ML20235T549
| ML20235T549 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 02/22/1989 |
| From: | Hiatt S OHIO CITIZENS FOR RESPONSIBLE ENERGY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| FRN-54FR5177, RULE-PR-MISC 54FR5177-00001, 54FR5177-1, NUDOCS 8903080348 | |
| Download: ML20235T549 (2) | |
Text
.
,p g
t Dbn 54PKrl'1huu"&Myggy3 3, h
February 22, 1989 I
fc I
Regulatory Publications Branch
'89 FEB 27 P1 :40 Division of Freedom.of Information and Publications Services Office of Administration and Resources Management U.S.
Nuclear Regulatory Commission Washington, DC 20555 De Sir /Ms.:
The undersigned is submitting these comments on behalf of the Ohio Citizens for Responsible Energy, Inc. ("OCRE") uith regard to the operating license amendment reu,ue s t by the Cleveland Electric Illuminating Co. et al. for the Perry Nuclear Power Plant located in Lake
- County, Ohio.
The notice of this amendment request was published in the Federal Register on n -,
y?1_W 1989F(542 Fed Mteg a5177)??
1Februar u e
_y w.
-2 The subject request would amend certain plant Technical Specifications to accomodate the new fuel load to be used for the second operating cycle.
OCRE believes that the amendment request, as submitted by the licensees on November 29, 1988, is deficient in that a stability analysis has not been conducted.
The stated reason for not conducting a stability analysis is:
GE SIL-380 recommendations have been included in the Perry Nuclear Power Plant Unit 1 Technical Specifications; therefore, no stability analysis is required as documented in the letter Cecil O. Thomas (NRC) to H.C.
Pfefferlen (GE), " Acceptance for Referencing of Licensing Topical Report NEDE-24011 Rev.
6, Amendment 8,
' Thermal Hydraulic Stability Amendment to GESTAR-II'," April 24, 1985.
This paragraph appears on page 11 of Attachment 1
to CEI's November 29 amendment request.
On March 9, 1988 the LaSalle Unit 2
BWR experienced power oscillations which GE analytical methods failed to predict. The NRC's Office for Analysis and Evaluation of Operational Data found that "GE SIL 380, Revision 1, even if implemented, is inadequate to ensure compliance with GDC 12."
AEOD Special
-Report No. AEOD/S803, June 7,-
1988, p.
5.
In light of the LaSalle event, the GE/CEI failure to conduct a
stability analysis for the reload is unacceptable.
Reference to pre-LaSalle event documents cannot possibly provide a
justification for the lack of analysis.
It is OCRE's position that CEI should be required to conduct a stability analysis for 8903080348 890222 PDR PR MISC 54FR5177 PDR
p 3
'_ 3,..
t q
{i g,f g C ;l ' t.; >
4 4
gf -
it'.te second operating cycle demonstrating' compliance.with GDC 10.
7 Ja n d.' 1 2..- a s
-a-condition for. restart following _ the current Id
' refueling. outage.
t-4 b
Respectfullycsubmitted, u.3 3,
.. g
. Susan'L.-Hiatt:
f/-
OCRE^ Representative
?
- 8275 Munson Road Mentor,,OH - 44060 i ]/ >
(216) 255-3158 m
Llb l
.r Q
cc:. Timothy Colburn, Project Manager A
L L-j F.
f) 1I
{-
_________m_m_--____
.____-.._--.-___..._m__-
_m_--____