E-2
4. Gross alpha radioactivity
Ci
<4.52E-7
C5.61E-7
D. Tritium
1. Total release
Ci
2.34E0
5.92E0
3.20E+1
2. Average release rate for period
ji a/sec
3.01E-1
7.52E-1
3. Percent of Technical Specification limit
%
-
-
707
TABLE IB
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT ( 1982 )
GASEOUS EFFLUENTS - ELEVATED RELEASE
January - June 1982
CONTINUOUS MODE
BATCH MODE
Nueiid« RalMMd
Uiwt
Qunar
Quvtar Quwlw Ouanar
LFuBonpM*
krypton-85
Ci
-
1.37E-2
krypton-fiSm
Ci
•
2.93E+2
kiypton-87
Ci
-
6.55E+1
kjypton-88
a
-
3.62E+2
ienon-133
Ci
-
2.28E+3
xaton-135
a
-
2.61E+2
zenon-lSSm
Ci
-
<6.06E-K)
xenon-138
Ci
-
<2.38E+1
ienon-131m
Ci
-
-
xanon-137
Ci
-
-
xenon-133in
a
-
4.28E+1
Total for period
Ci
-
3.33E+3
lIodiiMt
iodine-131
Ci
-
2.53E-3
iodine-133
Ci
-
7.90E-3
iodine-135
a
-
<6.55E-3
Total for period
a
-
<.1.70E-2
3. PartieuUtat
itTontium-89
a
^6.32E-7
5.16E-4
fUontiuin-90
a
<6.26E-8
5.50E-6
ccfiuin-134
a
ce«iuin-137
a
<1.04E-5
1.UE-5
bahuffl-lanthanum-1 40
a
1.57E-3
chromium-Si
a
manganete-S4
Ci
8.90E-6
2.90E-6
cobalt-68
a
i;on-69
a
cobalt-60
a
^7.86E-5
:.U0E-5
—
ziDc-65
a
Drconium-niobium-95
a
cehum-141
a
cerium- 144
a
rutfaemum-103
a
nitheniuffl-106
a
- 4
708
TABLE 1C
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT ( igg^
GASEOUS EFFLUENTS - GROUND LEVEL RELEASE
January - June 1982
CONTINUOUS MODE
BATCH MODE
z\
NudidM RttaMd
Uiut
QiMrtar
QuvtB-
Quartar
1. Fifdon gum
krypton-85
a
-
l.OlE-5
kiypton-85m
a
•
2.47E*!
krypton -87
a
-
2.51E-K)
krypton-88
Ci
-
4.55E+1
xenon-133
a
-
4.19E+1
zenon-135
Ci
-
1 .07E+2
xenon-135m
Ci
-
-
xenon-138
a
-
-
ToUl for period
a
-
2.22E+2
2. lodinn
iodin*-131
Ci
-
1.44E-3
iodine-133
Ci
.
6.50E-3
iodine-135
a
-
<1.02E-2
Toul for period
Ci
-
<1.81E-2
3. Particulate*
itxontium-89
Ci
1.64E-5
1-46E-3
(trontiuin-90
a
4.76E-7
1.44E-6
cenum-134
Ci
1.17E-6
ce«iuio-137
a
2.42E-5
3.67E-5
bvium-Unthaaum-140
a
3.95E-4
mangane**-54
a
1 .08E-5
5.88E-6
cobalt-58
Ci
iion-69
a
cobtlt^O
a
2.16E-4
2.27E-4
Bnc-65
Ci
nrconium-niobium-9S
Ci
oeriuin-141
a
rutl.enium-103
Ci
ruthenium -106
a
-5
709
TABLE 2A
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT (1982)
LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES
January - June 1982
Unit
Omtht
Eft. Total
Error. %
A. Fisdon and activation products
1. Total rcleue (not including thtium,
noble poet, or alpha)
Ci
5.72E-1
1 .44E-1
3.00E+1
2. Average diluted concentration
during period
uCilml
8.91E-8
7.58E-8
S. Percent of applicable limit
%
5.72E0
1.44E0
B. Tritium
1. Total releaae
Ci
5.26E0
1.99E-1
3.00E+1
2. Average diluted concentration
during period
tiCilml
8.19E-7
1.05E-7
3. Percent of applicable limit
%
8.19E0
1 .05E0
C Diisolved and entrained
1. Total release
Ci
-
-
- 1
2. Average diluted concentration
during period
>ia/ml
-
-
3. Percent of applicable limit
%
-
-
D. Groa alpha radioactivity
1. Total releaae
Ci
il.44E-4
^1.73E-5
4.00E*!
E. Volume of waate releaaed (prior
to dilution)
bten
1.61E5
1.10E5
2.00E+1
F. Volume of dilution water uaed
during period
Utcn
6.42E9
1.90E9
2.00E+1
710
TABLE 2B
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT (1982)
LIQUID EFFLUENTS
January - June 1982
CONTINUOUS MODE
BATCH MODE
Nudidn R(l«nd
Unit
Ouartv
Quartar
Quartar
Quartar
rtrontiuin-89
Ci
6.70E-4
1.89E-3
»trontiuin-90
a
4J7E-4
1.65E.4
ce*ium-134
Ci
1.46E-2
7.42E-4
cetium-137
a
1.08E-1
6.60E-3
iodin«-131
Ci
-
2.25E-6
cobmlt-58
Ci
2.54E-3
8.23E-4
cobalt-60
Ci
2.44E-1
7.00E-2
iron-59
a
4.27E-5
3.06E-6
Bnc-65
Ci
4.28E-3
1.20E-3
iiianganM*-B4
Ci
2.61E-2
1.01E-2
chromium-Si
a
-
1.20E-5
xiiconimum-niobium-95
a
5.16E-4
6.74E-4
molybdenum 99-
technetium 99m
a
-
-
b«hum-lanthanum-l 40
a
-
4.96E-5
cenum-141
Ci
1.65E-5
-
2.70E-6
iodine-133
cehum-144
■ilver-llOm
iion-65
Ci
a
Ci
a
unidentified
a
Total for period (above)
a
zenon-133
xenon-135
Ci
a
1.47E-1
2.40E-2
5.72E-1
1.75E-5
2.43E-2
Z. 121-1
.44E-1 j
Zl
- 7
711
TABLE 3
EFFLUENT AND WASTE DISPOSAL SEMI-ANNUAL REPORT (1982)
SOLID HASTE AND IRRADIATED FUEL SHIPMENTS
JANUARY • JUNE 1982
A. SOLID MASTE SHIPPED OFF SITE FOR BURIAL OR DISPOSAL. (Not irradiated fuel,
1 . TYPE OF HASTE
UNIT
6 MONTH
PERIOD
EST. TOTAL
ERROR X
a.
Spent resins, filter sludges,
evaporator bottoms, etc.
in3
CI
97.299
123.60353
N/A
N/A
b.
Dry compressible waste, contanrinated
ei^uipment. etc.
m3
Ci
1539.11
10.67373
N/A
N/A
c.
Irradiated components, control
rods, etc.
«3
CI
NONE
N/A
d.
Other (Descrtbe)
Miscellaneous low-level waste
■|3
CI
NONE
N/A
2. ESTIMATE OF MAXR NUCLIDE COMPOSITION. (By Type of Haste)
Sr90
X
E( Curies)
a. Spent Resins. Filter
.522
.64564
Sludges, Evap. Bottoms.
Srflg
19.972
?4.fififi1B
Diatomateous Earth. Etc.
F*55
1? f97
1i;.fiq4'?4
Cs134
4.T?6
5.13671
5^137
?6 . ■\:>7
32.54062
K5fi
1.220
1.50773
f%i54
2.712
3.35228
Zn«5
.450
.55669
Co60
31.633
39.09916
La.l40
.niq
M'm
Ra.lAn
.005
.nnfi?i
1-131
.004
.004?'
Cr-51
.283
..... , ..r?2S .
TOTALS
100.000
1?3. 60353
8A -
712
••
X
E( Curies)
b. Dry Compressible Waste Co60
50.24
5.36260
Contaminated Equipment Co58
7.63
.81467
CS137
22.48
2.39956
Csl34
6.75
./ZOII
Fe55
1.75
.18635
Fe59
1.14
.12171
Sr89
.12
.01328
Sr90
.01
.00027
Zn65
.23
.02488
Hn54
9.65
1.03030
TOTALS
100,00
10.67373
c. N/A
d. N/A
3. SOLID WASTE DISPOSITION
Number of Shipments Mode of Transportation
20 Tractor Trailer
32 Tractor Trailer
B. IRRADIATED FUEL SHIPMENTS (Disposition)
NjTfeer of Shipments Mode of Transportation
NONE N/A
Destination
Richland, Wash.
Barnwell, S.C.
Destination
N/A
713
PILGRIM NUCLEAR POWER STATION
Radioactive Effluent and Waste Disposal Report
including
Radiological Impact on Humans
July 1 through December 31, 1982
BY: NUCLEAR OPERATIONS SUPPORT DEPARTMENT
ENVIRONMENTAL AND RADIOLOGICAL
HEALTH AND SAFETY GROUP
Date: March 1, 1983
BOSTON EDISON COMPANY
H303290478 930308
PdH ADOCK 05000Z93
R
714
PILGRIM NUCLEAR POWER STATION
RADIOACTIVE EFFLUENT AND WASTE DISPOSAL REPORT
INCLUDING RADIOLOGICAL IMPACT ON HUMANS
JULY 1 THROUGH DECEMBER 31, 1982
Prepared By: 6>/uSZ^wg ^
Approved By:
Christine E. Bowman
Senior Radiological Engineer
-^J^
Thomas L. Sowdon
Environmental Radiological
Health and Safety Group Leader
Date of Submittal: Marcn 1, 1983
Section
Table
715
TABLE OF CONTENTS
Page
1. Introduction and Summary 1
2. Effluent, Waste Disposal and Wind Data 1
3. Off-Site Doses Resulting From Radioactive Liquid Effluents 41
4. Off-Site Doses Resulting From Radioactive Gaseous Effluents 46
5. Off-Site Doses From Direct Radiation 68
LIST OF TABLES
Page
Supplemental Information 2
lA Gaseous Effluents - Summation of All Releases 3
IB Gaseous Effluents - Elevated Release *
IC Gaseous Effluents - Ground Level Release 5
2A Liquid Effluents - Summation of All Releases 5
2B Liquid Effluents 7
3 Solid Waste and Irradiated Fuel Shipments 8
4A-1 Distribution of Wind Directions and Speeds - 33 ft. Level 9
of 160 ft. Tower
4A-2 Distribution of Wind Directions and Speeds - 160 ft Level 25
of 160 ft. Tower
3.2-1 July-December 1982 Liquid Release Maximum Individual Doses 42
from all Pathways for Adults (MREM)
3.2-2 July-December 1982 Liquid Release Maximum Individual Doses 43
from all Pathways for Teenagers (MREM)
3.2-3 July-December 1982 Liquid Release Maximum Individual Doses 44
from all Pathways for Children (MREM)
3.3-1 Population Doses Resulting from the July-December 1982 45
Liquid Effluents
lii
716
LIST OF TABLES (cont.)
Table
Paae
4 1-1 Undepleted Relative Concentrations per Unit Emission for
Reactor Building Vent for July-September 1982 47
4 1-2 Depleted Relative Concentrations per Unit Emission for
Reactor Building Vent for July-Septenber 1982 48
4 1-3 Relative Deposition Concentrations per Unit Emission for
Reactor Building Vent for July- September 1982 49
4.1-4 Undepleted Relative Concentrations per Unit Emission for
Main Stack for July-September 1982 50
4.1-5 Depleted Relative Concentrations per Unit Emission for
Main Stack for July-September 1982 5'
4.1-6 Relative Deposition Concentrations per Unit Emission for
Main Stack for July-September 1982 ='
4 1-7 Undepleted Relative Concentrations per Unit Emission for
Reactor Building Vent for October-December 1982 53
4 1-8 Depleted Relative Concentrations per Unit Emission for
Reactor Building Vent for October-December 1982 54
4 1-9 Relative Deposition Concentrations per Unit Emission for
Reactor Building Vent for October-December 1982 55
4 1-10 Undepleted Relative Concentrations per Unit Emission for
Main Stack for October-December 1982 56
4.1-11 Depleted Relative Concentrations per Unit Emission for
Main Stack for October-December 1982 57
4.1-12 Relative Deposition Concentrations per Unit Emission for
Main Stack for October-December 1982 5b
4.2-1 Maximum Individual Locations and Pathways 59
4 2-2 July-December 1982 Gaseous Release Maximum Individual Doses
from all Pathways for Adults (MREM) &U
4.2-3 July-December 1982 Gaseous Release Maximum Individual Doses
from all Pathways for Teenagers (MREM) oi
4 2-4 July-December 1982 Gaseous Release Maximum Individual Doses
from all Pathways for Children (MREM) o^
4 2-5 July-December 1982 Gaseous Release Maximum Individual Doses
from all Pathways for Infants (MREM) dJ
IV
717
LIST OF TABLES (cont.)
Taple Me
4.2-6 July-December 1982 Gaseous Release Maxiirum Individual Doses
0.6 Miles ESE 64
4.3-1 Population Distribution 65
4.3-2 Population Doses Via Major Pathways Resulting from Gaseous
Effluents during July-December 1982
66
718
INTRODUCTION AND SUMMARY
This report is issued for the period July-December 1982 in accordance
with NRC Regulatory Guide 1.21, "Measuring, Evaluating and Reporting
Radioactivity in Solid Wastes and Releases of Radioactive Materials
in Liquid and Gaseous Effluents from Light-Water Cooled Nuclear Power
Plants" (Rev. 1). The information supplied includes actual effluent
releases, radioactive waste and meteorological data; doses from licuid
releases, doses from gaseous releases and direct gamma radiation doses.
2. EFFLUENT, WASTE DISPOSAL AND WIND DATA
Radioactive liquid and gaseous releases, wind speed data together with
measurement errors and solid waste disposal information are given in
Tables lA, IB, IC, 2A, 2B, 3, 4A-1, 4A-2, and supplemental information
section in the standard Regulatory Guide 1.21 format.
719
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT
Supplemental Information
July-December 1982
Ficililv PUgriin Nuclear Power Suoon UctnKc DPR -35
1 Rejublory Limits
2. FisSlun and a^itvaiion ^jses yS + WV = ^ 1
0.25// 0.1 0/r"
h Iodines 2Ci per quarter
. PjriKuloies lull^livesMKdjvs 13(1.8E4Qs + 1.8E5Qv)<l
d Liquid ellluenis ]Q(;.j pgp quarter
2- Maximum Permissible Concentration
Ptiivide Ihe MPCs used in dciennininp jtl.'w, jhle rclejie rjies ui LonLenir jimn^
J Fission jnd Jvlivjlion pjscs \ I0CFR2O
h Iodines > Appendix B
L Pariiculjics. hjli-hves >>■ djvs ' Table II
d Liquid diluenis H - 3 = 1 X 10-« AiCi/ml.aU reit. lOCFR 20. Appendu B, Table II
Average Energ>
Provide ilie jverj^e energy i tl oi ilie rjdHinui.lide hhmikc in iclejsc. oi tission jndj^iivjiioiiLjsei iijppli^jnle E=l Mev
MS = 0.304S0.287: RBV = 0.391 SO. 494 (3rd & 4th quarter)'
Measurements and ^ppro\imaiions of Total Kadioactivitv
Providf ihe me'luHJs UiCd lo iiicjsure nr jpptoMiiMW 4lic luijl rjdiMj^iivn\ m cillutfius jnd Hic nicili-.J^ u-rfd u-
determine rjdn)nu».lide mmposuK'n
3, Fission jnd JviivjiiDn ^j$es \ QeLi
h Iodines ( ,
n , > IStOpIC
L PjriiLuljies £
d Liquid elilucnts ) Ajialys.s
Batch Releases
Puivido I Ik" luMuwint inl'ornuln'n reljiinc lo hjii.h fclcjses ui radnu^iive mjienjlb in liquid jnd bjsci'Ui ^r' "'Lie"'.)
a Liquid
1 Numhef i>r bai^h relejies 77
2 Tatjl lime period tor bjuli relcj^es 87 .48hrS
Mjximum time peruKj for J baicli release - a QRhrc
4 Average inrte period lor bjiwh lelcjscs ] ^ ] 4hrS
5 Minimum lime penod loi 3 hjicli release — n "JThpc
(■> Averjpc stream How during periods ul release t)r'ei!Tueni inivt j iIo^mmb si ream 3 . 05E+5 GPM
b Gaseous (No( Applicable)
Abnormal Releases
b. ^^^^
720
TABLE 1A
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT
GASEOUS EFFLUENTS ■ SUMMATION OF ALL RELEASES
July-December 1982
Unit
Quarter
(3)
Quarter
(4)
i Est. Total j
I Error, % |
A. Fission and activation gases
1. Total release
Ci •<;1.07E+4 '^S.igE+S 2.49E+1 |
2. Average release rate for penod
MCi/sec <1.35E+3 •^6.53E+2
3. Percent of Technical Specification limit
% <1.77E-1 '<8.25E-2
B. Iodines
1. Total iodine-131
Ci
1.03E-2
9.32E-3
2.51E+1
2. Average release raie for penod
yCi/sec
1.30E-3
1.17E-3
3. Percent of Technical Specification limit
%
5.15E-1
4.66E-1
C. Particulates
1. Particulates with half-lives > 8 days Ci
8.20E-3
8.01E-3 1 3.03E-1 i
2. Average release rate for period
jiCi/sec
1.03E-3
l.OlE-3
3. Percent of Technical Specification limit
%
9.67E-2
8.72E-2
4. Gross alpha radioactivity
Ci
<5.14E-7
< 4.50E-7
D. Tritium
1. Total release
Ci
4.90E0
5.93E0
3.30E+1 1
2. Average release rate for penod
wCi/sec
6.16E-1
7.46E-1
i 3. Percent of Technical Specification limit
%
-
-
721
TABLE IB
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT ( 1982 )
GASEOUS EFFLUENTS - ELEVATED RELEASE
July-December 1982
CONTINUOUS MODE
BATCH MODE
Nuclides Released
Unit
Quarter
Quarter
Quarter
Quarter
1. Fission gases
2. Iodines
3. Particulates
(3)
(4)
krypton-85
Ci
1.62E-2
1.60E-2
krypton-85m
Ci
7.69E+2
5.47E+2
krypton-87
Ci
< 1.87E+2
<.4.58E+1
krypton-88
Ci
8.99E+2
4.99E+2
xenon-133
Ci
4.51E+3
3.07E+3
xenon-135
Ci
3.73E+3
7.36E+2
xenon-135ra
Ci
^1.54E+1
•C9.26E0
xenon-138
Ci
<■ 3.75E+1
<3.90E+1
xenon-131m
Ci
-
-
xenon-137
Ci
-
-
xenon-133m
Ci
1.30E+2
8.49E+1
Total for period
Ci
< 1.03E+4
5.03E+3
iodine-131
Ci
4.66E-3
6.53E-3
iodine-133
Ci
1 .68E-2
2.24E-2
iodine-135
Ci
< 1.22E-2
< 1 .48E-2
Total for period
Ci
< 3.37E-2
<4.37E-2
strontium-89
Ci
1.62E-3
2.78E-3
strontiutn-90
Ci
1.73E-5
1.83E-5
cesium-134
Ci
8.15E-6
2.61E-6
cesium-137
Ci
7.38E-5
5.76E-5
barium-Ian thanum-140
Ci
3.55E-3
2.68E-3
chromiujn-51
Ci
-
-
manganese-54
Ci
1.28E-5
3.65E-6
cobalt-58
Ci
-
2.09E-6
iron-59
Ci
-
-
cobalt-60
Ci
1.55E-4
3.97E-5
zinc-65
Ci
-
-
zirconium-niobium-95
Ci
-
-
cerium-141
Ci
-
-
cerium- 144
Ci
-
1.53E-5
ruthenium-103
Ci
-
-
ruthenium-106
Ci
2.70E-5
-
I
722
TABLE 1C
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT (1982 )
GASEOUS EFFLUENTS - GROUND LEVEL RELEASE
July-December 1982
CONTINUOUS MODE BATCH MODE
Nuclidn RalusMl
Unit
Quamr
Quarter
Quarter
Quarter 1
1. Fission gases
(3)
(4)
krypton-85
Ci
< 1.49E-5
5.03E-6
krypton-85m
a
< 3.46E+1
1.21E+1
krypton-87
Ci
O.ieEO
<4.07E0
krypton-88
Ci
< 1.55E+1
2.43E+1
xenon-133
Ci
1.41E+2
5.99E+1
xenon-135
Ci
1 .86E+2
5.86E+1
zenon-135m
Ci
-
-
xenon-138
Ci
-
-
Total for period
a
< 3.86E+2
<1.59E+2
2. Iodines
iodine-131
Ci
«; fifiF--?
2.79E-3
iodine-133
Ci
2.63E-2
1.18E-2
iodine-135
Ci
4.26E-2
2.10E-2
Total foi period
Ci
7.46E-2
3.56E-2
3. Particulates
strontium-89
Ci
1.29E-3
1.53F-3
strontiuin-90
Ci
2.55E-6
2.53E-6
cesium- 134
Ci
1.89E-6
4.46E-6
cesiuin-137
Ci
6.64E-5
2.14E-5
barium-lanthanum- 1 40
Ci
1.24E-3
7.85E-4
mangane9e-54
Ci
I.J!bt-b
1.31E-6
cobalt-58
Ci
.
3.74E-6
iron-59
a
.
cobalt-60
Ci
1.29E-4
5.90E-5
zinc-66
Ci
-
-
zirconium-niobium-95
Ci
-
-
cerium-141
Ci
.
.
nithenium-103
Ci
.
.
iuthenium-106
Ci
-
2.60E-5
723
TABLE 2A
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT (1982)
LIQUID EFFLUENTS - SUMMATION OF ALL RELEASES
JULY-December 1982
Unit
QLaHer
Qu^a^r
Est. Total
Error. %
A. Fission and activation products
1. Total release (not including tritium,
noble gases, or alpha)
Ci
3.09E-2
1.25E-1
2.98E+1
2. Average diluted concentration
during period
*iCi/ml
7.39E-9
6.65E-8
3. Percent of applicable limit
%
3.09E-1
1.25E0
B. Tritium
1. Total release
Ci
8.29E-4
4.55E-1
3.00E+1
2. Average diluted concentration
during period
liCilm\
1.98E-10
2.42E-7
3. Percent of applicable limit
%
1 .98E-3
2.42E0
C. Dissolved and entrained gases
1. Total release
Ci
-
5.39E-3
3.98E+1
2. Average diluted concentration
during period
»iCi/ml
-
2.87E-9
3. Percent of applicable limit
%
-
-
D. Gross alpha radioactivity
1. Total release
Ci
^6.60E-6
< 1.65E-5
4.01E+1
E. Volume of waste released (prior
to dilution)
Uters
8.47E+4
2.01E+5
2.00E+1
F. Volume of dilution water used
during period
liters
4.18E+9
1.88E+9
2.00E+1
724
TABLE 2B
EFFLUENT AND WASTE DISPOSAL SEMIANNUAL REPORT { 198^
LIQUID EFFLUENTS
July-December 1982
CONTINUQUS MODE
BATCH MODE
Nuclides Released
Unit
«3rd
Quarter
„4th
Quarter
Quarter
Quarter
strontium-89
Ci
1.64E-5
2.10E-5
strontium-90
Ci
4.70E-5
7.78E-5
cesium-134
Ci
3.30E-4
7.05E-4
cesium-137
Ci
3.73E-3
9.65E-3
iodine-131
Ci
5.87E-6
4.12E-5
cobalt-58
Ci
4.42E-5
1.96E-3
cobalt-60
Ci
8.67E-3
3.66E-2
iron-59
Ci
3r49E-6
5.30E-4
zinc-65
Ci
5.09E-5
5.37E-5
manganese-54
Ci
6.49E-4
3.74E-3
chromium-51
Ci
4.02E-5
6.57E-3
2irconimum-niobium-9 5
Ci
-
1.21E-6 J
molybdenum 99-
technetium 99m
Ci
-
5.71E-5
barium-Ian thanum-1 40
Ci
1.03E-6
4.3SE-5
cerium-141
Ci
2.14E-6
l.lOE-4
iodine-133
Ci
-
3.04E-6
cerium-144
Ci
-
-
silver-llOm
Ci
-
8.01E-4
iron-55
Ci
1.28E-2
2.41E-2
unidentified
Ci
4.49E-3
3.95E-2
Total for period (above)
Ci
3.09E-2
1.25E-1
xenon-133
Ci
-
2.18E-3
xenon-135
Ci
-
3.21E-3
725
TABLE 3
EFFLUENT AND WASTE DISPOSAL SEMI-ANNUAL REPORT (1982)
SOLID WASTE AND IRRADIATED FUEL SHIPMENTS
JULY - DECEMBER 1982
A. SOLID WASTE SHIPPED OFF SITE FOR BURIAL OR DISPOSAL. (not irradiated fuel)
1. TYPE OF WASTE
UNIT
6 MONTH
PERIOD
EST. TOTAL
ERROR %
a. Spent resins, filter sludges,
evaporator bottoms, etc.
b. Dry compressible waste,
contaminated equipment, etc.
m3
Ci
99.007
819.10
m3
CI
547.666
5.14564
N/A
N/A
N/A
N/A
c. Irradiated components,
control rods, etc.
m3
Ci
none
none
N/A
N/A
Other (describe)
Miscellaneous low-level waste
m3
Ci
none
none
N/A
N/A
2. ESTIMATE OF MAJOR NUCLIDE COMPOSITION, (by type of waste)
Co -60
%
E(Curies)
a. Spent Resins, Filter
41.324
338.48620
Sludges, Evaporator
Co-58
3.864
31.65107
Bottoms, etc.
Cs-137
13.426
109.97068
Cs-134
1.489
12.19371
Fe-55
11.164
99.44832
Fe-59
.597
4.89055
1-131
.464
3.79925
1-133
.070
.57668
La-140
.220
1.80569
Ba-140
.019
.15592
Sr-89
15.478
126.78505
Sr-90
.345
2.82477
Sr-91
.003
.02146
Tc-99m
.040
.32557
Zn-65
.723
5.92615
Mn-54
4.614
37.7974U
8A -
726
2 -
2. ESTIMATE OF MAJOR NUCLIDE COMPOSITION, (by type of waste)
CONTINUED
Nb-95
X
E(Curles)
a. Spent Resins, Filter Sludaes.
.002
.01495
Evap. Bottoms, Dlatomateous
Cr-51
6.090
49.88606
Earth, etc.
Ag-llOm
< .001
.00641
continued
Ce-141
.030
.24916
Ru-103
.014
.11290
Sr-92
.001
.00691
Sb-124
.010
.08267
Xe-133
< .001
.00034
Xe-135
.004
.03266
Mo-99
.007
.05629
TOTAL:
100.000
819.10682
Co -60
%
E(Curies)
b. Dry Compressible Waste,
17.46
.89843
Contaminated Equipment
Co-58
6.32
.32546
Cs-137
6.04
.31058
is-lii
1.65
.08565
Fe-59
1.17
.06038
1-131
2.74
.14116
Ba-140
3.76
.19341
Zn-65
.86
.04430
Mn-54
3.39
.17442.
Cr-51
56.60
2.91179
TOTAL:
100.000
5.14564
c.
N/A
d.
N/A
3.
SOLID WASTE DISPOSITION
Number of Shipments
37
2
Mode of Transportation
Tractor Trailer
Tractor Trailer
IRRADIATED FUEL SHIPMENTS (Disposition)
Numher of Shipments Mode of Transportation
none M/A
Destination
Barnwell, S.C.
Richland, Wash.
Destination
N/A
8B -
727
QUESTION 8. In recent years, Boston Edison has had unsatisfactory ratings
in the area of fire protection. I would like to know if
Pilgrim is now in full compliance with fire protection
requirements? Are all barriers, fire doors and penetration
seals repaired and capable of passing required testing? Are
fire watches still required in certain areas o^ the plant?
How many fire watches are still needed? Will the NRC require
Edison to complete the upgrading of the entire fire protection
system prior to allowing restart? How many maintenance
requests are still outstanding in the area of fire protection?
Please also comment on the condition of the Halon system in
the computer room at the plant and the smoke detectors over
the spent fuel pool.
ANSWER.
Pilgrim is either in compliance or will be in compliance with its fire
protection requirements prior to restart.
During the last one and one-half to two years, Boston Edison Company has made
significant improvements in their entire fire protection program. Additional
personnel with extensive experience in nuclear power plant fire protecticr
have been hired. Realignment of responsibilities and authority among these
licensee personnel have strengthened the entire fire protection program and
728
QUESTION 8. (Continued) 2
provided a higher level of accountability and continuity of effort that has
resulted in substantial improvement in the program. This is evidenced by the
methodology and thoroughness exhibited in identifying and correcting
deficiencies.
One activity of the additional licensee fire protection personnel described
above was the licensee has performed a reevaluation of plant fire protection
features, comparing those features against NRC requirements and guidance, in
an effort to determine (a) the level of actual compliance, and (b) the adequacy
of the features provided to prevent unacceptable fire damage.
During the course of this reevaluation the licensee found several cases
where they did not literally comply with the NRC requirements or specific
commitments they had made earlier. The licensee, however, provided
justification to demonstrate adequate protection against unacceptable fire
damage and on that basis, asked for exemptions from those requirements. In
most cases the staff granted the exemptions. In those cases where the staff
did not agree with the justification provided, the licensee made modifications
so as to be in compliance.
Because of the more or less constant activity at operating plants, temporary
changes, repairs and, modifications, may result ir a particular conditicn that
is not in compliance. These situations are contemplated by the licensee and
provisions are in place to assist in identifying the situation beforehand,
providing Interim protection measures (such as fire watches) and maintaining
administrative control of the situation to assure that the out-of -compliance
condition is corrected.
729
QUESTION 8. (Continued) 3
The licensee has indicated that all modifications and work associated with
upgrading required fire barriers, fire doors and penetration seals has been
completed. The licensee has committed to having all of the necessary document-
ation concerning the above work completed prior, to plant startup.
Fire watches continue to be used in some areas at Pilgrim as well as most
operating plants. At the beginning of the present outage approximately 18
months ago, eight persons per shift were assigned full time responsibility for
continuous or roving fire watches covering approximately 180 individual
deficiencies. As of March 17, 1988, no continuous fire watches are required.
Two persons per shift are assigned roving as fire watches covering 41 separate
deficiencies throughout the entire plant. Of those 41 deficiencies, 25 are
related to fire barriers, 15 are related to maintenance activities, and one is
related specifically to activities pertaining to the outage.
Some minor upgrading to the fire protection systems may remain at the time
Pilgrim restarts. However, those modifications yet to be completed will have
been identified and the schedules for completion will have been reviewed for
acceptability by the staff.
One hundred and sixty-one maintenance requests were still outstanding in the area
of fire protection on March 17, 1988. However, this number by itself does not
give an accurate picture of the Pilgrim fire protection maintenance program. On
January 5, 1987 there were 260 open maintenance requests related to fire protection.
Since January 1, 1987, approximately 1,480 new fire protect-!cr-related maintenance
requests have been generated and approximately 1,580 have been closed.
I
730
QUESTION 8. (Continued) 3
You also asked for our comments on the condition of the Halon System in the
computer room, and smoke detectors over the spent fuel pool. A computer located
in a small room adjacent to the Cable Spreading Room is being phased out. The
room is protected by an operable automatic Halon fire suppression system. A
new plant computer has been installed next to the Technical Support Center and
the primary fire protection is provided by a sprinkler system with secondary
protection provided by an automatic Halon fire suppression system. Both of
these systems are operable.
Six smoke detectors are located over the Spent Fuel Pool in the ventilati
system exhaust ducts. Four of the six detectors have already been tested
during this current plant outage. The other two are scheduled for testing
prior to plant startup.
on
731
QUESTION 9. How many automatic and manual scrams have occurred at Pilgrim
since the plant became operational? What is the annual
industry-wide average?
ANSWER.
Table 1 provides data on unplanned automatic and manual scrams during operational
modes (criticality to 100"? power) for Pilgrim from 1984 through 1987 compiled
from licensee event reports submitted pursuant to 10 CFR Part 50.72 and
10 CFR Part 50.73. The comparable industry average rates are also provided in
Table 1. Prior to 1984, reactor scrams were not directly reportable to the NRC
(Pilgrim entered commercial service December 1, 1972).
Enclosure:
Table of Unplanned Scrams
When Critical for Pilgrim
and Industry
732
Enclosure to Question 9
Table 1
Unplanned Scrams When Critical for Pilgrim and Industry
1984 - 1987
1984* 1985 1986 1987*
Pilgrim
Automatic
Manual
Industry Average
Automatic 5.4 5.0 4.0 3.2
Manual 0.6 0.5 0,5 0.6
*Pilgrim critical hours for 1984 = 170.
**Pilgrim critical hours for 1987 = 0.
733
QUESTION 10. How many "Unusual Events" and how many "Alerts" have been
declared at Pilgrim since 1972? Please describe and give the
date of each report. How does this compare to the industry-
wide average?
ANSWER.
The NRC did not use the terms "unusual events" and "alerts" until 1980 and
did not established them as reportable categories in our regulations until
1983. Our computer records of notifications to the NRC Operations Center show
that Pilgrim has declared 12 Unusual Events and no Alerts since 1983. Of the
12 Unusual Events, 2 were caused by fires in nonsafety related equipment, and
1 was due to a potentially contaminated individual being transferred off site
for medical treatment. The remainder were attributed to safety system in-
operability, which necessitated shutdown of the plant in accordance with the
plant's Technical Specifications. Two tables are enclosed - the first compares
the number of unusual events at Pilgrim since 1983 with the industry average
per year; and the second provides descriptive data and the date for each unusual
event at plants.
Enclosure:
Tables of Unusual Events at
Pilgrim Nuclear Station
734
QUESTION 10. (Continued) 2
A comparison of Pilgrim Unusual Events versus the industry average follows:
Industry Unusual
Licensed
Industry
Pilgrim Unusual
Year
Events
Units
Average
Events
*1982
•
1983
205
85
2.4
0
1984
224
91
2.0
1
1985
312
98
3.2
5
1986
209
104
2.0
5
1987
231
109
2.1
0
*1988
-
-
-
"
5 Year
Total
11.7
n
♦This table was prepared from data contained in computerized data base from
August 1982 to the present. For comparison purposes, incomplete data for
1982 and 1988 are not shown. However, Pilgrim did report Unusual Events
(a fire in a face mask fitting machine) on August 18, 1982 and on February 11,
1988 (a fire in the machine shop). Pilgrim also had one Alert on June 3, 1982
relating to a withdrawn incore detector resulting in abnormal radiation levels.
This event lasted approximately 2 hours. Pilgrim had no other Alerts from 1983
to 1987; however, Alerts have been reported from other licensed facilities.
735
QUESTION 10. (Continued)
Enclosure to Question 10
Unusual Events at Pilgrim Nuclear Station
August 1983 to Present
Event
Description
4/26/84
5/16/85
05/23/85
09/20/85
10/15/85
11/04/85
01/04/86
01/09/86
02/11/86
02/14/86
04/11/86
02/11/88
Potentially contaminated man taken to hospital.
2 safety system trains inoperable.
2 safety system trains inoperable.
2 safety system trains inoperable.
2 safety system trains inoperable.
Residual Heat Removal safety train A inoperable.
2 of 8 Main Steam Isolation Valves fail closure
time test.
Fire in line to hydrogen storage tanks.
Low pressure coolant injection inoperable.
2 safety system trains inoperable.
Loss of containment integrity.
Fire in machine shop.
736
QUESTION 11. How many violations of NRC regulations have occurred at Pilgrim
since it began operation? What is the industry-wide average?
ANSWER.
The NRC does not maintain industry wide statistics on the total numbers of
violations per plant.
In order to provide this requested data for the Pilgrim faciUies, a review of
inspection report data was performed. Our review indicated that Pilgrim was
cited approximately 425 times for violations or deviations since the plant began
operation in June, 1972 through the end of 1987. This number however, does not
reflect whether the citations involved individual or multiple violations, whether
the citations were subsequently withdrawn, or the severity level of the vio-
lations. Moreover, enforcement history is only one of a variety of factors NRC
considers in assessing licensee performance.
I
737
QUESTION 12. There have been a number of allegations concerning the illegal
dumping of radioactive waste on Boston Edison property.
Concerns have also been raised over Edison's use of the town
dump for disposal of radioactive material. Would you please
describe what monitoring the NRC conducts or requires on
materials and waste leaving the Pilgrim site. Has the NRC or
the licensee performed tests on Edison property and at the
town dump to ensure that there are no elevated levels of
radiation at areas suspected of containing radioactive waste?
Where and when were tests conducted? What were the results?
ANSWER.
The NRC staff does not Itself monitor materials and waste leaving the Pilgrim
site. The licensee Is required to monitor all Items containing or contaminated
with radioactivity that leave the site and there are several facility procedures
that provide specific guidance and Instructions to plant health physics workers
regarding this activity. All radioactive wastes that are sent to sites specifically
intended for burial must meet federal regulations for radiation dose rate and
contamination levels as well as special requirements of the burial sites. NRC
performs routine inspections of thie radioactive transportation area to ensure
that licensees are conforming to these regulatory requirements. Further, onsite
materials that have the potential of being contaminated and are being shipped
off site are surveyed prior to being shipped. The licensee is not allowed to
dispose of contaminated objects in non-radwaste facilities without obtaining a
special variance required by in 10 CFR Part 20.302(a). BECo has not applied for
738
QUESTION 12. (Continued) 2
these variances. To our knowledge, no contaminated objects have been disposed
of in the town dump or in other public facilities not specifically intended for
contaminated objects.
The NRC received allegations that contaminated shrubs had been removed from the
site and improperly disposed of on BECo property in 1987. NRC inspectors
determined that appropriate surveys were performed, measurements were within
established limits and properly recorded prior to offsite disposal. An NRC
inspector accompanied by the licensee collected clippings from the shrubs which
were disposed of offsite. The clippings were independently analyzed by the NRC.
Only one sample had detectable levels when we used sensitive laboratory instru-
ments but was not detectable using standard survey meters.
The contamination levels were lower than typical soil background levels and
they posed no health hazard (see pages 12 - 13 of the enclosed Inspection Report
50-293/87-57, dated March 11, 1988, p. 12). NRC has not performed surveys for
contamination of the town dump or at other BECo properties and does not routinely
perform contamination surveys of this type. As stated in the Inspection Report,
the inspectors reviewed the licensee's program for release of material from the
site and concluded that it was adequate.
Enclosure:
Inspection Report dated 3/11/88
739
UNITED STATES
NL..EAR REGULATORY COMMISSION
REGION I
47S ALLENDALE ROAD
KING OF PRUSSIA. PENNSYLVANIA 19406
Enclosure to Ouestion Ij
MAP 1 ' 1988
^.-:ket No. 50-293
'.osxon Edison Company
ATTN: Mr. Ralph G. Bird
Senior Vice Pre:"id'-.'t - Nuclear
800 Eoylston Str-et
Boston, Massachusetts 02199
Gentlemen:
/
Subject: Region I Inspection Report No. 50-290/87-57
This refers to the routine safety inspection (50-293/87-57) conducted by
Messrs. C. Warren, J. Lyash and T. Kim of this office on DeceT.ber 7, 19S7 to
January 19, 19SS at the Pilgrim Nuclear Poher Station, Plymouth, M?ssachusetts.
Areas examined during this inspection are described in the N^C Region I
Inspection Report which is enclosed with tnis letter.
Based on the results of this inspection, it appears that one of your activities
related to high radiation area access control was not conducted in full com-
pliance with NRC requirements, as set forth in the Notice of Violation enclosed
herewith as Appendix A. The problem was identified by your staff. However, a
Notice of Violation is being issued because effective corrective actions
apparently have not been taken for previous problems with high radiation area
access control. In addition to following the instructions of Append''x A .n
preparing the required response, please include those actions you intend to
take to preclude recurrence of this problem by insuring that your corrective
actions are effective and lasting.
Two significant integrated plant tests were successfully executed during the
inspection period. Preplanning and control of these activities was generally
strong. We also observed that increased management involvement in assuring
effective problem followup has resulted in substantial improvement. Equipment
failures identified as a result of an unanticipated safety system actuation
however, indicate the need for stronger post-work test practices and a thorough
power ascension test program.
The response directed by this letter and the accompanying Notice are not
subject to the clearance procedures of the Office of Management and Budget as
required by the Paperwork Reduction Act of 1980, PL 96-511.
740
Boston Eai'son Corpany 2
Your cooperation with us in this matter is appreciated
MA?: ] 1 ]9S:'
Sincerely,
'mm
samuel J. (^)Tins, Deputy Director
Division nf Rpartnr Prniprtc
Enclosures :
1. Appendix A, Notice of Violation
2. NRC Region I Inspection Report No. 50-293/87-57
cc w'encls:
R. Barrett, Nuclear Operations Manager
B. Mclntyre, Chairman, Department of Public Utilities
Chairman, Plymouth Board of Selectmen
Chairman, Duxbury Board of Selectmen
Plymouth Civil Defense Director
J. Keyes, Boston Edison Regulatory Affairs and Programs
E. Robinson, Nuclear Information Manager
R. Swanson, Nuclear Engineering Department Manager
The Honorable Edward J. Markey
The Honorable Edward P. Kirby
The Honorable Peter V. Forman
S. Pollard, Secretary of Energy Resources
P. Agnes, Assistant Secretary of Public Safety, Commonwealth of
Massachusetts
R. Shimshak, MASSPIRG
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Massachusetts (2)
bcc w/encls:
Region I Docket Room (with concurrences)
W. Russell, RA
M. Perkins, DRMA (w/o ends)
R. Blough, DRP
L. Doerflein, DRP
R. Bores, DRSS
S. Collins, D«P
C. Anderson, DRS
0. McDonald, LPM, NRR
T. Chandrasekaran, SPLB, NRR
M. Callahan, OCA
J. Nickerson
i'i
741
APPENDIX A
NOTICE OF VIOLATION
Boston E::':s:r, Cc-pany Docket No. 50-293
Pilgrirr Nuclear Power Station License No. DPR-35
As a result of the inspection conducted on December 7, 1987 to January 19, 1988,
and in accorcance with the NRC Enforcement Policy (10 CFR 2, Appendix C), the
following violation was identified. Three previous Notices of Violation dated
March 13. March 23, 1987, and April 28. 1987 were issued for problems related
to the control of Locked High Raaiation Areas. It is evident that corrective
actions taken in response to these Notices of Violation have not been effective
in precluding recurrence.
The Station Technical Specification 6.11, "Radiation Protection Program,"
requires that "procedures for personnel radiation protection shall be
prepared consistent with the requirements of 10 CFR 20 and shall be
approved, maintained and adhered to for all operations involving perscn.'iel
radiation exposure."
The Station Procedure 6.1-012, "Access to High Radiation Areas," requires
in part that the areas controlled under this procedure remain locked or
guarded at all times.
Contrary to the above, on December 15, 1987, December 27, 1987, and on
January 3, 1988, doors to the areas being controlled as Locked High
Radiation Areas were found to be unlocked and unattended, in violation of
the Station Procedure 6.1-012.
This is a Severity Level IV Violation (Supplement I).
Pursuant tc the provisions of 10 CFR 2.201, Boston Edison Company is hereby
required to submit to this office within thirty days from the receipt of the
letter which transmitted this Notice, a written statement or explanation in
reply, including: (1) the corrective steps which have been taken and the
results achieved; (2) corrective steps which will be taken to avoid further
violations; and (3) the date when full compliance will be achieved. Where
good cause is shown, consideration will be given to extending this response
time.
I
742
U S NUCLEAR REGULATORY COMMISSION
REGION I
Docket/Report No. 50-293/87-57
Licensee: Boston Edison Company
800 Eoylston Street
Boston, Massachusetts 02199
Facility: Pilgrim Nuclear Power Station
Location: Plymouth, Massachusetts
Dates: December 7, 1987 - January 19, 1988
Inspectors: C. Warren, Senior Resiaent Inspector
J. Lyash, Resident Inspector
T. Kix, Resident Inspector
A. Randy ElougH, Chief Date
Reactor Projects Section No. 3B
Approved Ey :
Areas Inspected: Routine resident inspection of plant operations, radiation
protection, physical security, plant events, maintenance, surveillance, outage
activities! and reports to the NRC. The inspection consisted of 350 hours of
direct inspection. Principal licensee management representatives contacted are
listed in Attachment I. Observations made by the NRC Region I, Regional
Ac-in1 sfutc during a tour on December 8, 1937 are documented in Attachment
II of this report. A copy of Attachment II was provided to licensee management
for followup.
Results:
Violation: Repeated occurrences of locked high radiation area doors being left
open and unattended were identified by the licensee. Problems with high radia-
tion area access control have been previously identified and were the subject
of violations during inspections 50-293/87-03 and 50-293/87-11. Corrective
actions taken in response to these findings have not prevented their
recurrence. (Section 3.b, VIO 87-57-01)
Unresolved Item: The licensee identified that two reactor vessel level gauges
were incorrectly installed. A licensee investigation is currently ongoing to
determine the cause and to assess the adequacy of post installation test.
(Section 4.d, UNR 87-57-02)
743
Inspection Results (Continjed)
Concerns;
5.
The licensee experienced safety related equipment malfunctions upon
receiving a spurious reactor scram signal on January 17, 19S3. (Section
4.d)
Inadequate procedures and planning of surveillance tests resulted in un-
necessary engineered safety feature actuations. (Section 3. a)
Poor preplanning and control of maintenance was noted during f- electrical
relay replacement. A similar problem was the subject of a v ition dur-
ing inspection 50-293./87-50 . (Section 4.c)
Weak identification and tracking of lifted leads and jumoers led to a
water spill in the high pressure coolant injection system room during the
integrated leak rate test'. (Section 6.0)
The prelube pump for the "B" emergency diesel generator failed to restart
during a surveillance test. An identical failure occurred during a loss
of offsite power event on November 12, 1987. Licensee followup apoeared
adequate b'jt the failure root cause has not been identified. (Section
3.b)
The inspectors evaluated the erosion of construction dirt into wetlands
area. The inspector's independent survey of the area, and the licensee's
analyses indicate that the level of activity does not represent a health
or safety concern. However, the material should not be allowed to erode.
(Section 3.c)
Strengths:
1. The licensee's preparation and execution of the reactor vessel hydrostatic
test was well organized and controlled. (Section 5.0)
2. The licensee's response to a January 17, 1988 reactor scram signal and
subsequent equipment malfunctions was prompt, thorough and effective.
(Section 4.d)
3. Using non-nuclear steam for testing of high pressure coolant injection
system and reactor core isolation cooling system enabled the licensee to
discover problems which may not have been easily identifiable using
nuclear steam due to radiological conditions. (Section 3.b)
744
TABLE OF CONTENTS
1. S'-mrnary of Facility Activities
2. Followup on Previous Inspection Findings
3. Routine Periodic Inspections
a. Surveillance Testing
b. Radiation Protection and Chemistry
c. Fire Protection
4. Review of Plant Events
a. Spurious Isolations of RHR Shutdown Cooling System
b. Reactor Water Cleanup System Spurious Isolation
c. Engineered Safety Feature Actuations Due to a
Failed Logic Relay
d. Spurious Reactor Protection System Actuation
5. Review of Reactor Vessel Hydrostatic Test Procedure
and Test Results
6. Integrated Leak Rate Testing
7. Licensee Nuclear Organization Management
Realignment
8. Management Meetings
Pa^
1
1
4
15
19
21
23
24
Attachment I - Persons Contacted
Attachment II - Regional Administrator's Tour Observations
745
DETAILS
1.0 Summary of Facility Activities
The plant was shutdown on April 12, 1985 for unscheduled maintenance. On
July 25, 1986, Boston Edison announced that the outage would be extended
to include refueling and completion of certain modifications. The reactor
core was defueled on February 13, 1987. The licensee completed fuel re-
load on October 14, 1987. Reinstallation of the reactor vessel internal
components and the vessel head was also subsequently completed.
During this report period, the licensee performed the reactor vessel
hydrostatic test and the primary containment integrated leak rate test
(ILRT) as described in Sections 5.0 and 6.0. On December 9, 1987, Pilgrim
Station conducted a partial participation emergency preparedness exercise.
On December 14, 1987 the licensee announced as part of a planned manage-
ment realignment, the appointment of eight managers to key management
positions in the licensee nuclear organization at Pilgrim Station. The
details of the management realignment are described in Section 7.0.
NRG inspection activities during the report period included: 1) observa-
tion of the licensee's annual emergency preparedness exercise on
December 9, 1987, 2) NRC Reactor Operator Licensing examinations were
administered to eight candidates on the week of December 7, 1987, 3) ob-
servation of the primary containment ILRT and review of the test results
during the week of December 21, 1987. The results of these inspections
are documented in inspection reports 50-293/87-54, 50-293/87-56, and
50-293/87-58. In addition, represertatives of the NRC's Office of Inves-
tigation were onsite December 3, December 7, and December 8, 1987 to
interview onsite security personnel. On December 8, 1987, the NRC
Regional Administrator for Region I, Mr. William T. Russell, toured the
plant with the resident inspectors. On January 7, 1983,
Dr. Thomas E. Murley, Director of the Office of Nuclear Reactor Regulation
(NRR) and other NRC representatives toured the plant with the resident
inspectors.
2.0 Followup on Previous Inspection Findings
(Closed) Unresolved Item 82-24-02 - Discrepancies in the Licensee's
Response to IE Bulletin 79-08
Previous reviews of this item are documented in the inspection reports
50-293/82-30, 50-293/83-01, 50-293/83-14, and 50-293/84-26. IE Bulletin
(lEB) 79-08 and the TMI Action Plan Item II.E.4.2 required licensees to
review the containment isolation initiation design and procedures to
ensure proper initiation of containment isolation, upon receipt of an
automatic containment isolation signal. The licensee provided the
results of their review in letters dated April 25, and August 21, 1979.
746
Tne licensee stated that the RBCCW supply and return lines, instrument air
line, RHR to spent fuel pool cooling tie line, and torus make up line
would be manually isolated and that station procedures would specify the
requirements for manual isolation if a containment isolation signal was
receives. This was documented as acceptable by NRC:NRR in letters to the
licensee dated December 18, 1979 and April 3, 1930. However, an inspector
identifiea that manual isolation of these lines with qualified valves is
not possible. Any valve which is used for primary containment isolation
must meet Seismic Class I ( FSAR section 12.2) and applicable 10 CFR 50,
Appencix J, containment leakage testing criteria. Further, if manual
operation of a valve is required to effect containment isolation, the
isolation point for the valve must also be accessible under those condi-
tions which make its use necessary.
In response to the inspector's questions, the licensee re-evaluated their
respo'-.sr to tne lEB 79-08 and TMI Action Plan Item II.E.4.2, and concluded
that isolation of these lines is assured by the use of Seismic Class I
check valves. The licensee also agreed that isolation for the RBCCW
supply line, instrument air line, RHR to spent fuel pool cooling tie line,
and tcrus makeup line cannot be performed by manual valve closure. The
R2CCW return line from the drywell can meet the isolation valve criteria
with MOV-4002 which is seismic class I, local leak rate tested and can be
ciosec by a control switch located in the main control room. The licensee
subsequently submitted a supplemental response to IE Bulletin 79-08 and
TKI Action Plan Item II.E.4.2 on October 24, 1984 correcting the previous
response. The inspector reviewed the supplemental response and verified
that the contents were consistent with the conclusions drawn from the
licensee's re-evaluation and the FSAR. Both RBCCW supply line and instru-
ment air lire are considered Class C lines in Section 7.3 of the FSAR
since tney penetrate containment but have no interaction with the primary
containment free space or the reactor vessel. According to the original
cesign criteria, a single check valve is provided to attain isolation for
a Class C line. Tnese check valves are seismic class I and local leak
rate tested. The inspector reviewed the results of local leak rate test
data for these check valves which were performed on June 12 and July 26,
1957 and found no discrepancies. The torus makeup line is identified as
Class B in Section 7.3 of the FSAR. The torus makeup line is non-essen-
tial and ties the condensate transfer system into the RHR test line, which
penetrate primary containment and ends below the torus water level. For
water-sealed Class B lines such as the torus makeup system, the original
plant design bases allow one isolation valve in addition to the water seal
to meet isolation requirements. Also, the Safety Evaluation by the NRR on
Appendix J Review indicate that Type C testing is not required for valves
in lines which terminate below the level of the suppression pool. As for
the RHR to spent fuel pool line, the licensee revised the operating pro-
cedures 2.2.85, Fuel Pool Cooling and Filtering System, prohibiting the
use of the RHR to spent fuel pool lines except in cold shutdown. The
inspector had no further questions. This item is closed.
747
(dosed) Inspector Follow Item (IFI 87-27-02) - Cracking of Surge Ring
Brackets in Large GE Motors
On July 2, 1987, IE Information Notice 87-30, Cracking of Surge Ring
Brackets in large GE motors, was issued. The purpose of the notice was
to alert recioients of a potential for failure of surge ring brackets and
cracking of felt blocks in large, vertical electric motors manufactured
by General Electric Co. Felt blocks are used in large electric motors to
keep the windings separated where they loop back at the end of the stator.
The blocks are attached to a surge ring that is held in place by L-shaped
surge ring brackets welded to the surge ring and bolted to the motor cas-
ing. Failure of these surge ring brackets and cracking of the felt blocks
allows movement and wear of the end-turns, leading to a reduction in
insulation resistance and possible motor failure. In addition, broken
pieces of the surge ring bracket may enter the space between the stator
and tne rotor, resulting in electrical or mechanical motor degradation.
Following an investigation to determine the applicability of the subject
notice to the Pilgrim Station, the licensee found that RHR, core spray,
and recirculation pump motors were potentially affected. RHR and core
scray pump motors were overhauled on site by GE under contract with the
Vicensee in 1986. The surge ring brackets were not inspected during the
cverhaiil . However, small cracks were found on the "A" and "C" RHR pump
meter winding felt blocks. The amount of cracking found was di spositioned
by GE to be acceptable and a normal phenomenon found in form-wound motors.
On July 27 through August 5, 1987, GE performed a surge ring bracket
inspection of the RHR and recirculation pump motors using a horoscope with
the motors in place. The inspection of the RHR motors (A thru D) revealed
absence of cracks on the surge ring brackets. During the inspection of
the "B" recirculation pump motor, it was noted that the recirc motor surge
rinc bracket construction is of the bolt and stud design, whereas the RHR
and core spray motor brackets are of the L-shaped design. The L-shaped
aesign configuration is known to have the potential of cracking, according
to the IE Notice 87-30 and the GE letter to the licensee dated
July 14, 1937.
During the week of October 26, 1987, "B" core spray pump motor was dis-
assembled and the surge ring brackets inspected by G.E. Due to the geo-
metry of the core spray pump motor internals, there is limited access for
the bore scope, therefore, this inspection could not be accomplished with-
out partial disassembly of the motor. It was verified that the design had
12 brackets per surge ring and two surge rings for the top end turn assem-
bly and two surge rings for the bottom end turn assembly. None of the
brackets had indications of cracking. The licensee scheduled the inspec-
tion of the "A" core spray pump motor during the next outage because of
scheduling conflicts. The licensee indicated that based on the inspection
I
748
results of the RHR and "B" core spray pump motors, postponement of ihe "A"
core spray pump motor inspection is justified. The licensee also added
that the number of operating hours and starts are similar between tne A
and B core spray pump motors since both core spray systems' testing and
surveillance requirements are similar,
questions. This item is closed.
The inspector had no further
(Closed) Unresolved Item 87-45-05 - Failure to Issue Licensee Event
Reports
In inspection report 50-293/87-45 the NRC identified three engineered
safety feature actuations which appeared to be reportable under 10 CFR
50.73 but had not been reported by the licensee. The licensee reviewed
the three actuations, agreed that they should have been reported and
agreed to issue License Event Reports (LER) to document the occurrences.
In addition tne licensee agreed to perform a review of previous actua-
tions to determine if any additional reports were needed.
During this inspection period the licensee's compliance section conducted
a review of all Failure and Malfunction Reports (F&MR) issued from April
1956 through the present. This review Identified four F&MRs that fit the
description of an ESF actuation under the current EECo interpretation of
N'uREG 1C22. The licensee will submit LERs to document tne following ESF
actuations at a later date.
4/23/S7 Initiation signal to both Emergency Diesel Generators (EDG)
6/7/87 Actuation of Reactor Building Isolation and Standby Gas
Treatment System start signal
9/17/S7 Auto start of "A" EDG
10/6/S7 Reactor Water Cleanup and Shutdown Cooling System Isolation
These LERs will be reviewed upon issue as part of the normal resident
inspection program. The inspector has reviewed the licensee's actions in
addressing open item 87-45-05 and is satisfied that those actions were
thorough and timely. This item is closed.
3.0 Routine Periodic Inspections
The inspectors routinely toured the facility during normal and backshift
hours to assess general plant and equipment conditions, housekeeping, and
adherence to fire protection, security and radiological control measures.
Inspections were conducted between 10:00 p.m. and 5:00 a.m. on January 17,
18, and 19, 1988 for a total of four hours and during the weekends of
December 12, 19. 27, 1987 and January 3, 9, 17, 19S& for a total of 17
hours. Ongoing work activities were monitored to verify that they were
749
being conauCiea in accorcance with approved adiriini strati ve and tec"inical
procedures, and that prooer coTmunications with the control room staff had
been estaolishea. The inspector observed valve, instrument and electrical
equipment lineuns in the field to ensure that they were consistent with
systerr cpe-aci 1 i t> requ" rernents and operating procedures.
During tours of the co'-tro' rooT the inspectors verified proper sta^'fing,
access cortrcl anc cperato" attenti veress. Adherence to procedures and
liiT^itinc concitiors for coerations was evaluated. The 'nsoectors examined
equiprent lineup and operability, instrument traces and status of control
room annunciators. Various control room logs and other available licensee
documentation were reviewed.
Tne i^soecto" observer anc reviewed outage, maintenance and problem inves-
tigation activities to verify co:::pliance with regulations, procedures,
codes a"C sta'-cards. In/o 1 ve'-ent of QA/QC, safety tag use, personnel
qual i f icaf ons , *ire protection precautions, retest requi '•ements , and
reportabi 1 ■' ty were assessed.
Tne insoectc cbse-'ved tests to verify performance in accordance with
aporove: procec^'-t-s a'-c LCG's. collection of valid test '■esults, removal
and restoration of eauipment, anc deficiency review and resolution.
Racioloc'cal controls were observed on a routine basis during the report-
ing period. Standard inOuStry raciological work practices, con'^^ormance
to rad^^clogica'' confcl procedures and 10 CFR I'a'-t 20 requirements were
observed. Independent surveys of radiological boundaries and random
surveys of nonradi ol ogical points throughout the facility were taken by
the irspector.
Cnecks were mad? to determine whether security conditions met regulatory
requirements, the pnysical security plan, and approved procedures. Those
checKS 'rcluded security staffing, protected and vital area barriers,
personnel iaent i f ication , access control, badging, and compensatory
measures when required.
a . Surveillance Testing
Diesel Generator P--eljbe Pump Failure
On December 13, 1927, the prelube pump for the "S" emergency
diesel generator (EDj) failed to restart on demand during a
routine surveillance test. Upon disassembly it was identified
that a small piece of metal had become lodged between the pump
rotor and idler gear. The interference from the metal caused
the pump motor breaker to trip on pump start. An identical
failure occurred during a loss of offsite power event on
November 12, 19=7. In that case the failure caused a lengthy
delay in returning an idle diesel to service. While not
required fc" diesel operation, the prelube system reduces EDG
bearing wea" during equipment start.
750
In response to the failures, the licensee drained and inspected
the lube oil sump, and disassembled and inspected the lube oil
filters, strainers and heater. The lube oil heater was found
to have failed in the energized mode resulting in significant
rarbon deposits in
the heater and filter. No appreciable
deposits were found in the lube oil sump. In addition, a piece
of filter ele:tient packaging material was found in the lube oil
filter housing. No foreign material which could have contrib-
uted to the prelube pump failure, however, was found. The pump
was replaced and the diesel was returned to service. No adai-
tional failures occurred during the inspection period. The two
pumps which failed had in-sequence serial numbers. Licensee
Quality Control personnel performed magnetic particle and dye-
penetrant testing of the internals of a third in-sequence pump
in the warehouse. No flaws were noted. The licensee is pursu-
ing the '•c;t cajse or' the faiKres in cooperation with the pump
vendor. Viking Pump. The licensee stated at the exit interview
tnat tne "A" EDG prelube pump and lube oil heater would be
inspected during the next "A" diesel outage. The inspector will
continue to monitor licensee followup to this problem.
Steam Testing of the High Pressure Coolant Injection and Reactor
Cce Isolation Cooling Systems
The licensee completed full pressure steam testing of the High
Pressure Coolant Injection (HPCI) and Reactor Core Isolation
Cooling (RCIC) system turbines by utilizing temporary oil fired
auxiliary boilers as a source of non-nuclear steam. The full
pressure steam testing is part of a post-maintenance and system
operaDility check. Both HPCI and RCIC systems were overhauled
du'-ing the current outage. Utilizing temporary test procedures
TP 87-198 and TP 87-199, the HPCI/RCIC testing included turbine
overspeed trip, pump full flow capacity and operation from the
alternate shutdown panels. Also during the test, the suction
path was changed from the condensate storage tank to the torus
and back.
During the testing, several problems were identified by the
licensee in both HPCI and RCIC systems. In HPCI, problems with
the governor control system were noted including a minor oil
leak in the servo-motor. Steam leaks at gauges and turbine
drain line were also discovered. In RCIC, the licensee dis-
covered a previously installed blank flange in the turbine steam
leak off line which caused steam leaks. A few problems were
also noted on the RCIC governor control system. The licensee is
in the process of di sposi tioni ng these items. The inspector
notea that using non-nuclear steam for the testing enabled the
licensee to discover problems which may not have been easily
identifiable using nuclear steam due to the radiological condi-
tions. The inspector will review the results of the tests and
disposi tioning of the problems identified during the tests.
751
Incorrect Installation of Fire Da:npers
On December 17, 1987, during performance of a routine su'-veil-
lance test the licensee inadvertently actuated two fire danpers.
One of the dampers failed to fully close due to interference
with a hook used to secure it in the open position. When the
fusible link was energized, the metal damper retaining strap
should have fallen away allowing full closure. The hook attach-
ing the strap to the fusible link was oriented with the open
side toward the damper. The damper caught on the hook and re-
mained partially open. Upon discovery the licensee immediately
stationed fire watches at all areas containing suspect dampers.
Inspections were promptly conducted and it was identified that
all of the installed hooks were oriented in this manner. The
hooks were repositioned so that the open side faces away from
trie damper. Three damoe'-s were inaccessible and cojipensaiory
measures remain in place pending inspection.
The dampers were originally supplied to the licensee without the
hooks. A revision to the plant design change (PDC) package
adaed the hooks to facilitate surveillance testing. Installa-
tion instructions contained in the PDC specified hook orienta-
tion with the open side toward the damper. The vendor data
sheet suDolied by Air Balance Inc. also showed the hook instal-
led in this manner.
Licensee event report (LER) 87-020-00 was issued describing the
problem and corrective actions taken. The LER states that pre-
liminary licensee assessment of the issue determ-'ned that it did
not meet the reporting threshold of 10 CFR Part 21. The inspec-
tor discussed the Part 21 reportabi 1 i ty with the licensee's
Nuclear Engineering Department (NED). NED personnel stated that
the failure mechanism was created by the licensee when the hook
was added. In addition the presence of mitigating factors such
as fire detection and suppression, and control of combustible
materials support the conclusion that a substantial safety
hazard did not exist. The licensee also feels that LER 87-020-
00 contains sufficient information to clearly define the
problem. The inspector had no further questions in this area.
The inspector examined two dampers in the cable spreading room
to verify that the hooks had been reoriented. Both hooks had
been modified, however, neither of the dampers had locking rings
installed at the hook to retaining strap connection as required
by the installation instructions in the PDC. The licensee
reviewed the function of the locking rings and concluded that
they were not required. A change to the PDC was initiated to
delete the ring. The inspector had no further questions.
752
b. Radiation Prctecticr and Cherni stry
Locked Hign Radiation Area Access Control
u'jrirg the period covered by inspection report 87-57, ''oj'-
instances occurred in which the licensee failed to properly con-
trol access to areas that had been designated as locked higr
radiation areas. In three of these cases, doers to locked high
radiation areas were found closed but not locked and in tne
'ourtn cas3 a door into a locked high radiation area was ^"ounc
to not be on the list of doors that were being controlled under
the locked high radiation area door procedure.
On December 15, 19S7, a contract painter failed to check that
the door to the locked high radiation area he was exiting was
prcperly laichec. Tne unlatchec door was identified during the
next routine check of high radiation area doors. Licensee per-
sonnel imrreciately latched the door and initiatec a radiological
occurrence report (ROR) to document the occurrence and track all
actions taken during the investigation. Surveys of the area
showed no dose rates greater than 1000 millirems per hour
(MR/hr). Interviews with the individual involved determined
tnat the procedures and requirerrents were well understood and
that the HP technician had informed them of their responsibil-
ities prior to entry into the area.
On December 27, 1987, and again on January 8, 1°S8, instances
similar to the one described above took place. - both cases
the licensee initiated RORs and took steps to determine: 1) who
had been in the area, 2) were they aware of the procedure, and
3) had they been properly briefed prior to entry into the areas
involved. In both of these cases the root cause has been deter-
mined as personnel error.
In one instance the licensee identified that one of the multiple
doors into an area classified as a locked high radiation area
was not on the list of doors to be checked on a routine basis.
The door was immediately checked and found to be locked. Records
have been audited to determine if any unauthorized entry into
the area had occurred and no instances were identified. The
door has been placed on the list and is now routinely checked.
The inspector reviewed licensee actions as a result of these
instances and is satisfied that in all cases, the immediate and
followup actions were timely and complete. Surveys tat^en were
comprehensive and conducted almost immediately after discovery
of unlocked areas. Dose calculations were performed and
dosimetry read in all cases. Involvement by senior HP and plant
management was evident in all instances.
753
Inadequate control of locked high radiation areas has been an
area of longstanding NRC concern. Notices of Violation have
been issued in the past, during inspections 50-293/S7-03 ,
50-293/87-11, and 50-293/87-19 which addressed these concerns.
In regard to these violations the licensee instituted corrective
actions which have been successful in addressing segments of the
problem but have not been successful in preventing recurrence of
events involving high radiation area door control.
The inspector has independently reviewed the licensee's program
for control of high radiation areas and high radiation area key
control and has found them adequate. Although the programs
themselves are adequate and personnel have been trained on those
programs, instances still occur where locked high radiation
areas are not adequately controlled.
Based on review of these four instances coupled with the review
of Unresolved Item 87-50-03, the inspector determined that the
licensee actions in response to these previous findings have not
prevented recurrence. Failure to comply with the requirements
of Technical Specification 6.11 and Implementing Procedure
6.1-012 is an apparent violation of NRC requirements as docu-
mented in Appendix A of the cover letter to this report
(87-57-01). Licensee response to Appendix A should include
those measures taken to insure that corrective actions are
effective and lasting.
Contaminated Clothing Offsite
On December 17, 1987, at 7:26 p.m. hours a Bechtel pipefitter
wno was exiting the reactor building, set off a whole body por-
tal monitor alarm. The portal monitor indicated contamination
of his chest area and left hand. The health physics technician
on duty at the access point removed the individual from the por-
tal monitor and began performing a survey using a RM-14 with DT
260 probe. The HP technician identified; 1) contamination on
the individual's left hand, 1-2 thousand dpm per 100 square
centimeters (K DPM), which was removed by washing, 2) contamina-
tion on the shirt in both the chest (80K DPM) and lower stomach
area (IK DPM). The shirt contamination was removed by tape (80K
DPM) and washing with soap and water (IK DPM). The employee,
now wearing an undershirt and trousers, was then sent to clear
the portal monitor which again alarmed and indicated contamina-
tion in the chest area. The HP technician again surveyed the
individual and identified contamination on the undershirt in the
chest area (70K DPM). The individual was then sent into the
portal monitor bare chested and was cleared. The individual was
given his outer shirt, which was still wet from decontamination
and cleared through portal monitor. At this point, the indi-
vidual removed the wet shirt, put on his jacket, cleared the
portal monitor again, and left for his home.
754
10
LiDcr returning to work, December 18, 1987, the individual was
given a whole body court to determine if any internal contamin-
ation had occurred. The whole body count showed no internal
contamination. After completion of the whole body count the
inciv'djal was interviewed to determine how he had been contam-
inated, where the occurrence took place and how long he was
contaminated prior to detection, to calculate skin dose received.
The interview revealed that the individual had been contaminated
when ne disconnected a partially pressurized service air hose
and depressurized it. The interview also revealed that the
individual used the portal monitor at the 91 ft. elevation of
trie reactor building, received an alarm, did not call for HP
assistance but instead tried to decontaminate himself prior to
proceeding to the reactor building access. Station procedu-es
rec^ire trat a", inaivicual who finds rimself contaminated is to
call health physics for assistance. The individual stated that
he was aware of this requirement. During the interview the
incividual expressed concern about whether his heavy winter
jacket could have shielded the contamination on his shirt and
uncersnirt from detection by the portal monitors. To demon-
strate that this could net happen, a HP suoervisor placed
plastic bags, which contained the contamination removed from his
shirt, inside the coat and attempted to exit through two por-
tals. Tne postal monitors alarmed on each attempt. The indi-
v'cja' apceared satisfied wHh the demonstration put his jacket
back on. with the plastic bags removed and attempted to leave
the reactor building. An alarm was actuated on the portal
-:>'■■'-.:■- and co'tami naf' on was indicated on the left arm. The
en Si-ty HP technician removed the individual from the portal
Toritcr and identified 3K DPM contamination on the upper right
sleeve (outside) of the jacket even though the jacket had not
been worn into the reactor building. At this juncture the indi-
vidual expressed concern over whether the shirt that he had worn
the previous day could still be contaminated. The licensee had
a np tecnnician accompany the individual to his home. The
individual's shirt was found to be contaminated, was bagged and
returned to the site. Surveys of the individual's home and
vehicle identified no further contamination.
Efforts to determine how the contaminated shi-t was worn through
the portal monitors without setting of an alarm yielded positive
results. The individual stated that he had purposely kept him-
self away from the portal monitor in an attempt to keep his wet
shirt away from his skin. The licensee taped the plastic bags,
with the contamination in them, back onto the shirt and an HP
supervisor attempted to pass through the portal monitors by
755
11
mimicking the body posture used by the individual when he cleared
the monitor. The HP supervisor was able to pass through six
different monitors without setting off an alarm. The HP super-
visor then used the portal monitors in the correct manner and
all six monitors alarmed proving that the equipment was func-
tional .
The licensee has evaluated the occurrence to identify the root
causes and immediately implemented corrective action. This
occurrence was caused by one sequence of events that involved
two distinct personnel errors. The primary cause involved the
failure of the HP technician to perform an adequate survey of
the contaminated individual's clothing when the portal monitor
alarm was received. The second problem involved the failure to
properly use the installed portal monitors at the reactor build-
ing access.
In addition to personnel interviews to identify the sequence of
events the licensee also reviewed procedural adequacy, personnel
training and portal monitor calibration and performance. These
reviews verified tfat training was adequate and portal monitor
performance was as designed. Procedures for control of contam-
inated individuals at the reactor building access did not spec-
ifically require that all articles of clothing require a 100%
frisk prior to this occurrence. Inst>-jctions have been posted
at the reactor building access which now clarify the procedure
to be followed when an individual is found to be contaminated.
The portal monitors in use at Pilgrim do not presently have a
switch at chest level which must be actuated to start the moni-
toring process. Lack of this feature allowed the individual
wearing a contaminated shirt to lean away from the machine suf-
ficiently to clear the monitor without any alarm. The licensee
has determined that the manufacture of the portal monitor now
produces a chest high switch for the installed model and will
install them in the future.
Calculations have been performed by the licensee to determine
the radiation dose received by the individual and the amount of
radioactive material that was released from the site on the con-
taminated shirt. The results of these calculations show that
the individual received a localized radiation dose to the skin
of 260 MRem, which is below the federal limits for skin exposure,
and that the amount of radioactive material on the individuals
clothing was 0.2 microcuries which meets the federal criteria as
an exempt quantity of Co-60. The inspector is satisfied with
the licensee's analysis and corrective actions and has no
further questions.
756
12
Allegation of Improper Disposal of Radioacti vely Contaminaied
Shrubs (RI-87-A-0107)
On August 31 and September 11, 1987, the NRC resident office at
Pilgrim received allegations that radicacti vely contaminated
shrubs had been removed from the site and improperly disposed.
Tne alleged improper disposal occurred on July 23, August 26 ana
August 28, 19S7. During this time period the licensee removed a
large number of shrubs from various areas of the site, including
those planted near the old administration building and the
switchyard. The shrubs were removed to facilitate site con-
struction activities and to alleviate certain security concerns.
Upon receipt of the first allegation on August 31, 1987 the NRC
requested that the licensee perform an evaluation and provide
tne results for review. In addition an independent NRC review
was initiated.
Resident and specialist inspectors reviewed the licensee's con-
clusions. The licensee evaluated material release records and
interviewed personnel regarding removal of shrubs during the
week of July 20, 1937. Several trucklcads of shrubs that were
transported offsite during the midnight shift on July 24 were
exarr.ined in Cetail. Because trace amounts of Cobalt-53 had pre-
viously been found in soil onsite, some of the shrubs had the
soil removed from the roots prior to release. Each shrub was
hand surveyed and found to meet established offsite release
criteria. They were transported first to the licensee's shore-
front area and later to a dump site on licensee property. The
1^'censee concluded that the shrubs had been adequately surveyed
and that no radioactive material had been improperly released.
The resident inspectors reviewed the licensee's program for ccn-
fol of release of material fro~ the site. This area was also
evaluated by NRC specialist inspectors during inspection 50-293/
87-19. Both inspections concluded that appropriate surveys and
release limits have been established and implemented. Resicert
and specialist inspectors examined licensee release records for
the dates in question to verify that vehicles leaving the pro-
tected area had been properly surveyed. No discrepancies were
identified. An NRC resident inspector accompanied by a licensee
representative collected four samples of the shrubs which had
been deposited in the dump site discussed above. Each of the
four samples consisted of root, branch and foliage clippings
from a number of different shrubs. The samples were indepen-
dently analyzed by the NRC. Three of the samples incicated no
contamination. One sample indicated only trace levels of Cobalt
-60. Measurements showed that the amount of CO-60 present in
this sample was about Z% of the average radioactivity typically
found in soil due to naturally occurring isotopes.
757
13
The licensee's pro^ran for release of material froT the site
appears aaequate. Appropriate survey techniques and release
limits have been establ i s'^.ed. Review of reco-ds confirmed that
the prccram is being implemented. Sairiples of the shrubs col-
lectec by the N'iC showed le-'c or negligible contamination and
pcse no health and sa'^'ety concern. Based on the above this
allegation is considered closed. KRC Region I staff provided
status briefings concerning this allegation to Senator Kennedy's
staff and to the Massachusetts Department of Public Health.
Allegation of Airborne Radioactivity in the Trash Compaction
Fac-lity (RI-87-A-0120)
Cr Octcbe"" 5, 19S7, the resident c'"^ice received an anonymous
al'egation that personnel working at the sort table in the trash
ccpact'on facility (*Cr) were seirg routinely exposed to air-
borne radioactive contamination. The alleger stated that the
two filter systems designed to treat exnaust air from the sort
tafie prior to discharge into the roor. were not functioning, and
that the filter different'al pressure alarm circuits had been
d 1 sao'ea.
C' Octocer 7 ard 3, 19c7, N'RC specialist inspectors tourea the
TC.^ and examined the design and concition of the equipment. The
sort table is used to separate contar^inated r.aterials for com-
cacf'cn and disposal. Potential'y contaminated air is exhausted
from the table, passed tnrcugh two filters operating in parallel,
and released into the room. Airborne radiation levels in the
roz~ are aieasured by "eans c; a separate ai'^ r;:or"tor nhich is
ope'-ated whenever the sorting table is used. The alarm is
typ-'cally set at 3 X 10 -IG (3E-1C) ~icroc-ries per cubic cen-
tireter (cc). In aaditicn the filters are surveyed daily and
cha-ced It contact dose rates es'ceed 2mR per hour. The irspec-
tci also examined the trash compaction unit in the area and
*:-''C trat si~iiar controls nad been applied. Based on the
ab:ve, no imnediate health and safety concerns were indicated.
On January 15, 1988, the resident inspectors toured the TCF,
examined equipment operation and interviewed licensee and con-
tractor personnel involved in ongoing work, activities. A radia-
tion worf, permit specifying protective clothing, health physics
coverage, and use of a continuous air monitor is in place to
octroi work at the sort table. Personnel involved stated that
trash bags were surveyed prior to sorting and rejected if radia-
tion levels exceedec 5mr/hr, if they contained liquid, or i" any
powdery material was present. The health physics technician on
duty stated that filter radiation levels are monito-ed daily.
758
14
Workers and health physics personnel also stated that filter
differential pressure (dp) instruments are monitored to detect
filter plugging, however no one had been clearly assigned this
responsibility and no dp limit was established. The inspector
observed the operation of the table and noted that the "filter
restricted" alarm actuated for one of the two filters. The
alarTi octuatec for the filter displaying the lower di f fe^e-'ti a'
pressure. When questioned workers stated that much of the
monitoring and alarm circuitry for the table was rot functional,
and that the filter alarm was not reliable. The table was
originally part of a larger processing system and much of the
disconnected circuitry was intended to perform functions which
are no longer needed. The inspector verified that current
filter dp reacings are consistent with the manufactures name
plate data.
It appears that the general process applied, including inspec-
tion and survey of trash bags prior to sorting, daily filter
surveys and continuous air monitoring would preclude airborne
radioactivity proolems. Based on the above this allegation is
closed. However, the inspector noted that no work instructions
existed describing the controls applied and equipment monitoring
requirements. Wren discussed with licensee radiation protection
management they promptly committed to review the situation and
issue app'-opriate guidance. This was confirmed during the
inspector's exit interview.
Erosion of Construction Dirt into Wetland
On January 15, 1988, at 5:45 p.m. the licensee made an ENS
notification in accordance with 10 CFR 50.72 (b)(2)(vi) which
requires the licensee to inform the NRC of an event or situation
related to health and safety of public for which a news release
was made or notification of another government agency has been
made. During routine environmental monitoring, the licensee
observed erosion from a pile of construction dirt into an adja-
cent licensee controlled wetland. The Plymouth Conservation
Commission and the Massachusetts Department of Public Health
were notified and the press release was made by the licensee.
Also on January 16, 1988 two representatives from the Plymouth
Conservation Commission toured the area.
In the last several years during onsite excavation for plant
modifications, dirt, asphalt and concrete containing low levels
of contamination were stored in a fenced in storage area outside
the protected area on the licensee's property. The licensee
estimated that the storage area contains 110,000 cubic feet of
material. Before removal from the protected area, samples of
759
15
material were obtained and isotopic analyses was performed by
the licensee. The activity found was reasonably uniform at
levels of 10(lE-6) ard 10(lE-7) microcur-;es of Cobait-60 and
Cesiuni-137 per graii. Sampling and storage cf tnis material was
previously reviewed during inspection 50-293/87-18. On
January 21, 1983 the inspector toured the area, accompanied by
a licensee health physics technician, and performed a survey of
the storage area and found no detectable radiation above back-
ground levels. During the tour the inspector noted tnat bales
of hay had been put around the perimeter of the fence which
borders wetlands area to prevent further erosion of material.
The fenced in storage area was secured with a locked gate. The
inspector's survey of the area and review of licensee's analyses
inaicate that the level of activity does not represent a health
or safety concern. However, the inspector raised a concern to
the licensee managerrent tnat the material should net be allowed
to erode. The inspectors will continue to monitor the licensee
actions in formulating long term solution to properly dispose of
the material .
' re tec ti on
Cr January 17, 193S. at 4:55 a.m. the control room received a report
from a security guard of smoke coming from a contractor lavatory
trailer, which is located adjacent to the Bechtel warehouse inside
tn? protected area fence. The onshift fire brigade chief was dis-
patched to the scene and confirmed smoke and smoldering in the area.
The fire brigade was immediately dispatched and fire was extinguished
using a portable dry cneT.ical extinguisher and a hose from a nea-by
hydrant house. Electrical maintenance was called to shut off the
power to the trailer. By 5:30 a.m., the fire brigade members had
cleared the scene and a continuous fire watch was posted in tne area.
The cause of the fire was believed to be overheating of an overhead
heating unit for the trailer. No personnel injury occurred. The
insoector toured the scene with a licensee fire protection engineer
on January IS, 1988. Minor damage to a small area of the ceiling in
the trailer was observed. The Plymouth Fire Department was notified
by the licensee in the morning of January 18, 1988.
4.0 Review of Plant Events
The inspectors followed up on events occurring during the period to deter-
mine if licensee response was thorough and effective. Independent reviews
of the events were conducted to verify the accuracy and completeness of
licensee information.
760
ic
spurious Isolations of RHR Shutdown Cooling System
Or DeceT.ber 7, 195^, at Z:2S p.m., an inadvertent isolation of both
inboai'd and outboai^d containment isolation valves on the RHR shutdown
cooling suction line occurred. Preoaration ^or the reactor vessel
hydrostatic test was in progress. As part of the hydrostatic test
procedure, a tecnnician was installing an electrical jumper in the
primary containment isolation system logic panel C-9'll to bypass the
reactor coolant system (RCS) high pressure interlock on the inboard
isolation valve. When the termination screws were loosened to in-
stall the jumper, the leads lost contact and caused a false high
pressure isolation signal. RHR was in its shutdown cooling mode when
the isolation signal was generated, and the shutdown cooling suction
valves (VOV lCC"i-47, 1000-50) automatically closed as designed.
Coincident with the closure of the valves, the "A" and "C" RHR pumps
trippea automatically to protect the pumps from loss of acecuate
suction. The licensee determined the actuation was due to a oerson-
nel error. The licensee revised Procedure 2.1.8.1, Class I System
Hydrostatic Test, to caution the I&C technician of potential isola-
tion of RHR shutdown cooling system while installing the jumper.
On December 3, 1987, at 9:45 p.m., the inboard isolation valve (MOV
1001-50) on the RHR shutdown cooling suction line automatically
closed. The automatic isolation occurred when the plant reached
100 psig during pressurization for performance of the class I hydro-
static test. The outboard isolation valve (MOV 1001-47) was already
closed to form a pressure boundary for the test. The licensee's
investigation determined that the cause of the isolation was that
Procedure 2.1.8.1 did not identify all the jumpers necessary to
bypass the RCS high pressure interlock on the inboard isolation
valve.
As immediate corrective action, the licensee halted the pressuriza-
tion of RCS and reviewed the logic prints. The licensee revised
Procedure 2.1.8.1 to reflect the need to install an additional jumper
in panel C-942. In reviewing this event along with other similar
events documented in previous inspection reports, the inspector noted
that inadequate planning and inadequate procedures appear to be a
common root cause for several ESF actuations which occurred on
September 17, September 22, October 15 and October 24, 1987. The
inspector expressed this concern at the exit meeting with licensee
management. The licensee informed the inspector that the Technical
Group is in the process of developing generic guidance for isolating
or jumpering an electrical component which may cause inadvertent
safety system actuations. The inspector will continue to monitor the
effectiveness of licensee's corrective action to prevent further ESF
actuations due to inadequate planning and inadequate procedures.
761
17
b. Reactor Water Cleanup System Spurious Isolation
On December 17, 1987, at 11:05 a.m., the inboard primary containment
isolation valve on the reactor water cleanup (RWCU) system suction
line automatically isolated. I&C technicians conducting a routine
surveillance of the RWCU high area temperature isolation logic inad-
vertently grounded a lead which had been lifted during the test.
Grounding the lead resulted in a blown logic power fuse and isolation
of the valve (MOV 1201-2). Following investigation by the control
room supervisor, the fuse was replaced and the isolation was reset.
The licensee's investigation concluded that the root cause is a per-
sonnel error. The licensee informed the inspector that the proced-
ure, 8. M. 2-1. 2. 2, Reactor Water Cleanup Area High Temperature, will
be revised to provide cautions to che control room operators and the
I&C technicians. Also, an effort is ongoing to review recent ESF
actuations caused by personnel error to formulate appropriate
corrective actions.
c. Engineered Safety Feature Actuations Due to a Failed Logic Relay
On January 6, 1988, at 2:50 p.m., the coil of primary containment
isolation system (PCIS) electrical relay 15A-K57 failed, creating a
fault and resulting in blown logic power fuses. The deenergi zation
of this portion of the PCIS logic caused a partial primary contain-
ment isolation along with a reactor building isolation and start of
the "6" Standby Gas Treatment system (SBGT). The licensee notifiea
the NRC at 5:12 p.m. via ENS. The failed relay was a GE type CR120A
relay. The licensee has experienced several failures of this type of
relay in the last few years. The licensee's evaluation of this high
failure rate and corrective actions to address it are described in
the inspection report 50-293/87-50.
On January 7, 1983, the inspector reviewed maintenance request (MR)
88-9 which had been initiated to investigate the cause of the above
mentioned ESF actuations and to replace the blown fuse and the faulty
relay. The inspector noted that the relay replacement was performed
using only procedure 3. M. 1-11, Routine Maintenance. This procedure
contains general guidance and its stated use is for performing main-
tenance activities which are not complicated or critical enough to
require detailed written procedures. In this case, no step-by-step
instruction was initiated to control the sequence of work, to control
and tag lifted leads and jumpers, and to ensure verification and
independent verification of system restoration. A similar problem
involving lack of a sufficiently detailed controlling procedure and
the appropriate reviews during an electric relay replacement on
November 24, 1987 was the subject of a violation as documented in the
inspection report 50-293/87-50. The licensee informed the inspector
that the corrective actions to address the violation are being
formulated and will be submitted to the NRC.
762
18
Spurious Reactor Protection Systerr Actjation
On January 17, 1988, at 1:13 a.m., a spurious reactor scram signal
was generated during the performance of a reactor level instrument
calioration. The full scram signal on low water level was received
due to a disturbance in the reactor water instrument line when an I&C
technician was valving a level instrument (LI-253-59A) back in ser-
vice. The Rosenount level transmitters (LT-263-57 A&B) which initi-
ated the scram signal are on the same instrument rack. The licen-
see's preliminary investigation indicated that the root cause of the
event is attributed to a combination of personnel error and inade-
quate procedure. The investigation also identified that the level
instruments (Ll-253-59 A&B) were incorrectly installed in that the
sensing lines were reversed. The new Barton level instruments
(LI-263-59 A&3) were recently installed during this outage and would
on'y oe usea for local indication during a shutdown from outsiae the
control room. The licensee is currently reviewing the plant design
change (^DC £5-07) records and post-installation test data to deter-
mine the cause. Surveillance test records are also being reviewed
by the licensee. This item is unresolved pending the completion of
tr.T "icersee i rvest igation (87-57-02).
Uoon receiving tne spurious scram the control room staff noted that
scram discharge instrument volume (SDIV) vent valve CV302-23B primary
containment vent and purge valves A05044B and A05035B and one of two
redundant secondary containment isolation dampers in each line did
not close. In addition the "B" standby gas treatment system (SGTS)
did not sta'^t. Based on the initiating event, these components
sh:-ulc have actuated. The licensee notified the NRC of the failures
via ENS at 5:0C a.m. on January 17, 19SS.
The control room staff conducted an immediate critique with available
ILZ personnel, and documented observations for management followup.
Later on January 17, the licensee inspected the physical condition
of the SDIV vent and drain valves and noted paint on the stem of
CV302-23B. The paint was removed and the valve successfully stroke
timed. The licensee held a second critique with management repre-
sentatives on the morning of January 18, 1988 to assess the situa-
tion. Subsequently, a walkdown of involved isolation logic components
was performed to verify relay contact configuration and to identify
any jumpers or lifted leads. This walkdown was performed to the
extent possible without disturbing components. No discrepancies were
noted. Early on January 19, the licensee performed a test in which a
reactor scram was intentionally initiated. The same equipment failed
to actuate as during the January 17 scram. Based on this licensee
management stopped all work on the affected components. A task force
composed of members from the technical staff, systems group, I&C and
operations was designated to investigate the incident. This team
reviewed available information and developed an action plan.
763
19
Walkdowns of the air system piping and components supplying motive
air to SDIV vent valve CV302-23B were performed to verify that the
as built configuration is in accordance with design documents and
that components are in good physical condition. No discrepancies
were identified. Valves CV302-23B and CV302-22B are supplied air by
the same so'.enoid operated valves. The licensee deenergized these
solenoid valves and observed that CV302-22B closed while CV302-23B
did not. This indicates a mechanical problem with the valve or
operator. The licensee was identifying replacement parts and pre-
paring to disassemble the valve by the close of the inspection
period. The inspectors will continue to monitor licensee followup
to this failure.
Licensee review of logic drawings confirmed that the remaining equip-
ment which had not properly actuated shared common isolation 'ogic
components. A series of surveillance tests was performed to . low
monitoring of key relay actuations. A single contact on a General
Electric (GE) HFA relay was determined to be mi sfunctioning . The
contact is required to close when an isolation signal is received,
actuating the affected equipment. However, contact resistance
remained high with the contact closed. The relay was replaced and
the system successfully tested. The licensee contacted GE to coor-
dirate disassembly and inspection of the relay. Dissassembly had not
begun by the close of the inspection period. The inspector will
continue to monitor licensee investigation of this failure.
The inspector expressed concern that three separate equipment mal-
functions had occurred during the inadvertent actuation. This may
reflect weakness in the surveillance and post-work test program.
However, the licensee's response to the actuation and subsequent
malfunctions was prompt, thorough and effective. Control room oper-
ators quickly recognized each of the failures. They held a critique
on the same shift with involved personnel. Critique observations
were clearly documented and provided to management. An additional
critique with management present established priorities. Action was
taken to freeze equipment uniil an investigation plan could be
developed and implemented. Followup was well coordinated and in-
volved representatives of several portions of the organization. In
this case licensee commitment to determining and correcting the
problem root cause was evident.
5. 0 Review of Reactor Vessel Hydrostatic Test Procedure and Test Results
During the inspection period the licensee completed the reactor vessel
hydrostatic test. Several reactor vessel instrument nozzles were repaired
during this outage, prompting performance of a hydrostatic test rather
than a system leakage test. The reactor vessel reached minimum test
pressure and all inspections were completed on December 9, 1987. Only
minor leakage associated with mechanical connections, such as flanges and
valve packing was identified. The reactor vessel was depressurized on
December 12, 1987 after completion of excess flow check valve testing.
764
20
The inspector reviewed the licensee's hydrostatic test procecure to verify
that appropriate prerequisites, precautions and instrjctions had been
included. A sample of valve lineups was reviewed to determine the ade-
quacy of established test boundaries. Completed valve lineups were also
examined. Control of temporary electrical and mechanical jumpers was
evaluated to ensure proper documentation and restoration. The inspector
observed installed pressure instrumentation and verified appropriate range
and calibration status. The adequacy of staffing to support test per-
formance was periodically verified. The inspector reviewed test results
and discussed them with engineering, operations, and quality control
personnel to ensure that test changes were properly processed, adequate
inspections were conducted, and that inspection results were promptly
disposi tioned.
The licensee's preparation for and execution of the test was generally
well organized and controlled. Procedures for test performance and con-
duct of visual inspections were clear and comprehensive. A detailed
Quality Control (QC) work instruction was developed specifying components
and piping requiring inspection. Inspection assignments were broken down
by location, elevation and component. This QC instruction also included
a series of piping diagrams depicting the test boundaries which were
utilized to assist in inspection performance and documentation. The
licensee's Technical Engineering Section, Quality Control staff and
Nuclear Engineering Department each reviewed test boundary adeauacy. In-
spection results were well documented, and maintenance requests were
promptly initiated to cor-ect identified leakage.
The licensee experienced two shutdown cooling isolations during implemen-
tation of tPe test procedure. These isolations are discussed in detail in
section 4. a of this report. During the test tne licensee identified leak-
age past the seal ring at the stuffing box to pump casing joint on both
recirculation pumps. Leakage flow was estimated to be one to two gallons
per minute for each pump. The leakage wet the punp casings and portions
of the suction piping, and acceptable inspections could not be completed
in these areas. The licensee stated that similar leakage on at least one
of the pumps was noted during the last outage. That leak sealed as system
temperature increased during startup. The licensee believes that the
leakage observed during the recent test will also stop as temperature is
increased, and no pump repairs are planned. The licensee stated at the
inspector's exit interview that the pump casings and suction piping will
be reinspected during startup.
The inspector noted that the test procedure did not contain valve lineups
for manual instrument isolation valves within the test boundary. Many
instruments and a significant portion of instrument piping has been
replaced this outage. Visual inspections were performed of class I piping
downstream of these valves. The inspector questioned the basis for licen-
see confidence in instrument line isolation valve positions during the
test. The licensee pointed out that hydrostatic testing of these lines
was not required during this outage. In addition excess flow check valve
765
21
testing was conducted impeciateiy after ccT.pietion of the hycrostatic test
with the system still pressurized. Successful completion of the check
lignment of tne ranual isolation valves,
es assu'-ance that the piping was pressurized during the visual
1 psoect" 3r 5 . "he licensee however, ag'^eed that the intent of the test had
been tc pressurize and -inspect this piping and that the current procedure
c:r; not ac;:-itelv assume f'i ccrect valve alignment. Licensee manage-
ment statea that tne procedure would be revised to address this weakness.
vaive testi"g requires proper a
and prc>'-'^2 =
6.0
Leak
C'l December 2i
■ - ' T^, — '■
1 I
19S7, the licensee began performance of the primary con-
■ted leak rate test (lLf(T). The containment was pressur-
■s: t'
Dse"'
-d^c.
se
wn
i r
W"
've
ich
soe
•'t- a'r to the full test p^ess-re of ^5 pounds per square inch and
.■nee at tnis oressure for 24 hou^s. The 24 hour test period started
:".5 z.~. on leceioer 21, 13£7. A regional special'st inspector was
: c:,.'-ing tre ILRT to review the adequacy of the test procedure and to
'3 t^e concuct cf the test. The preliminary licensee test results
itec a successful test, with measured leakage slightly greater than
-cent of the allowable leakage. A primary contributor to the ob-
; 'ear age v.as identified as a drywell pressure transmitter piping cap
had rot been fully tightened. Lpcn completion of the specialist
itc-'s review of the ILRT results, inspection report 50-293/87-58
;e issued cocumenting the inspectors findings.
While o-'eo5'"inc fo" the orimary containment integrated leak rate test
(ILRT) f^e "ice"see observed that several torus temperature and moisture
elements were not functioning properly. Troubleshooting identified cir-
c-"'t -a-'ts at 5 tcus electrical penetration assembly. The licensee
remove; t^e oenetration assemoly protective cover inside the torus and
found t^at it was filled with water. The penetration is installed ver-
tically through tne top of the torus. On both the inboard and outboard
s'des G* the penetration a metal frame is attached on which 28 terminal
boa-ds are mounted. Cables passing through the penetration, and supplying
insfu-e-tation in the torus also landed on these terminal boards. A
P'-otective cz</er is bolted over the frame and terminal boards on both
sides of the penetration. Design drawings specify that cover joints are
to be sealed with silicone tape. The licensee stated that the protective
cover had not been properly sealed, allowing water intrusion and buildup.
The water caused significant corrosion of the cable connectors, terminal
boards and metal framework. This corrosion and water buildup resulted in
the observed electrical circuit faults. Licensee inspection of the other
torus electrical penetration identified similar conditions. Tempora'-y
repairs cf the temperature and moisture elements were made to allow ILRT
performance. Cables for communications, lighting, and torus to drywell
vacuum breaker indication also run through the penetration. The penetra-
tion is not considered by the licensee to require environmental qualifica-
tion b-t is designated as a "Q" component. The licensee is evaluating the
root cause cf the water intrusion and is developing a temporary procedure
to conf'ol repair and testing of the penetration. The inspectors will
continue to monitor licensee followup and corrective actions.
766
22
The licensee informed the inspector that penetration repairs wojld not De
completed until after ILRT performance. The inspector questioned the
effect of the planned repairs on the penetration leak tightness, and the
ability to perform adequate leakage test after the planned rework. The
licensee stated that the work would not affect penetration leakage but
that adequate testing could be performed after work completion. Eased on
available drawings however, the licensee could not demonstrate adequate
testability. In response to NRC concern the licensee obtained the needed
drawings from the vendor and verified that the penetration was completely
testable. The inspector had no further questions.
During the ILRT, the licensee identified a water leak in the high pressure
coolant injection (HPCI) turbine room. It was determined that the in-
creasing pressure in the torus air space caused the suppression pool water
to back up through the HPCI turbine exhaust line and through the drain
piping, overflowing tne HPCI glanc seal condenser onto the HPCI room
floor. The turbine exhaust line discharges to the torus through a check
valve and a locked open stop-check valve. To prevent any condensation
from collecting in the turbine exhaust line downstream of the check valve,
a drain piping drains any condensation to the HPCI gland seal condenser
through a drain pot. Two solenoid operated dra^n valves on the drain pot
close automatically on a HPCI (Group IV) isolation signal. This is to
provide the isolation from the torus to the gland seal condenser. The
licensee's investigation determined that leads had been lifted in the HPCI
isolation interlock logic circuit since October 30, 1987 in support of the
HPCI steam testing utilizing temporary oil-fired auxiliary boilers. With
the HPCI isolation signal bypassed, the drain valves remained open as the
drain pot was filled with the suppression pool water. The licensee sub-
sequently relanded tne leads in the HPCI isolation interlock logic circuit
and the drain valves closed.
After reviewing the ILRT procedure, HPCI test procedure and interviewing
licensee personnel, the inspector concluded that licensee review of the
active maintenance requests prior to the ILRT was not thorough in that the
lifted leads controlled by the MR 87-663 were not identified. The MR tags
were attached on the HPCI isolation logic circuit inside a logic panel and
thus the tags were not identified during a system walkdown prior to the
ILRT. The drain valve positions were verified by the light indications on
the control room panel 903 as prescribed in the ILRT procedure.
The inspector also determined that the maintenance request above may not
be an adequate method of identifying and tracking jumpers and lifted
leads, especially for a long term application and for components which
could affect other ongoing maintenance or surveillance. Station proce-
dures do not require temporary modification controls for jumpers and
lifted leads which are controlled by active maintenance requests. The
inspector discussed these findings at the exit interview with licensee
management. The licensee informed the inspector that a lifted leads and
jumper log will be kept in the control room to aid the operators in con-
trolling lifted leads and jumpers.
767
23
7.0 L-'censee Nuclear Organization Management Realignment
On December 14, and on December 31, 19S7, the Boston Edison Co. announced,
as part of a planned realignment occurring over the next several weeks,
the appointment of the following managers to key management positions in
the licensee nuclear organization at Pilgrim Station.
Mr. Kenneth L. Highfill was named to assume the new position of
Station Director. In this capacity, Mr. Highfill will oversee day
to day operation of the Pilgrim Station including plant operations,
planning and outage, nuclear training, plant support functions, and
administrative services. Mr. Highfill will report directly to Mr.
Ralph G. Bird, Senior Vice President-Nuclear.
Mr. Robert J. Barrett was named the new Plant Manager. Mr. Barrett
w'li report to Mr. Highfill, the Station Director.
Mr. Roy Anderson, currently Deputy Outage Manager, was na.-ed to
assume the new position of Planning and Outage Manager. Mr. Anderson
will report to Mr. Highfill. the Station Director.
Mr. Ed Kraft was named to assume the new position of Plant Support
Manager. In this capacity, Mr. Kraft will oversee radiological,
security, industrial safety and fire protection, and other station
support functions. Mr. Kraft will report to Mr. Highfill, the
Station Director.
Mr. Donald Gillespie, currently Director of Planning and Restart, was
appointed to the position of Quality Assurance Department Manager.
Mr. Gillespie will assume the position after completing his Senior
Reactor Operator training. The Quality Assurance Department Manager
reports to Mr. J. E. Howard, Vice President-Engineering.
Mr. Frank Famulari, currently Operations Quality Control Group
Leader, was named to assume the newly created position of Deputy
Quality Assurance Department Manager. Mr. Famulari will report to
Mr. Gillespie, and be acting Department Manager until Mr. Gillespie
assumes the position after completing the Senior Reactor Operator
training .
Mr. Jonn F. Alexander was named to assume the position of Operations
Section Manager. Mr. Alexander will report to Mr. Barrett, the Plant
Manager.
Mr. Donald J. Long was named Security Section Manager. Mr. Long will
report to Mr. Kraft, the Plant Support Manager.
»
I
2 . C Maragenert Nleetircs
768
24
At periodic intervals during the course of the inspecfior oericd re^t-qs
were held with senior facility management to discuss the
and p'elirT^inary '^incings of the resident inspectors" Or
the inspectors conducted a final inspection exit interview to formally
present inspection findings.
insoecticn scope
Jar-L^ary 25.
769
Attachment I to Inspection Report 50-293/87-57
Persons Contacted
R.
K.
K.
R.
R.
E.
F.
D.
J.
N.
J.
J.
R.
P.
R.
N.
D.
F.
Bird, S
Highfil
Roberts
Barrett
Anderso
Kraft,
Famular
Swanson
Alexand
Erosee
Jens, R
Seery ,
Gra:io,
Mastran
Sherry,
Gannon ,
Long, S
Wozniak
enior Vice President - Hue
1 , Station Di rector
, Plant Manager
., Deputy Plant Manager
)n. Planning and Outage Manag
Plant Support Manager
ear
Plant Support Manager
-i , Deputy Quality Assurance Manager
1, Nuclear Engineering Department Manager
jer. Operations Manager
, Maintenance Manager
Maintenance Manager
tacio logica I Protection Manager
Technical Manager
Field Engii '"" M-,r.,,«,.
gel
ct-
Cnie: Radiological Engineer
lecurity Manager
Fire Protection Manager
echnical Manager
Field Engineering Manager
elo. Chief Operating Engineer
Chief Maintenance Engineer
Cnie: Radiological Engineer
'Senior licensee representatives present at the exit meeting.
770
ATTACHMENT II
January 5, 1938
MEMORANDUM FOR: Ken Roberts
Plant Manager
FROM: Clay Warren
Senior Resident Inspector - Pilgrim
SUBJECT: FACILITY TOUR FINDINGS, DECEMBER 8, 1987
The items on tne attacnment were noted during the facility tour on
December 8, 19S7. Please contact the Resident Inspector Office when your staff
is ready to discuss the evaluation of the items and the status of any actions
taken. Please note the items and the facility response will be addressed in a
routine inspection report.
Thank you for your time and attention to these matters.
Sincerely,
Clay C. Warren
Senior Resident Inspector J
Attachment:
As stated
cc w/attachment:
R. Blough
W. Kane
W^ Russell I
J . Wiggins ^
1
771
ATTACHMENT
Njmerous motors appear to have failed grease seals caused by overgreasing
without first removing grease drains. This condition causes a buildup of
grease and d'rt in the cooling airflow path and in extreme cases grease
in the motor windings. (SBGT fans and SLC pumps)
Nuts and bolts were noted laying Inside an electrical cabinet in the RCIC
room.
Multiple cases of open junction boxes, terminal boxes and conduit pulled
away from terminal boxes were noted.
Motor heaters for the "B" RKR pump appear to have overheated causing the
insulation on the heaters to melt.
HPCI room cooler drip pan is full of paint scrappings which could lead to
drain clogging.
Standby Liquid Control system relief valves have boric acid crystal
buildup which could alter setpoints.
Painting effort should be more closely controlled to prevent painting
inap::rcpriate surfaces, i.e., linkages, valve packing glands, trip
throttle valves, limit switches, etc.
Numerous instances of scaffolding materials, i.e., nails and wood chips,
laying on floors. This material could migrate to drain systems and cause
pump or valve damage. Scaffolding was also noted attached to permanent
equipment such as piping and conduit.
Valve 10Ci-36A motor operator conduit had melted plastic cover.
772
QUESTION 13. Has Pilgrim ever violated established radiation emission
levels; i.e., have there been any releases from the plant which
exceeded standards set by the NRC?
ANSWER.
The permissible levels of radiation in unrestricted areas and of radioactivity
in effluents to unrestricted areas are established in NRC regulations embodied
in 10 CFR Part 20, Standards for Protection Against Radiation. These regulations
specify limits on levels of radiation and limits on concentrations of radio-
nuclides in the facility's effluent releases to the air and water (above natural
background) under which the reactor must operate. Further, the regulations require
that there be no unmonitored release paths from the plant. The regulations
are structured to provide reasonable assurance that no member o''^ the general
public in unrestricted areas will receive a radiation dose, as a result of
facility operation, of more than 0.5 rem in 1 calendar year. These radiation-dose
limits are established to protect the health and safety of the public.
In addition to the Radiation Protection Standards of 10 CFR 20, 10 CFR 50.36a
establishes license requirements in the form of license Technical Specifica-
tions on effluents from nuclear power reactors. The purpose of the Technical
Specifications on effluents is to keep releases of radioactive materials to
unrestricted areas during normal operations, including expected operational
773
QUESTION 13. (Continued) 2
occurrences, as low as is reasonably achievable (ALARA). Appendix I of
10 CFR Part 50 provides numerical guidance on dose-design objectives for light
water reactors to meet this ALARA requirement. The dose-design objectives are
low, about 1% of the Radiation Protection Standards of 10 CFR Part 20. Thus, it
is possible for a licensee to exceed the dose-design objectives, but still be
within the Radiation Protection Standards.
The NRC staff has reviewed the agency records on radioactivity releases ^rom
the Pilgrim nuclear power plant. Although there were situations when the
radioactivity releases exceeded Pilgrim's Technical Specifications, these
releases did not exceed the Radiation Protection Standards of 10 CFR Part 20.
We have also reviewed the agency records on the amounts of radioactivity measured
in the environment around the Pilgrim nuclear power plant. The licensee has
reported elevated levels above normal background of some radionuclides in some
environmental samples over the time period 1978 through 1981. However, it
should be noted that Pilgrim's previous guidelines for reporting elevated levels
of radioactivity in environmental samples were conservative. Under Pilgrim's
current Technical Specifications, many (if not all) of the previously reported
elevated levels would no longer be considered reportable. The previously reported
elevated levels of radioactivity in environmental samples would lead to doses
less than specified in the Radiation Protection Standards and thus would be
below NRC regulatory limits.
774
EDWARD M. KENNEDY
UASSACHUSFTTS
^ntteb Ss>mtsi B>tmtt
WASHINGTON, DC 20510
March 7, 1988
Mr. Richard Krimm
Assistant Associate Director
Office of Natural and Technological
Hazards Program
Federal Emergency Management Agency
500 C Street, S.W.
Room 630
Washington, D.C. 20472
Dear Mr. Krimm:
I would like to take this opportunity to thank you on
behalf of the Senate Labor and Human Resources Committee for
your participation in the hearing concerning the restart of
the Pilgrim nuclear power plant in Plymouth, Massachusetts.
During your testimony, I asked if you would support a
Congressional initiative aimed at providing FEMA with the
authority to shut down or keep closed a nuclear power plant
which did not have in place an approved emergency evacuation
plan. Such authority would effectively change FEMA's role
in emergency preparedness from advisory to regulatory. In
response to my question, you requested additional time to
prepare your answer for the hearing record. I would
appreciate your response so that it may be included in
the hearing record.
I have attached a list of additional Questions which
I would also like you to address for the record.
Again, thank you for your assistance
to your reply.
With best wishes,
I look forward
enclosure
775
FEMA's Self-Initiated Review and Interim Finding for the
Pilgrim Nuclear Power-station identified six areas of
major deficiency in Emergency Preparedness. These areas
were (1) lack of a reception center for people evacuating
to the north; (2) lack of evacuation plans for public and
private schools and daycare centers; (3) lack of identifi-
able shelters for the beach population; (4) inadequate
planning for the evacuation of people with special needs;
(5) inadequate planning for evacuation of the transport
dependent population; and (6) an overall lack of progress
in planning and in emergency preparedness. I would like
to know in detail what progress has been made during the
past six months to address these six areas of deficiency.
What projections can FEMA make relative to the length of
time it may require to remedy existing deficiencies in
Emergency Preparedness? In your answer, please respond
to the following:
(a) What new measures have been undertaken to ensure
that the handicapped population has been identified,
is adequately informed of what actions to take in
an emergency, and is provided with transportation to
leave the area, if necessary? Please include in your
answer the specific procedures which will be followed
for persons who are Isedridden or in nursing homes
and hospitals.
(b) Does FEMA believe that a third evacuation reception
center is needed for people evacuating to the north?
If so, has a center been selected or proposed?
(c) It is my understanding that bus transportation will
be provided to evacuate public and private school
children. I would be interested to learn what firms
and/or school districts will be supplying the buses.
Have written contracts been made with the bus companies
to ensure their commitment? How many buses have been
contracted? How many children attend public and
private schools within a 10-mile radius of the plant?
(d) In relation to the beach population, it is my under-
standing that in the summer months, there are frequently
hundreds, and sometimes thousands, of bathers at
Duxbury Beach. The beach is 4i miles long, it has
only two small dwellings and a congested unpaved access
road. I would like to learn what provisions are in
place to ensure that the beachgoing population is
protected by shelter in the case of a radiological
emergency. I would like you to address the same
question concerning the Plymouth town beach.
(e) What measures are proposed for dealing with the prison
population at the Plymouth County House of Correction
if events at Pilgrim warrant an evacuation?
776
QUESTIONS - page two
f
II. In the case of the Chernobyl accident, an area significantly
greater than ten miles was evacuated. Would FEMA support
an increase in the Emergency Planning Zone around the
Pilgrim plant which would encompass Cape Cod?
III. During adverse weather conditions, such as in the case of
a severe snowstorm or during traffic tie-ups which occur
during summer weekends, a great deal of additional time
would be required for evacuation of the area. What
assumptions does FEMA make concerning the affect of
traffic and wq^ther on an orderly and safe evacuation?
Specifically, does FEMA base its Emergency Preparedness
assessments on worst-case scenarios?
IV. You mentioned in your testimony that the FEMA Regional
Office in Boston can expect to see a staff increase.
When will this occur? How many people will be assigned
to the Boston Regional Office in addition to the current
staff (which you said numbered six people)? What are
the specific duties of each one of the Regional Office's
present emergency preparedness staff? What will be the
duties of the new staff?
777
I Federal Emergency Management Agency
Washington, D.C. 20472
The Honorable Edward M. Kennedy
United States Senate
Washington, D.C. 20510
Dear Senator Kennedy:
This is in response to your letter of March 7, 1988, to Mr. Richard W. Krimm,
Assistant Associate Director, Federal Emergency Management Agency (FEMA), in
which you reiterated a question you had posed to him during the Senate Labor
and Human Resources Committee hearings on the restart of the Pilgrim Nuclear
Power Plant. Your letter also raised several additional questions concerning
off site planning at Pilgrim and related matters.
At the hearing you asked Mr. Krimm if he would support a Congressional initia-
tive aimed at providing FEMA with separate regulatory authority to shut down or
keep closed a nuclear power plant which did not have in place an approved emer-
gency evacuation plan. The response to this question, which has already been
provided for insertion into the hearing record, follows:
° On the whole the Nuclear Regulatory Commission (NRC) has used and reflected
FEMA's offsite findings and determinations in all of its licensing decisions.
This would indicate that the present arrangements are satisfactory;
° A change could bifurcate the current integrated licensing process resulting
in two separate licensing processes, both onsite and offsite;
° It is estimated that FEMA would require an additional staff of 50 to 75 FTE
and an increased annual budget of $ 7 to $ 8 million dollars. The additional
resources would be required for judicial reviews, hearings, public meetings,
and administrative requirements associated with regulatory activity.
In the enclosure to your letter you raised four additional questions concerning
the status of offsite planning at Pilgrim, the size of the Pilgrim emergency
planning zone (EPZ), evacuation assumptions, and FEMA Region I staffing. Your
first question is related to FEMA's Self-Initiated Review and Interim Finding
for the Pilgrim Nuclear Power Station and the progress the Commonwealth of
Massachusetts has made in correcting the deficiencies identified by FEMA. The
Massachusetts Civil Defense Agency (MCDA) submitted portions of draft plans for
four local communities (Plymouth, Carver, Kingston, and Taunton) in February 1988
in an attempt to begin addressing the issues raised in the FEMA Self-Initiated
Review and Interim Finding. An informal technical review by FEMA of the four
draft plans was returned to MCDA on March 30, 1988. In addition, draft plans
for two local communities (Duxbury and Bridgewater) were received on March 30,
1988, and are currently undergoing technical review in Region I. We have re-
quested that our Region I Office provide more specific details on the planning
progress that has been made by the Commonwealth of Massachusetts so that we can
completely respond to the questions you raised. We will provide this additional
information to you in early May.
778
-2-
In response to your second question, F.PZ's around nuclear power plants are not
being expanded as a result of the Chernobyl accident. This subject has been
reviewed in NUREG-1251, "Implications of the Accident at Chernobyl for Safety
Regulation of Commercial Nuclear Power Plants in the United States." I have
enclosed a copy of this report for your infonnation. Based on this report the
UKC does not consider that a change to the existing size of the plume exposure
pathway EPZ is necessary.
In response to your third question, FEMA has not established detailed require-
ments or specific assumptions regarding the effects of traffic and weather that
must be considered in developing evacuation time estimates. Every site plan is
required to have time estimates developed for the evacuation of the plume exposure
pathway EPZ. Guidelines for evacuation time studies are provided in Appendix 4
of 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." At a minimum, a time estimate is recommended for "good" weather
conditions and "adverse" weather conditions. It is important to emphasize that
there are no minimum dose savings required by the NRC and therefore, no minimum
evacuation time estimates can be established. However, the estimates provide
information and decision points for responsible decisionmakers in adopting and
approving plans for dealing with radiological emergencies. Knowledge of the
amount of time required to evacuate a certain segment of the population enables
the decisionmaker to choose the protective action recommendation likely to achieve
the greatest dose savings for the public. Specifically, FEMA does not base its
emergency preparedness assessments on worst-case scenarios, but includes consider-
ation of such contingencies among the possible range of occurrences.
In response to your fourth question, our full-time FEllA Regional Office staff in
Boston will be increased to the allocated total of eight full-time staff. Cur-
rently there are four full-time staff members on board. The FEHA Office of Per-
sonnel is in the process of recruiting four additional full-time staff. I have
requested our Region I Office to provide the specific duties being performed by
existing staff and those duties proposed for the four new staff members and will
provide this to you as soon as it is received.
If we can be of any further assistance, please have a member of your staff
contact the FEMA Office of Congressional Relations at 645-4500.
:erson
Associate Oi rector
State and Local Programs
and Support
(Editor's Note: Due to printinp; limitations, and in the interest
of economy, the copy of NirREG-1251 referred to above was retained
in the files of the committee. )
779
BOSTON EDISON
Executive Offices
800 Boylston Street
Boston, Massachusetts 02 199
Ralph G. Bird
Senior Vice President - Nuclear
January 21, 1988
The Honorable Edward M. Kennedy, Chairman
Senate Committee on Labor & Human Resources
Senate Dirksen Office Building
Washington, D. C. 20510-6300
Re: Pilgrim Nuclear Power Station
Dnar Senator Kennedy:
This letter and its attachments are intended to provide
nciditional information to the Senate Committee on Labor & Human
RpKOurces and to clarify the record of the testimony presented at
its hearing held on January 7, 1988, concerning the Pilgrim Nuclear
Power Station.
Boston Edison Company appreciates the opportunity to provide
this statement for the record.
Bird
Attachment
780
Boston Edison Company's Statement for the Record
of the
Senate Committee on LzJsor & Human Resources Hearing
Held on
January 7, 1988
Boston Edison Company is filing this statement to provide
additional information to the Senate Committee on Labor & Human
Resources and to clarify portions of the record of testimony
presented at the January 7,. 1988 hearing.
Boston Edison's first priority is the health and safety of
the public and its employees. Boston Edison is committed to
providing necessary sources of power for the citizens of
Massachusetts at a reasonable cost. The restart and operation of
the Pilgrim Nuclear Power Station is an important element in
Boston Edison's ability to supply safe, reliable and sufficient
power.
Boston Edison will not restart the Pilgrim Station until its
management and Board of Directors are satisfied that the outstand-
ing issues have been addressed and the plant and its personnel
are ready to support safe and reliable operation. Stephen Sweeney,
Chairman of the Board and Chief Executive Officer, and Ralph
Bird, Senior Vice President-Nuclear, have repeatedly stated this
policy.
Several specific issues were raised during the hearing that
require correction or clarification. These include the possible
health effects in communities near Pilgrim Station, elevated off-
site dosimeter readings, loss of off-site power to Pilgrim on
November 12, 1987, stoppage of construction work on November 9,
781
2
1987, Off-site Emergency Planning for Pilgrim Station, and plans
for eventual decommissioning of the plant.
Boston Edison strongly endorses Senator Kennedy's request
that the National Institute of Health conduct a study of possible
health effects in communities around nuclear power plants through-
out the United States. Boston Edison has supported, and is cur-
rently supporting, localized studies which have been undertaken
by the Commonwealth of Massachusetts.
In the interest of expediting a more complete understanding
of leukemia incidence rates in five towns north of Pilgrim Station,
Boston Edison commissioned Epidemiology Resources Incorporated
(ERI) to review the report published by the Massachusetts
Department of Public Health on March 16, 1987. The ERI analysis
explains some of the difficulties in interpreting data from a
study of small groups of people exposed to low doses of ionizing
radiation. A copy of the results of this review is attached to
this statement (Attachment A) .
The term "downwind" was used to describe the location of the
communities which were the subject of the Massachusetts studies
(Transcript p. 43). However, the distribution of wind direction
observations at the Pilgrim meteorological towers does not indicate
that any direction is predominantly and consistently "downwind".
However, the most commonly observed wind directions are generally
out to sea, not toward the local communities.
782
3
The theory that the Seabreeze effect is responsible for
redirecting and concentrating airborne pollutants is not well
supported by the available evidence. Investigation of this effect
by knowledgeable meteorologists has determined that seabreezes
rarely contain pollutants in a small radius and most never recircu-
late over the same location. In addition, seabreezes occur only
seasonally and relatively infreguently.
The issue of elevated Thermoluminescent Dosimeter ("TLD")
readings off-site (Transcript pp. 10-14) should be clarified.
Radiation levels as measured by TLDs are measurably elevated at
locations on the Pilgrim Station site during plant operation.
Some individuals have confused on-site and off-site TLD locations
and measurements which has led to allegations of higher radiation
doses to the general public at off-site locations. Historically,
within the standard fluctuation of background levels, there has
been no detectable increase in direct radiation levels at any
location that is normally occupied by members of the general
public beyond the property owned by Boston Edison. The
Massachusetts Department of Public Health has stated similar
conclusions.
Even after the incident in June of 1982 where slightly con-
taminated resin was discovered on the Pilgrim site, a survey done
just outside of the site fence using sensitive laboratory-type
instruments was unable to detect elevated dose rates or evidence
of off-site radioactive contamination. In fact, radiation levels
on-site and within the Exclusion Area are much more strongly
783
4
affected by the Station's power level and direct radiation from
the main turbine than from any release of radioactive material
from the Station. \
Several persons raised the issue of the loss off-site power
on November 12, 1987 (Transcript pp. 25-28). A line-to-line fault
on off-site transmission lines during a severe winter storm re-
sulted in loss of the 345KV line supplying power to Pilgrim
Station. This has been fully investigated by a Nuclear Regulatory
Commission ("NRC") Augmented Inspection Team ("AIT") . The AIT
concluded that "... the operational staff responded well to the
event and adequately coped with the equipment failure and malfunc-
tion." [Docket No. 50-293, Region I Inspection Report No. 50-
293/87-53, December 14, 1987, page 1.] The AIT further found
that reactor safety was never a factor as Pilgrim Station was in
an extended outage and there was very low decay heat. In response
to this incident, Boston Edison has committed to take a number of
actions designed to improve the availability and reliability of
on-site power prior to restart. Boston Edison has committed to
complete the installation of: the new third Diesel Generator
prior to restart; a backup instrument air compressor and additional
instruments to analyze off-normal switchyard operation.
The issue of Boston Edison having ordered construction work
stopped following events on November 9, 1987 was raised (Transcript
p. 34). The specific errors were minor and are not safety or
health concerns. Work was suspended to get prompt answers to
management questions about errors, or possible errors, which had
784
5
occurred. Ralph Bird, Senior Vice President-Nuclear, did not
permit work to proceed until the potential for further errors was
understood and appropriate corrective actions had been initiated.
Information on the specific events, the underlying causes, and
the corrective actions has been provided to officials in the
office of the Commonwealth of Massachusetts Secretary of Public
Safety, as well as to the Nuclear Regulatory Commission.
With respect to the status of Emergency Planning issues, a
topic of discussion throughout the hearing, Boston Edison has
supported with funds, resources and personnel the efforts of the
Commonwealth of Massachusetts and the towns in and around the
Pilgrim Emergency Planning Zone ("EPZ") to revise and enhance
their off -site Emergency Preparedness Program. Substantial pro-
gress has been achieved. This spirit of cooperation has resulted
in such significant achievements as: (1) completion of draft
revisions of the emergency plans for all five towns in the Pilgrim
EPZ, the two reception center communities, and the Massachusetts
Civil Defense Agency Area II; and (2) numerous agreements for
renovation of local emergency operations centers; funding for
full-time Civil Defense staff positions; and provision of training
compensation from Boston Edison. The professional planning staff
provided by Boston Edison is currently assisting the towns in
developing specific implementation procedures and training lesson
plans. The planning efforts underway encompass the actions neces-
sary to assure satisfactory resolution of the concerns raised by
the Federal Emergency Management Agency.
785
6
The record needs to be corrected with respect to one par-
ticular statement regarding the Pilgrim Emergency Planning effort.
In the testimony of Ms. Ann Waitkus-Arnold (hearing transcript
pp. 18- 20), she states that ". . . potassium iodine will be
stockpiled [to provide thyroid protection] for those who will be
left behind . . . " in an evacuation, and that such a policy is
". . .a very inhuman way to treat people, especially elders and
disabled. Those are the only people targeted out for this partic-
ular type of treatment."
To the best of our knowledge, it has never been the intention
of any of the parties involved in the emergency planning process
that KI be administered to elderly or disabled persons in lieu of
evacuation. On the contrary, the draft emergency plans to which
Ms. Waitkus-Arnold referred in her testimony include specific
provisions for the prompt evacuation of nursing home and hospital
residents as well as the remainder of the special needs population.
KI would be administered to elderly or disabled person only in
those exceptional cases where medical authorities determine that,
due to the condition of the particular individual involved, the
evacuation itself could be life-threatening.
Finally, questions were raised about the planning for Pilgrim
Station decommissioning (Transcript pp. 55-56). In fact, Boston
Edison has planned for eventual decommissioning of Pilgrim Station.
A 1985 study done for Boston Edison by Nuclear Energy Services,
Inc. describes three options for the decommissioning of Pilgrim
Station which range in cost from $121,694,000 to $140,175,000.
786
7
Subject to the regulatory approval of the Department of Public
Utilities (DPU) and the Federal Energy Regulatory Commission
(FERC) , the $121,694,000 option has been selected. Currently,
Boston Edison is collecting from its customers about $5 million a
year towards decommissioning which is being placed in a separate
interest-bearing account with a current balance of approximately
$16 million. The cost estimates and amount being collected are
subject to continuing review by the DPU and the FERC.
787
LEUKEMIA INCIDENCE IN COMMUNITIES IN THE VICINITY OF THE
PILGRIM I NUCLEAR POWER GENERATING STATION
September 11, 1987
Submitted to:
Boston Edison Co.
800 Boylston Street
Boston. MA 02199
Prepared by:
Charles Poole
Karen Donelan
Kenneth J. Rothman
Epidemiology Resources Inc.
826 Boylston Street
Chestnut Hill. MA 02167
Telephone: (617) 734-9100
788
XABLS OF CORTERTS
Page
Sianmary 1
I. Introduction A
II. Materials and Methods 5
III. Replication of the MDPH Results 11
IV. Critique of the MDPH Analyses 13
V. Radiation Doses Predicted from Radioepidemiological Tables. 19
VI. Leukemia Rates in Relation to Proximity to Pilgrim I ... 28
VII. References • . 35
789
LIST OF TABLBS AHD FIGDKBS
Page
TABLES
1. Comparison of hDDPH and ERI Calculations of Observed and
Expected Cases of Leukemia in the Five Coastal Towns
Selected by the MDPH. by Sex. 1982-1984 12
2. Observed and Expected Incidence of Acute Lymphocytic
Leukemia Among Residents of the Five Towns Selected by
the MDPH. by Age (0-19) and by Sex. 1982-1984 15
3. Observed and Expected Incidence of All Leukemias Except
Chronic Lymphocytic Leukemia among Residents of the Five
Towns Selected by the MDPH. by Age and Sex. 1982-1984 ... 16
4. Observed and Expected Incidence of Leukemia Among Adult
Residents (Age >_ 20 Years) of the Five Towns Selected by
MDPH. by Leukemia Type and Sex, 1982-1984 17
5. Rate Ratios (RR) Corresponding to Different Exposed
Proportions (Pe) in a Total Population (Exposed and
Unexposed) with an Attributable Proportion (AP~) of 37% . . 26
6. Directly Standardized Incidence Rate Ratios in Zones of
Proximity to Pilgrim I, by Age and Leukemia Type,
1982-1984 31
7. Crude Rate Ratios and Selected SMRs Comparing Zones I
and II with Zone III. by Age and Sex 33
FIGDRES
Twenty- four Towns Identified by the MDPH as Lying
Within 20 Miles of Pilgrim I 6
Towns in Four Zones of Proximity to Pilgrim I 29
790
LEDKEKIA INCIDENC8 IH CCWDIONITIES IN THE VICIHITZ OF THE
PILGKIM I mCLEAR PO0ER GENERATIHG STATION
SDMMART
The Boston Edison Company asked Epidemiology Resources Inc. to review
analyses by the Massachusetts Department of Public Health (MDPH) of leukemia
incidence rates in communities in the vicinity of Boston Edison's Pilgrim I
nuclear power generating station. With data obtained from the Massachusetts
Cancer Registry, we were able to replicate the main results of the analyses
the MDPH has conducted thus far. The observed numbers of cases correspond
exactly and the expected numbers almost exactly between our analyses and
those of the MDPH.
We are critical of the way in which the MDPH has developed hypotheses
about potential environmental exposure to ionizing radiation from Pilgrim I.
The MDPH has concentrated on one highly speculative hypothesis about
recirculating air above the coastline to the north of the facility. The
MDPH has provided no supporting data for this unusual hypothesis, despite
the availability of substantial amounts of meteorologic and radiation
monitoring data. Neither has the MDPH contrasted the circulating-wind
hypothesis with alternatives, such as the simpler hypothesis that exposure
is directly proportional to the proximity of one's residence to the
facility.
E.R.I. Page 2 September 11. 1987
The MDPH analysis found elevated leukemia rates among adult males,
but not among women or children, in five towns that lie along the coast to
the north of Pilgrim I. That the increased incidence rates are limited to
adult males is inconsistent with explanations that might be proposed in
terms of general environmental exposures to ionizing radiation or other
leukemogens. Advilt males spend much less time, on average, in the immediate
vicinity of their homes in this particular geographic area than do women or
children. Consequently, adult males would receive the least amounts of such
exposures, on average, of the three groups of people.
We found lesser elevations of leukemia incidence rates in 13 towns
that lie within 17 miles of Pilgrim I than the MDPH found in the five
coastal towns. Both our analyses and those of the MDPH yielded estimated
leukemia incidence rate ratios that would be produced by high levels of
radiation exposure, according to predictions from the Radioepidemiological
Tables developed by the National Institutes of Health in 1985. These
predicted doses, on the order of 1-100 rad per person, are much higher than
would be expected in the communities near Pilgrim 1 or any other operating
nuclear power plant. The Radioepidemiological Tables were developed for the
purpose of estimating the probability that a cancer case was caused by
radiation exposure. The Tables are often used for lower doses and dose
rates than those for which effects have been reliably estimated. Doses of
1-100 rad, however, fall within the range of observed doses in the studies
that were used to construct the Tables (e.g., studies of survivors of atomic
bomb blasts) . These were studies of comparatively high dose rates, but no
792
E.R.I. Page 3 September 11. 1987
better data are currently available from which to estimate effects reliably
at lower dose rates. Thus, attribution of elevated leukemia rates to
ionizing radiation released to the general environment by Pilgrim I would
imply either extraordinarily high exposure that has evaded environmental
monitoring or substantial conflict with the Radioepidemiological Tables.
Of the accepted causes of leukemia, only occupational exposures to
ionizing radiation or other leukemogens (e.g., benzene) or medical exposures
to ionizing radiation would be high enough to produce the increases in
incidence among adults that we and the HDPH have estimated for the towns
near Pilgrim I. The case-control study under development by the MDPH should
emphasize a thorough assessment of the occupational history of each study
subject. This assessment shotild focus on ionizing radiation from all
sources and on industrial solvents, especially benzene, and should include a
plan for validation and quantification of reported exposures by contacting
employers.
793
E.R.I. Page A September 11. 1987
I. mTRODUCnON
The Boston Edison Company asked Epidemiology Resources Inc. (ERI) to
review analyses by the Massachusetts Department of Public Health (MDPH) of
leukemia incidence rates in communities in the vicinity of Boston Edison's
Pilgrim I nuclear power generating station.^ Boston Edison also asked ERI
to conduct its own analyses.
In Section II of this report, we describe the data we obtained from the
MDPH and other sources and the analytic methods we used. Section III
presents the results of our successful efforts to replicate the main MDPH
results. In Section IV, we offer a critique of the MDPH analyses, which are
based on an undocumented meteorologic theory. In Section V, we use
Radioepidemiological Tables developed by the National Institutes of Health
in 1985 to predict the average ionizing radiation dose that would produce
the association reported by the MDPH for leukemias other than chronic
Ijnnphocytic letikemia. Section VI presents the results of our own analyses,
which are based on proximity of residence to Pilgrim I.
794
E.R.I. Page 5 September 11, 1987
II. MATERIALS AHD METHODS
To replicate the analyses already conducted by the MDPH, and to conduct
our own analyses, we obtained from the Massachusetts Cancer Registry the
following data:
1) Listings by histology, race, sex and age group of all cases of
hematopoietic and reticuloendothelial cancers reported in the years 1982,
1983, 198A in the Commonwealth of Massachusetts. These cancers are assigned
code 169 in the International Classification of Diseases for Oncology
(ICD-0) .
2) Listings by hospital, date of diagnosis, sex, race, town, age. primary
site, histology, and confirmation method of all cases with ICD-0 code 169 in
2A Massachusetts towns in the vicinity of Pilgrim I (see Figure 1) for 1982,
1983, 1984.
To estimate the person-time in Massachusetts and the 24 towns, we
obtained 1980 census data^ and projections made for 1985 by the State Data
Center.* We used linear interpolation within categories of age, sex, race
and town for the years between 1980 and 1985 to estimate the number of
persons living in the state and in each town each year and thus the total
number of person-years for 1982-1984.
795
E.R.I.
Page 6
FIGURE 1
I !
September 11, 1987
SOLE oe MILES
10 15
Twenty-four Towns Identified by
the MDPH as Lying Within 20 Miles of
Pilgrim I
^^
C<»»7ri9l.r, THE NATIONAL SURVEY. Ch,,,*,.
796
E.R. 1. Page 7 September 11. 1987
Data entry and analysis posed various problems. The most significant
problem concerned the classification of cancers reported to the
Massachusetts Cancer Registry. For the years in question, the histologies
of cancers reported to the Registry were coded with three different
nosologic coding schemes: ICD-0, Systematized Nomenclature of Pathology
(SNOP), and Healthstat. Although the SNOP and Healthstat codes are similar,
there are substantial differences between these codes and ICD-0 codes,
which are the standard used by the MDPH and the National Cancer Institute's
Surveillance, Epidemiology, and End Results (SEER) Program. The MDPH had
previously prepared a concordance among the coding schemes for leukemias; we
obtained and used this concordance in our analyses after checking it for
consistency.
We encountered other problems as we prepared the census data for entry.
Census projections for 1985 were stratified by 5-year age group, gender and
race (White. Black. Other) . In all strata in which the number of people was
fewer than 10, the State Data Center did not report the number. Whenever we
could determine what the missing number was, we entered that number;
otherwise, we arbitrarily entered the number 4. (Four was our estimate of
the average number of unreported residents.)
Census figures for 1980 were not stratified in the same race and age
categories as the 1985 data. The Bureau of the Census reported race as
White. Black and Spanish origin. The category of Spanish origin included
people who were also reported in White or Black classifications. People who
were not White or Black were reported in the totals of the tables but
797
E.R.I. Page 8 September 11. 1987
otherwise were not represented. We entered figures in categories of White,
Black and Other, classifying as "Other" all people who were not White or
Black and who were in the total. In towns where age groupings were not
consistent with 1985 data, we distributed people proportionally according to
their distribution in the state as a whole.
We wrote a computer program to read all data files and perform the
calcxilations for the standardization of rates for individual towns and
certain groupings of towns. We determined the observed nxjmber of cases and
person— years by age and sex in each town or group of towns for the following
leukemia subgroupings : acute lymphocytic, chronic lymphocytic, other
lymphocytic, acute myelocytic, chronic nyelocytic, other myelocytic, and all
other leukemias.
To replicate the MDPH resiilts, we combined these groupings into the
following categories: leukemia, all subtypes (total leukemia, ICD-0 codes
9800 to 9940) ; leukemia, all subtypes except chronic lymphocytic leukemias
(non-chronic- lymphocytic leukemias. ICD-0 codes 9800-9940 except 9823); and
myelocytic leukemias (acute, chronic and other combined, ICD— 0 codes 9860 to
9866) . It should be noted that these categories are not mutually exclusive;
the second is a subset of the first and the third is a subset of the second.
In our analyses, we focused on the following leukemia categories:
acute lymphocytic leukemia among persons age 0-19; chronic, acute and
other myelocytic leukemias among adults; and other non-chronic- Ijnnphocy tic
leukemias among adults. For adults, we also used a broad category employed
798
E.R.I. Page 9 September 11. 1987
by the MDPH: all non-chronic- lymphocytic leukemias. Of the leukesnias that
occur primarily among adults, chronic myelocytic leukemia has received
particular attention in the literature on ionizing radiation and
leukemia. •-* Acute lymphocytic leukemia, which has also been linked to
radiation exposure, is the predominant type of leukemia among children. We
did not include chronic lymphocytic leukemia because of its consistent lack
of association with ionizing radiation in the studies of higher exposures.
Like the MDPH, we stratified the data for adult letikemias by gender
-icsuse of expected differences in exposure between men and women. Men are
expected to receive a greater share of the effect of many occupational
exposures and women are expected to receive a greater share of the effect of
domiciliary environmental exposures. Unlike the MDPH, we also stratified by
age. There were two reasons. First, the differences in exposure between
males and females apply only to adults; children do not receive occupational
exposures and boys and girls would receive an equal degree of environmental
exposure. Second, as noted above, the specific leukemia types are highly
related to age.
In contrast with the MDPH analyses, we did not compare a specific t(wn
or group of towns with Massachusetts as a whole, since the figures for
Massachusetts would include the data for that town or group of towns.
Instead, for comparison, we computed rates in the remainder of
Massachusetts by taking the total number of cases and the total number of
person-years in the Commonwealth within each category of sex, race (Black.
E.R.I.
799
Page 10 September 11. 1987
White. Other) and age (five-year categories) and subtracting from this total
the corresponding number for the specific town or group of towns of
interest.
I
800
E.R.I. Page 11 September 11, 1987
III. RKFLICATIOH OF THE MDFH RESULTS
In Tables 4a - Ad of the MDPH's report of March 16, 198?!, data are
presented on the observed and expected incidence of cancers of the
hematopoietic and reticxiloendothelial system, with a specific focus on
incidence of leukanias. We attempted to replicate the calculations of the
observed and expected numbers of cases of leukemia in the five coastal
towns of Plymouth, Kingston, Duxbury, Marshfield and Scittiate during the
years 1982-198A (see Table 1) . The observed numbers of cases of all
leukemias, all non-chronic-lymphocytic leukemias, and all myelocytic
leukemias in the data available to us were identical to the figures reported
in the March 16th report.
Our calculations of the expected numbers of cases in some categories
differed slightly from those of the MDPH. One reason for the difference may
be that our expected numbers are based on the rates observed in the
remainder of Massachusetts, whereas the expected numbers determined by the
MDPH are based on rates for the entire State, including the town or towns
involved in the comparison. A second reason may be that we had to make
minor approximations for those few numbers that were not reported in the
town census figures.
We calculated incidence rate ratios standardised to the age-race
distribution of the population whose incidence rate was the numerator of
each ratio. Rate ratios that are standardized in this way are known as
SMRs.^ Each SMR may be considered the ratio of observed to expected
I
801
E.R.I.
Page 12
September 11. 1987
numbers of incident cases. SMRs determined from data reported by the MDPH
and from our own calculations are shown in Table 1. The differences between
our results and those of the MDPH are trivial.
TABLE 1
Covparison of MDFH and EEUC Calculations of Observed and
Brpected Cases of Leukeaia in the Five Coastal Towns
Selected by the MDFH. by Sex. 1982-1984
OBSERVED
MDPH
ERI
EXPECTED
MDPH
ERI
SMR
MDPH ERI
Leukemia-
-all
subtypes:
Males
22
22
12.1
12.7
1.82
1.73
Females
12
12
9.3
9.8
1.29
1.22
TOTAL
34
34
21.4
22.5
1.59
1.51
Leukemia-all subtypes except CLL:
Males
19
19
Females
_8
_8
TOTAL
27
27
Leukemia-
-Myelocytic only:
Males
13
13
Females
_6
_6
TOTAL
19
19
9.4
7.6
17.0
5.2
4.8
10.0
9.2
7.8
17.0
5.0
5.0
10.0
2.02 2.07
1.05 1.03
1.59 1.59
2.50
1.25
1.90
2.60
1.20
1.90
I
802
E.R.I. Page 13 September 11, 1987
IV. CRITIQUE OF THE MDFH iJIALYSBS
In the report issued on March 16th, the MDPH presented data from 24
towns that lie approximately within a 20-mile radius of Pilgrim I. The MDPH
report focused on five coastal towns near the plant — Plymouth, Kingston,
Marshfield, Duxbury and Scituate — chosen because of "their proximity to
the Pilgrim plant, area topography, and coastal meteorological conditions"
(p.l). Pilgrim I is located in Plymouth. The other four towns lie
northward along the Atlantic coast.
The hypothesis that resulted in the selection of the five tcwns relies
on the supposition of a "'circulating' pattern of air" that would be
created by the temperature differential between land and sea masses and that
would trap radiation from Pilgrim I and continually expose coastal residents
to it. To date, the only meteorologic reference cited by the MDPH is a
drawing entitled "Land and sea breezes," from Dr. Frank Field' s Weather
Book.' No meteorologic data or measurements of emissions or environmental
radiation levels in the geographic aea around Pilgrim I have been used,
despite the acknowledgement by the MDPH that large amounts of such data are
available. In the absence of any data supporting this particular selection
of towns to study, we have chosen to expand the analysis to include other
towns in the vicinity of Pilgrim I (see Section V) .
If there were an environmental exposure producing a geographically
localized increase in a disease rate, we would expect to find the same or a
greater increase in the incidence rate among women than among men, because
803.
E.R.I. Page 14 September 11, 1987
of differences in exposure that might be experienced in each group. Data
based on 1980 census figures and prepared by the Data Resource Center of
Boston Central Transportation Planning reveal that for the five-town area
studied by the MDPH, 81% of males over age 16 work outside the home, in
contrast to 51% of females. Of those who were in the workforce in 1980, 64%
of men and 45% of women who lived in the five-town area worked outside of
that area. ' Thus, 77% of women but only 48% of men who lived in the
five-town area in 1980 remained in that area during the work week.
Therefore, adult women (and, of course, children of both sexes) would
receive a greater share than adult men of any hypothetical exposure that was
geographically localized in the five towns, and would sustain a greater
effect if that exposure increased the incidence of one or more types of
leukemia.
When viewed in light of previous studies of the effects of exposure to
ionizing radiation, results of the five-town analyses suggest that radiation
exposure is an insufficient explanation for the elevated leukemia rates in
this area. Studies conducted in the United Kingdom have indicated possible
excesses of leukemia in children, but not of adults, living in the vicinity
of nuclear power generating facilities. '•^"•^^ Biological Effects of
Ionizing Radiation (BEIR) and Radioepidemiological Table reports also
indicate greater relative risks for leukemia due to radiation exposure among
children than among adults. ^'^ By contrast, neither acute lymphocytic
leukemia in particular (Table 2) nor non-chronic- lymphocytic leukemia in
general (Table 3) was elevated among children in the five towns selected by
the MDPH. Adult males, but not females, in the five towns had elevated
804
E.R.I. Page 15 September 11. 1987
rates of myelocytic leukemlas and of all other non-chronic- lymphocytic
leukemias considered as a group (Table 4) . The elevated rates of chronic
and acute myelocytic leukemias among men were the most pronounced and
statistically stable, as indicated by the comparative widths of the
confidence intervals for these leukemia types.
TABLE 2
Observed and Expected Incidence of Acute Lyaphocytic Leukeaia
Aaong Besidents of the Five Towns Selected by the MDFH,
by Age (0-19) and by Sex. 1982-1984
Cas
90% Confidence
Sex
Observed
Expected
SMR
Interval
Male
2
1.A2
1.40
0.34 - 4.01
Female
0
1.04
0.00
0.00 - 2.21
Both
2
2.46
0.81
0.20 - 2.31
805
E.R. 1.
Page 16
September 11. 1987
TABLK 3
Observed and Expected Incidence of All Letikeaias Except
Chronic Lymphocytic Leokeaia aaong Residents of the
Five Tons Selected by the HDPH, by Age and Sex. 1982-1984
— Case
ed
Age
Sex
Ob
serv
Expected
SMR
Interval
n_i g
Males
2
1.92
1.04
0.25 - 2.96
Females
_1
1.48
0.67
0.07 - 2.78
Both
3
3.41
0.88
0.29 - 2.10
>20
Males
Females
Both
17
_7
24
7.29
6.34
13.63
2.33
1.49 -
- 3.50
1.10
0.56 -
- 1.98
1.76
1.21 -
- 2.48
All Males
19
9.21
2.06
1.35 - 3.03
Females
_8
7.82
1.02
0.55 - 1.77
Both
27
17.03
1.59
1.12 - 2.19
806
E.R.I.
Page 17
September 11, 1987
TABIS 4
Observed and Krpected Incidence of Leuke«xa iaiong Adult
Residents (Age >^ 20 Tears) of the Five Toms Selected by MDPH.
by Lenkesda Type and Sex. 1982-1984
Ca
90% Confidence
Leukemia
Type
Sex
Observed
Expected
SMR
Interval
Chronic
Male
3
1.13
2.66
0.89
^
6.34
myelocytic
Female
Both
0
3
0.97
2,10
0.00
1.43
0.00
0.48
~
2.37
3.41
Acute
iMale
9
2.86
3.15
1.75
-
5.30
myelocytic
Female
Both
4
13
3.29
6.14
1.22
2.12
0.48
1.31
~
2.60
3.28
Other
Male
1
0.62
1.62
0.16
-
6.63
myelocytic
Female
Both
1
2
0.40
1.02
2.48
1.96
0.25
0.48
~
L0.28
5.58
Total
Male
13
4.60
2.82
1.74
_
4.37
Diyelocytic
Female
Both
5
18
4.66
9.27
1.07
1.94
0.48
1.25
~
2.13
2.88
Other
Male
4
2.68
1.49
0.59
_
3.20
non-chronic-
Female
2
1.68
1.19
0.29
-
3.39
lymphocytic
Both
6
4.36
1.38
0.66
^
2.59
Total
Male
17
7.29
2.33
1.49
.
3.50
non-chronic-
Female
7
6.34
1.10
0.56
-
1.98
lymphocytic
Both
24
13.63
1.76
1.21
^
2.48
807
E.R. I. Page 18 September 11. 1987
Our comparisons of the SMRs in Tables 2-4 would not be valid if the
distributions of age, race or sex differed substantially between compared
groups and if any or all of these factors modified the effect of some cause
or causes of leukemia associated with living in the five-town area. The
reason for this possible lack of comparability is that each SMR is, in
principle, standardized to a different distribution of these variables. We
checked these distributions and found them not to differ appreciably. In
particular, the distributions of race and sex are virtually identical in the
age groups we have compared, as are the distributions of age and race in the
comparisons between men and women. Consequently, these results would not
change appreciably if the rate ratios were standardized to identical
distributions of these variables.
808
E.R.I.
Page 19
September 11. 1987
V. RADIATION DOSES PREDICTED FROl RADIOEFIDBMIOLOGICAL TABLES
The NIH Radioepidemiological Tables can be used to compute the ionizing
radiation dose that would produce a given increase in incidence, such as
the SMR of 1.59 for all non-chronic-ljrmphocytic leukemias in Table 3. The
Tables predict the probability of causation (PC) of cases of leukemia in
people of given ages who were exposed to certain doses of low-LET radiation
(1, 10. or 100 rad) at given ages.^ (These predictions are based on studies
in which doses were received at higher dose rates than in the population
near Pilgrim I.) To take a single example. Table PC-l-C-30 gives a
probability of causation (PC) of 28% for a man diagnosed with a non-
chronic-lymphocytic leukemia at age 35 after having received a dose of 10
rad at age 30. We shall use this Table and the other Tables for
non-chronic-lymphocytic leukemias to compare the predictions with the MDPH
results for the five-town area.
The PC, also known as the attributable proportion for the exposed
population, ^2 can be expressed as a direct function of the incidence
ratio (RR) :
rate
PC =
RR - 1
RR
(1)
809
E.R.I. Page 20 September 11. 1987
We can rearrange this equation to express the RR as a function of the
PC:
RR = (2)
1 - PC
Thus, PC = 28% in the example above corresponds to RR = 1.39. The tables
therefore predict that a study of a group of men age 35 who received a dose
-: 10 rad at age 30 would produce an RR of 1.39 for non-chronic-lymphocytic
leukemia.
The PC may be viewed as the proportion of a group of exposed cases that
is attributable to the exposure. An analogous measure is the attributable
proportion for the total population (AP^) , which is the proportion of a
12
group of exposed and unexposed cases that is attributable to the exposure.''
One expression for this measure is a combination of the RR and the exposed
proportion of the population (P-) :
Pg (RR - 1)
APj = (3)
Pg (RR - 1) + 1
I
810
E.R.I. Page 21 September 11, 1987
We can rearrange this equation to express the RR as a function of the
AP^ and the Pg:
AP™ - (APr/Pg) - 1
RR = -— (4)
APt - 1
We used equations 2 and A to compute the SMR that the
Radioepidemiological Tables would predict for the population of the five-
tovn area if all or part of that population were to receive a dose of 1 , 10
or 100 rad. (The SMR is a standardized RR, standardization being a way of
controlling confounding by such factors as age.) To do so, we assumed an
average induction time of eight years, corresponding to the interval between
1975 and 1983. (We chose 1975 as the time of exposure in this illustrative
computation because several MDPH authors expressed interest in an exposure
period ending in 1975.^^'^^ We chose 1983 as the end of the induction
period because 1983 is the midpoint of the three-year interval for which
leukemia incidence data are available.) To simplify the computations, we
applied the Radioepidemiological Table for exposure at age zero to the
person-time in the five-town area for ages 0-9, the Table for exposure at
age 10 for the age-group 10-19, etc.
To see how the computations proceeded, consider males in the age group
0-9 and a dose of 1 rad. Radioepidemiological Table PC-l-C-0 gives
PC = 13% for cases occurring eight years later (corresponding to the eight-
year induction time assumption). With equation 2, we obtained RR = 1.15.
811
E.R.I. Page 22 September 11, 1987
From the age- and sex-specific rate for the rest of the Commonwealth, we
obtained an expected ntimber of 1.16 cases in this stratum for the five-town
area. We multiplied this number by the RR to yield a predicted number of
1.33 observed cases. After repeating these computations for all categories
of age and sex, we added the expected ntimbers together and we added the
predicted-observed numbers together. The predicted-observed total divided
by the expected total equals the hypothetical SMR that the
Radioepidemiological Tables predict would be produced in the five towns,
eight years after the population of the area received an average dose of 1
rad. We then repeated the entire set of calculations for doses of 10 rad
and 100 rad.
The results are as follows:
DOSE PREDICTED SMR
1
rad
10
rad
100
rad
1.11
1.50
8.80
These predictions should be compared with the observed SMR of 1.59
obtained by comparing the five-town area to the rest of the Commonwealth
(see our Tables 1 and 4) . This comparison is premised on the hypothesis
that the average radiation dose was sustained by all members of the five-
town area; it indicates that the average dose would have been approximately
10 rad. The MDPH has assumed, however, that exposure occurred in only a
subset of this population in its proposal to conduct a case-control study
I
812
E.R.I. Page 23 September 11, 1987
restricted to the five tcjwns.^^ (Without this assumption, the proposed
study would contain no unexposed people.) The assumption of restricted
exposure was explicitly made by Dr. Sidney Cobb and several MDPH co-
authors, '•^•^ who claimed to have found a four-mile by twenty-mile area
within which the entire excess of non-chronic Ijnnphocytic leukemias was
confined.
We do not know what proportion of the population of the five-town area
lives in the four-by-twenty mile strip. Neither can we predict the
proportion that would be classified as exposed under alternative exposure
hypotheses. We can, however, use equation 4 to compute the RR that would
correspond to any given exposed proportion, P^, of the population in those 5
towns. For example, we can see from equation 4 that if P^ = 1.00 (i.e., the
entire population is exposed), then:
-1
RR =
AP^ - 1 1 - APj
Comparing this expression with equation 2, we can see that when P^ = 1.00,
AP^ = PC.
1 2
Another expression for the AP,j, is as follows:
AP^ =
813
E.R.I. Page 24 September 11. 1987
where I^ is the rate in the total population of exposed and unexposed people
and Iq is the rate among unexposed people.
Me can divide the top and bottom portions of the right-hand side of
this equation by Ig to obtain the following expression:
AP„ = =
The quantity, I-j-Zlo" is equivalent to the SMR comparing the five-town area
to the rest of the Commonwealth, under the assumption that only part of the
population of the five-town area is exposed. Thus, the SMR of 1.59 for the
five-town area as a whole corresponds to AP^ = (1.59 - 1)71.59 = 0.37, or
37% of the cases in the area hypothetically attributable to the exposure.
If only half of the population was exposed. P^ = 0.50 and, according to
equation A, RR = 2.18. This value is the predicted RR that the case-control
study proposed by the MDPH would estimate for the exposed subset of the
population of the five towns, if the apparent excess were in fact
attributable to the exposure. The value of this RR would not change if the
study were expanded to include other towns, because under this exposure
hypothesis the enlargement of the study would merely add to the size of the
unexposed portion of the population.
We have calculated the predicted RR that would be estimated for the
exposed subpopulation of the five towns, assuming a wide range of values for
the proportion of the population of the towns that is classified as exposed.
814
E.R.I. Page 25 September 11. 1987
These are shown in Table 5. If the exposed proportion (e.g., within the
four— by- twenty mile strip described by Cobb et al.) is as low as five per
cent of the overall population in the five towns, the corresponding RR would
be as great asP12.78.
We can now compare these RRs to the predicted SMRs we computed for the
five-town area from the Radioepidemiological Tables (see page 20 above) .
The Tables predict that, if the entire five-town area were exposed to
ionizing radiation responsible for the estimated SMR of 1.59 for that area,
the radiation dose would have been on the order of 10 rad per person on
average. The smaller the subset of the popvilation for which the average
dose is computed, the higher the RR and the higher the corresponding
average dose to that subset that woiild be predicted by the
Radioepidemiological Tables. As noted above, the RR of 1.59 under the
assumption of P^ = 100% corresponds to about 10 rad per person. The Tables
predict an RR of 8.8 for an average dose of 100 rad. This RR corresponds to
a Pg of 8% (see Table 5) . Although the four-by-twenty mile strip identified
by Cobb et al. may contain less than 8% of the area's population, it seems
safe to conclude that the elevated leukemia incidence rate in the five towns
corresponds to an average dose of 10-100 rad per person according to the
Radioepidemiological Tables.
815
E.R.I. Page 26 September 11. 1987
TABLE 5
Rate Ratios (RR) Corresponding to Different
Brposed Proportions (Fe) in a Total Population (Exposed and
Unexposed) with an Attributable Proportion (AF^) of 37Z
Pg (%) RR*
100 1.59 ( 10 rad)
95 1.62
90 1.65
80 1.7A
50 2.18
20 3.94
10 6.89
8 8.80 (100 rad)
5 12.78
* The RRs that would be produced by ionizing radiation dose
levels of approximately 10 and 100 rad. according to the
Radioepidemiological Tables, are indicated.
We have no knowledge of any attempt to estimate quantitative exposure
levels corresponding to the circulating-wind liypothesis proposed by Dr. Cobb
and the MDPH. It is our understanding, however, that this hypothesis would
predict average doses at least two orders of magnitude lower than 10-100
rad per person.
There are several uncertainties and assumptions in the computations we
have made with the Radioepidemiological Tables. Nevertheless, the predicted
doses are so high that one of two conclusions must be true. One is that the
Tables underestimate the effect of low-level ionizing radiation at low dose
'1
816
£_jl j_ Page 27 September 11. 1987
rates on non-chronic-lymphocytic leukemias by at least two orders of
magnitude. Because the Radioepidemiological Tables are based on studies in
which observed radiation doses were in the range of 10-100 rad, this first
conclusion wovild imply that radiation doses differing by several orders of
magnitude (but received at different dose rates) produce the same increase
in leukemia incidence. The second conclusion is that ionizing radiation
from Pilgrim I cannot be responsible for even a small proportion of the 59
per cent elevation in incidence reported for the five towns as a whole.
817
E.R.I. Page 28 September 11. 1987
VI. LEDKEKEA RATES IN RELATION TO PROZIMITT TO PILGRIM I
Given the current lack of an exposure assessment scheme based on
meteorologic and environmental radiation monitoring data for the environs of
Pilgrim I, we offer as an alternative to the circulating-wind hypothesis the
standard approach of grouping towns solely on the basis of proximity to the
plant. The towns of Duxbury, Kingston, Plympton, Carver and Plymouth form
an approximate semicircle around the plant with a radius of about 13 miles.
We place these towns into Zone I (see Figure 2) .
The next set of eight towns — Marshfield. Pembroke, Hanson, Halifax,
Middleboro. Wareham, Bourne and Sandwich — lie within a ring formed by
adding a second semicircle approximately 17 miles from Pilgrim I. We call
these towns Zone II.
Zone III consists of the remaining 11 towns on the list compiled by the
MDPH. As shown in Figure 2, Zone III is somewhat patchy. It might have
been advisable to include Lakeville, Mattapoisett, and Falmouth in this
zone. Because these towns were not on the original MDPH list, we did not
obtain data for them from the Cancer Registry. Zone IV is the remainder of
the Commonwealth of Massachusetts.
\
818
Page 29
Sepceniber I I , '987
FIGURE 2
Towns in Four Zones
of Proximity to Pilgrim !•
•NOTE: Lakeville, Mattapoisett and Falmouth are
in Zone IV (see text)
819
E.R.I. Page 30 September 11. 1987
Table 6 shows our comparisons of leukemia rates for all four zones. We
used Zone IV, the farthest zone from Pilgrim I, as the reference category.
An incidence rate ratio (RR) of 1.00 is arbitrarily assigned to this zone.
The RRs for the other zones indicate the relative degree to which the rate
in each zone exceeds or falls short of the rate in Zone IV. The RRs in each
row of Table 6 are "directly" standardized (SRR) to the age distribution in
Zone rv. An effect that would steadily decline with distance from the plant
would be indicated by a steadily increasing set of SRRs from Zone IV to
Zone I.
As shown in Table 6, the rates in Zones III and TV were very similar
for every type of leukemia examined except for childhood acute lymphocytic
leukemia, for which the rate in Zone III exceeded the rate in Zone IV by 30%
(SRR = 1.30). For all leukemia types in Table 6. the rates in Zones I and
II more closely resembled each other than did the rates in the other two
zones. The rate of childhood acute lymphocytic leukemia was depressed and
the rates of the other leukemia types among adults were somewhat elevated in
Zones I and II. The proportional elevation was greater, nearly a 50%
excess, for all n^elocytic leukemias as a group than for other leukemia
subtypes.
E.R.I.
N..l<
820
Page 31
September 11, 1987
TASLB 6
Directly Standardized Incidence Rate Ratios in
Zones of Proximity to Pilgria I*, by
Age and Lenkeu.a Type. 1982-84
Leiikemia
Type
Age
IV
-Proximity Zone* —
III II
Acute lymphocytic 0-19
Chronic myelocytic >_20
Acute myelocytic >20
Other myelocytic >20
Total myelocytic >20
Other
non-chronic-
lymphocytic
Total non-chronic
lymphocytic
>20
>20
(1.00)
(1.00)
(1.00)
1.30
0.88
1.01
0.75
1.26
1.39
0.60
(1.00)
0.95
1.92
1.4A
(1.00)
1.18
1.38
1.A2
(1.00)
0.61
0.97
1.A7
(1.00)
1.13
1.A6
1.46
0.95
1.29
*See Figure 2
821
E.R.I. Page 32 September 11, 1987
To simplify these computations, we made a comparison between the 13
towns in Zones I and II and the 11 towns in Zone III, leaving the remainder
of Massachusetts out of the analysis. This dichotomization of the 24 towns
selected by the MDPH divides the person-time in this geographic area
approximately in half and improves comparability by removing the influence
of any differences that might exist between this part of the Commonwealth
and such areas as Boston and Western Massachusetts.
Table 7 shows the results of this analysis. The rate of childhood
3C'jte lymphocytic leukemia in Zones I and II is only half the rate in Zone
III. Among adults, the total elevation of all non-chronic-lymphocytic
leukemias is not as great as in the five-town area defined under the
exposure hypothesis of Dr. Cobb and the MDPH (Tables 3 and 4) . There are
differences within this category as well. The rate ratio in the MDPH five-
town area was greater for myelocytic leukemia, whereas types of leukemia
other than myelocytic leukemia were in greater excess in Zones I and II.
The disparity by sex appears to be present for myelocytic leukemia (an
elevated rate among men but not women), but for the other non-chronic-
lymphocytic leukemias there is an indication in our analysis of a greater
elevation among women than among men. These estimates are very imprecise,
as indicated by the confidence intervals in Table 7. When all adiilt, non-
chronic-lymphocytic leukemias are considered as a group, there is little if
any disparity by sex.
As in our analysis of the data for the five towns selected by the MDPH,
we confirmed that the distributions of the stratification factors were
822
E.R.I.
Page 33
September 11. 1987
nearly identical between the subpopulations for which we compared SMRs. In
addition, the comparison of SMRs to "crude" (i.e. unstandardized) RRs in
Table 7 indicates little confounding by age or sex. Thus, we computed
confidence intervals for the crude RRs.
TABLE 7
Cmde Rate Ratio* and Selected SMRa
Ccaparijig Zones I and II vith Zone III. by Age and Sex
Leukemia
Age
Sex
Crude Rate Ratio*
90% Confidence
Type
Interval
Acute
lymphocytic
0-19
Both
0.53
(0.48)
0.15 -
1.83
Total
> 20
Male
1.22
0.63 -
2.37
myelocytic
Female
Both
1.05
1.16
(1.18)
0.43 -
0.68 -
2.54
1.97
Other non-
> 20
Male
1.15
0.40 -
3.31
chronic-
Female
3.14
0.55 -
17.91
lymphocytic
Both
1.55
(1.69)
0.63 -
3.78
Total non^
> 20
Male
1.20
0.68 -
2.10
chronic-
Female
1.34
0.62 -
2.93
lymphocytic
Both
1.25
(1.29)
0.79 -
1.98
* Selected SMRs in parentheses
823
E.R.I. Page 34 September 11. 1987
These results differ in some ways from those obtained under the MDPH
exposure hypothesis. Under the circulating-wind hypothesis proposed by the
MDPH, there is a clear difference by sex among adults, with only men having
an elevated rate of myelocytic leukemia. This observation, as noted above,
is inconsistent with an effect of domiciliary environmental exposure.
Under the proximity-based exposure hypothesis, on the other hand, the
association among adults is not restricted to men. This observation favors
the proximity-based exposure scale under the causal hypothesis.
The estimated incidence rate ratios are lower using the proximity-based
exposure scale than under the circulating-wind hypothesis. By corresponding
to lower predicted radiation dose, these observations put the proximity-
based scale slightly more in line with existing theory and data (as
represented by the NIH Radioepidemiological Tables) than the circulating-
wind hypothesis. Nevertheless, the estimated rate ratios still correspond
to predicted exposures that are much higher than would be expected tinder any
quantitative exposure hypothesis based on radiation monitoring data and
meteorology in the geographic area near Pilgrim I. The estimated rate ratio
of 1.25 for all non-chronic-lymphocytic leukemias in Table 7, for example,
corresponds to a dose of 1-10 rad according to the predictions from the
Radioepidemiological Tables (see page 20) and the computation of an average
dose for all residents of Zones I and IX. An even higher dose would be
predicted if the average were computed for a subset of this population.
Under either exposure l^pothesis, however, there is either no increase
or even a deficit of acute lymphocytic leukemia among children in towns that
824
E.R.I. Page 35 September 11. 1987
are hypothesized to have received greater degrees of environmental radiation
exposure. This observation is inconsistent with a causal interpretation in
terms of radiation released from Pilgrim I to the general environment.
The comparatively high rate ratios and the restriction of the elevated
rates to adtilts in these analyses tend to run counter to the hypothesis of
environmental radiation exposure. On the other hand, these observations
might be predicted by lypotheses concerning occupational exposures to
leukemogens. Such exposures would include ionizing radiation and industrial
- '-o-nr'2, o--^oi ■'■''' benzene.
From the data available thus far, it would be prudent to concentrate
available resources on developing and implementing an in-depth occupational
exposure assessment plan for the case-control study the MDPH is planning. A
complete occupational history should be obtained for all cases and controls.
Employers should be contacted for details of the work history of each
individual. Workplace exposures to ionizing radiation, benzene, and other
industrial solvents should be emphasized. Such exposures are more promising
explanations for the observed pattern of leukemia rates in this part of
Massachusetts than any hypothesis of widespread environmental exposure to
ionizing radiation.
825
E.R.I. Page 36 September 11. 1987
VII. RKFERENCBS
1 . Health Surveillance of the Plymouth Area. Massachusetts Department
of Public Health Center for Health Promotion and Environmental Disease
Prevention, March 16, 1987.
2. Report of the National Institutes of Health Ad Hoc Working Group to
Develop Radioepidemiological Tables. NIH Publication No. 85-2748,
January 4, 1985.
3. 1980 Census of Population. Volume 1. Chapter B, Part 23. Bureau of the
Census. U.S. Department of Commerce. June. 1982.
4. Provisicr.al ?opulation Projections; 1985, 1990 and 1995. Cities and
Towns in Massachusetts. Massachusetts Institute of Social and
Economic Research. June. 1986.
5. The Effects on Poptilations of Exposure to Low Levels of
Ionizing Radiation. Committee on the Biological Effects
of Ionizing Radiation. Washington. B.C.: National Academy of Sciences.
1980.
6. Miettinen OS: Standardization of risk ratios. Am J Epidemiol
1972;96:383-8.
7. Field F: Dr. Frank Field's Weather Book. New York:
G.P. Putnam's Sons, 1981.
8. Data prepared by the Data Resource Center, Boston Central
Transportation Planning Staff, June 3, 1987.
9. Beral V: Cancer near nuclear installations (letter).
Lancet. 1987:i:556.
10. Darby SC and R Doll: Fallout, radiation doses near Dounreay.
and childhood leukaemia. Br Med J 1987:294:603-7.
826
g H j^ Page 37 September 11. 1987
11. Roman E, V Beral, L Carpenter et al : Childhood leukaemia
in the West Berkshire and Basingstoke and North Hampshire
District Health Authorities in relation to nuclear
establishments in the vicinity. Br Med J 1987 ;29A:597-602.
12. Rothman KJ: Modern Epidemiology. Boston: Little,
Brown & Co.. 1986. pp. 38-39.
13. Walker B and DM Cute: Testimony before the Joint Committee
on Energy. Commonwealth of Massachusetts, July 31, 1986.
lA. Cobb S, KW Clapp, CK Chan, B Walker: Leukemia in five
Massachusetts coastal towns (Abstract) . American Epidemiologic
Society. March 18. 1987.
15. Study Proposal: Case-Control Study of Leukemia in Five Towns-
The Plymouth Area. The Massachusetts Department of Public
Health, The Division of Environmental Epidemiology &
Toxicology, January 16, 1987.
16. Cobb S: Testimony before the Joint Committee on Energy,
Commonwealth of Massachusetts, March 24, 1987.
827
U. S, SENATE
COMMITTEE ON LABOR AND HUMAN RELATIONS
HEARING ON RESTART OF PILGRIM NUCLEAR PLANT, 1/7/88
Statement of Dr. Sidney Cobb
I am Sidney Cobb MD MPH , Pr'ofessor Emeritus of Community
Health in the E-irown University Medical Program. My degrees
are -from Harvard and my clinical training was at the Johns
hlopkins Hospital. I tsiught epidemiology -from 1953 until my
retirement in 1979. I have published five books and over 100
scientific papers in refereed journals. Almost all of my
written contributions have been reports of epidemiologic
investigations. For the last three years I have been studying
the environmental aspects of nuclear power in New England with
particular reference to the effects on human health.
Much to the annoyance of some of my colleagues I take no
position on the propriety of using nuclear fission to generate
electricity for domestic use. I maintain that any society
that can put a man on the moon and bring him back again can
operate a nuclear power plant safely.
The price of complete safety may be too high, but an
acceptable level of risk can and must be achieved. I take it
that one purpose of these hearings is to ascertain the level
of risk from a nuclear plant that the area residents would
find acceptable. Route 3 from Plymouth to Boston has a lot of
accidents, yet many area residents take the risk regularly and
would describe the trip as safe. Curiously the same numerical
risk is not considered "safe" across a variety of other risks
and benefits. The bals^ncing of risks and benefits is always a
delic^^te task. In particular it is important to determine if
the people taking the risks are the people that 3.re getting
the benefits and if the persons taking the risks have any
choice in the matter. In the case of the automobile the risk
takers and the beneficiaries 3.rs mostly the same, and the
risks Are taken voluntarily. However, for the power
generation situation, those who recieve the benefits are
usually at little if any risk; and those who are at risk have
little if any choice in the matter.
I enclose several documents: -
1. "Leukemia in Five Massachusetts Towns - Abstract for the
American Epidemiological Society, Mar 18, 1987.
2. "Commonwealth of Massachusetts, Joint Committee on Energy
828
- TEstimony o-f Sidney Cobb MD , March 24, 19B7.
Z. Clapp RW, Cobb S, Chan Cl< & Walker B Jr. Leukemia Near
Massachusetts Nuclear Power Plant. Letter to the Editor,
Lancet, Dec. 5, 1987, pi 324.
4. MEMORANDUM, Dec 15, 1987; To Bruce Cohen; From Dick Clapp;
Subject Epidemiologic Resources Inc. Critique. (This is an
internal memorandum o-f the State Health Dept. indicating
possible lines o-f reply to a crtique o-f the work; that Dick
Clapp and I have done that was prepared by Epidemiology
Resource Inc. under contract with Boston Edison Co. I assume
the Committee has received a copy. If not I will be glad to
•f urni sh one. )
5. Correspondence with Maine Yankee Atomic Power Inc. This
is included because the great similarity betweeri what happened
in Massachusetts and what happened on a similar part o-f the
Maine coast strengthens the suspicion that the e-ffact might be
radi ogeni c .
In conclusion, it appears to me that there are two coastal
areas in which an excess o-f leukemia hs^s shovgn up roug-ily five
years a-fter a substantial release o-f radioactive materials
from a nuclear power plant at the southerly tip of the area.
Investigation by the several State Health Departments are
continuing. At the moment it seems possible that these small
epidemics of leukemia are causally related to the antecedent
r-eleases from the relevar-it plants. Further di spassi onatti and
unbiased research is required. Some of this research should
be directed at the suspicious increases in infant mortality
and congenital defect that might also be related. If it seems
clear that these are related the theory of radi ogr^ni ci ty v>ji 1 1
be strengthened. Also it will be important to study the
summer residents on the beaches of these coastal towns and to
look at the possible pathways via the air, the water and the-;
air-water interface. I believe that Federal funds should be
made available for this kind of research.
Sidney .Cobbi
UM
4 Water St.
S. Easton MA 0237^
January 6, 1988
M
1 n
829
LEUKEMIA IN I- IVE MASSACHUSETTS COASTAL TOWNS
Abstract for Amer i, can Ep i dena o.l oqi c, Sccietv
March 18, 1 «B7
Sidney iJoblj , Richard W. C.lapp, C. K. CLian Ze Bailu--- Wi^ller Jr.
w;i Ml Ihe SK<51 litanco o-f J. I. . P8?rl:ins
Co^sLai d J. atr I but 1 on of lei-'kernia a-'.J i ■jcf^iit l.n nuclear
i. riBl. sJ 1 c< I i TiriE. ha!=; been observed in Enqlrind, in Scotland ^nd
the; State of I'laint;'.. 11. seemed pt/ss i. b 1 €€■ that a %iai:ilar
S] ti.iat 1 ori ni3. qht »?>; :i -^it rternr ITie Pilqrini 1 nucJear plant on
Massachusetts B<n > , The hypnthe'ij. s. was I. hat , a<i m Naxne, the
e4-fect would be : ti the tuwri?; di.'wri wind, ie north ot the plant
and woiO d lieqiii sonie -five year-s after activation of t'cis rilarii:..
ltii>:. ['l^.nt went on 1 i iie December 19/2.
Cancer registry data, available on I / for the yearB 1932-04.
Bhow S1R''.D with 957 confidence intervals for the f i v-e towns,
nor-th of the plant a=i follows: hematopoetic !;■
r eti cul r.iendothel i al cancer 156 (118,206) , leulemia 159
'.113,224^ and myeloqenous leuk€=mia 191 (120,3iJ4). No sur:h
excess occurs inland ar south along tlie coast.
Mortality data, m fi v'i4? yii^ar groupings, show SMR ' s that taeijan
to be e;:ceBsive about 1977. Analysis by census tract reveals
G-issenti al 1 y all the excess inc:id(-?nce in the coastal tracts,
defining tlie affected art^a as less th-m five miles wide and *
about 2i.i miles long. Occupational data reveal no clusterinq.
Wafer and noil: supplies are man/ and do not fit this narrow
c D a, si a 1 |"j a t i: <? r n .
f'\'(-'[M 'r 1 ed al rlior rii:> r ol oa' .i-^'" i r i,m tlie ulaut art- too '^rtiill t o
pi oducc- tills effec:;t, unle'ij-:. the r-ff I uen f were lielLi to a
ctiastal d 1 'rif 1 i but ion 1j v s-oiiie meteoro I c^' ii > p<:Ktter ri . ;jurh a
pattern i '., well known l .,j hh-I eor ol Cigi ^st r. .
If tills e:;i:es-,& leul:fc'Hiia w<;.s caused bv radioactive material
releaseil fr-om !.ht- plant, the relearies iiiiqht tiave beei. fallowed
(jr ■ jiiifu l> b- -.riiii'v adverse r epr oduct i ./t' outcomes. "I rie- larqest
reported releases iron, ttie plant, were betweeri 10/ /4 and ■?/>"::.■.
Ill the period 19 '5- ^<.. l-l,t- i rO" an ' mortality rates and the rates
for ccinQ€iri 1 ta ! delects rt'iJC^rted on birtli certificates were
elevated in i wr I ai ii eB^ventiallv identical areas that L'^r^
related tu Ihc plant, and to the area of leukemia. I hese
reproductive of feels were riior e widespread than the Jeutemia,
but they support the hypothesis of r adiogeni c i t v .
830
831
FIGURE 2,
LEUKEMIA SMRS IN PLYMOUTH COUNTY.
1969-1983
[7V1 nVE COASTAL TOWNS
IXXl REMAINDER OF COUNTY
832
FIGURE 3,
AIR OVEI lAnr
)VING TCr.yAP.D
Land and sea breezes.
SOURCE: Field F: Dr. Frank Field's Weather Book. New York: G.P,
Putnam's Sons, 1981.
833
Figure 4. '
Leukemia Incidence in Lincoln, Knox and
Waldo Counties, Maine, 1959-80 and 1983-84
Cases
16
14
12
10
8
6
4
2
0
X X
XXX
//
69 70 71 72 73 74 75 76 77 78 79 80 // 83 84
Year
NOTE: The data from 1969-1980 are from Stutzman, et al (13). The data for
1983-1984 are from the State of Maine (14). There were no published data in
1981-1982.
834
•a-
o
40 ..
30
[2 20..
10
L J
ru
I I I I I
150 ..
100
I I I
50 ..
I_ _.^-^K~rl
I I I I I I i
150 ..
100 ..
CJ
50 ..
Th-u-T
MAIN STACK
All Isotopes
I I I I I I I
REACTOR BUILDING VENT
A11 Isotopes
I I I I
I I
I I
IODINE - 131
Main Stack and Reactor Bidg. Vent
171 172 |73 |74 175 176 1 77 178 I 791 801 811 821 831 84 1 851 861
YEARS
(by quarter)
Fig. 1 Airborne radioactive effluents from Pilgrim I nuclear reactor in
Plymouth, MA, by quarter, 1972-1986.
(Source: Boston Edison Semi-Annual Effluent Reports to USNRC)
835
Tabie 1.
Incidence d+ Hematoloqic Mai i qnanci es ( ICD 169)
in five Coastal Towns, 1982-1984.
Hale KemalB Tptal 95V. test-
based
H<-ilxqi-,ancy Dbs/E;:p SIF< Obs/Eiip SIR Obs/E;;p SIR Conf. Int.
«l I II .?< RE* 31/18. 1 171
Leukemiii 22/ 12.1 132
I eiikcfiiia 19/ 9. 4 203
mi nus (;i_L
l-K'C'l oqetious 12-/S.2 252
I ei.tkeiiii a
21/15.2 138 52/33.4 156 118,206
12/9.3 .129 34/21.4 159 113,224
8/7.6 1 C)6 27/16.9 1 60 108, 23 7
6/4.8 126 19/9.9 191 120,304
*A1 I Hematopoet 1 c ?< Reticuloendothelial
836
ii:,i;i K: i I Ul ' K.-^MlOj. NG HS1-.E. f UK I Ht Pt.K ,1 iJi:- .Iv7£j-6 IN EXCESS 1 MF hM I
1-U JK I AL. X T V iiNU COIlbLNl i Rl. UEFEC'I I (A I ES
KijWK
I MR
WSl-i Kii I I ij
5-3 1 . /
1S--6 1-fe
?;v .,■• 1 . 4
tj-X 1-2
6 3 X . 2
6 --5
ci;)R
llbA
r
rn r 1 IJ
6 .1.
I, . 0
fa-3
X . li
5-2
1 . u
S--3
X . >'i
6-b
X . i.
t:.--X
.1 .5
r 1 Our e i Massachusett s heal tf". service areas sr.oipjitiu
that are ir. vol ved in the 1975-76 "epi d(?mi c " o* i n t ai i L
fiior tai 1 t V . I he ar eas were ranked by their ratios o4 in* ant
(dOr h,alitv rates t or l*y7ti- 7 is over thei r rates t or the two ycfii
uf erteedi no ar.d the two years toiiawino. irie si >. towfis th«it
-j.-o ~rt^dc-a art; the too si -■ i " this i-.ini > ""
riqure 3. Massachusetts health service areas showing those
that are involved in the 1973-76 "epidemic- o4 conaenital
d«*»ct« reported on birth certificates. The areas were rani:
by their ratios o* conqenital defects reported in 197S-76
over those reported for the two years precoeding and the two
years .following. The f j ve towns that era shaded »re the top
five in this ranking. (As can readily be seen
Of the tin towns sf^aded on the previous map)
they are * i >
837
1324
IHKIANCIiT.DnCCMBr.RS, 1987
Lcncrs to the Editor
LEUKAEMIA NEAR MASSACHUSETTS NUCLEAR
POWER PLANT
Sir, — Your Oci 17 issue (p 924) camcd a note about the latest
revTcw of cancer around nuclear installations in Bniain. We
observed an increased incidence of leukaemia, particularly
myelogenous leukaemia, in a five-town area in Massadiusens
dunng the yean 1 982-*4. One of those towns ( Plymouth) is the sue
of a commercial nuclear power plant that began operations in late
1972 and from which releases of vanous isotopes in late 1974 and
1975 have been recorded (figure) ''
The standard inadence ratios (SIR) for all haematopoietic and
reticuloendothelial system (ICD 169) neoplasms, all types of
leukaemia combined, and all types of leukaemia minus chrome
lymphocytic leukaemu are presented in table i The standard rates
from which the SIR value? were calculated are the statewide rates
tur Massachusens for 1982-84 ITit-se arc for all ages combined,
although It IS of interest that the excess was in adults and the elderly,
not in those under 25 as noted m British data. Hie most striking
excess was for myelogenous leukaemia tn males.
We calculated age-adiusied morbidity odds rauos.companng the
incidence m the five coastal towns with thai in the sumHmding
communiues in south-eastern Massachuscns, The rauonale foe this
was that there mi^t be a registrauon effect whereby patients from
these towns might be more likely to be diagnosed and reported to
the Massachusetts Cancer Registry than pauents in the State as a
whole, A further consideration is the faa that about 90% of the
_ JkJ
IM.,
100 , ,
HKTOI lUllOlat I
_ ^Jh^ lllfL.-rm_
Airborne radioacuvc cfTlucnu frum PUgriin I nuclear reactor in
Plymouth, MauachuKlts, by quarter, 1972-M.
Source Htniun Eilison ^(.-im-jnitiul ftriut-ni reixtn* lo USNRC
Since the nuclear p«.twt.'r plant is on ihc coa^i and suki.' the
rcponed relcasiTN of radittiictive cHlucnis anj lou small in pniducc a
di>ubling iti niyeli'gcniius kukj^-mij ui roMdents ol iht- ^llwn^, wc
must postulate a mechanism by which airborne releases jrc
contained in a ciiaital pattern- Such a meteorological mechanism is
well known n» wtxiihcr observers,' and, m this instance, ui'uld
contain airbttmc clHucnti and recycle ihcm over the imnitdutc
coastal area. No other senes of towns along the Massachusetts coast
had had similar increases m Icukacnua or m the mvelogencus
subtype.
TABLL 1— INt,lUhN(.t Oh HAli.WA lOLOGlCAL MALKiKANt.lLS
ICl> I69i IN HVl.MASSACHUit ITS COASTAL lOVCNS. 1982-84
Diagnusit
31 in I (171) I
22 12 I i.l/<2: I
m 4 4 iJOfl
M 15 2 (/.?>?)
!2 9 1 u:9)
H7h ilOfti
All-
Leukaemia
leukaemu
minus Cl.L
MyelogeTMHu
k^Jucmij
*AI1 Kaemaliipinnn. jr\d ntKuh^-nJuttKlul nVnuti
Hnuh« arr xhwwTi a <4»»-ni'0 npwiMJ .iml SIK . *
(XL * (iinma. lvmpht«.M*k IrukA-mu
52/334 (/M. IIH-2(M^)
34/21 4(/.S9. in-224'
21lltt9(IM; lllH-217,
19/99 {I9til20-H^i
iih >*S"/. omlkloirc inivrvitJ i,<r ii«^ i.
1ABU-. II— Al>H.SI1IHn)l>SKAIIOSHlHHAi:MAlOI1>ll lU AND
Ri:ri(.UU)|.MK>lHl 1 lAi SVs:i.MSU)riJ\SMS \K H\,1 ( HASI ai
IO>rKS(UMI'AKI.l>V-| 111 VKimiAVIl KK .NAAiSAlHUSI II S ANIl
nu' VI Air. I9H2-85
-
.S.iuih-cjsuni Ntjwjthu SI-US
MaftMKilU<<^-Us
Males
Fmules
1 I 52(35), I i)r>~3 IH
1 56, 1 tW-2 20
I 35;(mi-l 4«
Toial
! 1 3M(^ll, 1 .15-1 HI
1 44, 1 IVI yS
Numbtn in pwuiihr^t rclcr <•> («■■>. .* L;i-<-t
Clearly, more detailed nuxielling of the meteorlocicai conditions
in the mid-1970s is needed before dose escimaics could be made.
Nevertheless, these des^npuve data are suggestive and will be
followed by more investigations and more intensive observation of
canter incidence trends around this and other US nuclear power
plants
Mj-s-jiuw.ix I *K.f KvK.Mrv Richard W Clapp
< jnif>nJi,v. VlJ^^M,hu^<ll^
Sidney Cubb
C. K- Chan
Bajlus Walklr. Jr
>•« Nc« Vorfe l*u
paucnis from the five-iou-n area and the rest of south-casiem
Massachusetts arc cjpiured in a regional registry sysiem
(Healthsut, Inc/ It might be jrgucd ihai the diagnostic and cinJing
cunvenuons used by iliii reKUuul regisirdtion bystem diflered from
those used in ht»spitals elsewhere in Massachuscns, jithougli wc
know of no evidence insupp«tn this The odds raut« comparing the
incidence in the Itve-town area and the two compans»»n .irt-as for the
four-year penod 1982-85 are pre^nted in table li We conclude
that a registration cITcct is noi a plausible explanation for the
apparent excess in the live-town ar^a for this lime perio*.!
838
■Oaiiuj Wallier Jr. PhD.. M P H
Commtssionef
■ '/li.Wtn. ■ //il,Mn/inM//j/J///
December 15, 1987
Memorandum
To: Bruce Cohen
From: Dick Clappif^m^
Subject: Fpi demi o 1 ogy Resources, Inc. Critique
As we have discussed, I wanted to do some cal'ulations in
response to the analyses done by ERI in their Sept. 11, 1987 doc-
ument entitled, "Leukemia Incidence in Communities in the Vicin-
ity of the Pilgrim I Nuclear Powe- Generating Station." From
their text, you can see that thei- analyses are based on data
they received from me, although many of their arguments are di-
rected toward a March 16, 1987 report issued by the Center. It
seems that the key argument made by ERI is that the "coastal
meteorological conditions" that led to a focus on the five towns
including Plymouth represents undocumented conjecture. They note
that the only meteorologic r e f e r e n c e c i t ed is to Dr. Frank
Field's Weather Book. In fact, there are many technical and non-
technical meteorologic references to the phenomenon and it is
well-known not only to researchers but to residents along the
coast; the reason to use the Field reference is that it has a
particularly clear figure.
Having dismissed the coastal meteorological theory as a
valid basis for selecting towns for analysis, ERI go on to pro-
pose a concentric circles model based (approximately) on linear
distance from the power plant and ignoring any meteorologic or
plume dispersion analyses. They refer to it as a "proximity-
based exposure hypothesis" (p. 34). Their concentric circles
analyses are summarized in Tables 6 and 7 and they claim the
results favor this "exposure scale under the causal hypothe-
sis." (ibid.)
I think it is important to highlight how the concentric
rings analysis compares to the equivalent analyses based on
a coastal meteorologic pattern, so I have re-cast the data for
the years 1982-84 into Zones I', II' and III' and summarized them
in the attached Tables. These Zones start with the five original
coastal towns as Zone 1', then the next contiguous inland towns
as Zone II' (Norwell, Pembroke, Halifax, Plympton, Carver, and
Wareham), and finally, the next contiguous Inland towns as Zone
MI' (Hanover, Hanson, East Bridgewater, Bridgewater, Middleboro,
839
p. 2
and Rochester). This is ap p -o x i ma t e 1 y the same as a decreasing
exposure zone analysis, as done by ERI in thei- Table 6, but with
a meteorologic dispersion model in mind; this, too, is theoreti-
cal and would be improved by the types of data being considered
by Dr. Spengler and his colleagues unde- contract to the Center.
Nevertheless, :he conclusions from this analysis are quite dif-
ferent from those in the ERI document. In particular, the pat-
tern of myelogenous leukemia seems to show a monotonic decline
in both males and females as one goes further inland. Rased on
the findings of the A-bomb survivors, this is the only type of
leukemia that one would expect to observe in a time period as
short as 8-10 years from exposure, which is what we are talk-
ing about in these data.
I do not think it is necessary to respond formally
ERI report, and I do not intend this to be such a respon
one thing, I would like to know more about how they did
calculations in Table 7 before going on record in a form
Also, I was intrigued by their use of the Radioepidemiol
Tables and would be interested in hea-iny from someone w
familiar with them whethe- thpy were used properly. In
I would be interes_t_ed in your "eactions and comments on
t ached Tables.
to the
se . For
their
a 1 way .
og 1 c a 1
ho is
any case
the at-
cc : nan F r i edm
U
840
Leuk em 1 a
Type
All ICn 169
Total Myelogenous
Table 1
SIRS in ERI Zones I-Iil
including Marsh f i el d
Zone
I II
Males Females Males Females
118
206
116
54
121
153
82
103
I I I
Mai es Fetnal es
142
147
106
78
Leuk emi a
Type
All Icn 169
Total Myelogenous
Tabl e la
SIRs in ERI Zones I - I II
excluding Marshfield
Zone
I II
Males Females Males Females
118
206
1 16
54
90
102
87
42
I I I
Males Fema 1 es
142
147
106
78
L e u k e m i a
Type
Al 1 ICO 169
Total My e 1 ogenou s
Tabl e 2
SIRS in Zones I' - I I I
Ma 1 es Fema 1 es
170 136
265 122
Zone
I I '
Mai es Fema 1 es
94
65
65
97
III'
Males Fema 1 es
59
61
92
31
841
mmic POWER company . ..ous.^ZlZ"::'.
(207) 623-35?l
August 4, 1987
Dr. Sidney Cobb
4 Water Street
South Easton, MA 02375
Dear Dr. Cobb:
It has come to our attention that you have made
statement? before the Joint Committee on Energy of the
Massachusetts General Court that concern the safety and health
effects of the operations of our company.
A copy of your remarks at the legislative hearing is
attached for your reference.
Contrary to the unsupported allegations you made, in so
public a forum, in fact there has been no evidence of adverse
effects on public health from the operation of the Maine Yankee
plant, as documented by the Center for Disease Control 1982
Study and the yearly Cancer Registry Reports, generated by the
Maine Department of Human Services, Bureau of Health, Division
of Disease Control.
The pertinent facts are as follows:
1. A critical review of the CDC data and 1983-1985
Maine Cancer Registry data reveals that
leukemia incidence is not rising as you
implied, but rather is actually below the
National average as evidenced by negative Z
scores for all five counties surrounding Maine
Yankee.
2. Environmental monitoring surveillance data
indicates that the radiation exposure to
persons living within ten miles of the plant is
on the order of a few hundreths of one percent
of the exposure received from the average
natural radiation level found in Maine. This
is far less than the normal variation in
background radiation due to varying geological
formations and radon concentrations found
throughout the State. To attribute any
particular effect to an extremely small
exposure increment which is only a small
fraction of the normal variation found in the
environment is utterly unjustifiable.
842
Dr. Sidney Cobb
4 Water Street
South Easton, MA
August 4, 1987
02375
3. Maine Yankee Atomic Power Plant has one of the
finest safety records of the industry. The
plant has never had an incident requiring
activation of any of its emergency safeguards
equipment. The plant has never even had an
"Alert" level event. Normal radiological
releases are routinely held to tiny fractions
of the federal guidelines. The plant has never
had a worker exposed in excess of federal
guidelines .
We are certain, Dr. Cobb, that you recognize how
damaging your unfounded and untrue accusations can be to our
company and the confidence Maine people have in the plant.
Our purpose in sending this correspondence is to
either: 1) have you acknowledge in writing that your
statements to the Massachusetts Legislature on March 24, 1987,
concerning Maine Yankee were false and inaccurate; or 2) have
you supply us with credible scientific evidence in support of
your allegations within ten business days of the date of this
letter.
This is obviously a very serious matter and we trust you
will respond to this inquiry. However, if you choose to ignore
this letter, we will presume it is because you have no
scientific evidence to substantiate your damaging allegations,
and we will proceed accordingly.
Sincerely,
Senior
Law and Administration
843
4 Water St.
3. Easton Mrt 0237S
Auqust 14, 19B7
Mr. David I. f-ianaaari
Maine Yankir'e Atomic powti" to.
Edison Drive
Aiinurita, ME 04:>36
Dt'ar Hr . FJanaqari:
This ;i^ 1 ri rfeplv to vour letter o+ Auqust 4, in which you
reque-zit ''credible ^icientific evidence" to si.tpport my testimony
ahout Maine be-fore the Joint Committee on Enerqy ot the
Massachusetts Leqislature. It was with the data presented m
the r^'S2 report by Sti>ti:man et al . of C. D. C. that 1 started
ifi , investigation. I h.nve always been one to pay more
aiitenlion to the data presented i ri a scienti-fic paper than to
the opinions offered by the authors. This is one o+ the cases
in which this behavior pattern served me well. What I found
in table 1 was tt.at the h-ates tor I eukeriu a in Maine have tieen
consi steritl V lower than ttiose found in the Ihird Natiortaj
Cancer Survev and that the rates for the counties down wind of
the nuclear p 1 ari f in Wiscasstt, Lincoln, Kno;. and Waldo, were
if anything even lower through the year 19".'6 or 1977. Ihis
made me think that it was probably most appropriate to compare
the recent leukemia experience o-f the thi-ee counties with
their own previous ejcpier i ence. Since numbers were small and
the populations of those counties were riot changing very
rapidly, it seemed sensible to look at ttie verv simplest set
of numbers, namely the numtier of leukemia cases identified
each year .
T plotted the number of leukemia cases per year ttiat were
identified by Stutzman et al . tor each year from from
1^>69 19B0. Similar data obtained from the publications of
the Maine Cancer Registry were plotted for 1933 ?,: 1984. No
data are available for the vecirs 1931 f. l',?82. ftiis qrapti w.;
presented as the first Hgure m the handout used m
p r e s e n t a 1 1 c* r i t
M^
wh
ita are available for the vecirs 1931 f. l',?82. ftiis qrapti was
• esented as the first Hgure m the handout used m my
'esentatiori to the American Epidemiological Association ovi
srch 18, 19a7. i Unf or tunatei v tkie graph was labeled fiq. 4,
rich has created £i certain j mount Cjf confusion.)
1 enclose a copv of ttiis haridO'it for- voui- convenient
i-f>f erenct-. Iri e>; am i cii nu ttii'.- -ou will note that my co- authors
include lii chard Clapp, Oirectoi ui the Massachusetts Cancer
Reqis.tr y and Bail us Walker Jr., whci is 1 'r esi dent-el ect of the
Amer-ican F-ublic f-ler.iltki As<-;oc i at i on anci former Commi ss>i oner of
H€_^alth for the Commoi-twE-ai th of Massachusetts. Both of these
844
men checked l-.he dc-»t«
to thi' [iresent at, 1 ciii .
1 1 e I r. t p t p r e t a 1 1 o n e b e t o r" tv <? q r i.? t; i n q
T .-»l.BCi iriL IndC' an t--.;tra copv o* the qraph, to which I ti^ive
added by hand the tiaw available dat<? -for 1935, and onto which
I hdVR sketched an approx i mati on ot thrj Sfrioothed curve? that
(night represent the outbreak., Thit". figure? shows that thp
,-:ivi;>r aqc' number o-f cases o-f leukemia ;:i these counties di_irinr4
ttie period 1969.-75 was lust under tour per year. In the
period 1976-9 the number ot ca=:es increased appr oi; i matel / four
■fold to lo per year, at which 1 evtvl it remained for a second
y'd'air bet ore heqinninq t< qi- adual decline to S cases in 198S.
It IS regrettable that we don t have data tor the years
1901-2, tor ttiey might qive us a better under standi nq o-f the
exact shape of the curve.
It 'should be noted that ttie 1935 data were not available to me
in time to be included in the presentation in March. However
these 19S5 data strengthen the conclusion that the outbreak
had at that time not vet run its full course.
Credible scientitic evidence has been presented that supports
t.tie conclusion that an outbr-eak ot leukemia in the counties of
lincoln, Kno>; and Waldo began in about 1977 and was continuing
at least thrcjuqh 1935. No claim is made that this is all tl'ie
evidence that there might be. Please note that my original
testimony w.as that this matter had as yet not been thoroughly
:i nvevit i gated . T believe that a -f i.i 1 1 , + a) r arid open
1 n vEfst 1 qat 1 on 'ihould he undt^r t -.kei i .
i> I III er
Sidney Cobb MD
Fi'-D-fessor Emeritus ot Conimunity Health
Grown Uni ver <:?,i t v Medical Program
845
Cases
16
14
12
10
8
6
4
2
0
Figure 4.
Leukemia Incidence In Lincoln, Knox and
Waldo Counties, Maine, 1969-80 and 1983-84
//
69 70 71 72 73 74 75 75 77 78 79 80 77 83 84 ST
Year
NOTE: The data from 1969-1980 are from Stutzman, et a1 (13). The data for
1983-1984 are from the State of Maine (14). There were no published data in
1981-1982 ^ cfjr^J"^'' ^iTi. rtr^ /T?S r\,t .^c/uj'^ "■ /A'
tf- er<rt £' n ^
j"'' /'
^ro''ffv
846
THE POTENTIAL ADVERSE HEALTH EFFECTS
OF THE PLYMOUTH NUCLEAR POWER FACILITY
Bel ton Burrows, M.D. and Donald Muirhead, Jr., M,D.
No one doubts or denies the inherent dangers associated with
high level radiation exposure. The biological consequences over
time of low level radiation exposure have not been well documented
although studied extensively. However, increasing evidence should
warn us that low level radiation may cause significantly greater
health problems than have previously been realized. Pilgrim I has
now been shut down for nearly two years because of a number and
variety of problems related to mismanagement, faulty equipment,
safety design problems, poor SALP reports, and no workable evac-
uation plan.
Both the authors are medical physicians. Dr. Burrows has been
an internist specializing in Nuclear Medicine at the University
Hospital for 38 years. He has recently attended workshops and
conferences on non-military radiation emergencies and the con-
sequences of the Chernobyl accident. Dr. Muirhead is a pedia-
trician with a subspecialty in Neonatology, and in practice for
24 years on the staff of Massachusetts General Hospital, Children's
Hospital, and the Brigham & Women's Hospital.
Senator Kennedy, we appreciate being asked to present written
testimony this evening, and shall confine our remarks to the
potential adverse health effects of the Pilgrim I nuclear power
plant upon the surrounding population. Three facts should set
the stage.
847
Page Two
1) In 1986, the Massachusetts Department of Public Health
extensively studied the population surrounding Pilgrim I and
observed a two to nearly three-fold increase in certain types of
leukemia and multiple myeloma above expected levels.
2) Pilgrim I is nearly 15 years old and historically has a
track record of known planned and unplanned releases of radio-
nuclides into the surrounding salt water and atmosphere.
3) There is an increasing body of scientific and recorded
anecdotal information regarding the potential health consequences
of low level radiation emitted from nuclear power plants. In
addition to earlier and recent experimental evidence which will
be noted, the problems of Hanford, TMI , Chernobyl, Maine Yankee,
and other nuclear plants in England and Wales will also be dis-
cussed. Significant papers by Stewart; Cobb and Walker; Hauschka
and Holt; Relman, Lambie, Burrows, and Roy; Forman and Sternglass
have been written presenting evidence strongly linking the radio-
nuclides from nuclear power plants to the biological effects
resulting in congenital anomalies, cancer, and low birth weights.
This data is not reassurring and is growing.
The Nuclear Regulatory Commission has agreed and commented
that no level of radiation is completely safe. In 1978, the
occupation exposure limit was set at 5 rems/year, down from 52
rems/year set back in 1920. The National Council on Radiation
Protection set the public exposure at 0.5 rems/year and 170 mrems
average/persons/year. Thus, the "workers" were being allowed over
ten times the amount of exposure thought safe to the public at
large because the major concern was for the genetic burden of
848
Page Three
radiation to the total population! This amounts to over 2 million
radiation workers. The NCRP and ICRP acknowledged that the 5 rems
"involved a compromise between deleterious effects and social
benefits", and "provides reasonable latitude for the expansion of
atomic energy programs in the foreseeable future" — 1965.
Radiation comes from two basic sources: First is the NATURAL
radiation, which is made up of cosmic rays, radiation from the
earth (such as granite and soil), and the hydrogen, carbon, and
potassium in our bodies. This amounts to approximately 100
mrems/year/person, varying particularly according to altitude.
The second source is MANKADE radiation. This is largely made up
of a) medical x-rays and injected or implanted radionuclides,
b) nuclear weapons testing, and c) nuclear power facilities. It
is very important to note that manmade fission products such as
Cesiuim 137, Iodine 131, and Strontium 90 may be up to 1,000 times
biologically more dangerous internally than an equivalent amount
of external radiation. One should not combine the manmade sources
with naturally occurring radiation. The nuclear industry and the
NRC frequently refer to the nuclear facilities as adding "less than
1% more to background radiation", in which man-made environmental
radioactivity is apparently included. As has been pointed out,
they are vastly different entities with equally different con-
sequences.
The health effects from radioactive releases break down into
1) Immediate effects: as shown by TMI and Chernobyl, we are
unlikely to have many immediate deaths from acute radiation
849
Page Four
radiation sickness or explosions, 2) Delayed problems of a muta-
genic or cancerogenic nature. Most likely these would result
from relatively low level radiation and come from either continuous
planned emission, unplanned, small emission, or a major accident.
The individual health effects of any of these scenarios depends
on a number of variables. These include: a) weather--wind, pre-
cipitation; b) age of the patient--very young and very old are
most susceptible; c) present illness — immune problems, genetic
problems; d) shelter — wooden/glass give only about 10% protection
whereas stone or brick add 20-40% protection from radiation.
What have we learned from previous accidents at nuclear power
plants? The accident at Three Mile Island continue to engender
conflicting information regarding cancers, etc. There have been
approximately 2,500 suits to date with 300 settled out of court
for $14. 5M. Dr. E.J. Sternglass, Professor of Radiation Physics
at the University of Pennsylvania said, "the rise (following the
accident) moved Pennsylvania from well below the U.S. average to
the highest infant mortality rate east of the Mississippi River".
The Hanford Study of workers showed 10-30 times expected
cancer rates with low level radiation.
The Department of Energy Study also reported excessive cancer
rates among workers.
The Chernobyl accident has been well documented and the Depart-
ment of Energy estimated that 21,000 Europeans would die of cancer
over the next 50 years. It was estimated that 3 million curies
fell over Europe and the Northern Hemisphere, the total amount
850
Page Five
being a significant fraction of the fallout from all atmospheric
weapons tests. Cesium 137 (half life of 30 years) accounts for
approximately 20% of all long-lived fission products.
In NATURE, October, 1987, Forum et al examined the study
"Cancer Incidence and Mortality in Vicinity of Nuclear Installa-
tions in England and Wales from 1959-1980". The populations
around 15 nuclear plants were compared with an equal number of
control populations. They concluded that there was a possible
increase in leukemia, multiple myeloma, and Hodgkin's disease
around the nuclear facilities.
In 1986, Sidney Cobb, M.D. and Bailus Walker, M.D. of
Massachusetts reported that in the Pilgrim I area there was an
increase in low birth weights, congenital anomalies, and cancer,
particularly over the downwind communities.
Dr. Alice Stewart from England showed in the Oxford Thirty
Year Study, a 2-3 times the usual leukemia rate in infants of
mothers who had received early prenatal x-rays.
Hauschka and Holt showed at the Maine Yankee nuclear power
plant that there was an increase in leukemia in surrounding
downwind areas after the plant began operations in 1972.
In the 1950 's, Relman, Lambie, Burrows, and Roy showed that
Cesium 137 is preferentially taken up by the muscle cells instead
of potassium. This resides in direct proximity to DNA. There
have been no adequate measurements of internal body burden of
radioactivity and outcome. Said Dr. Burrows, "Until more reliable
information is obtained to rule out any deleterious effects, it
would seem prudent to avoid further global accumulation of fallout
851
Page Six
radionuclides that might become available to biological systems".
(Burrows, Cardarelli, Sinex, Lefkin, and Teager. 1982),
An unending stream of problems at the Pilgrim I power plant,
coupled with seemingly unsurmountable logistical and geographical
problems vis a vis the evacuation plan presently suggests to the
NRC that Pilgrim I is not ready for restart! Even with better
management and better evacuation plans, we feel that these
serious potential health problems will remain for a much larger
population than most believe. The information collected is too
horrifying not to heed, of too great a magnitude not to thoroughly
study, and has potential consequences of too lasting a nature.
In 1986, George Woodwell of Brookhaven National Laboratory and
Director of the Woods Hole Research Center said, "Reactors are
intrinsically complicated and unstable. There operation as with
so much of human enterprise, is a compromise with safety. From
time to time there will be reactor accidents that will pro-
gressively and irreversibly contaminate the biosphere. .. It seems
clear that we have given nuclear power a fair trial and that its
promise falls far short of even the most modest hopes. The earth
is not large enough to accommodate this technology..."
To summarize, there is a growing and impressive list of papers
documenting mutagenic and carcinogenic effects of low level radio-
nuclides, particularly Cesium 137, Iodine 131, and Strontium 90.
The community surrounding the Pilgrim I power facility has been
shown to have a two to nearly three-fold increase in the number
of cases of leukemia. Lastly, similar reports concerning a rise
852
Page Seven
in rates of leukemia in other communities with nuclear power plants
have been published. This information, added to the poor track
record of Pilgrim I, only reinforces our resolve to recommend that
Pilgrim I be kept closed until the issues of safety and potential
health effects can be satisfied.
Belton Burrows, M.D.
50 Edgehill Road
Brookline, MA 02146
Donald M. Muirhead, Jr., M.D.
23 Lovers Lane
Duxbury, MA 02332
853
Eileen Kugelmann
P.O. Box 71
South Chatham, MA 02659
(617) 430-0875
TESTIMONY FOR:
SENATOR EDWARD M. KENNEDY'S
LABOR AND HUMAN RESOURCES COMMITTEE HEARING
REGARDING THE HEALTH AND SAFETY ISSUES
OF THE PILGRIM I NUCLEAR REACTOR IN PLYMOUTH, MASS.
January 7, 1988
SUBMITTED BY: Eileen Kugelmann, Director
Mass Safe energy Alliance (SEA): Cape Cod
Mass SEA: Cape Cod is a citizen group whose primary
mandate is to keep the Pilgrim nuclear power station closed.
Mass sea's members are concerned about all issues related to
the Pilgrim reactor. Our concerns regarding Pilgrim's
health and safety issues are as follows:
1. We are angry and concerned about the laclc of an
evacuation plan for Cape Cod and the islands. With the
Pilgrim reactor in our back yard, we are trapped here in the
event of an accident (or "incident") at Pilgrim. Further,
we are convinced that no evacuation plan, whether or not it
takes the Cape into account, is feasible.
Since there is no evacuation plan for our area, none of
Barnstable County's public service organizations, such as
our hospitals, are prepared to cope with an accident at
Pilgrim. Our hospitals are not equipped properly to handle,
at one time, more than one or two vij:ims of radiation exposure.
2. The Pilgrim reactor has been mismanaged from the
start, and this mismanagement translates into serious threats
to our health, above and beyond the health hazards inherent
in nuclear technology.
3. We are enraged at and disappointed in Boston Edison
Company and the Nuclear Regulatory Commission for consistently
and consciously witholding information about mishaps at Pilgrim,
and for deliberately misleading the public about the critical
problems with Pilgrim's evacuation plan, its safety standards,
and its management.
Thank you for this opportunity to air my concerns, and
the concerns of my group, regarding this nuclear monstrosity
called Pilgrim I.
Sincerely,
Eileen Kugelmann
854
January 8, 1988
Senator Edward M. Kennedy
Room 2400A JFK Bldg.
Boston, MA 02203
Dear Senator Kennedy:
Would like to thank you for holding the hearing last Thursday in
Plymouth. I am writing as a member of the Nuclear Affairs committee
for the town of Scituate and also as a concerned citizen as Boston
Edison talks about asking for permission to restart.
In December the League of Women Voters in Scituate hada debate
between members of CURE, f4ASSPIRG and Boston Edison on affairs
concerning the Pilgrim I plant in Plymouth. In Duxbury ' s latest
Emergency Response Plan from Boston Edison in May 1987, Page 40
Table 2-2, Scituate is listed as a "Secondary Shelter Community",
capable of sheltering 4,800 persons in our schools. Our Civil
Defense Director, Walter Stewart who is also our Fire Chief has
never been contacted or consulted on our participation. I have
been told Mr. Bergman, our Administrator is intending to write a
letter to Boston Edison expressing our displeasure at being in-
cluded without our permission. As another source of information,
I went to the Plymouth Public Library recently and consulted their
latest Emergency Response Plan which is from 1985. We are also
listed there on Page 25 alonq with 17 other schools, which probably
have not been contacted either. Incidently, Hanover Mall is still
listed as their "Primary Reception Center"; although they pulled
out of the plan at least a year ago. This is their latest plan
for the people to rely on for directions in case of an emergency.
If Scituate is supposed to be prepared to shelter 4,800 people I
think they should at least know about it I At the League of Women
Voter's meeting in Scituate when questioned about our part in the
evacuation we were told by Boston Edison's new Director of ERP ,
who consulted with another "expert" there that we were not in
the plan. The members of CURE and concerned are more informed than
Boston Edison's management. When T callec his office the other day
for a description of "Secondary Shelter Community", I was told they
no longer use Duxbury ' s 19S7 plan and that Plymouth's 1985 plan is
accurate; the one that lists Hanover Mall as Primary Reception Center.
Needless to say, I was more confused after I hung up!
I would like this information entered as part of the testimony for
keeping Plymouth plant closed permanently. Another example of
Boston Edison's mismanagement & blatant disregard for the safety
of the South Shore citizens.
Respectfully ,
Judy Theriault
106 Mann Hill Road
Scituate, MA 02066
545-2300
855
STATEMENT OF
STATE SENATOR EDWARD P. KIRBY
FOR THE UNITED STATES SENATE COMMITTEE ON
LABOR AND HUMAN RESOURCES
EDWARD M. KENNEDY
CHAIRMAN
January 6, 1987
856
w
SENATOR EDWARD P KIRBY
SECOND PLYMOUTH DISTRICT
ROOM 413.M
TCt.. 16171 722-1330
COMMONWEALTH OF MASSACHUSETTS
MASSACHUSETTS SENATE
STATE HOUSE. BOSTON 02t33
January 6, 1988
Committees
wavs and means
TRANSPORTttTlON
Criminal Justice
Energy
I commend Senator Kennedy for coming to
Plymouth to hold this hearing. It is regrettable
that the time allowed for it is so short. Were
there more time made available, perhaps the Senator
from the district including the Town of Plymouth,
would have been invited, and an effort made to
secure for the committee the use of the
work-product of the special joint legislative
committee created by an order I filed in 1986,
which conducted lengthy hearings in 1987. I am
thankful to Senator Kennedy and the Senate
committee on Labor and Human Resources for allowing
me the opportunity to present a statement.
Recognizing that this hearing was called
at the request of Senator William B. Golden, I
expect that the greater part of the committee's
time in Plymouth will be devoted to hearing the
views and data to be adduced by those who oppose
857
-2-
the restart of this generating facility under any
circumstances. The Senator's mind is already made
upon the issue.
senator Gold.en has already circulated a
petition asking the stockholders and board of
directors of Boston Edison to shut the Pilgrim
Nuclear Power plant down and press reports indicate
his reason is that it is not cost effective.
Senator Golden has said he believes the Pilgrim
Plant should be converted to a natural gas fired
plant. Whether such a move would really save money
is questionable, but there is no question that one
of the environmental effects of burning anything is
to produce vast amounts of Carbon Dioxide,
aggravating the greenhouse effect, and increasing
sea levels and moisture in the atmosphere.
Granted, there are environmental risks
attendant to nuclear operations, but risks attend
all combustion systems for generating power, so
Senator Golden's gas-fired proposal is hardly a
certain alternative for restarting Pilgrim.
Also, such a move would have more
immediate environmental effects on the community.
858
-3-
If the plant were to be shut down, perhaps the town
of Plymouth and its citizens should have something
to say about the next use of the property.
The issue of the effect of Pilgrim's
operation on area residents' health and safety is
one that merits further study. The Massachusetts
Department of Public Health is already planning
such studies but awaits state budgetary support.
There have been highly publicized reports that are
said to prove a higher than average incidence of
cancer among those living near Pilgrim. Presumably
testimony about those will be presented to your
■ committee. These reports are far from conclusive.
One who does not believe that Pilgrim is
responsible for increased incidences of cancer is
Dr. Joseph Ring, a senior health physicist at
Harvard University. In a letter dated November 30,
1987 he states that such a conclusion is based on
mistaken interpretation of the data. To quote Dr.
Ring, "...The data I have accumulated show that
there has not been any significant increase in the
background radiation levels as monitored by TLD's
[radiation detection devices] in
859
-4-
the area outside of the Pilgrim Nuclear Power
plant." in fact. Dr. Ring suggests in this study
that if, indeed, impermissible radiation had been
emitted from Pilgrim, no increase in the incidence
of cancer would be noticeable for 30 years after
exposure (based upon atomic bomb survival data).
The Pilgrim plant has only been operating for 15
years. Research shows, according to Dr. Ring, that
the incidence of cancer from natural causes in a
given population is vastly higher than what could
be expected as the result of exposure from a
nuclear power plant. Therefore, detecting the
effects of radiation from Pilgrim, or any other
nuclear power plant, on populations near the plant
is difficult, if not impossible.
An editorial in the Sunday, December 27
Boston Globe pointed out that New England protest
has focused on "hypothetical danger from a
still-inoperative nuclear power plant ... where no
death has taken place and none is apt to", and
cited in contrast, the subdued level of concern for
those who perished in the Phillipine tanker-steamer
accident which recently claimed at least 1,570
lives.
860
-5-
I believe that it is unconscionable to
exploit this issue in such a way as to increase the
fears of the residents. The residents of Plymouth
and surrounding towns .have been subjected to a
drum-fire of sensational statements and one-sided
concerning Pilgrim. I strongly
,ize with them over their anxiety. It is
e
interpretations
sympathi;
time that a more objective view is taken of the
ntire situation and that people hear some
assurances about their safety, their health, and
the truth about the true measure of risk we all
..i.^ .^^=r^^- anH its future management,
face concerning the plant ana its
I hope senator Kennedy's hearing will
provide the opportunity for such testimony to be
given.
861
WHAT THE NRC AND BECo WILL TELL YOU ABOUT PILGRIM S SAFETY
--AND WHAT THEY WILL WITHHOLD:
Regarding Evacuation
They will tell you that any major accident at Pilgrim
would not reach a point requiring a release of radioactive
material into the air -^or several hours a-^ter onset, leaving
ample time to evacuate within the 3 to 6 hours estimated
by KLD Associates, Edison's consultant on time estimates.
They will withhold the following, however:
1) The NRC ' s most recent Reactor Risk Assessment (NUREO-ll 50 )
estimated the probability of early containment failure
during a severe core melt at Peach Bottom, another Mark-I
reactor, to be over 90?J for most core melt scenarios.
2) A more recent study done for the NRC and published
in August, 1987(NUREG-1029) concludes that Mark-I reactors
have a high propensity for early containment failure during
a severe core melt, resulting in a release into the environment
within the first one to three hours after onset.
Regarding Safety Enhancements
They will tell you that the proposed safety enhancements
now underway are designed to mitigate early containment
failure in response to the five problem areas recently
highlighted by the NRC staff as potential early containment
failure avenues in Mark-I 's.
They will withhold the following, however:
1) NUREG-1090 and NUREG-1150 indicate thatmost
scenarios under which early containment failure is likely
involve direct attack of the molten core material onto the floor o-f
the reactor room after a breach in the containment liner.
However, the erection of reactor room barriers, one of the
five points suggested by the NRC as a potential factor in
mitigating early releases, has been rejected as a safety
enhancement option by Boston Edison.
2) Direct Torus Venting, another proposed safety
enhancement designed to allow small early releases to
relieve vessel pressure in order to prevent total containment
failure, has been disallowed by the NRC because of uncertainty
over the risks it would introduce.
3) NUREG-1150 indicates that among the highest
probable scenarios for early containment failure is
Station Blackout. BECo claims to be installing another
862
backup deisel generator to address this problem. However,
industry statistics indicate that such generators are
historically unavailable an average of \5% of the time,
hence even with another back-up, the probability of such
power being unavailable during a blackout is still
significant .
Regarding Design Flaws Noted in the Reed Report
This report, issued by GE in the early 70 ' s , noted a
number of potential design deficiencies in Mark-I's.
The NRG has had access to it, but only released it
very recently. BECo immediately asserted that all the
problems highlighted in the report have long since been
remedied .
What they failed to disclose, and what the NRG will not
discuss, however, is the fact that a recent reanalysis
of the Reed Report by the NRG concludes that there are
still 8 unresolved issues from that original report,
one of which is the unreliability of the Main Steam
Isolation Valve.
This valve was recently replaced by BEGo because it was
the root cause of the second scram of April 1986 which
led to the immediate investigation by the NRG and the
subsequent shutdown of Pilgrim to this date.
The NRG and BEGo will not admit that these unresolved items
pose j.ny safety risks, even though the one noted above
clearly did pose a serious risk which almost led to a
catastrophe just a few short months ago.
Regarding Severe Accident Risk
BEGo and the NRG will tell you that the risk of a severe
accident at Pilgrim is extremely low.
They will not disclose the following, however:
1) A 1982 risk assessment of a similarly designed
plant. Brown's Ferry, done by the industry itself, estimated
a probability of severe core melt at a mean value of
2.8 X 10" per reactor year. That translates to about
1 in 200 over the life of a Mark-I plant. Given the previously
noted high probability of early containment failure in Mark-I's,
this indicates a nearly 1/200 chance that Pilgrim will
render Plymouth and its surroundings uninhabitable for eternity.
863
Regarding Radioactive Releases
The NRC and BECo will tell you that they have not released
any isotopes in excess of background levels or in violation
of technical specifications.
They will not tell you that:
1) The acceptable limits were set long ago, based on
data from an aia.ysis of Hiroshima victims which has since
been discredited by more recent studies which indicate
that those limits may be too high by a factor of between
10 and 200. Other countries, ii response to recent scientific
data that suggest that low level radiation is more mutagenic
than previously thought, have decreased the allowable limits
by at least a factor of 10. The Federal Republic of Germany
is one of these countries.
2) It is documented in BECo ' s own records that
releases in excess of tech specs occurred over several
months in the mid-70 's. A DPH report correlates these
releases with a high incidence of cancer and infant mortality
in the area along the coast, just north of Pilgrim.
3) Plant-created isotopes are on record for samples
of sediment, shellfish, algae, ocean fish, and garden produce
in areas ranging from Marshfield to Bourne. Thisis well-
documented in a report by the Plymouth Town Committee on
Nuclear Matters.
Regarding Health Effects
The NRC and BECo will tell you that there is more danger in
potassixim table salt and X-rays than in plant releases
because plant releases are at much lower radioactive levels.
They will not tell youthat:
1) An incorporated dose that lodges in body tissue
as a result of its assimilation into the food chain is
much more dangerous than an X-ray or other such external
dose which has a limited exposure risk. Even potassium
salts which are naturally radioactive do not have the
propensity for replacing Vitamin B-12 in mussels or being
absorbed by cranberries, as do Co-60 and Cs-137i respectively.
2) Comparing levels of released isotopes to background
radiation gives the mistaken impression that there is some
qualitative difference between them, when it is a fact that
the effect on health is cumulative, regardless of the source.
Even if , taken alone. Pilgrim is not releasing mutagenic
864
levels of radioactivity, the proper health question should
be whether they are, or have been, increasing existing
levels in the environment beyond threshhold limits for
mutagenic diseases.
3) The health effects projected by the CRAC-2
computer model relied upon by the ^fRC in computing the
health impact of a reactor accident at Pilgrim are
severely understated since they are based upon old
census data of the area's population and the absurd
assumption that the area can be evacuated in 1 hour.
As noted previously, the earliest estimate for evacuating
predicted by KLD Associates is 3 hours.
Management
BECo will tell you that they have changed personnel at
the top to provide better management and to prevent the
mismanagement of the past.
They will not mention, however, the following:
1) This is what they said the last time they changed top
level management in response to charges of mismanagement.
2) Ralph Bird, the new head of nuclear operations, was
asked in a recent legislative hearing whether he had any
objective indices by which to measure the adequacy of
future operational performance at Pilgrim. His answer
was "No, but I know a good operation when I see one".
3) Richard Starostecki of the NRC staff was asked in
a 1986 public hearing whether BECo management would be
good enough to manage Pilgrim safely once it went back on
line. He answered that the NRC could not make such a determination
without first observing a pattern of steady management
improvement for at least three consecutive years.
'+) When asked in a legislative hearing whether he would
shut down Pilgrim completely if he saw that it could not
be operated safely, Mr. Bird stated that he had been hired to
manage it safely and that any other alternative would not
be considered.
865
Conclusion
Allof the statements contained herein are documented,
verifiable, and credible to the best of my personal knowledge
They comprise the half of the story that the NRC and
Boston Edison Company have failed to recognize for the
inp."! .-.cations it may have on the ccntiu'ed life of Pilgrim.
We in this community have a vested interest in our health
and safety, not in the need to recover a return on an
investment. Congress must heed our message and take
responsibility for the risk it has allowed to be set upon us.
By law. Congress has the power over Pilgrim and we have
no recourse but to appeal to you. You have allowed five
"revolving door" political appointees of a disinterested
and detached President to run slipshod over our rights
to health and safety. Must it continue until a major
accident creates the proper political climate for you to
act?
If the NRC refuses to discuss with you the issues I have
included in this statement, many of which are contained in
their own publications, and if they continue to assert that
despite Pilgrim's historic mismanagement and design
deficiencies, it is safe, then you must ask vour selves
the question after reviewing all the information before you!
Is a 1 in 200 chance of losing America s Hometown
forever an acceptable level of risk?
If your answer is yes, then you must also ask yourself »
Would you trust a company with a proven record of
failure with such a plant, knowing that the new
chief executive admits to having no objective
indices by which to evaluate performance, and no intention
to consider a shutdown oinder any circumstances?
If still you answer yes, then at least consider thisi
Would you allow your family to live in a community
with an above average mortality rate ^^rom mutagenic
diseases, knowing that a mismanaged nuclear plant
was adding to the radiation in their environment
on a daily basis?
If your answer is still yes, then you are non-representative
of the citizens who live in the shadow of Pilgrim, because
in November 1986, we voted 3 to 2 in a non-binding referendum
to shut it down. The message was clear and I relay it to you
from all the voters of Plymouth and Kingston! STOP PILGRIK I
866
The Chairman. If the audience will stay for one more minute, I
would like to make a final comment and then we'll break.
First of all, I would like to express our thanks to the many
people here during the course of these hearings. We also want to
thank WPLM for all of their good help and assistance and re-
sponses which they have given to us; Jack Campbell who has taken
a great interest in this whole undertaking and all those who have
been part of WPLM.
I have just a brief concluding comment. Tonight we have had the
opportunity to hear from the citizens who have the most to risk in
assuring that Pilgrim is safe. At least tonight they had the oppor-
tunity to have their voices heard. And we have heard from our
State and local officials, expressing their frustrations in attempting
to protect the well-being of their communities before a noncaring
and insensitive bureaucracy. We heard from the Federal officials
who are charged with the responsibility of deciding if restarting
the plant can be permitted without compromising the safety of the
residents.
Let me say that I am somewhat appalled by what I have heard
this evening — appalled that a federal agency would ignore the
advice of its own experts, especially when a similar reactor was in-
volved in the nuclear nightmare at Chernobyl; appalled that this
Federal agency would even contemplate restarting a plant without
the existence of a workable evacuation plan in the event of a nucle-
ar accident. Allowing Pilgrim to restart at this time would be dis-
graceful and in reckless disregard for the safety of the people who
live here. It is apparent from the testimony tonight that this plant
is light years away from restarting. And I want to make this com-
mitment to you — when I return to Washington, I intend to visit
with my colleagues in Congress and bring this matter to their at-
tention. Congress should take a hard look at what it is spending
your money on. The NRC has been delegated the responsibility to
see that the nuclear industry adequately protects the people from
the dangers of nuclear power. Instead, I'm afraid, we have seen
that the NRC that is merely a spokesman for the industry.
I firmly believe that the people should have the opportunity to
present the same evidence that we have heard tonight to the mem-
bers of the Nuclear Regulatory Commission directly — before an ad-
judicatory hearing, but if they can't, I will.
Our hearing stands in recess.
[Whereupon, at 11:30 p.m., the hearing w£is adjourned.]
O
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