ML20141N780
| ML20141N780 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 03/12/1986 |
| From: | Bernero R Office of Nuclear Reactor Regulation |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8603180114 | |
| Download: ML20141N780 (35) | |
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MAR 121986 MEMORANDUM FOR: Darryl G. Eisenhut, Deputy Director Office of Nuclear Reactor Regulation i
FROM:
Robert M. Bernero, Director j
Division of BWR Licensing
SUBJECT:
PERRY 1 LICENSE Enclosed is the final Perry 1 low power operating license. This license updates the final draft sent to you by my note dated January 22, 1986 by:
(1) listing (in Attachment 1) the Region III post-licensing items; (2) reflecting the fire protection license condition identical to that contained in the SECY paper recom-mending to the Commission deletion of fire protection from Tech Specs; and (3) referencing CEI's letter dated February 19, 1986 in Attachment 3 which resolves additional human engineering discrepancies before fuel load.
4 All necessary concurrences within NRR were previously obtained with the final draft of the license, provided with my January 22nd note. We need no further concurrences but are providing the enclosed final license to all by copy of this memorandum for a last look. The signed Indemnity Agreement will be
.available just prior to licensing. The CEI Tech Spec certification letter was received on March 10, 1986 a copy of which is enclosed. We are awaiting the Region III statement on readiness of the plant for licensing, which should be provided by March 12, 1986.
J We are meeting with the ACRS this week to discuss the staff's findings on the Perry earthquake as documented in SSER #9 (released on March 5th), and expect to be ready to issue the enclosed license by about March 14, 1986.
l As indicated above, those receiving a copy of this memorandum are requested to inform the Project Manager (John Stefano; X29743) of any further required changes by noon, Wednesday, March 12, 1986.
o,igiasi signedMh g,,,n u.Som88**
Robert. Bernero, Directar Division of BWR Licensir.g
Enclosure:
As stated DISTRIBUTION N
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NRC PDR J. Scinto/J. Gray, ELD Local PDR J. Saltzman/I. Dinitz, SP PD#4 Reading W. Russell, DHST JStefano G. Lainas, AD/ DBL MRushbrook E. Jordan, IE J. Partlow, IE C. Norelius/R. arnick 1
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D;cument Name:
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}t PERRY LOW POWER LICENSE /2 Requestor's ID:
MARLENE Author's Name:
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(BWD-4) LTR EDELMAN -ISSU OF FAC OPER LICENSE NPF PERRY O
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UNITED STATES 8
NUCLEAR REGULATORY COMMISSION l;I l
E WASHINGTON, D. C. 20665 CLEVELAND ELECTRIC ILLUMINATING COMPANY DUQUESNE LIGHT COMPANY OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY' TOLEDO EDIS0N COMPANY DOCKET NO.
50-440 PERRY NUCLEAR POWER PLANT, UNIT NO. I i
FACILITY OPERATING LICENSE t
i License No. NPF-45 i
1.
The Nuclear Regulatory'Comission (the Comission) has found that:
i A.
The application for license filed by the Cleveland Electric.
Illuminating Company * (CEICO) acting on behalf of itself and as i
agent for the Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company and the Toledo Edison Company (licensees) complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's regulations set forth in 10 CFR Chapter I, and all required notifications to other
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agencies or bodies have been duly made; i
B.
Construction of the Perry Nuclear Power Plant, Unit No. 1 (the facility) has been substantially completed in conformity with Construction Pemit No. CPPR-148 and the application, as amended, i
the provisions of the Act, and the regulations of,the Comission; C.
Tae facility will operate in confomity with the application, as amended, the provisions of the Act, and the regulations of the Com-mission, (except as exempted from compliance in Section 2.D below);
l D.
There is reasonable assurance:
(1) that the activities authorized by this operating license can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Comission's regulations set forth in 10 CFR Cha Section 2.D. below)pter I (except as exempted from compliance in
' Cleveland Electric Illuminating Company is authorized to act as agent for Duouesne Light Company, Ohio Edison Company, Pennsylvania Power Company and the Toledo Edison Company, and has exclusive responsibility and control over the physical construction, operation and maintenance of the facility.
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r E.
The Cleveland Electric Illuminating Company is technically. qualified to engage in the activities authorized by this license in accordance with.the Comission's regulations set forth in 10 CFR Chapter I; F.
The licensees have satisfied the applicable provisions of 10 CFR Part 140 " Financial Protection Requirements-and Indemnity Agreements,"
a of the Commission's regulations; G.
The issuance of this license will not be inimical to the common defense and security or to the. health and safety of the public; H.
After weighing the environmental, economic, technical and other bene-fits of the facility against environmental and other costs and con-l sidering available alternatives, the issuance of this Facility Oper-ating License No. NPF-45, subject to the conditions for protection of l
l the environment set forth in the Environmental Protection Plan attached i
i as Appendix B, is in accordance with 10 CFR Part 51 of the Commission's l
regulations and all applicable requirements have been satisfied; and 1
I.
The receipt, possession, and use of source, byproduct and special nu-i clear material as authorized by this license will be in accordance with the Commission's regulations in 10 CFR Parts 30, 40 and 70.
2.
Based on the foregoing findings and the Partial Initial Decisions issued December 2,1983 and September 3,1985, by the Atomic Safety and Licensing Board regarding this facility, Facility Operating License No. NPF-45, is hereby issued to the Cleveland Electric Illuminating Company, Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company and Toledo t
I Edison Company (the licensees) to read as follows:
l A.
The license applies to the Perry Nuclear Power Plant, Unit No. 1, a boiling water nuclear reactor and associated equipment (the facility),
owned by the Cleveland Electric Illuminating Company, Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company and the Toledo Edison Company. The facility is located on the shore of Lake Erie in Lake County, Ohio, approximately 35 miles northeast of Cleve-land, Ohio and.is described in the licensees' Final Safety Analysis Report, as supplemented and amended, and in the licensees' Environ-mental Report, as supplemented and amended.
B.
Subject to the conditions and requirements incorporated herein, the Comission hereby licenses:
(1)
The Cleveland Electric Illuminating Company (CEICO) pursuant to Section 103 of the Act and 10 CFR Part 50, to possess, use and operate the facility at the designated location in Lake i
Caunty, Ohio, in accordance with the procedures and ifmitations 1
set forth in this license; j
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, (2)
Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company and Toledo Edison Company, to possess the facility at the designated location in Lake County, Ohio, in accordance with the procedures and limitations set forth in this license; (3)
CEICO, pursuant.to the Act and 10 CFR Part 70, to receive, possess and use at any time specia.1 nuclear material as reactor fuel, in accordance with the limitations for storage l
and amounts required for reactor operation, as described in the Tinal Safety Analysis Report, as supplemented and amended; (4)
CEICO, pursua'nt to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material such as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) CEICO, pursua,nt to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chem-ical or physical form, for sample analysis or instrument cali-bration or associated with radioactive apparatus or components; and (6) CEICO, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.
C.
This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Consnission now or hereafter in effect; and is sub,iect to the additional conditions specified or incorporated below:
(1) Paximum Power Level CEICO is authorized to cperate the facility at reactor core power levels not in excess of 3579 megawatts themal (100% power) in accordance with the conditions specified herein and in Attach-ment I to this license. The items identified in Attachment 1 to this license shall be completed as specified. Attachment 1 is hereby incorporated into this license. Pending Commission ap-proval, this license is restricted to power levels not to exceed 5 percent of full power (178 megawatts themal);
b.
F (2) _ Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A and the Environn. ental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this 5
license. CEICO shall operate the. facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Antitrust Conditions Cleveland Electric Illuminating Company, Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company end the Toledo
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Edison Company shall comply with the antitrust conditions delineated in Appendix C to this license; Appendix C is hereby incorperated into this license.
(4) Pcst-Fuel Loading Initial Test Program (Section 14, SSER #3)*
Any changes to the Initial Test Program described in Section 14 of the FSAR made in accordance with the provisions of 10.CFR 50.59 shall be reported in accordance with 50.59(b) within one month of such change.
(5)
Inservice Inspection Program (Section 6.6.3, SSER #7) blithin six (6) months after exceeding 5% of rated thermal power, CEICO shall submit the Initial Inservice Inspection Program required by 10 CFR 50.55(a) for the NRC staff's review and approval.
(6)
Fire Protection (Section 9.5, SER, SSER #1, 2, 3, 4, 7 and 8) i CEICO shall comply with the requirements of the fire protection program as specified in Attachment 2.
Attachment 2 is hereby incorporated into this license.
(7)
Detailed Control Room Desion Review (Section 18, SSER #7 and 8)
CEICO shall implement the activities remaining to complete the Detailed Control Room Design R: view and correct all human engineering discrepancies (HE3's) identified in Attachment 3. is hereby incorporated into this license.
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- The parenthetical notation following the title of many Itcense conditions denotes the section of the Safety Evaluation Report (SER) and/or its supple-ments wherein the license condition is discussed.
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(6)
Emergency Planning (Section 13.3. SSER #7) e (a) Prior to exceeding 5% of rated thermal power, CEICO shall obtain letters of agreement from all school districts for i
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the supply of buses for evacuation purposes.
i (b) Prior to exceeding 5% of rated thennal power, CEICO shall l
verify that the training of fire protection persor.nel in i
radiological monitoring and decontamir,ation procedures are completed and verify that the necessary decontamination equipment has been provided at the fire department facilities l
4 for each reception center.
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(c) le the event that the NRC finds that the lack cf progress
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in completion of the procedures in the Federal Emergency i
Management Agency's final rule (44 CFR Part 350) indicates that a major substantive problem exists in achieving or maintaining an adequate state of emergency preparedness, l
the provisions of 10 CFR 50.54(s)(2) will apply.
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(9)
TOI Diesel Generator Reliability (Section 9.6.3. SSER #6 & 8) 4 CEICO shall comply with the requirements identified in Attachment 4 i
relative to the Transamerica Delaval Inc., diesel engines.
t is hereby incorporated into this license.
(10) Hydrogen Control Preliminary Design (ASL8 M&O. September 3. 1985)
I i
i (a) Prior to exceeding 5% of rated thermal power, CEICO shall have made further confirmatery artalysis of equipment in the containment that has not been qualified for pressure I
survhability, or has narrow margin of pressure surviv-i ability. The equipment includes containnent vacuum breakers, hydrogen mixing compressor and discharge check i
valves.
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(b) Prior to exceeding 5% of rated thermal power, CEICO snall
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ensure that written procedures are available for operation l
of.the hydrogen igniter system.
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D.
CEICO is exempted from the Section III.D.2(b)(ii) containment airlock i
testing requirements of Appendix J to 10 CFR Part 50, due to the special circumstance described in Section 6.2.6 of SER Supplement No. 7 authortred by 10 CFR 50.12(a)(2)(iii). This exemption is authorized by law, will.not present an undue risk to the public health and safety and is consistent with the common defense and security. The i
exemption is hereby granted pursuant to 10 CFR 50.12. With the granting of this exemption, the facility will operate, to the extent J
authorized herein, in conformity with the application, as amended, the l
- provisions of the Act, at'i the rules and regulations of the Connission.
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E.
CE!CO shall fully implement and maintain in effect all provisions of the Comission-approved physical security, guard training and qualif-ir:ation, and safeguards contingency plans, including all amendments and revisions made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Infomation pro-l tected under 10 CFR 73.21, are entitled:.. " Perry Nuclear P r Plant r
Security Plan," with revisions submitted through November.
1985;
" Perry Nuclear Power Plant Security Force Training and Qualification t
Plan," with revisions submitted through September 27, 1985; and " Perry Nuclear Power Plant Safeguards Contingency Plan" (Chapter 8 of the i
Security Plan), with revisions submitted through October P2,1985.
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F.
Except as otherwise provided in the Technical Specificatiohs or Envi-ronmental Protection Plan, CEIC0'shall report any violations of the requirements contained in Section 2.C of this license in the following i
manner: initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC t
Operations Center via the Emergency Notification System with written followup within thirty (30) days in accordance with the proce6res described in 10 CFR 50.73(b), (c) and (e).
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G.
The licensees shall have and maintain financial protection cf such type and in such amounts as the Comission shall require in acenrdance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover i
public liability claims.
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H.
This license is effective as of the date of issuance and shall expire j
at midnight on
, 2026.
FOR THE NUCLEAR REGULATORY C0pmISSION
[
i Harold R. Denton, Director Office of Nuclear Reactor Regulation Attachments / Appendices:
l
- 1. - 4 2.
Appendix A - Technical Specifications (NUREG-1162) 3.
Appendix 8 - Environmental Protection Plan 4.
Appendix C - Antitrust Conditfons t
l Date of Issuance:
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. E.
CE?C0 shall fully implement and maintain in effect all provisions of the Corrnission-approved physical security, guard training 'mendmentsand qualif-ication, and safegua'ds contingency plans, including all a r
and revisions made pursuant to the authority of 10 CFR 50.90 and 10 CFR50.54(p). The plans, which contain Safeguards Inforra. tion pro-tected under 10 CFR 73.21, are entitled: " Perry Nuclear Power Plant Security Plan," with revisions submitted through November 25, 1985;
" Perry Nuclear Power Plant Security Force Training and Qualification Plan," with revisions submitted through September 27, 1985; and " Perry NuclePr Power Plant Safeguards Contingency Plan" (Chapter 8 of the Security Plan), with revisions submitted through October 22. 1985.
F.
Except as otherwise provided in the Technical Specifications or Envi-rormental Protection Plan, CEICO shall report any violations of the requirements contained in Section 2.C of this license in the following manner:
initial notification shall be made within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the NRC Operations Center via the Emergency Notification System with written followup within thirty (30) days in accordance with the procedures described in 10 CFR 50.73(b), (c) and (e).
6.
The licensees shali have and maintain financial protection of such type end in such amounts as the Corrnisdon shall reoutre in accordance with Section 170 of the Atomic Energy Act of 1954, as amended, to cover public liability claims.
H.
This license is effective as of the date of issuance and shall expire at midnight on
, 2026.
FOR THE NUCLEAR REGULATORY COPFISSION Harold R. Denton, Director Office of Nuclear Reactor Regulation Attachments /Apperdices:
- 1. - 4
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App (endix A - Technical Specifications iiUREG-1162) 3.
Appendix B - Environmental Protection Plan 4.
Appendix C - Antitrust Conditions Date of Issuance:
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JScinto WRButler RHouston RBernero DEisenhut HDenton
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k ATTACHMENT 1 t
This attachment identifies specific items which must be completed to the Commission's satisfaction in accordance with the operational models'as identified below.
l A.
The preoperationa' tests and testing exceptions identified in the attachment to the February 27, 1986 letter from Mr. Edelman to James G. Keppler ihall be completed in accordance with the schtduled commitments contained in that attachment.
B.
The following open or unresolved items must be resolved prior to entering the mode indicated:
1.
CEI shall complete installation of all raceway separation barriers required to meet IEEE 384-1974 independence requirements (Inspection Report 50-440/85-018 Item 01). Complete prior to initial criticality.
2.
CEI shall complete evaluation of audibility problems encountered on evacuation of personnel from high noise areas.
IE Bulletin 79018 j
(Inspection Tracking No. 50-440/79018-BB), Complete prior to initial criticality.
3.
CEI shall obtain, install, and test IEEE Class IE qualified isolation l
transformers in the power supply for Division 3 APRM circuits.
Complete prior to exceeding 5% power.
l 4.
CEI shall complete a verification of System Operation Instructions (SQI) in accordance with the schedule set forth in a letter from Edelman to Keppler dated March 4,1986.
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ATTACHMENT 2 TO NPF-45 FIRE PROTECTION PROGRAM REQUIREMENTS CEICO shall comply with the following requirements of the fire protection program:
1.
CEICO shall implement and maintain in effect' all provisions of the '
approved fire protection program as described in the Final Safety Analysis Report as amended, for the Perry Nuclear Power Plant and as approved in the Safety Evaluation Report (NUREG-0887) dated May 1982 and Supplement Nos. I thru 8 thereto, subject to the following prevision':
a.
CEICO may not make changes to the approved fire protection program which would adversely affect the ability to achieve
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and maintain safe shutdown in the event of a fire withnut prior approval of the NRC.
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ATTACHMENT 3 TO NPF-45 DETAILED CONTROL ROOM DESIGN REVIEW CEICO shall comply with the following requirements related to the Detailed Control Room Design Review (DCRDR):
1.
Prior to exceeding five percent of thermal rated power, the licensee shall implement corrections to human engineering discrepancies per commitments in the October 14, 1985 letter from M. R. Edelman (CEICO) to B. J. Youngblood (NRC) and February 19, 1986 letter from Mr. R. Edelman (CEICO) to W. R. Butler (NRC) and shall, per comitment in an October 2, 1985 letter from M. R. Edelman to B. J. Youngblood (NRC), provide for NRC review:
a.
Results of a human factors survey of communications equipment in the control room and at the remote shutdown facilities b.
Results of the interim sound surveys in the control room and at the remote. shutdown facilities c.
Results of the augmented process for verifying that selected improvements provide the necessary correction and do not introduce new human engineering discrepancies d.
Commitments and implementation schedules for correction of human engineering discrepancies identified in the above results or justifications for decisions not to correct or to partially correct them.
2.
Prior to startup following the fir:t refueling outage, the licensee shall implement corrections to human engineering discrepancies per comitments in the January 10, 1985 Detailed Control Room Design Review Sumary Report, in the October 2,1985 letter from M. R.
Edelman (CEICO) to B. J. Youngblood (NRC), and in'the October 14, 1985 Supplement to the Detailed Control Room Design Review Sumary Report and shall provide for NRC review results of the final sound surveys in the control room and at the remote shutdown facilities.
Additionally, CEICO shall complete the validation of the Perry Nuclear Power Plant Emergency Instructions, and issue a sumary report, prior to achieving initial criticality.
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ATTACHMENT 4 TO NPF-45 TRANSAMERICA DELAVEL, INC. (TDI) DIESEL ENGINE REQUIREMENTS CEICO shall comply with the following requirements related to the TDI diesel engines:
1.
Changes to the maintenance and surveillance program for the TDI diesel engines, as identified and approved by the NRC staff in the supplemental safety evaluation report in the letter dated November 5, 1985, shall be subject to the provisions of 10 CFR 50.59.
2.
Crankshafts shall be inspected as follows:
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The oil holes and fillets of the three main bearing journals subject to the highest torsional stresses (Nos. 4, 6, 8) shall be examined with fluorescent liquid penetrant and, as necessary, eddy current, during each 5 year maji ' disassembly. The same inspections on oil holes and fillets shall be performed on at least three crankpin journals between journals 3 and 8.
3.
Cylinder blocks shall be insoected at intervals calculated using the cumulative damage index (CDI)...odel and using inspection methodol-ogies described by Failure Analysis Associates Inc., (FaAA) in the report entitled " Design Review of TDI R-4 Series Emergency Diesel Generator Cylinder Blocks" (FaAA-84-9-11) dated December 1984.
J Liquid penetrant inspection of the cylinder liner landing area shall be performed anytime liners are removed.
4.
The engines shall be rolled over with the airstart system and the cylinder stopcocks open prior to any planned starts, unless that start occurs within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of a shutdown. The engines shall also be rolled over with the airstart system and the cylinder stopcocks open after 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, but no more than 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> after. engine shutdown and then rolled over once again approximately 24 h'ours after each shutdown.
In the event an engine is removed from service for any reason other than the rolling over procedure prior tc expiration of the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> periods noted above, that engine need not be rolled over while it is out of service. The licensee rinll air roll the engine over with the stopcocks open at the time it is returned to service. The origin of any water detected in the cylinders must be determined and any cylinder head which leaks due to a crack shall be replaced. No cylinder heads that contain a through-wall weld repair where the repair was perfonned from one side only shall be used on the engines.
5.
If inspection of either TDI engine reveals cracks in the crankshaft or in the cylinder block between stud holes of adjacent cylinders, this condition shall be reported promptly to the NRC staff and the affected engine (s) shall be considered inoperable. The engines shall not be res6ored to " operable" status until the proposed disposition and/or corrective actions have been approved by the NRC staff.
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6.
Operation beyond the first refueling cutage shall require staff l
approval based on the staff's final review of the Owners Group generic findings and of the overall implementation status of Owners Group recomendations at Perry.
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Technical Specifications Perry Nuclear Power Plant, Unit No.1 Docket No. 50-440 Appendix "A" to License No. NPF-45 I
lasued by the
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U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation I
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to APPENDIX B l
TO FACILITY OPERATING LICENSE NO..'NPF-45 PERRY NUCLEAR POWER PLANT UNITS 1 AND 2 CLEVELAND ELECTRIC ILLUMINATING COMPANY DOCKET NOS. 50-440 AND 50-441 ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL) t i
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PERRY NUCLEAR POWER PLANT UNITS 1 AND 2 ENVIRONMENTAL PROTECTION PLAN (NONRADIOLOGICAL)
TABLE OF CONTENTS 5
Section Page 1.0 Objectives of the En'vironmental Protection Plan.............
1-1 2.0 Environmental Protection Issues.............................
2-1 2.1 Aquatic Issues..............................................
2-1 2.2 Terrestrial Issues..........................................
2-1
~3.0 Consistency Requirements....................................
3-1 3.1 Plant Design and Operation..................................
3-1 3.2 Reporting Related to the NPDES Permit arid State Ce r ti fi ca t i o n s............................................
3-2 3.3 Changes Required for Compliance with Other Environmental Regulations...............................................
3-3 4.0 Environmental Conditions....................................
4-1 4.1 Unusual or Important Environmental Events...................-
4-1 4.2 Environmental Monitoring....................................
4-1 5.0 Administrative Procedures...................................
5-1 5.1 Review and Audit............................................
5-1 5.2 Records Retention...........................................
5-1 5.3 Changes in Environmental Protection P1an....................
5-2 5.4 Plant Reporting Requirements................................
5-2 m.
1.0 Objectives of the Environmental Protection Plan The Environmental Protection Plan (EPP) is to provide for protection of nonradiological environmental values during operation of the nuclear facility. The principal objectives of the EPP are as follows:
(1) Verify that the facility is operated in an env'ronmentally acceptable '
i manner, as established by the Final Environmental Statement - Operating Licensing Stage (FES-OL) and other NRC environmental impact assessments.
(2) Coordinate NRC requirements and maintain consistency with other Federal, State and local requirenents for environmental protection.
_(3) Keep NRC informed of the environmental effects of facility construction and operation and of actions taken to control those effects.
Environmental concerns identified in the FES-OL which relate to water quality matters are regulated by way of the licensee's NPDES permit.
i 1-1
2.0 Environmental Protection Issues In the FES-OL dated August 1982, the staff considered the enviro'nmental impacts associated with the operation of the two unit Perry Nuclear Power Plant.
Certain environmental issues were identified which required study or license conditions to resolve environmental concerns and to assure adequate protection of the environment.
2.1 Aquatic Issues (1) No specific nonradiological aquatic impact issues were identified by NRC staff in the FES-OL.-
(2) The presence of Asiatic clams (Corbicula sp) in western Lake Erie renders their eventual presence near Perry as likely. Should the presence of Corbicula in the vicinity of Perry threaten the operation of a safety system, due to biofouling, measures to control Corbicula will be undertaken (FES Section 4.3.6.2).
Section 9.2.1 of the SER (May 1982) recognizes the potential safety-related problem of biofouling by Corbicula, and cites the licensee's monitoring program that consists of: (a) sampling of the lake for the presence of Corbicula, both at Perry and at one of the licensee's nearby fossil-fueled power plants; (b) maintenance inspections; and (c) sur-veillance testing. This EPP addresses the lake sampling in (a) above.
2.2 Terrestrial Issues (1) Cooling tower drift was not expected to cause adverse effects but the need for operational data to confirm this conclusion was identified by the staff.
(FESSection5.5.1.5)
(2) Herbicide use should conform with current Federal and state regulation.
(FESSection5.5.1.4) i 2-1 m.
3.0 Consistency Requirements 3.1 Plant Design and Operation The licensee may make changes in station design or operation or perform tests or experiments affecting the environment provided such activities
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do not involve an unreviewed environmental question and do not involve a change in the EPP*.
Changes in station design.or operation or performance of tests or experiments which do not affect the environment are not subject to the requirements of this EPP. Activities governed by Section 3.3 are not subject to the requirements of this Section.
Before engaging in additional construction or operational activities which may significantly affect the environment, the licensee shall prepare and record an environmental evaluation of such activity. Activities are
. excluded from this requirement if all measurable nonradiological environ-mental effects are confined to the on-site areas previously disturbed during site preparation and plant construction. When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provid.e a written evaluation of such activity and obtain prior NRC approval. When such activity involves a change in the EPP, such activity and change to the EPP may be implemented only in accordance with an appropriate license amendment as set forth in Section 5.3 of this EPP.
A proposed change, test or experiment shall be deemed to involve an unreviewed environmental question if it concerns:
(1) a matter which may result in a significant increase in any adverse environmental impact previously evaluated in the FES-OL, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant change in effluents or power level; or (3) a matter, not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which may have a significant adverse environmental impact.
The licensee shall maintain records of changes in facility design or operation and of tests and experiments carried out pursuant to this Sub-section. These records shall include written evaluations which provide bases for the determination that the change, test, or experiment does not involve an unreviewed environmental question or constitute a decrease in the effectiveness of this EPP to meet the objectives specified in Section 1.0.
The licensee shall include as part of the Annual Environmental Operating Report (per Subsection 5.4.1) brief descriptions, analyses, interpretations, and evaluations of such changes, tests and experiments.
This provision does not relieve the licensee of the requirements of 10 CFR 50.59.
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3.2 Reporting Related to the NPDES Permit and State Certification Changes to, or renewals of, the NPDES Permits or the State certification shall be reported to the NRC within 30 days following the date the change or renewal is approved.
If a permit or certification, in part or in its entirety, is appealed and stayed, the NRC shall be notified within 30 days,
following the date the stay is granted.
The licensee shall notify the NRC of changes to the effective NPDES Permit proposed by the licensee by providing NRC with a copy of the proposed change at the same time it is submitted to the permitting agency. The licensee shall provide the NRC a copy'of the application for renewal of the NPDES Pemit at the same time the application is submitted to the pemitting agency.
-3.3 Changes Required for Compliance with Other Environmental Regulations Changes in plant design or operation and performance of tests or experiments which are required to achieve compliance with other Federal, State, and local environmental regulations are not subject to the requirements of Section 3.1.
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4.0 Environmental Conditions i
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4.1 Unusual or Important Environmental Events l
Any occurrence of an unusual or important event that indicates rir could f
result in significant environmental impact causally-related to plant 1
j operation shall be recorded and reported to the NRC within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> followed by a written report per Subsection 5.4.2.
The following are j
examples: excessive bird impaction events, onsite plant or animal disease outbreaks, mortality or unusual occurrence of any species protected by the l
Endangered Species Act of. 1973, fish kills, increase in nuisance organisms a
or conditions, and unanticipated or emergency discharge of waste water or chemical substances.
.No routine monitoring programs are required to implement this condition.
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4.2 Environmental Monitoring i
j 4.2.1 Aquatic Monitor,ing (1) The certifications and pemits required under the Clean Water Act pro-vide mechanisms for protecting water quality and, indirectly, aquatic i
biota. The NRC will rely on the decisions made by the U.S. Environmental Protection Agency and the State of Ohio under the authority of the Clean Water Act for any requirements for aquatic monitoring.
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(2) Semi-annual (late spring and early fall) st9pling of areas adjacent to l
1 the Perry intake and discharge structures and the licensee's Eastlake i
plant intake and discharge shall be conducted to detect the presence of Corbicula.
Thesamplingmethodologyshallbethatcommittedtoanddescriydby the licensee in his December 3,1982 affidavit of R.S. Nugent A,
I that was reviewed and found to be acce> table by the ASLB in its Memo-randu.n and Order of December 22, 1982 16 NRC 1909'(1982)].
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M Affidavit of Dr. Richard S. Nugent in Support of NRC Staff's Motion for f
Susuary Disposition of Issue No. 7, In the Matter of The Cleveland i
Electric Illuminating Company, et. al. Perry Nuclear Power Plant Units 1 i
and 2.
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o 4.2.2 Terrestrial Monitoring 4.2.2.1 Aerial Remote Sensing Vegetative communities of the site and vicinity within 1 kilometer of the cooling towers in all directions shall be aerially photographed to detect and assess the significance of damage, or lack ;thereof, as related to cool,
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ing tower drift dispersions. Photography shal1 be done by aerial overflight during August or September. Monitoring shall include a program of low alti-tude color infrared photography. The scale for full coverage shall be adequate to enable identification of vegetative damage over relatively st all l
areas of terrain. Some circumstances may warrant inspection of photographs t
I discerning individual trees. Such scale should be adequate to resolve l
impacted features. Photographs shall be compared with baseline to ascertain changes in vegetation. Photographic interpretations shall be verified by l
ground inspection surveys to confirm areas of stress and non-stress. This program shall require aerial photographic monitoring during the first August-September period after the station has been in operation for one l
year and the program shall be repeated once the following year
! alter-nate years for three (3) additional periods. A report shall be submitted as part of the annual report following each serial photographic monitoring period. The report shall contain a description of the program, results, and interpretative analyses of environmental impacts. Results reported shall contain information encompassing but not limited to the following-sampling date; time of day; film types; and one (1) set of resultant color j
transparencies encompassing an area within approximately a one kilometer j
(1 km) radius of the Unit
- and 2 towers.
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4.2.2.2 Herbicide Use If herbicides are used, their use shall conform to the U.S. EPA regul.ztions printed on the labels. Records of which herbicide was used, date of appli-J cation, where herbicide was applied and quantity applied shall be made
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available for a five year period for inspection by NRC.
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5.0 Administrative Procedures 5.1 Review and Audit The licensee shall previde for review and audit of compliance with the EPP.
The audits shall be conducted independently of the individual or groups responsible for performing the specific activity. A description of the organization structure utilized to achieve the' independent review and audit function and results of the audit activities shall be maintained and made available for inspection.
5.2 Records Retention Records and logs relative to the environmental aspects of station operation shall be made and retained in a manner convenient for review and inspection.
'These records and logs shall be made available to NRC on request.
Records of modifications to station structures, systems and components determined to potentially affect the continued protection of the environ-ment shall be retained for the life of the station. All other records, data and logs relating to this EPP shall be retained for five years or, where applicable, in accordance with the requirements of other agencies.
l 5.3 Changes in Environmental Protection Plan Requests for changes in the EPP shall include an assessment of the environmental impact of the proposed change and a supporting justification, i
Implementation of such changes in the EPP shall not commence prior to NRC approval of the proposed changes in the form of a Ifcense amendment incorporating the appropriate revision to the EPP.
5.4 Plant Reporting Requirements 5.4.1 Routine Reports An Annual Environmental Operating Report describing implementation of this EPP for the previous year shall be submitted to the NRC prior to May 1 of each year. The initial report shall be submitted prior to May I of the year following issuance of the operating license, i
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i The report shall include summaries and analyses of the results of the environmental protection sctivities required by Subsection 4.2 of this EPP 4
studies, operational controls (g a comparison with related preoperationalas approprif for the report period, includin i
environmental ronitoring reports, and an assessment of the observed impacts 4
i of the plant operation on the environment.
If harmful effects or evidence,
of trends toward irreversible damage to the environment are observed, the licensee shall provide a detailed analysis of the data and a proposed course of mitigating action.
f The Annual Environmental 0perating Report shall also include:
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(1) A list of EPP noncompliances and the corrective actions taken to remedy them.
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-(2) A list of all changes in station design or operation, tests, and i
experiments made in accordance with Subsection 3.1 which involved a potentially significant unreviewed environmental question, i
(3) A list of nonroutine reports submitted in accordance with Subsection i
5.4.2.
i In the event that some results are not available by the report due date, the report shall be submitted noting and explaining the missing results. The missing results shall be submitted as soon as possible in a supplementary report.
i 5.4.2 Nonroutine Reports i
I A written report shall be submitted to the NRC within 30 days of occurrence i
I of a nonroutine event. The report shall (a) describe, analyze, and evaluate l
j the event, including extent and magnitude of the impact, and plant operating characteristics, (b) describe the probable cause of the event, (c) indicate i
the action taken to correct the reported event, (d) indicate the corrective
.i action taken to preclude repetition of the event and to prevent similar i
occurrences involving similar components or syster, and (e) indicate the l
agencies notified and their preliminary responses, t
Events reportable under this subsection which also require reports to other i
i Federal, State or local agencies shall be reported in accordance with those reporting requirements in lieu of the requirements of this subsection. The NRC shall be provided with a copy of such report at the same time it is submitted to the other agency, i
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APPENDIX C PERRY NUCLEAR POWER PLANT, UNIT 1 ANTITRUST CONDITIONS FOR CLEVELAND ELECTRIC ILLUMINATING COMPANY DUQUESNE LIGHT COMPANY ~
L OHIO EDISON COMPANY PENNSYLVANIA POWER COMPANY TOLEDO EDISON COMPANY A. The licensees are subject to the following antitrust conditions:
Definitions Applicants shall mean the five companies listed above.
Entity shall mean any electric generation and/or distribution system or municipality or cooperative with a statutory right or privilege to engage in either of these functions.
Wheeling shall mean transportation of electricity by a utility over its lines for another utility, including the receipt from and delivery to another system of like amounts but not necessarily the same energy.
Federal Power Commission, The 1970 National Power Survey, Part 1,
- p. 1-24-8.
Licensing Conditions (1) Applicants shall not condition the sale or exchangeiof wholesale power or coordination services upon the condition that any other entity:
(a) enter into any agreement or understanding restricting the use of Ja alienation of such energy or services to any customers or territories; (b) enter into any agreement or understanding requiring the receiving entity to give up any other power supply alternatives or to deny itself any market opportunities;
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2-(c) withdraw any petition to intervene or forego participation in any proceeding before the Nuclear Regulatory Commissinn or refrain from instigating or prosecuting any antitrust action in any other forum.
(2) Applicants, and each of them, shall offer interconnections upon reasonable tems and conditions at the request of any,other electric entitvfies) in the Combined CAPC0 Company Territories (CCCT), such interconnection to be available (with due regard for any necessary and applicable safety procedures) for operation in a closed-switch synchronous operating mode if requested by the interconnecting entity (fes). Ownership of trans-mission lines and switching stations associated with such interconnection shall remain in the hands of the party funding the interconnection subject, however, to any necessary safety procedures relating to disconnection facilities at the point of power delivery. Such limitations on ownership shall be the least necessary to achieve reasonable safety practices and shall not serve to deprive purchasing entities of a means to effect additional power supply options.
(3) Applicants shall enga'ge in wheeling for and at the request of other entities in the CCCT:
(a) of electric t.nergy from delivery points of Applicants to the entity (fes); and, (b) of power generated by or available to the other entity, as l
a result of its ownership or entitlements* in generating facilities, to delivery points of Applicants designated by the other entity.
Such wheeling services shall be available with respect to any unused capacity on the transmission lines of Ap)1icants, the use of which will not jeopardize Applicants' system.
In tie event Applicants must reduce r
wheeling services to other entities due to lack of capacity, such reduction shall not be effected until reductions of at least 5 percent have been made in transmission capacity allocations to other Applicants in these proceedings and thereafter shall be made in proportion to reductions ** imposed upon other Applicants to this proceeding.
" Entitlement" includes but is not limited to power made available to an entity pursuant to an exchange agreement.
The objective of this requirement is to prevent the pre-emption of unused capacity on the lines of one Applicant by other Applicants or by entities the transmitting Applicant deems noncompetitive. Competitive entities are to be allowed opportunity to develop bulk power services options even if this results in re-allocation of CAPC0 (Central Area Power Coordination Group) transmission channels. This relief is required in order to avoid prolongation of the effects of Applicants' illegally sustained dominance.
Applicants shall make reasonable provisions for disclosed transmission requirements of other entities in the CCCT in plar.ning futur'e trans-mission either individually or within the CAPC0 grouping. By " disclosed" is meant the giving of reasonable advance notification of future require-ments by entities utilizing wheeling services to be made ava'ilable by Applicants.
f (4)
(a) Applicants shall make available membership in CAPC0 to any entity in the CCCT with a system capability of 10 Mw or greater, j
i (b) A group t f entities with an aggregate system capability of f
10 Mw or greater may obtain a single membership in CAPC0 on a collective basis;*
(c) Entities applying for membership in CAPC0 pursuant to License f
Condition 4 shall become members subject to the terms and con-i ditions of the CAPC0 Memorandum of Understanding of September 14, 1967, and its implementing agreements; except that new members may elect to participate on an equal percentage of reserve basis rather than a P/N allocation formula for a period of twelve years from date of entrance.** Following the twelfth year of entrance, new members shall be expected to adhere to such allocation methods as are then employed by.CAPCO (subject to equal opportunity for waiver or special consideration granted to original CAPC0 members which then are in effect).
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- E.g.,WholesaleCustomerofOhioEdison(WC0E).
The selection of the 12-year period reflects our determination that an adjustment period is necessary since the P/N formula has a recognized effect of discriminating against small systems and forcing them to forego economies of scale in generation in order to avoid carrying excessive levels of reserves.
We also found that P/N is not entirely irrational as a method of reserve allocation. We have observed that Applicants themselves provided adjustment periods and waivers to integrate certain Applicants into the CAPC0 reserve requirement program. The 12-year period should permit new entrants to avoid initial discrimination but to acconnodate and adjust to the CAPC0 system over some reasonable period of time. Presumably new entrants will be acquiring ownership shares and entitlements during the 12-year period so that adverse consequences of applying the P/N formula will be mitigated.
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f (d) New members joining CAPCO pursuant to this provision of' relief j
shall not be entitled to exercise voting rights until such time as the system capability of the joining member equals or exceeds
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the system capability of the smallest member of CAPC0 which enjoys i
voting rights.*
l (5) Applicants shall sell maintenance power to. requesting entities in the l
4 CCCT upon terms and conditions no less favorable than those Applicants make available:
(a) to each other either pursuant to the CAPC0 agree-ments or pursuant to bilateral contract; or (b) to non-Applicant entities l
outside the CCCT.
l (6) Applicants shall sell emergency power to requesting entities in the CCCT
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i upon tems and conditions no less favorable than those Applicants make available:
(a) to each other either pursuant to the CAPC0 agreements or
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pursuant to bilateral contract; or (b) to non-Applicant entities outside l
j the CCCT.
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(7) Applicants shall sell' economy energy to requesting entities in the CCCT, j
when available, on terms and conditions no less favorable than those I
available:
(a) to each other either pursuant to the CAPC0 agreements
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or pursuant to bilateral contract; or (b) to non-Applicant entities f
outside the CCCT.
l (8) Applicants shall share reserves with any interconnected generation entity i
in the CCCT upon request. The requesting entity shall have the option i
of sharing reserves on an equal percentage basis or by use of the i
CAPCO.P/N allocation formula or on any other mutually agreeable basis.
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(9) (a) Applicants shall make available to entities in the CCCT access to j
the Davis-Besse 1. 2 and 3 and the Perry 1 and 2 nuclear units and l
any other nuclear units for which Applicants or any of them, shall
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- Our objective is to prevent impediments to the operation and development of t
an area-wide power pool through the inability of lesser entities to respond j
timely or to make necessary planning comitments. While we grant new member entities the opportunity to participate in CAPC0 it is not our intent to relieve joining ent1ttes of responsibilities and obligations necessary to the successful operation of the pool. For those smal'er entities which do I
not wish to assume the broad range of obligations associated with CAPC0 membership we have provided for access to bulk power service options which will further their ability to survive and offer competition in the CCCT.
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, next 25 years. Such access, at the option of the requesting entity, shall be on an ownership share, or unit participation or contractual pre-purchase of power basis.* Each requesting entity (or collective group of entities) may obtain up to 10%
of the capacity of the Davis-Besse and Perry Units and 20% of future units (subject to the 25-year limitation) except that once any entity or entities have contracted for allocations totaling 10% or 20%, respectively, no further participation in any given units need be offered.
(b) Commitments for'the' Davis-Besse and Perry Units must be made by requesting entities within two years after this decision becomes final. Comitments for future units must be made within two years after a construction permit application is filed with respect to such a unit (subject to the 25-year ifmitation) or within two years after the receipt by a requesting' entity of detailed written notico of Appli-cants' plans to construct the unit, whichever is earlier; provided, however, that the time for making the commitment shall not emire until at least three months after the filing of the application for a construction permit. Where an Applicant seeks to operate a nuclear plant with respect to which it did not have an interest at the time of filing the application for the construction permit, the time periods for com.itments shall be the same except that reference should be to the operating license, not the construction i
permit.
(10) Applicants shall sell wholesale power to any requesting entity in the CCCT, in amounts needed to meet all or part of such entity's requirements. The choice as to whether the agreement should cover all or part of the entity's requirements should be made by the entity, not the Applicant or Applicants.
- Requesting entities' election as to the type of access may be affected by provisions of State law relating to dual ownership of generation facil-r ities by municipalities and investor-owned utilities.
Such laws may change during the period of applicability of these conditions. Accordingly, we allow requesting entities to be guided by relevant legal and financial considerations (including Comission regulations on nuclear power plant ownership) in fashioning their requests.
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,t (11) These conditions are intended as minimum conditions and do not preclude Applicants from offering additional wholesale power or coordination services to entities within or without the CCCT. However Applicants shall not deny wholesale power or coordination services required by these conditions to non-Applicant entities in the CCCT based'upon prior commitments arrived at in the CAPC0 Memorandum of Understanding or implementing agreements. Such denial shall be regarded as incon-sistent with the purpose and intent of these conditions.
The above conditions are to be implemented in a manner consistent with the provisions of the Federal Power Act and all rates, charges or prac-tices in connection therewith are to be subject to the approval of I
regulatory agencies having jurisdiction over them.
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O 7590-01 CLEVELAND ELECTRIC ILLUMINATING COMPANY DUQllESNE LIGHT COMPANY OHIO EDISON COMPANY.
PENNSYLVANIA POWER COMPANY TOLEDO EDISON COMPANY DOCKET NO.
50-440 PERRY NUCLEAR POWER PLANT, UNIT NO. I NOTICE OF ISSUANCE OF FACILITY OPERATINr. LICENSE Notice is hereby given that the U. S. Nuclear Regulatory Comission (the Comission or NRC), has issued Facility Operating License No. NPF-45 to the Cleveland Electric Illuminating Company, Duquesne Light Company, Ohio Edison Company, Pennsylvania Power Company and the Toledo Edison Company (licensees) which authorizes operation of the Perry Nuclear Power Plant, Unit 1 (the facility), at reactor core power levels not in excess of 3579 megawatts therr.a1 in accordance with the provisions of the License, the Technical Specifications and the Environmental Protection Plan with a condition limiting operation to five percent of full power (178 megawatts thermal). Authorization to operate beyond five percent of full power will require specific Comission approval.
Perry Unit 1 is a boiling water reactor located near Lake Erie in Lake County, Ohio, approximately 35 miles northeast of Cleveland, Ohio, i
The license is effective as of the date of issuance. The application for the license complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Comission's regulations. The
a 7590-01.
Comission has made appropriate findings as required by the Act and the Comission's regulations in 10 CFR Chapter I which are set forth in the License. Prior public notice of the overall act.iori involving the proposed issuance of an operating ifcense was published in the Federal Register on February 13, 1981 (46 FR 12372).
The Comission has determined that the issuance of this License will not result in any environmental impacts other than those evaluated in the Final Environmental Statement since the activity authorized by the license is en-compassed by the overall action evaluated in the Final Environmental Statement.
For further details with respect to this action, see (1) Facility Operating LicenseNo.NPF-45,withTechnicalSpecifications(NUREG-1162)andtheEnviron-mental Protection Plan; (2) the report of the Advisory Comittee on Reactor Safeguards, dated July 13,1982;(3) the Comission's Safety Evaluation Report, datedMay1982(NUREG-0887),andSupplements1through8;(4)theFinal SafetyAnalysisReportandAmendmentsthereto;(5)theEnvironmentalReport and supplements thereto; and (6) the Final Environmental Statement, dated August 1982(NUREG-0884).
These items are available for inspection at the Comission's Public Docu-ment Room located at 1717 H Street, N. W., Washington, D. C. 20555, and at the Perry Pubite Library, 3753 Main Street, Perry, Ohio 44081. A copy of Facility Operatir.g License NPF-45 may be obtained upon request addressed to the U. S.
Nuclear Regulatory Comission, Washington, D. C. 20555, Attention: Director, l
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7590-01.
Division of BWR Licensing.
Copies of the Safety Evaluation Report,and Supplements 1 through 8 (NUREG-0687) and the Final Environmental Statement (NUREG-0884)
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may be purchased at current rates from the Scperintendent of Documents, U. S.
Government Printing Office, Post Office bcs. 37082, Washington, D. C.
20012-7982 or by calling (202) 275-2060 or (202) 275-2171.
Dated at Bethesda, Maryland this day of FOR THE NUCLEAR REGULATORY COMPISSION.
Walter R. Butler Director Project Directorate No. 4 Division of BWR Licensing i
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7590-01.
Division of BWR Licensfrg. Copies of the Safety Evaluation Report and Supplements 1 through 8 (NUREG-0887) and the Final Environmental Statement (NUREG-0884) may be perchased at current rates from the Super-intendent of Documents, U. S.
Ga/erment Printing Office, Post Of fice Box 37082. Washington, D. C.
20012-7982 or by calling (202) 275-2060 or (202) 275-2171.
Dated at Gethesda, Maryland this day of FOR THE NUCLEAR PEGULATORY COMMISSIOf!.
Walter R. Butler, Director Project Directorate No. 4 Divisfor of BWR Licensing l
PD&2 PDf4 OELD PDf4 MRushbrock:kab JStefano WPButler
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THE CLEVELAND ELECTRIC ILLUMIN ATING COMP ANY P.o. Box $000 - CLEVELAND. oHlo 44101 TELEPHONE (216) 622 0800 - tLLUwiNATING 8 log - 55 PUBLIC SoutRE Semng The Best I.ocation in the Nation MURRAY R. EDELMAN D
VICE MESIDENT March 10,1986 sucuAA PY-CEI/NRR-0427 L
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Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D. C.
20555 Perry Nuclear Power Plant
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Docket Nas. 50-440; Technical Specification Certification
Dear Mr. Denton:
In your letter dated November 19, 1935, transmitting the Final Draft Perry Unit 1 Technical Specifications. you requested that CE1 certify that the document is consistent with the Final Safety Analysis Report (FSAR), the NRC Safety Evaluation Report (SER) and the as-built facility as a prerequisite for issuance of an operating license. CEI had long been aware this would be required, and had begun implementing programs to ensure that the resources and processes used would provide a detailed and comprehensive basis for certification. These programs are described in Attachment 1.
Further technical specification changes were identified in your letters dated November 29, 1985, December 30, 1985, and March 7, 1986. We have continued to work with the NRC staff during the latest review cycle to address their concerns and assure the latest as-built information was included in these technical specification changes. Examples of such changes resulting from the NRC technical staff review are the addition of neutron flux and containment isolation valve position indication instrumentation to the Accident Monitoring Instrumentation table in the technical specifications. Although these changes to the technical specifications have been included, they are not applicable prior to exceeding 5% power and we recognize the need for further discussion with the staff to resolve this issue. Another change resulted f rom additional information having been supplied to a staf f reviewer followed by an on-site visit. The requirement for a routine high-pressure test of the drywell airlock has been deleted.
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Mr. H. R. Denton. March 10, 1986 PY-CEI/NRR-0427 In summary, based on all the programs described herein, the Perry Nuclear Power Plant Technical Specifications are consistent with the PSAR, SER and its supplements, and the as-built plant.
If you have any questions, please let me know.
Very truly yours, SD h
A Murray R. Edelman Vice President Nuclear Group C
MRE:nje cc: Jay Silberg, Esq.
D. Eisenhut John Stefano (2)
R. Bernero J. Grobe W. Houston S.. Brown, NRR W. Butler l
n e,a PY-CEI/NRR-0427 L Technical Specification Review Programs The Perry Technical Specifications were initially developed using the BWR/6 Standard Technical Specifications (NUREG-0123, proposed Rev. 4) and have been modified by Perry specific design values, FSAR information and preo'perational test results. The Perry Technical Specifications have been updated to reflect modifications to plant design and are traceable to design documents..The Technical Specifications have undergone numerous extensive reviews by both CEI and the NRC, including two early draft reviews, the proof and review phase and two final draf t reviews.
The Perry FSAR has undergone a verification review. This was performed by representatives of the utility, the architect / engineer, and the NSSS vendor.
The purpose of this review was to ensure the information in the FSAR was accurate and traceable to design documents. To ensure consistency between the FSAR and Technical Specifications, a detailed review of the Technical Specifications against the FSAR and the SER was conducted in June 1985. Each individual Limiting Condition for Operation (LCO), action statement, surveillance requirement and bases section was reviewed against the FSAR descriptive material related to the specification under review. All apparent discrepancies were identified and resolved. The SER and its supplements were also reviewed for descriptive material related to the specification under review. Prior to the review, seven items identified in the SER as requiring technical specifications were requested to be revised in letters dated February 11, February 12, February 13 and February 19, 1985. The results of the SER review showed consistency with the Safety Evaluation Report through Supplement No. 9.
The results of this total intensive review have been compiled in a matrix format to support our certification letter. Through an on-going process of plant walkdown, the conduct of preoperational tests which demonstrated the acceptance criteria of technical specifications, where practical, and our program of performing dry runs of surveillance requirements of the technical specifications, we have confirmed the technical specifications are consistent with the as-built facility.
During the week of November 18, 1985 a regional inspection team conducted an audit of the Perry Technical Specifications. The audit team reviewed the Technical Specifications against the FSAR and the as-built plant for selected systems (Reference Inspection Report 50-440/85082). During the review, an apparent discrepancy was identified. Our response was provided to NRC Region III by letter dated December 12, 1985. Although previously accomplished through the development of the FSAR/ Technical Specifications matrix described above, an additional sample review of FSAR and Technical Specifications consistency was performed in response to the inspection. The values chosen were representative of the key input variables in the Containment Response Analysis (Chapter 6), the Accident Analyses (Chapter 15), and the Instrumentation and Controls Section (Chapter 7).
The additional comparison of the Technical Specifications values and respective FSAR parameters has been completed and the results further demonstrate that the Perry Technical Specifications are consistent with or conservative with respect to the Perry FSAR.