ML20136A746
| ML20136A746 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/30/1997 |
| From: | Curran D HARMON, CURRAN, SPIELBERG & EISENBERG, LLP. |
| To: | Racquel Powell NRC OFFICE OF ADMINISTRATION (ADM) |
| Shared Package | |
| ML20136A726 | List: |
| References | |
| FOIA-97-29 NUDOCS 9703100040 | |
| Download: ML20136A746 (4) | |
Text
FB1 Flu 1EQUEST y
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IEMtMON, CURRAN & SPIRIRREG CD, 2 2001 S STRElfr. N.W.
surrs 430 WASHINGTON, D.C. 20009-1125 January 30, 1997 TmJBPHONE (202) 328 3500 Russell Powell, Chief (202)3Yseis FOIA-LPDR Branch Division of Freedom of Information and Publication Services Office of Administration i
U.S. Nuclear Regulatory Commission
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Washington, D.C.
20555 i
j BY FAX:
(301) 415-5130
SUBJECT:
Freedom of Information Act Request
Dear Mr. Powell:
I on behalf of the Seacoast Anti-Pollution League ("SAPL"), and pursuant to the Freedom of Information Act, 5 U.S.C.
S 552(b), at i
seg,, I hereby request that you make available copies of all l
documents in the NRC's possession which describe or discuss:
(1) any aspect of the on-line maintenance program for the 4
j Seabrook nuclear power plant.
This program is referred to i
at page 2 of a letter from Richard W.
Cooper, II, Director, i
NRC Division of Reactor Projects, to Jane Doughty of SAPL, j
dated August 22, 1996 (copy attached).
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(2) any instance (s) at the Seabrook nuclear power plant in which one or both trains of a system for which NRC regulations
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require redundancy has been intentionally disabled for pur-poses of on-line maintenance.
j This request covers but is not limited to all draft and final j
reports, correspondence, memoranda, notes, records of telephone contacts, or other written records, whether in paper or computer files.
For any portion of this request that you deny, SAPL requests that you describe the information that is denied, identify the excep-tion to the FOIA on which you rely, and explain how that excep-tion applies to the withheld information.
Pursuant to NRC regulations at 10 C.F.R. S 9.41, SAPL requests that any searching and copying fees incurred as a result of this search be waived, and provides the following information in response to the eight criteria listed in S 9.41(b):
9703100040 970305 PDR FDIA CURRAN 97-29 PDR
i HARMON, CURRAN O SPHOUBERG l
Russell Powell j
January 30, 1997 Page 2 i
1)
Purpose of request:
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The purpose of the request is to gather information on the nature j
and scope of the on-line maintenance program for the Seabrook l
nuclear power plant.
This information is not currently available in the NRC's Public Document Room.
i 2)
Extent to which SAPL will extract and analyse the substan-tive content of the records:
SAPL staff, and attorneys, who have many years of experience with safety and environmental issues regarding nuclear power plant operation, will thoroughly extract and analyze the substantive content of the records requested.
SAPL also plans to obtain expert assistance in evaluating the safety implications of the Seabrook on-line maintenance program.
SAPL considers the on-line maintenance program at Seabrook to be a high-priority safety concern, and thus SAPL is devoting significant time and resources to its evaluation of the program.
3)
Nature of the specific activity or research in which the records will be used and SAPL's qualifications to utilise the information for the intended use in such a way that it will con-tribute to public understanding:
SAPL is concerned about the safety risks posed by the growing trend of on-line maintenance at Seabrook and other nuclear power plants.
It appears that with increasing frequency, licensees are intentionally. disabling safety equipment during operation in order to perform routine maintenance, thus defeating the redundancy of the systems.
As noted in a December 27, 1990, let-ter from James H. Sniezak, NRC NRR, to Kenneth A. Stram, INPO (copy attached), the NRC is concerned that the growing trend toward on-line maintenance may lead to a greater unavailability of essential safety equipment than was contemplated when the plants were designed and licensed.
SAPL currently is conducting an evaluation of the safety of on-line maintenance, with a focus on the Seabrook program.
Accord-ing to Richard Cooper's August 22, 1996, letter to Jane Doughty, this program has been in place since April 1995.
If SAPL's evaluation of the Seabrook on-line maintenance program and activities reveals that on-line maintenance at Seabrook are violating NRC regulations and/or imposing undue safety and
l HARMON, CURRAN & SPIELBERG Russell Powell January 30, 1997 Page 3 environmental risks on the public, SAPL intends to publicize this information widely through the press and its newsletter, and to take appropriate legal action before the NRC.
SAPL is well-qualified to utilize the requested information in a j
way that it will contribute to public understanding.
SAPL is a non-profit charitable and educational organization with a member-ship of about 600 people.
Founded in 1969, the group is dedi-cated to the protection of the environment in the New England seacoast area.
For over 25 years, SAPL's attorneys and staff have been actively involved in efforts to stop or limit the i
unsafe operation of the Seabrook plant.
The organization was an intervenor in opposition to the issuance of the construction permit and operating license for the Seabrook plant, and con-l tinues to follow, evaluate, and publicize the safety and environ-mental risks posed by tae operation of the Seabrook plant.
I SAPL's newsletter regularly publishes information about the safety of the Seabrook plant and other safety and environmental issues affecting the New England seacoast.
In addition, SAPL widely disseminates information and analyses of nuclear power plant safety issues in the press and in television and radio news shows.
Thus, SAPL has well-established means of contributing to public understanding of the risks posed by on-line maintenance of nuclear power plant safety systems.
4)
Likely impact on the public's understanding of the subject as oampared to the level of understanding of the subject prior to disclosure:
At present, the public knows little or nothing about the nature and extent of the on-line maintenance program at Seabrook.
There is no information about the program in the NRC's Public Document Room, and the NRC does not appear to have conducted a formal evaluation of the program.
Thus, any information yielded by this request regarding the nature and extent of the program, the equipment it affects, and its safety risks, will make a major contribution to public understanding of the risks of on-line maintenance at Seabrook.
5)
Sise and nature of the public to whose understanding a con-tribution will be made:
The people whose understanding of on-line maintenance will be greatly enhanced as a result of the requested disclosures include
I HARMON, CURRAN O SPIELBERG Russell Powell January 30, 1997 Page 4 the 600 members of SAPL who receive its newsletter and other direct communications, as well as the entire population of New England who read newspapers, watch television, and listen to the radio.
In addition, SAPL intends to disseminate its findings to citizen groups around other nuclear power plants, as the practice of on-line maintenance appears to be widespread across the coun-try.
6)
Means of distribution of the requested information:
The information will be distributed through SAPL's newsletter, through SAPL's contacts with the press, and by sending the information to other citizens' groups around the country.
7)
Whether free access to infermation will be provided:
Information will be provided to the public at no charge.
Sub-scribers to the SAPL newsletter pay an annual membership fee, but copies of newsletters are free upon request.
8)
Commercial ints'oct by SAPL or any other party:
This request is befnt made solely on behalf of SAPL, a non-profit j
organization which a s no commercial interest in the requested
~
records.
SAPL is not aware of any other party with a commercial interest in the requested records.
If for any reason you decide to deny this fee waiver request, please contact me before incurring any charges on behalf of SAPL.
I look forward to receiving your response within ten worxing days of receipt of this request, as required by the Freedom of Information Act.
Sincerely, CC Diane Curran Counsel to SAPL cc:
Jane Doughty j
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KING OF PRUSSIA. PmN$vtVAMIA (340;;.14:g, August 22, 1996 Me. Jane Doughty The Seacoast Anti-Pollution League P. O. Box 1136 Portsmouth, NH 03802
Subject:
ON-LINE MAINTENANCE AT SEABROOK STATION
Dear Ms. Dougnty:
This is In response of your letter dated July 1,1996, in which you question the practice of on-line maintenance and asked two specific ouestions. The specific questions are repeated below in italics, and our responses are as follows.
O-1 How does a snaintenance program which allows the licensco to render safoty systerns inoperable during operations squsru with the Nuclasr Raguletory Commission's much-touted "delansa in dapch philosophy"?
A-1 Allowing equipment t' oe taken out of service for maintenance or testing is permitted under the plant Technical Spscifiestions and is consistent with Commission regulations. According to 10 CFR 50.36(cM2Hil:
" Limiting conditions for operation are the lowest functional capability er performance levels of equipment reQu: red for saia operation of the facility.
When the Ilmiting enndition for noe.rr. finn is not met, the licensee shsil follow any remedial action permittad by the technical specifications until the conditien can be nwt,"
Furthermore, perforcting on-line maintenance cas. assure a high degtse of reliability that the equicment will be able to parform its iunctiors it required. The Commission 1
i permits orHine maintenanca in cases where the small risk associated with the unavailability of the system is outweighed by tha bsnefit to be gained from continued reliability. Regulatory Guide,1.160'. citsched, provides additional information on the Commissior.'s defense in depth philosnphy.
0-2 The Saabrook Nuclear Power Plant was Ecensed pursuant to regulations that mandeted that there be redundant ssfary systarr s in place to assure that tha public health and safety would be protected. What is thc NRC's Icgoljuctification for allowing plant safety systems, that are mendotory rcquirements for plant Scansing[sici, to be danberately dafaated during plant operation?
6 1
Regulatory Guide 1.100, Revision o, Monitorie.g the Chetiv6nass of Mainterlance c:
Nu*er Power Plants a
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Letter to Ms. Jane Doughty 2
t A-2 The maintenance rule addresses both on-line and shutdown maintenance. Under paragraph (a)(3) of the Maintenance Rule, the NRC expects !!censees to assess the j
totalImpact on plant safety before taking plant equipment out of service for monitoring or preventive rnalntenance. Tnis assessment is to be performed on an ongoing basis, not just during the periodic assost. ment performed during every refueling cycle. This ongolng assessment is to be performed regardless of plant mode, i.e., whether the plant is operating or shutdown. The curnulative irnpact ei j
outmf-service equipment on the performanca of r.afety functions is intended to onsuro that the plant is not placsd in safety (or iialt) significont configurationo. Out inspection guidance
- tor the maintenance rule (sttached) provides additional j
information about unavailability and reliability of equipment.
For Seabrook, as described in the IPAP report. we found that plant personnel were 8
well aware of probabilistic risk assessment (PRA) conditions and t ie risk essessment staff was involved with work planning fue on-line maintenance and for outage work planning. PRA engineers had d&veloped a newly issued procedure to more formally define their input to the maintenanca plocass. When the licensas started an on line maintenance program in April 1995, this program was designed to increase reliability of equipment by not having to wait until outages for needed i
surveillance testing and repairs. As you noted, o.1 several different occasions during 1995. It became evident that the on-line maintenanco and related issues were not well planned. The operations departmar.t stoppad the on line maintenance activity until proper controls could be put in place. Although the initi&l on-line maintenance j
i process did not succeed, the ficanssa showed a good safety perspective by stopping the work and would not rost:rt the process until it could be performed safely.
The licensee resumed on-line maintenanca on Ju:V 19,199d, after extensively 4
changing the program to improve the work planning and wo'k contrcl process. The NRC will continue to monitor the resumptinn of on lina malnierance activities 4 Seabrook as well as other activities important tu cafety. Our pos? tion, remsas that 4
on line maintenance is allowed by the pirun licensos and is desirable under well controlled conditluns. Our concern is that licenset s make adequate preparation and carefully assess the risk to safe plant operation during all maintenance activities,
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including on-line.
In closing, I would like to comment on your stoiement that "potentially devastating otrorc" occurred on October 19 and 26,1995. As stated in the, reforenced Inspection reports (60-i 443/95-13 and /96-80), the thermal power exceedence on both dstes was a small fraction (0.06E of the licensed ilmit, was self identified by the licanses and corrected. and wss bounded by the plant accident analyses ocwor lavel (2.00% above 3411 MWt).
1 2
NRC Inspection Manual Chapter 62706. August 31.1995. Maintenance Rule
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3 NRC Inscecdon Report 50 443/96-80. April 3,1996, scabrook Station Integrated f
Pestormance Assessment Process j
i 1.etter to Ms. Jane Doughty 3
In addition, the reactor protection system was fully operable and capable of performing its Intended safety function. V's c'serly identified thio so a non-cited violation due to its minimal actual safety significance. The issue, which was coused by insdoquete avsluation of the affect of a maintenance evolution on plant operation, was addressed in the reports to emphasize to the licenses that better work planning snd control was necessary for maintenance work.
The above references, excluding the inspection reporta vou have, are attached for your pouiow, If you houo additional quootionc. ploacu cont:rt thn roepnncihlo branch rhi::f fnr Saabrook, Mr. John F. Rogge. Mr. Rogge cLn be rasched at (610) 337-5146.
Sincerely.
2 k f j('j Richard W. Cooper,11, Director Divicica of Reactor Projects Docket No. 50-443 cc w/ cy of SAPL ltr:
T. Feigenbaum, Executive Vice President - Nuclect, Nonhenst Utilities J. Austin Jr., RAC Chairman, FEMA RI, Bostun, Mun.
R. SUhn, Esquire, Backus, Meyer and Solomon, New Hampshire S. CM. frector, Nuclear Safety, Massachusatts Emergency i
Management Agency L. M. Cuoco, Senior Nuclear Counsal. Northeast Utilitioc F. W. Getman, Jr., Vice President snd Genarni Coun.se: Geeot th.y Power Corporation D. B. Miller Jr., Senior Vice President - Nuclect Safety and Oversight E. A. CeBarba, Vice President - Nuclear Technice.1 Corvices F. C. Rothen, Vice President - Maintensnca Servicas S. E. Scace, Vice President - Reengineering W. DiProfio, Nuclear Unit Director - Seabrook Str.tien A. M. Callendrello, Licensing Manager - Saabrook St; don (1. Hallissy, Director, Dept. of Public Health, Coinmonww.hh ci Massachusetts W. Meinert, Nuclear Engineer D. Tofft, Administrator, Bureau of Radiological Health, Stata of Naw Hampshire S. Comley, Executive Director, We tha Peopla ci the United Statns State of New Harnpshire, SLO Commonwealth of Massachusetts St.O Onionu Seacoast Anti Pollution Leagua i
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.gD Mr. Kenneth A. Strahm i
Executive Vice President Institute of Nuclear Power Operations 1100 Circle 75 Parkway Atlanta, GA 30339
Dear Mr. Strahm:
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The NRC staff has noticed an increased tendency to perform preventive maintenance during power operation. This inc;udes maintenance of equipment required to be i
operable by technical specificatiens.
In order to perform this maintenance, j
utilities enter action statements of the Limiting Conditions fo'r Operation (LCOs) in their technical specifications.
While u appears that utilities are attempting to limit the amount of time spent in an LCO to a reasonable fraction of the total outage time allowed by the LCO, in some cases the preventive caintenance may be repeated several times during an operating cycle. This leads to a concern that the total unavailability of important plant equipment may be higher than originally contemplated.
Of special concern is the entering into an LCO near the end cf an operating cycle for the primary purpose of performing preventive maintenance in order to shorten the refueling outage. A frequently i
encountered example is the overhaul of diesel generators.
Several factors may have contributed to this increase in on-line preventive caintenar.ce; among these appears to be the influence of INPO in encouraging utilities to limit the length of outages.
For example, INPO 89-017, pg. 8, encourages utt11 ties, *...to maximize the amount of work done on-line."
The NRC staff is concerned that the impetus to perfors more preventive caintenance on-line may not have been thoroughly considered from the safety (risk) perspective.
In some instances the increase in on-line preventive maintenance which requires entering LC0 action statements may contribute to more reliable on-line performance of important plant equipment and enhance overall safety. However, on-line maintenance primarily for the purpose of limiting plant outage time or other operational convenience, should not be undertaken without a full appreciation of the effects of this practice on plant safety.
It should be kept in mind that the allowed outage time set by an LC0 takes into account the single failure criterton, which is an important assumption in the overall facility safety analyses. We therefore consider the frequent entering of an LC0 action statement to perform preventive maintenance, or performing extensive preventive maintenance on important safety equipment for the purpose of reducing outage time, to be outside of the original intent of the technical specifications allowed outage time.
Although we believe a well founded preventive maintenance p-ogram can contribute to plant safety and reliability, we also believe that licensees should develop a numen em 4
4 Mr. Kenneth Str hm Decerrter 27, 1990 c
a full understanding of the impact on plant safety when removing equipment from service for preventive maintenance. This may be an area where INPO c~ould take a significant leadership role.
I c:ould be pleased to discuss this matter further at your convenience.
Sincerely, Daginal signed by James H. Snierek James H. Snietek Deputy Executive Director i
for Nuclear Restter Regulation Regional Operatieas and Research cc:
J JMTaylor JH5niezek 3
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