ML19332C997

FOIA Request for Documents Re Low Power Testing for Plant

ML19332C997
Person / Time
Site:	Seabrook
Issue date:	08/18/1989
From:	Brock M MASSACHUSETTS, COMMONWEALTH OF
To:	Grimsley D NRC OFFICE OF ADMINISTRATION (ADM)
References
FOIA-89-366 NUDOCS 8911290276
Download: ML19332C997 (12)

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1. k; .. THE COMMONWEALTH OF M ACOACHUSETTO  !

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.l DEPARTMENT OF THE ATTORNEY GENER AL

-g , t' JOHN W. McCORMACK STATE OFFICE BUILDING

g. ONE ASHBURTON PLACE. BOSTON o21o81698 :

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p , JAMES M. SHANNoN ATTORNtv O(NE R AL i

August 18, 1989 I.

fBEEDOM OF INFORMATION.

DonnieJ H. Grimsley, Director ACT REQUEST -

Division of Rules and Records Office of:= Administration p ,,g g g - ,

U.S. Nuclear Regulatory Commission 7735 Old Georgetown Road

@ /g f.22 M f 3 1 Bethesda, Maryland ,

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Dear Mr. Grimsley:

. Pursaant .to.the Freedom of Information Act, 5 U.S.C. S552,

• and 10'C.F.R. S9.1 et se ., the Massachusetts Attorney-

[* General's Office ( ."IIAG requests that you produce to MAG the '

'following-documents, including, but not limited.to . r records as oefined in 10 C.F.R.-59.13 (" Documents"), concerning low' power testing for: the Seabrook Nuclear Power Plant., All requested documents within the possession or control of NRC, or its-agents or contractors, should be produced, whether: generated by NRC, Appl 1 cants, their agents-or contractors, or otherwise.

'Please note this FOIA Request (Request'#24) seeks all documents that refer or-relate to the shutdown of the Seabrook Reactor on June- 22, 1989, or the cessation or suspension of low

, power operation. This FOIA Request, including Request 24(1),

is intended to supplement our prior FOIA. requests dated June 5 and July 12, 1989.

1. All documents identified or referred to by NRC Staff

' Counsel-Elaine Chan at Seabrook Transcript pages 23586 through 23591,1/ including, but not limited to:

a) pre-low power inspection report; E o b) readiness assessment team report; c) low power inspection report; 1/ A copy of these pages is attached as Exhibit A.

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8911290276 090818

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'd )r Llow power team: report; T" .ei) ' residentfinspector inspection report; p,

f ); Region 1 inspectorc inspection reports;;

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DU 19): 94'.300' letter from regional directorL o~NRC t

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including:any assessment on readiness for full-power and the NRC Staff's recommendat' ions; h) -all documents 1that identify or refer to.any.

. problem arising:during low power test'ing;-

J. g .i)- all; computer programs used or relied.upon'to conduct: or < evaluate' ' low Lpower testing including <

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special computer programssto track core exposure.

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, 2 '. -Por?eachidocument identified by Staff Counsel-Chan"inL.

-the priorfreguestc#1, produce'all supporting-documents reviewed 6' -c f ori.reliedLupon'by.NRC,-including. logs and. evaluation' notes, to g < cprepare'each such document.

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3 L. . A11Vdocuments reflecting test' protocols for low power; Etesting'.:

l 4,. i'Allidocuments reflecting: ,

'.(a). th'e process:to. determine core exposure during' low- ~

Ei power' testing program (LFTP);.

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+ (b)' . data obtained through thls, process; - l 4

the processicomputer program to record' IR:

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-detector currents and the time.between program executions and to evaluate core exposure; a

h aH (d) 'all' other' documents identified in'the enclosure

.to letter of. Victor Nerses to Edward A. Brown, May'21, 1989.2/

q 5. All-instructions, documents, evaluation criteria, and

information concerning the LPTP given'to federal evaluators, controllers, and observers prior to and/or during the Low Power Testing Program. This includes instructions, documents, and

" information.provided at training sessions and/or meetings.

I 2/ A copy-of the letter and enclosure is attached as Exhibit B. 1 1

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6.- ' All' communications or other documents concerning the

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scope,cmeth'odology or. implementation ofLthe LPTP,-and the

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specific: tests or procedures to be performed-or_actually

. performed.-

c. - 7. .All documents andLinformation concerning the Lower

.PoweriTesting Program or?concerning roles, functions, duties,

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-orievents expected'to occur during.the':LPTP that.were:

providedCbyithe NRC) or Applicants.~to. federal' evaluators,.

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simulators, controllers, observers,-or/NRC personnel, or any k other. persons atJany time prior to the. exercise.

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.8 . All' logs generated or maintained by each and every evaluator,(controller,.or observer, including NRC or s LApplicant's, during or' subsequent to the LPTP, including all appendices, comments,-and.summarl'es which are a part thereof.

9.. All: audio, Video or 'other electronic recordings, or

' transcripts;of recordings, of conversations involving NRC or 31 JAppl'icants' personnelfconcerning the LPTP.

[q,7[m E10 '. - All documents describing or pertaining to discussions cor communications on the LPTP, and occurring before, during,:

y'~ ' .and after the;LPTP between or among NRC evaluators,

" ' Leontrol-lers, and' observers; NHY controllers and evaluators, or

, between NRC and' Applicants' personnel.

-11. . 'All; photographs of' events occurring during the LPTP.

.12.1 All reproductions of ' status boards" as they existed .

'throughout.the1LPTP.

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. 13 . .- Allftime lines prepared by participants, evaluators, controllers, or observers of any events occurring during the p- .LPTP.

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. 14. All-charts, graphs, maps, diagrams, drawings, or physical evidence pertaining-to events which. occurred-during the LPTP. ]

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- 15. AnyLand all documents which describe the purpose of the.LPTP, or the'NRC evaluation process of the LPTP.

4 L, 16. All-summaries, notes, logs, or other documents which P -reflect the observations and other matters that took place at ,

any meeting (s) with the NRC or Applicants evaluators, (

' controllers, and observers concerning the LPTP, regardless of l 1 meeting'date. j s

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Page_4 -

m O - 117; .A11Ldocuments containing-factua'l or.evaluative y 7- informatlonL prepared during or after the LPTP,--by.NRC or

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Applicants' participants,: . evaluators, controllers, or-observers.;

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$' 118. All_otheriinformation,-communications,zor documents h, =provided.to federal evaluators after the LPTP to be used in' ,

P developing 1their evaluations.or. reports.-

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19. A11:other; documents, summaries, notes, logs, time b~ lines,. evaluations,1 comments, critiques,' or reports concerning -

' the - LPTP' andfprepared af ter the LPTP - by federal 1or Applicants'

' participants, evaluators,. controllers, or-observers.

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) 2 0.- All docu'ents,-including m minutes,.. transcripts,

-summaries,'or notes,.concerning.any meetings at which NRC or f

- - App 1'icants' evaluations, critiques, or comments on the LPTP J

.were discussed. >

21'.' All' correspondence,: memoranda,'or other records of

. communications between NRC personnel or cetween NRC and l

Applicants about drafts of documents or records on-tne LPTP.  ;

22. A111 correspondence, memoranda, or other documents

_regarding;the preparation _and/or content of_:the low power testing = program.

<2 3. :For each document previously requested;herein,-produce.

all. drafts of each document.

L24. All notes, logs, memoranda,' records, reports, manuals "oriother documents that refer or relate to theEshutdown of the  :

'Seabrook-Reactor'on June.22, 1989 or the suspension of. low-

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, power ; testing or operation, including, .but not limited to: n m

a) all operator manuals or~other documents that, y relate to procedures,. directives, or management policies for the start up or' shut down of the reactor; I b)- all documents that identify, describe or relate ,

to the responsibilities or authority.of personnel

o involved in the start up or. shut down of the reactor, including those-involved in low power ,

testing or the shut down of the reactor on June 22, 1989; c) all documents that identify or describe the steam valve involved in the June 22, 1989 shutdown; 5

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h , di lDonnie:H.7Grimsley, Director; p = August 18,e1989-Y ,

Page:S 1.,v 6 Td)L all.. documents--thatidescribe.or refer to'the.

-conduct lof'the natural circulation' start' upctest,:

[He .as: performed.at Seabrook Station'as:part of low power; testing; g -e )= call' documents'that, identify the individuals .

present-in the control room 4at theitimerof; plant shutdown 3on June 122,11989,Jor.itheirzroles,=

, responsibilities,' actions, or7 functions in-low;

[ power testingfor the shutdown;J lt

[n f): _all1 documents'that refer or contain the-D statements,: comments, or opinions-concerning low 32

. power testing or the shutdown,;of the individuals:

identifled In-Request 24(e), -}

t g) all documents'that relate or: refer to George S. s

. .Thomask and his resignation or removal as vice: :r i president.In charge ofiplant operations; j q

-h) all records, reports, memoranda or'other ,

' documents that refer or. relate to the reactor' '

"ic shutdown'on June 22, 1989, the facts-and ,

circumstances surrounding this event, oriopinions: ,

or conclusions as to~the causes/of:this event;.

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E[ 'i) all r'ecords,, reports,fmemoranda or other d u

documents that refer or relate to the cessation-or suspension of" low power testing; [

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! -j ) all documents that refer or relatecto confirmatory action letter (CAL)189-11, or to any statements--or actions undertaken by Applicantsior- 1 S NRC on the issuesiraised in the CAL,(ancopy.of

.the' CAL is attached);

k) all documents generated ons or after* June 1, 1988.

thatirefer or relate.to events or problems f

i involving plant-personnel, plant operation,-or-plant valve systems, whether related to low power-testing or otherwise; .

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1) all documents that support or relate to NRC

• Inspection Reports 50-443/89-80, 89-81 and 89-82.

m) for each_ document identified in response to Request 24, provide all drafts of each document; and

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Donnie H. Grimsley, Director n August 18, 1989-Page;6-n) for'each' document identified in response to Request 24, provide all supporting documents relied.upon in the preparation.of each document.

If, for any reason, you withhold any document or part thereof, please describe.the material that is withheld, by 1 title, date,, author, and summary of content, and explain your reasons for believing it is exempt from disclosure under the Freedom of Information Act. In addition, please explain why-the public interest does not require disclosure.

Please1 notify _me of the copying and mailing rosts for production.

I look forward to receiving your response within ten (10)-

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working days, as provided~1n the Act.

4 S a_cerely _ l k ,

I Matthew T. Brock Assistant Attorney General Nuclear Safety Unit (617) 727-2200 MTB/ tam Enclosures cc: Edwin Reis "

Deputy' Assistant General Counsel Reactor License Branch

.ee m mucura mauww commewan useseos i

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,s . m u .ses 0.ci.i. we.: io-44 M II S CAL No.: 89-11 Abitc' 5ervi:e of New Hampshire (P$NH)

ATTN: Mr. Edward A. Brown. President ,

and Chief Executive Officer i New Wampshire Yankee Division l Post Office Sox.300 Seapecok, New Hampshire 03874 Gentlemen:

Subject:

CONFIRDETORY ACTION t.tTTER (CAL) 8911 l

' This ' letter confirms our understanding of these actions you intend to take (n'

.resperse to the reactor manual trip which occurred on June 22. 1989 during the i performance of the natural circu'.ation startup test.. Those ections were ,

discussed during a June 23. 1949 Phone conversetten between yourself and Mr. 1 Thomas T. Martin, Deputy Regional Administrator, NRC Region 1. '

$pecifically, we understand that, prior to startup of the untt, P5NH will:

(1) Camelete and document the results of the post-trip review process associated with the June 22, 1989 event;

(2)= Estabitsh those short-ters corrective actions to be completed prior

' to resta*t- of the un't to address the specific deficiencies '

identified during your post trip' rev'evi (3) Datannine those longer ters corrective actions. and their res;sctive schedules, to address any potentially broeder implications associated with the specific deficiencias identified es a result of '

your review; and, (4) Review the results of itees (1), (2) and (3), above, with tha NRC staff, L

ire further understand that the aartement of the Regional Administrator, L

Region 1 Wuld be obtatred prior to restart of the unit. .

. . - . . . . . - _ .atf9(-S99tff .2ffw. - . . - - _ . _ _

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UN ic $4ryfC4 of New g g n-If yeve understanding differs fr04 that wl immedia te ly.

. forth above, please-call se

.116teral . s William T. Austell' tagionsi Acetnistratcr cc:

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T. C. C.Feigeebaus Owffett, President sad Chief Executiv J. M. Peschel, Re.gulatory Vice President, $e tsgineert e Officer D. f. Moody, Station ~NNYManager,rvices NHY Manager, ag, rogram,-NNY-t.tcens P$N  ;

e P. W. Agnes, Jr..: Assistant Secretary of P bi -

Public Commonwe41th Document Aeonof (PCR Massachusetts u tt $afety, i

1.ocal;Pubitt Document Room) (1.POR) 1 Wuclear NRC Resident Safety-Information In5Pector ~

Center (h5!C) f state of New Hampshire-

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Commonwealth Seabrook Hearing Service of Massachusetts 4,tst .

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, EXHIBIT A 23586

• 1 Secondly, the Board.has already referred to the 2-n fact the regulation itself restricts the discovery to 3

contentions in an operating license proceeding to matters 4

relevant to contentions that have been admitted.

5 More importantly, what we really heard here is the 6-old argument that I'm entitled to discovery to frame my 7 contentions.

That argument has been made to the Commission 8

since at least 1973.

It was first turned down in Nortan 9

States Power Company, ALAB-107, 6 AEC 188.

Reconsideration 10 denied,.ALAB-110, 6 AEC 247.

Affirmed CLI 73-12, 6 AEC,

11 241.

12 1 It was turned down again in 1974 in Wisconsin 1 13 Electric Company, Koshkonong Nuclear Plant, Units 1 and 2, i 14

.CLI 74-45, 8 AEC, 928, 1974, l h 15 E The doctrine th'a t you do not have discovery to 16 bring your contentions'was upheld jurisdictional 1y in BPI ,

L 171 versus AEC, 502 f.2nd 424, 428-29 D.C. Circuit 1974..

'18-

.That whole second argument you heard has been made 1 L 19 to the Appeal Board, the commission, and the Courts and it '

.20 has lost every time.- That's all I have to say. '

.21 JUDGE SHITH: Ms. Chan?

22 MS. CHAN:

l I think Mr. Dignan has probably covered

[ . 23 the field on the lack of rights of discovery for the purpose L 2 41 of framing contentions.

-25 However, specifically I would like to address the' Heritage Reporting Corporation (202) 628-4888 l

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23587 1- c Mass AG's argument that they need this observational status 2' to make their- hearing right meaningful.

3' The NRC documents, the entire low power testing 4- -procedure, s at the present time now there is a prolow power 5 ,

inspection going,on and that.will produce a readiness 6 assessment team report.

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Following the completion of that there is a low-8 ,

power inspection which results in a low-power team. report 9

plus the resident -inapector produces an inspection report.

10 And Region 1 inspectors also produce an inspection . report. -

11 Excuse me, the regional inspectors produce more 12.

L than one inspection report on the low-power testing.

L 13 '

All that information is put together. and released '

14 in the form of a 94.300 letter which is from the regional 15 director to Murley of the-NRC. 'And this contains an 16 assessment on readiness for full-power and the NRC Staff's '

b 17 recommendation.

L L* 18 If any problem arose during the low power testing 19 it would be documented. in one of these NRC inspection 20 reports.

21 Since low power testing must be successfully 22 L

conducted prior to full power operation, I don't think that L 23 the Mass AG is being deprived of any information.

1 h 24 l

The availability' of all these various reports, the 25 1

prolow-power report; the low-power report by the low power Heritage Reporting Corporation (202) 628-4888

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i, 23588 11 teams the inspection reports by the reetdent inspector and 2

the regional inspectors plus the 94.300 letter make the Mass I 3 AG's hearing right meaningful.

4 Massachusetts Attorney General has a right to 5

propose contentions based on this information and seek their c 6 admission, and if admitted, litigate those contentions.

7 This is the opportunity afforded the public to litigate the 8 low puwer testing.

1 9 JUDGE SMITH: You are not stating at this time 10 that they do have a right to litigate the low-power testing, 11' are you?

12 MS. CHAN: No, this is --

13- JUDGE SMITH: They do'have'the right, is that-it? '

14~ M3. CRAN:

'This is based _on the assumption we made

'15 ,

that they had a right to litigate. And also, that they had 16 some right to observe or obtain information. And this makes 17 this hearing right meaningful because this information is-18 available.

19 HR. TRAFICONTE: Could I just respond to that l 20 statesmant about the documents.

21 Could I have the Board either request, urge, or 22 order the Staff to retain any and all documents generated by j 23 the inspectors or anybody else in the control of the Staff, ,

24 all documents that then become the basis for these various 25 reports . l Heritage Reporting Corporation (202) 628-4888

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a J 1 23589 1 JUDGE SMITH: Mr. Traficonte, every time this  :

2 comes up you are faced with the same problem. ,

3 MR. TRAFICONTE: The jurisdictional problem is the 4 same even with regar'd to --

5 JUDGE' SMITH: ' We have ' absolutely no administrative '

6 authority over the Staff. 'No supervisory authority over the 7 Staff.

8 We-only have authority over the Staff as a party 9 to a proceeding on issues that are given before us.

10 MR. TRAFICONTE: I see.

11 JUDGE SMITH: In fact, the Commission has made it 12 clear in other decisions that if we believe that there is-13 some nonperformance upon.the Staff, we are not to order them 14 to performt we are to report the matter _ up the appellant 15 line.

16- MR. TRAFICONTE: So document retention is not in '

17 your jurisdiction.

18 JUDGE SMITE: Absolutely not.

19 MR. TRAFICONTE: I just wanted to indicate, and 20 again I am not happy to have to report this the second week 21 in a row, but I would want to seek an interlocutory review -

22 and- seek directive certification on the portion of the 23 denial, if the Board would officially deny, that portion of 24 the motion granting us some relief as to access or 25 observational status, and specifically the last request Beritage Reporting Corporation (202) 628-4888

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7 23590 1 _having to do with making sure that the documentation that'is

-2 generated is retained.

'JF M3. CHAN

- Mr. Traficonte, I can assure you at-.

4 this point that I will make sure that the documentation is 5 retained.

6 MR. TRAFICONTE: Would that include the special 71 computer program that has been written, so that the core '

8 exposure can'be tracked as well?

9 MS. CHAN:- Well, the information I have as to.the 10: reports that I'have discussed on the record, and as'to that '

11 information I will assure you and the Board that those 12 documents will be. retained. As- to other documents I'm not I

. 13 aware of, I can't make that same assurance.

14 But as to the ones that I have mentioned on the 15 record, all documentation pertaining to those will' be 16' retained.

17 JUDGE SMITH: The portion of your motion to be 18 granted observation opportunities during the power '

~19~ ascendancy is denied.

20 Your motion that we certify the matter is being 21 denied.

l 22 We will, however, provide for the most rapid 23 transmission of the transcript of this morning's arguments 24 and rulings to headquarters as we can possibly get them. I 25 MR. TRAFICONTEt Thank you, Your Honor.

5eritage Reporting Corporation (202) 628-4888 1

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j 23591 1- JUDGE SMITH:

It'will be'down in.the. hands of'my-'-

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.2 secretary for.further transmission depending upon what you l

3 need.

4- Off the record.

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(The Board confers.) '

-6 JUDGE SMITH: We're off the record here.

7-(Discussion off the record.)

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[t i NUCLEAR REGULATORY. COMMISSION ,

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I W ASHING TON, D. C. 20555

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G. a May 21,1989 e Docket No. 50-443 i

.Mr.. Edward A. Brown- -

e President 8' Chief Executive Officer: l '

New. Hampshire Yankee Division Public Service Company:of New Hampshire Post Office Box-300 Seabrook, New Hampshire 03874

SUBJECT:

"$EABR00K LOW POWER PHYSICS TESTS

" H

'In accordance with the Comission Order, CLI-88-10 dated December 21, 1989,.

for any low power . testing license that may be issued for Seabrook Unit 1, the license will. be- conditioned to allow operation at power levels not in excess-of five percent and shall. permit no more than 0.75 effective. full powerihours f(EFPH),of, operation.

~In consideration-that such a license may be issued,.we have revfewed the manner-in which your staff. intends ~ to perform low-power phys 1cs tests and-remain within the Itcense restriction of 0.75 EFPH and 5% maximum power level. The enclosure presents a summary of our understanding of how the two restrictions are expected to be met. We find the approach to be satisfactory. - ,

Sincerely, 5

Victor Nerses, Project Manager .

.... Project Directorate I-3 1 Division of Reactor Projects I/I! l

Enclosure:

i

-As stated

.cc w/o enclosure:  !

See next page l

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Enclosure

. Seabrook' 51/0.75 EFFH Operation GENERAL INFORMATION 0.75 vffective full power hours (EFPH) operation for Seabroo lent to 0.75 x 3411 W s equiva.

t x 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> = 2558 Wt -hr.

Seabrook.could operate continuously for 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />.At 55 power g (or The tests to be l conducted test. are primarily low power physics tests and n a na  !

The majority of the low power physics tests are conduc zero power test range (approximately .015 power).

will be conducted at approximately 11 power and the na 7

. test will be conducted at approximately 31 power.

The~ process that will be used to determine core exposure e low.

f power test program will be identical to that used to detemine cor exposure during normal plant operation. ,

However, instead of using a secondary calorimetric to calibrate (normalize)'the power range instruments the core AT power will be used to calibrate (no ,

the. intermediate range (IR) nuclear instruments.

This calibration will be bssed on the full power core temperature rise (corea T)

. One of the first evolutions to be performed in the low power test program to. increase.reacter power to 35 (based on core &T) and record th detector currents.

From the data obtained by this evolution, the normal-ization constants. for each intermediate range detector (asp will.be determined.

L A process aesputer program has been written to record the IR de currents and the time between program executions. The program then

.calculate utilizescore this data along with the IR detector normalization consti exposure.

'levelstimesthetesttimeandthiThe EFPH will be the sum of the tes Mwg -hr. s sum will be maintained below 2558  ;

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SPECIFIC'INFORMATION Reactor power will be measured using the core temperature rise normalized

- to the full power core temperature rise (cosmonly referred to as AT power). The IR detector outputs will then be normalized to.the measured '

core 4 T power. It will be necessary to calibrate (normalize) the IR l detectors to trace core exposure because most of the low power testing'is' conducted in the zero power test range where core &T is O'F but the IR detectors are' producing a current equivalent to approximately .015 power.

l The uncertainties associated with the measurement of core &T are about' the same magnitude as the measurement itself. To offset this, a full power core AT of 57.0'F is used to determine the IR detector normalization ,

constants. A full power core E of 57.0*F is conservative with_ respect i to the expected full power value of 59.4*F. The process of normalizing the IR detector output to match core 4T power also neraalizes out any.

uncertainties associated with the IR detector outputs. Thus, the IR

detector outputs simply inherit the error associated with the core of l' measurements which has already been accounted for.

All instruments necessary to monitor core exposure are calibrated with-L the exception of the IR detector output normalization. IR detector normalization will be performed during normal plant startup regardless of any core exposure limitations.

There is no specific plan or schedule for expending the .75 EFPH. The only plan that exists is the low power test sequence which, if goes as planned and without any unforeseen test or equipment difficulties, should l be completed within the allotted exposure Ifmit. The tests are expected to be completed in about ten days. I 1

l A special computer program has been written for the main plant computer to calculate and track core exposure. An administrative procedure will l be written to ensure that the exposure limit will not be exceeded and to document core exposure. The administrative procedure that tracks and p documents core exposure will contain a section on manual tracking of core exposure if the plant computer is unavailable.  !

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