ML030870004

E-Mail Regarding Oyster Creek Refueling 2.206 Additional Questions (Oyster Creek 2.206 Refueling Problems Dated 3/20/03)

ML030870004
Person / Time
Site:	Oyster Creek
Issue date:	03/26/2003
From:	Mulligan M - No Known Affiliation
To:	Landau M NRC/EDO
Tam P, NRR/DLPM, 415-1451
References
2.206, TAC MB2893
Download: ML030870004 (3)

Text

From: "Mike Mulligan" <steamshovel@adelphia.net>

To: "Mindy Landau" <MSL@nrc.gov>

Date: 3/26/03 12:38PM

Subject:

Oyster Creek refueling 2.206 additional questions ("Oyster Creek 2.206 refueling problems" dated 3/20/03)

Oyster Creek 2.206 Another important question that needs to be asked; just what value does the new refueling license amendment (refueling with interlocks INOP) provide to the utility "and the public". Is it always about the utility interest? We need to ask, might this bureaucratic change create no real actual results for the utilities -NEI churning and diverting NRC resources away from their primary safety function?

What it comes down to, was the license changes created because of a safety reason or was it done for the convenience of the utility? What we really need is a value tool -such as how many refueling hours (percentage of refueling time) was predicted/projected, and actual hours, that will to be saved by the amendments changes at Oyster Creek and the rest of the plants. You can do the estimation. As Ive mentioned in the past, the NRC and the industry has not justified with actual data and analysis that actual "unpreventable" events have distracted plant refueling, which leads to the need for the changes.

And that is a very dangerous issue. In that you are fearful of clearly explaining to the public about problems with safety system that ends up driving license amendment changes. You are organizing the facts to the utilities benefit and you think it is ethical that if the change gets legally through the license amendment process with a selective justification -this is your only responsibility to the public. Hey, it met the legal rules, even if we looked selectively at the problem towards a benefit to the utility.

Another set of questions that needs asking is about the 7 day surveillance testing of the refueling interlocks and components holding up the very valuable refueling time. Do we have any actual data and analysis about if really a critical path delay, such as a refueling holdup for interlock testing has any actual effect on lengthening outages? Just because refueling activities are delayed for a few hours for testing, there can be other things going on with the outage and refueling shutdown would not be delayed on the big picture. We further

question if the seven day clock runs out, could there have been ignored non refueling time where testing could have occurred. In other words, on day five, could they have had a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> hold-up time on refueling where surveillance testing could have been accomplished, and was not, and that creates the issues of the run out of the 7 day clock?

Is this really about "refueling mismanagement" that is driving the reduction of safety requirements? You put the acceptance of license amendments in only terms of risk calculation without any evaluation if the changes are being driven from utility negligence, mismanagement and cost savings pressures. Did I bring up yet about the Davis Besse containment sampling filters license amendment changes? You guys think that it OK if you just put it through an agency process - even if the outcome is illusional and distortive. Well, its OK because our selective risk calculation said there was an acceptable level of risk increase -even if the license changes was driven from utility negligence. "You got an insiders game going on here."

Again we are wondering about why the increasing intensity of refueling license changes nationwide in the last few years. What is driving this?

You have two years to prepare the refueling system for the upcoming outage -just why cant this "high value" system run for two or three weeks without the fear of breakdowns and the need to INOP systems? It really perplexes me that many of these plants can work for twenty years with their initial tech spec refueling characterization -so why are there changes now?

Thanks again, mike mulligan Hinsdale, NH

CC: <dlochbaum@ucsusa.org>

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Subject:

Oyster Creek refueling 2.206 additional questions ("Oyster Creek 2.206 refueling problems" dated 3/20/03)

Creation Date: 3/26/03 12:40PM From: "Mike Mulligan" <steamshovel@adelphia.net>

Created By: steamshovel@adelphia.net Recipients nrc.gov owf5_po.OWFN_DO MSL (Mindy Landau) ucsusa.org dlochbaum CC Post Office Route owf5_po.OWFN_DO nrc.gov ucsusa.org Files Size Date & Time MESSAGE 3771 03/26/03 12:40PM Part.001 7461 Mime.822 13269 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed

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