ML20043H294

Comments on Two Recent Requests by Boston Edison to Amend License for Plant.Trend to Reduce Testing & Lengthen Allowed out-of-svc Periods of Great Concern.Solution Should Be to Improve How Tests Conducted

ML20043H294
Person / Time
Site:	Pilgrim
Issue date:	06/11/1990
From:	Kriesberg J, Nogee A MASSACHUSETTS CITIZENS FOR SAFE ENERGY
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
FRN-55FR18407, RULE-PR-50 NUDOCS 9006250063
Download: ML20043H294 (3)

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.~n Massachusetts Citizens for Safe Energy 37 Temple Place, Boston, htA 02111 (617) 292 4821 y y er ra t2 June 11, 1990 Secretary

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U.S. Nuclear Regulatory Commission 1717 H St., NW Washington, DC 20555 SCFfLIf407 RE: Docket No. 50-293, May 2, 1990 Federal Register. b

Dear Secretary:

We are writing to express our concern over two recent requests by the Boston Edison Company to amend its operating license for the Pilgrim nuclear power plant (Docket No. 50-293).

Both of these amendments would reduce testing and 3engthen the allowed out-of-service periods for safety equipment. It is our understanding that these amendment requests, which are part of a general trend within the industry, for example, similar amendments were proposed for the Vermont Yankee plant in Vernon, VT.

This trend is of great concern to us. If industry experience shows that testing creates unexpected problems, the solution should not be reducing the number of tests, but rather should be improving how the tests are conducted. The industry and the NRC regularly emphasize the " safety in depth" concept ,

when explaining why nuclear plants are safe. That concept is undermined when back up systems are not being tested regularly or are completely out-of-service.

The first amendment of concern is dated March 8, 1990 and appears in the May 2, 1990 Federal Register, Vol. 55, No. 85, p.

18407.

The proposed amendment would lengthen the Logic System Functional Testing surveillance interval from six to eighteen months. Boston Edison wishes to reduce the number of tests because testing creates the " potential for inadvertent safety system actuations and isolations." A three-fold reduction in testing would appear on its face to " involve a significant reduction in a margin of safety," and therefore we question the staff's contention that such a reduction does not pose a "significant hazard."

To improve our understanding of this amendment request, we would appreciate written responses to the following questions:

9006250063 900611 PDR PR MISC 55FR18407 PDR A pro}ect of CITIZEN AGENDA

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y 9 l 1. How often do other plants test this equipment? Please indicate the industry average and range.

l 2. How often does testing reveal equipment problems which l require corrective actions?

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3. How often do other plants test this equipment?

4. Is the equipment expected to last the lifetime of the plant?

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5. For how many cycles is the equipment designed to last before needing replacement? '

1 l 6. How many total cycles would be required over the life of the equipment under the current and proposed technical

! specifications?

7. How long is the plant allowed to operate with this equipment inoperable?

The second amendment request with which we are concerned is dated March 15, 1990 and also appears in the Federal Register, May 2, 1990, Vol. 55, No. 85, p. 18408.

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This amendment would change surveillance requirements for l

redundant core and containment cooling systems and allowed out-of-service period for containment cooling system, diesel generators and low pressure coolant injection pumps.

In the Federal Register the NRC claims that industry experience shows that " repetitive surveillance testing can place demands and wear on plant systems without necessarily providing additional confidence of availability."

Please provide responses to the same seven questions listed above for this amendment request as well. In sddition:

1. Please provide documentation of the " industry experience" referred to above.

2. Please indicate why this problem cannot be corrected with mudified procedures and/or improved worker training.

3. Please indicate what the basis is for the NRC's claim that reduced testing doesn't reduce one's confidence that a given system will be available when necessary.

The equipment being considered in this amendment is vital to plant safety. Its availability is absolutely essential to the cafe operation of the plant. Reducing surveillance requirements could, it would appear, " involve a significant reduction in the

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margin of safety," and therefore we question the staff's contention that such a reduction does not pose a significant hazard.

We believe it makes more sense to avoid inadvertent actuations by modifying testing procedures, and by improving worker training, so that the tests are conducted properly, than '

by reducing the frequency of testing.

Before the NRC makes a final decisfon on these two amendment requests, we would appreciate receiving detailed written responses to the questions listed above.

Thank you for your attention to this matter.

Sincerely,

) f , .

A j/ Jo ph Kriesberg Director Alan N gee Energy Program Director Mass. Citizens r Safe Energy MASSPIRG cc. Ralph Bird Bob Palmer The Honorable Edward Kennedy The Honorable John F. Kerry 1

The Honorable Edward J. Markey i The Honorable Gerry Studds l The Honorable Edward P. Kirby The Honorable Peter V. Foreman i The Honorable Larry Alexander The Honorable William Golden Chair, Plymouth Board of Selectmen- ,

Chair, Duxbury Board of Selectmen i Paul Gromer

• Peter Agnes l

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