Similar Documents at Perry |
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Category:CORRESPONDENCE-LETTERS
MONTHYEARPY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl ML20217F3901999-10-14014 October 1999 Discusses Request That Proprietary Document NEDE-32907P,DRF A22-0084-53, Safety Analysis Rept for Perry NPP 5% Power Uprate, Class III Dtd Sept 1999 Be Withheld.Determined Document Proprietary & Will Be Withheld ML20217G9201999-10-14014 October 1999 Discusses Utils Request for Approval of Quality Assurance Program Changes PY-CEI-NRR-2435, Responds to NRC Re Violations Noted in Insp Rept 50-440/99-13.Corrective Actions:Ts SRs with Incorrect Descriptions Were Annotated to Ensure That CR Operators Are Aware That ACs Are Effect1999-10-13013 October 1999 Responds to NRC Re Violations Noted in Insp Rept 50-440/99-13.Corrective Actions:Ts SRs with Incorrect Descriptions Were Annotated to Ensure That CR Operators Are Aware That ACs Are Effect ML20212K9271999-09-30030 September 1999 Refers to 990927 Meeting Conducted at Perry Nuclear Power Plant to Discuss Initiatives in Risk Area & to Establish Dialog Between SRAs & PSA Staff ML20212J1451999-09-30030 September 1999 Forwards Order,In Response to 990505 Application PY-CEI/NRR- 2394L.Order Approves Conforming License Amend Which Will Be Issued & Made Effective When Transfer Completed ML20217E7111999-09-30030 September 1999 Documents Telcon Conducted on 990929 Between M Underwood of Oh EPA & D Tizzan of Pnpp,Re Request to Operate Pnpp Sws,As Is,Until Resolution Can Be Obtained ML20212G4161999-09-24024 September 1999 Informs of Completion of Licensing Action for Generic Ltr 98-01, Y2K Readiness of Computer Systems at Nuclear Power Plants, for Perry Nuclear Power Plant ML20212G5811999-09-23023 September 1999 Informs That Licenses for Ta Lentz,License SOP-31449,PJ Arthur,License SOP-30921-1 & Dp Mott,License SOP-31500 Are Considered to Have Expired,Iaw 10CFR50.74(a),10CFR55.5 & 10CFR55.55 PY-CEI-NRR-2432, Forwards NRC Form 536, Operator Licensing Exam Data, in Response to Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams1999-09-21021 September 1999 Forwards NRC Form 536, Operator Licensing Exam Data, in Response to Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams PY-CEI-NRR-2428, Submits Resolution to Seventh Question Proposed within NRC 980615 RAI Relating to Cooling Water Sys That Serve Containment Air Coolers & Assessment,Post Accident,Of Potential Water Hammer & two-phase Flow Conditions1999-09-16016 September 1999 Submits Resolution to Seventh Question Proposed within NRC 980615 RAI Relating to Cooling Water Sys That Serve Containment Air Coolers & Assessment,Post Accident,Of Potential Water Hammer & two-phase Flow Conditions ML20212D0151999-09-14014 September 1999 Requests Cancellation of NPDES Permit 3II00036.Permit Has Been Incorporated in Permit 3IB00016*ED.Discharge Point Sources & Associated Fees Currently Covered Under Permit 3IB00016*ED ML20212A8371999-09-13013 September 1999 Forwards Insp Rept 50-440/99-13 on 990712-30 & Notice of Violation.Insp Included Evaluation of Engineering Support, Design Change & Modification Activities,Internal Assessment Activities & Corrective Actions ML20217A8971999-09-0909 September 1999 Forwards Insp Rept 50-440/99-09 on 990709-0825.One Violation of NRC Requirements Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy PY-CEI-NRR-2431, Forwards Revised Emergency Plan for Perry NPP, IAW 10CFR50.54(q).Changes Constitute Revs,Temporary Changes or Reissued Pages1999-09-0909 September 1999 Forwards Revised Emergency Plan for Perry NPP, IAW 10CFR50.54(q).Changes Constitute Revs,Temporary Changes or Reissued Pages ML20211Q6911999-09-0606 September 1999 Informs That NRC Tentatively Scheduled Initial Licensing Exam for Perry Operator License Applicants During Wks of 010108 & 15.Validation of Exam Will Occur at Station During Wk of 001218 IR 05000440/19990011999-08-31031 August 1999 Requests That Page Number 4, P2 Status of EP Facilities, Equipment & Resources, of Insp Rept 50-440/99-01 Be Replaced with Encl Rev PY-CEI-NRR-2425, Forwards Copy of Oh EPA Approval for Use of Nalco 7348 & Nalco 7468 at Pnpp,Iaw License NPF-58,App B,Epp,Section 3.21999-08-26026 August 1999 Forwards Copy of Oh EPA Approval for Use of Nalco 7348 & Nalco 7468 at Pnpp,Iaw License NPF-58,App B,Epp,Section 3.2 PY-CEI-NRR-2411, Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl1999-08-19019 August 1999 Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl ML20210Q8421999-08-13013 August 1999 First Final Response to FOIA Request for Documents.Records Listed in App a Being Released in Entirety & Records Listed in App B Being Withheld in Part (Ref FOIA Exempt 5) ML20210R7861999-08-12012 August 1999 Forwards Insp Rept 50-440/99-12 on 990712-16.No Violations Noted.New Emergency Preparedness Program Staff & Mgt Personnel Were Professional & Proactive ML20210S3961999-08-11011 August 1999 Requests That Ten Listed Individuals Be Registered to Take 991006 BWR Gfes of Written Operating Licensing Exam.Two Listed Personnel Will Have Access to Exams Before Exams Are Administered PY-CEI-NRR-2423, Provides Final Response to NRC GL 98-01, Y2K Readiness of Computer Sys at Npps. Remediation of Meteorological Monitoring Sys Has Been Completed & Ppnp Facility Is Now Y2K Ready1999-08-10010 August 1999 Provides Final Response to NRC GL 98-01, Y2K Readiness of Computer Sys at Npps. Remediation of Meteorological Monitoring Sys Has Been Completed & Ppnp Facility Is Now Y2K Ready PY-CEI-NRR-2421, Forwards Semiannual fitness-for-duty Rept,Iaw 10CFR26.71(d) for Pnpp Covering Period of 990101-9906301999-08-10010 August 1999 Forwards Semiannual fitness-for-duty Rept,Iaw 10CFR26.71(d) for Pnpp Covering Period of 990101-990630 ML20210Q7981999-08-10010 August 1999 Informs That Intention to Utilize Sulfuric Acid in Pnpp Circulating Water Sys to Lower Ph Is Anticipated to Be Completed in Nov ML20210Q5831999-08-10010 August 1999 Requests Permission to Chemically Treat CWS for Algae Due to Cooling Water Basin Becoming Infected with Algae of Various Types PY-CEI-NRR-2422, Forwards Addl Info Re ASME Section IX Relief Request (IR-023) for Inservice Examination Program at Pnpp,Submitted on 9808261999-08-10010 August 1999 Forwards Addl Info Re ASME Section IX Relief Request (IR-023) for Inservice Examination Program at Pnpp,Submitted on 980826 ML20210K6331999-08-0404 August 1999 Submits Response to Requests for Addl Info to GL 92-01,Rev 1, Reactor Vessel Structural Integrity, for Perry Nuclear Plant,Unit 1 PY-CEI-NRR-2417, Forwards NP0059-007, Pnpp - Unit 1 ISI Summary Rept Results for Outage 7 (1999) First Period,Second Interval, IAW ASME Boiler & Pressure Vessel Code,Section XI,1989 Edition,Article IWA-60001999-08-0202 August 1999 Forwards NP0059-007, Pnpp - Unit 1 ISI Summary Rept Results for Outage 7 (1999) First Period,Second Interval, IAW ASME Boiler & Pressure Vessel Code,Section XI,1989 Edition,Article IWA-6000 ML20210G8411999-07-28028 July 1999 Informs That Based on Determination That Rev 14 Changes to Various Portions of Perry Nuclear Power Plant Emergency Plan Does Not Decrease Effectiveness of Licensee Emergency Plan & Meets Standard of 10CFR50.47(b),no NRC Approval Required ML20210E0661999-07-22022 July 1999 Forwards Insp Rept 50-440/99-08 on 990518-0708.No Violations Noted.Overall Conduct of Activities at Perry Facility, Conservative & Professional with Continuing Focus on Safety PY-CEI-NRR-2419, Forwards Four Copies of Rev 27 to Pnpp Security Plan,Per 10CFR50.54(p)(2).Changes Have Been Determined Not to Decrease Effectiveness of Security Plan.Rev Withheld1999-07-21021 July 1999 Forwards Four Copies of Rev 27 to Pnpp Security Plan,Per 10CFR50.54(p)(2).Changes Have Been Determined Not to Decrease Effectiveness of Security Plan.Rev Withheld PY-CEI-NRR-2415, Submits Estimate of Number of Licensing Submittal for FY00 & 01,for Pnpp,Per Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates1999-07-19019 July 1999 Submits Estimate of Number of Licensing Submittal for FY00 & 01,for Pnpp,Per Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates ML20210A6441999-07-15015 July 1999 Advises That Listed Operator Licenses for Company Personnel Have Expired,As of 990715,per 10CFR50.74(a) & 10CFR55.5. Individuals Listed Have Assumed Responsibilities at Pnpp That Do Not Require Operator Licenses ML20209E5951999-07-0909 July 1999 Ltr Contract:Task Order 46, Perry Engineering & Technical Support (E&Ts) Insp, Under Contract NRC-03-98-021 ML20209D5931999-07-0101 July 1999 Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Investigation Rept 3-98-005 Issued on 990510.Corrective Actions Will Be Examined During Future Inspections ML20211A3881999-06-30030 June 1999 Supplements Re NRC Incomprehensible Enforcement Inactions.Understands That NRC Claiming Hands Tied in Matter Re Discrimination Violation at Perry Npp.Requests That NRC Take Listed Two Actions PY-CEI-NRR-2410, Submits Response to NRC Request for Info Re GL 98-01, Y2K Readiness of Computer Sys at Npps. Attachment 1 Provides Y2K Readiness Disclosure for Plant1999-06-29029 June 1999 Submits Response to NRC Request for Info Re GL 98-01, Y2K Readiness of Computer Sys at Npps. Attachment 1 Provides Y2K Readiness Disclosure for Plant PY-CEI-NRR-2413, Advises That Jk Wood Will Replace Lw Myers as Pnpp,Vice President - Nuclear,Effective 9907061999-06-29029 June 1999 Advises That Jk Wood Will Replace Lw Myers as Pnpp,Vice President - Nuclear,Effective 990706 PY-CEI-NRR-2403, Submits Response to RAI Re GL 96-05 Program at Plant1999-06-29029 June 1999 Submits Response to RAI Re GL 96-05 Program at Plant ML20196H9641999-06-29029 June 1999 Confirms 990615 Telcon Request with J Lieberman for Addl Time to Respond to Enforcement Action 99-012.FirstEnergy Has 60 Days to Respond to EA PY-CEI-NRR-2412, Forwards Perry Nuclear Plant Simulator Four Yr Test Rept & NRC Form 474, Simulation Facility Certification, Which Describes Tests Conducted from June 1995-19991999-06-28028 June 1999 Forwards Perry Nuclear Plant Simulator Four Yr Test Rept & NRC Form 474, Simulation Facility Certification, Which Describes Tests Conducted from June 1995-1999 ML20211A3991999-06-28028 June 1999 Submits Concerns Re Proposed Changes to Enforcement Policy. Believes That NRC Existing Regulations & Policies Provide Adequate Controls & That NRC Not Administering Consistent Enforcement Policies in Response to Discriminatory Actions ML20196A6601999-06-16016 June 1999 Forwards Master Decommissioning Trust Agreements Revised After 1990 for Ohio Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & Pennsylvania Power Co Re Bvnps,Units 1 & 2,DBNPS,Unit 1 & Perry Unit 1 PY-CEI-NRR-2405, Informs NRC That Pnpp Staff Has Implemented Formal Industry Position on Severe Accident Mgt1999-06-14014 June 1999 Informs NRC That Pnpp Staff Has Implemented Formal Industry Position on Severe Accident Mgt ML20195H9051999-06-10010 June 1999 Forwards Two License Renewal Applications Consisting of NRC Form 398 & NRC Form 396 for Bk Carrier,License OP-30997 & Jt Steward,License OP-30564-1 ML20212H5841999-06-10010 June 1999 Responds to NRC Notice of Level III Violation Received by K Wierman.Corrective Actions:K Wierman Has Been Dismissed from Position at Perry NPP PY-CEI-NRR-2408, Forwards Rev 4 to Pump & Valve Inservice Testing Program Plan, Incorporating Changes to Program to Implement Second Ten Yr Insp Interval1999-06-10010 June 1999 Forwards Rev 4 to Pump & Valve Inservice Testing Program Plan, Incorporating Changes to Program to Implement Second Ten Yr Insp Interval ML20195G6741999-06-10010 June 1999 Forwards Insp Rept 50-440/99-03 on 990407-0517.Two Violations of NRC Requirements Occurred & Being Treated as non-cited Violations,Consistent with App C of Enforcement Policy PY-CEI-NRR-2407, Responds to NRC Re Violations Noted in Investigations Rept 3-98-005.Corrective Actions:Initiated Internal Investigation Into Matter to Discover Party Responsible for Falsification of Training Records1999-06-0909 June 1999 Responds to NRC Re Violations Noted in Investigations Rept 3-98-005.Corrective Actions:Initiated Internal Investigation Into Matter to Discover Party Responsible for Falsification of Training Records 1999-09-09
[Table view] Category:ENGINEERING/CONSTRUCTION/CONSULTING FIRM TO NRC
MONTHYEARML20247P9411989-05-17017 May 1989 FOIA Request for Final Open Item Transmittal Ltrs Per NRC Insp Procedure 94300B for Listed Plants ML20246L2551989-04-26026 April 1989 Forwards Review of Rev 3 to Odcm.Rev Submitted as Attachment 7 to Semiannual Effluent Rept for Jan-June 1988.Methodology Meets All Requirements of NUREG-0133 & Acceptable ML20247N1551989-03-31031 March 1989 Forwards Revised Proprietary Conformance of HPCS Div to NUMARC 87-00 Alternate AC Criteria, for Review as Result of Comments from 890216 Meeting.Rept Withheld ML17285A2351989-02-0606 February 1989 Forwards Proprietary Draft Conformance of HPCS Div to NUMARC 87-00 App B Aac Criteria, for 890214 Meeting ML17285A2341989-01-0606 January 1989 Discusses Issues Highlighted at BWR/6 Alternate Ac Task Force Meeting on 881115,including Need for Capability of Div III Sys to Maintain Plant in Safe Shutdown Condition (Hot Shutdown) for Min of 4 H ML20235A1251987-12-16016 December 1987 Forwards Info Re Resource Technical Svcs,Inc,Including Summary of NRC Contract Work,Nrc Form 26 for Three Existing Contracts,Audit Info,Work History & Lists of Expertise Available for Special Insps & of Current Resource Svcs ML20235V1321987-08-28028 August 1987 Forwards EGG-NTA-7471, Technical Evaluation Rept,Reactor Trip Sys Reliability Conformance to Item 4.5.2 of Generic Ltr 83-28.... Based on Licensee Responses,Plants Reviewed Conform W/Exceptions Listed in Section 14 ML20215M0561987-05-15015 May 1987 Forwards Final EGG-NTA-7627,Conformance to Generic Ltr 83-28,Item 2.2.2--Vendor Interface Programs for All Other Safety-Related Components:Perry Unit 1. Licensee Should Establish Interfaces w/safety-related Component Vendors ML20234B6211987-05-12012 May 1987 Requests That Listed Plants Be Added to Encl 870508 FOIA Request Re 94300 Region Input on Plant Readiness ML20234B6571987-05-0808 May 1987 FOIA Request for Placement,In Pdr,Region Input to NRC Headquarters,Nrr Re Status of Listed Plants in Terms of Plant Readiness for OL IE Manual,Chapter 94300 ML20214R4051987-05-0808 May 1987 FOIA Request for Region Input to NRR Re Status of Listed Plants Readiness for Ol,Per IE Manual Chapter 94300 ML20245A4451986-09-25025 September 1986 Forwards Revised Draft EGG-NTA-7188, Conformance to Generic Ltr 83-28 Item 2.1 (Part 1) Equipment Classification Hope Creek,Peach Bottom 2 & 3,Perry 1 & 2 & Pilgrim 1 ML20206L8701986-08-12012 August 1986 Forwards Rev 1 to 8666-02-01, Review of Effect of 860131 Earthquake on Perry Nuclear Power Plant ML20212H2911986-08-12012 August 1986 Forwards Rev 1 to Review of Effects of 860131 Earthquake on Perry Nuclear Plant ML20198D5811986-04-28028 April 1986 Forwards Rev 1 to Questions on Util Submittals & Previous Meetings W/Nrc Re Response Spectra Comparisons.Several Questions Inadvertently Deleted in Original Final Typed Version ML20202G2281986-03-25025 March 1986 Submits Evaluation of Ocre to Acrs,Per Request. Further Research Required to Delineate Areal & Vertical Extent of Aftershocks & Potential Fault Structures in Region ML20141M8251986-02-26026 February 1986 Forwards Contribution to SER Rev Re Effects of 860131 Earthquake.Compilation of Facility Technical Evaluation Rept Documentation Will Not Be Completed by Deadline.Telephone Discussion Requested ML20117J4381985-05-0202 May 1985 Forwards FEMA Exhibits 1 & 3 from Commission 850412 Hearing for Insertion Into Transcript ML20117J4511985-05-0202 May 1985 Forwards Exhibit 13 Re Analysis of Inaccessible & Potentially Rejectable Defects in Plant for Insertion in Transcript ML20112H8101984-04-0505 April 1984 FOIA Request for Repts Resulting from Listed Environ Qualification of Equipment Site Audits to Be Placed in Pdr. Access to Any Repts Resulting from Audits Held Since Oct 1982 Also Requested ML20084R6521984-02-24024 February 1984 FOIA Request for Computer Printout from Sept 1980 to Present of Civil Penalty Info on 27 Listed Nuclear Facilities.Sample Format Encl ML20069C6221982-07-0202 July 1982 FOIA Request for Documents Addressing Completion Status of in Terms of Elapsed Time,Committed Capital or by Physical Insp ML20038C5821981-12-0707 December 1981 Submits Errata to NUS-3910 Response to NRC Staff Question 240.03 Concerning Consequences of Liquid Pathway Releases from Core Melt Accident, Submitted as Part of Suppl 3 to Environ Rept ML20005A1561981-06-22022 June 1981 Forwards Addl Data Re Seismic Model Properties Per Telcon W/ Nrc.Data Revises Info Included in Item 3 of 810612 Response to Request for Addl Info Re Seismic Analysis ML20004C5181981-05-29029 May 1981 Forwards Summary of 810529 Telcon W/Nrc Re Postulation of Simultaneous Breaks in Safety & Nonsafety Piping.Breaks in Nonsafety Main Steam or Feedwater Lines Are Not Required to Be Postulated Concurrently W/Loca ML19329D3011976-01-0909 January 1976 Submits Corrections to 751231 & 760105 Transcripts. Certificate of Svc Encl 1989-05-17
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARPY-CEI-NRR-2438, Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl1999-10-14014 October 1999 Informs That DBNPS & Pnpp Staffs Have Modified or Withdrawn Several of Positions Proposed within Re Request for Approval of Qap.Revised Positions Encl PY-CEI-NRR-2435, Responds to NRC Re Violations Noted in Insp Rept 50-440/99-13.Corrective Actions:Ts SRs with Incorrect Descriptions Were Annotated to Ensure That CR Operators Are Aware That ACs Are Effect1999-10-13013 October 1999 Responds to NRC Re Violations Noted in Insp Rept 50-440/99-13.Corrective Actions:Ts SRs with Incorrect Descriptions Were Annotated to Ensure That CR Operators Are Aware That ACs Are Effect ML20212G5811999-09-23023 September 1999 Informs That Licenses for Ta Lentz,License SOP-31449,PJ Arthur,License SOP-30921-1 & Dp Mott,License SOP-31500 Are Considered to Have Expired,Iaw 10CFR50.74(a),10CFR55.5 & 10CFR55.55 PY-CEI-NRR-2432, Forwards NRC Form 536, Operator Licensing Exam Data, in Response to Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams1999-09-21021 September 1999 Forwards NRC Form 536, Operator Licensing Exam Data, in Response to Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams PY-CEI-NRR-2428, Submits Resolution to Seventh Question Proposed within NRC 980615 RAI Relating to Cooling Water Sys That Serve Containment Air Coolers & Assessment,Post Accident,Of Potential Water Hammer & two-phase Flow Conditions1999-09-16016 September 1999 Submits Resolution to Seventh Question Proposed within NRC 980615 RAI Relating to Cooling Water Sys That Serve Containment Air Coolers & Assessment,Post Accident,Of Potential Water Hammer & two-phase Flow Conditions ML20212D0151999-09-14014 September 1999 Requests Cancellation of NPDES Permit 3II00036.Permit Has Been Incorporated in Permit 3IB00016*ED.Discharge Point Sources & Associated Fees Currently Covered Under Permit 3IB00016*ED PY-CEI-NRR-2431, Forwards Revised Emergency Plan for Perry NPP, IAW 10CFR50.54(q).Changes Constitute Revs,Temporary Changes or Reissued Pages1999-09-0909 September 1999 Forwards Revised Emergency Plan for Perry NPP, IAW 10CFR50.54(q).Changes Constitute Revs,Temporary Changes or Reissued Pages PY-CEI-NRR-2425, Forwards Copy of Oh EPA Approval for Use of Nalco 7348 & Nalco 7468 at Pnpp,Iaw License NPF-58,App B,Epp,Section 3.21999-08-26026 August 1999 Forwards Copy of Oh EPA Approval for Use of Nalco 7348 & Nalco 7468 at Pnpp,Iaw License NPF-58,App B,Epp,Section 3.2 PY-CEI-NRR-2411, Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl1999-08-19019 August 1999 Informs That Firstenergy Nuclear Operating Co Has Developed Corporate QA Program Manual for Davis-Besse Nuclear Power Station & Perry Nuclear Power Plant,As Discussed on 990318 Between Util & Nrc.Revised USAR Pages,Encl ML20210S3961999-08-11011 August 1999 Requests That Ten Listed Individuals Be Registered to Take 991006 BWR Gfes of Written Operating Licensing Exam.Two Listed Personnel Will Have Access to Exams Before Exams Are Administered PY-CEI-NRR-2421, Forwards Semiannual fitness-for-duty Rept,Iaw 10CFR26.71(d) for Pnpp Covering Period of 990101-9906301999-08-10010 August 1999 Forwards Semiannual fitness-for-duty Rept,Iaw 10CFR26.71(d) for Pnpp Covering Period of 990101-990630 PY-CEI-NRR-2423, Provides Final Response to NRC GL 98-01, Y2K Readiness of Computer Sys at Npps. Remediation of Meteorological Monitoring Sys Has Been Completed & Ppnp Facility Is Now Y2K Ready1999-08-10010 August 1999 Provides Final Response to NRC GL 98-01, Y2K Readiness of Computer Sys at Npps. Remediation of Meteorological Monitoring Sys Has Been Completed & Ppnp Facility Is Now Y2K Ready PY-CEI-NRR-2422, Forwards Addl Info Re ASME Section IX Relief Request (IR-023) for Inservice Examination Program at Pnpp,Submitted on 9808261999-08-10010 August 1999 Forwards Addl Info Re ASME Section IX Relief Request (IR-023) for Inservice Examination Program at Pnpp,Submitted on 980826 PY-CEI-NRR-2417, Forwards NP0059-007, Pnpp - Unit 1 ISI Summary Rept Results for Outage 7 (1999) First Period,Second Interval, IAW ASME Boiler & Pressure Vessel Code,Section XI,1989 Edition,Article IWA-60001999-08-0202 August 1999 Forwards NP0059-007, Pnpp - Unit 1 ISI Summary Rept Results for Outage 7 (1999) First Period,Second Interval, IAW ASME Boiler & Pressure Vessel Code,Section XI,1989 Edition,Article IWA-6000 PY-CEI-NRR-2419, Forwards Four Copies of Rev 27 to Pnpp Security Plan,Per 10CFR50.54(p)(2).Changes Have Been Determined Not to Decrease Effectiveness of Security Plan.Rev Withheld1999-07-21021 July 1999 Forwards Four Copies of Rev 27 to Pnpp Security Plan,Per 10CFR50.54(p)(2).Changes Have Been Determined Not to Decrease Effectiveness of Security Plan.Rev Withheld PY-CEI-NRR-2415, Submits Estimate of Number of Licensing Submittal for FY00 & 01,for Pnpp,Per Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates1999-07-19019 July 1999 Submits Estimate of Number of Licensing Submittal for FY00 & 01,for Pnpp,Per Administrative Ltr 99-02, Operating Reactor Licensing Action Estimates ML20210A6441999-07-15015 July 1999 Advises That Listed Operator Licenses for Company Personnel Have Expired,As of 990715,per 10CFR50.74(a) & 10CFR55.5. Individuals Listed Have Assumed Responsibilities at Pnpp That Do Not Require Operator Licenses ML20211A3881999-06-30030 June 1999 Supplements Re NRC Incomprehensible Enforcement Inactions.Understands That NRC Claiming Hands Tied in Matter Re Discrimination Violation at Perry Npp.Requests That NRC Take Listed Two Actions PY-CEI-NRR-2403, Submits Response to RAI Re GL 96-05 Program at Plant1999-06-29029 June 1999 Submits Response to RAI Re GL 96-05 Program at Plant PY-CEI-NRR-2413, Advises That Jk Wood Will Replace Lw Myers as Pnpp,Vice President - Nuclear,Effective 9907061999-06-29029 June 1999 Advises That Jk Wood Will Replace Lw Myers as Pnpp,Vice President - Nuclear,Effective 990706 PY-CEI-NRR-2410, Submits Response to NRC Request for Info Re GL 98-01, Y2K Readiness of Computer Sys at Npps. Attachment 1 Provides Y2K Readiness Disclosure for Plant1999-06-29029 June 1999 Submits Response to NRC Request for Info Re GL 98-01, Y2K Readiness of Computer Sys at Npps. Attachment 1 Provides Y2K Readiness Disclosure for Plant ML20211A3991999-06-28028 June 1999 Submits Concerns Re Proposed Changes to Enforcement Policy. Believes That NRC Existing Regulations & Policies Provide Adequate Controls & That NRC Not Administering Consistent Enforcement Policies in Response to Discriminatory Actions PY-CEI-NRR-2412, Forwards Perry Nuclear Plant Simulator Four Yr Test Rept & NRC Form 474, Simulation Facility Certification, Which Describes Tests Conducted from June 1995-19991999-06-28028 June 1999 Forwards Perry Nuclear Plant Simulator Four Yr Test Rept & NRC Form 474, Simulation Facility Certification, Which Describes Tests Conducted from June 1995-1999 ML20196A6601999-06-16016 June 1999 Forwards Master Decommissioning Trust Agreements Revised After 1990 for Ohio Edison Co,Cleveland Electric Illuminating Co,Toledo Edison Co & Pennsylvania Power Co Re Bvnps,Units 1 & 2,DBNPS,Unit 1 & Perry Unit 1 PY-CEI-NRR-2405, Informs NRC That Pnpp Staff Has Implemented Formal Industry Position on Severe Accident Mgt1999-06-14014 June 1999 Informs NRC That Pnpp Staff Has Implemented Formal Industry Position on Severe Accident Mgt ML20212H5841999-06-10010 June 1999 Responds to NRC Notice of Level III Violation Received by K Wierman.Corrective Actions:K Wierman Has Been Dismissed from Position at Perry NPP ML20195H9051999-06-10010 June 1999 Forwards Two License Renewal Applications Consisting of NRC Form 398 & NRC Form 396 for Bk Carrier,License OP-30997 & Jt Steward,License OP-30564-1 PY-CEI-NRR-2408, Forwards Rev 4 to Pump & Valve Inservice Testing Program Plan, Incorporating Changes to Program to Implement Second Ten Yr Insp Interval1999-06-10010 June 1999 Forwards Rev 4 to Pump & Valve Inservice Testing Program Plan, Incorporating Changes to Program to Implement Second Ten Yr Insp Interval PY-CEI-NRR-2407, Responds to NRC Re Violations Noted in Investigations Rept 3-98-005.Corrective Actions:Initiated Internal Investigation Into Matter to Discover Party Responsible for Falsification of Training Records1999-06-0909 June 1999 Responds to NRC Re Violations Noted in Investigations Rept 3-98-005.Corrective Actions:Initiated Internal Investigation Into Matter to Discover Party Responsible for Falsification of Training Records PY-CEI-NRR-2404, Submits Rept of Reduction in PCT Greater than 50 F Due to Implementation of Ge,Safr/Gestr LOCA Methodology for Fuel Cycle 8.Methodology Replaces Original LOCA Methodology1999-06-0707 June 1999 Submits Rept of Reduction in PCT Greater than 50 F Due to Implementation of Ge,Safr/Gestr LOCA Methodology for Fuel Cycle 8.Methodology Replaces Original LOCA Methodology ML20195E4561999-05-25025 May 1999 Submits Petition Per Other Actions Provision of 10CFR2.206,requesting That Radiation Protection Manager at Perry NPP Be Banned by NRC from Participation in Licensed Activities at & for Any NPP for at Least Five Yrs PY-CEI-NRR-2401, Forwards Changes to ERDS Data Point Library & Communication Survey for Perry Nuclear Power Plant.Changes Are Identified by Margin Rev Bars1999-05-20020 May 1999 Forwards Changes to ERDS Data Point Library & Communication Survey for Perry Nuclear Power Plant.Changes Are Identified by Margin Rev Bars PY-CEI-NRR-2402, Notifies of Completion of Plant Core Shroud Insp in Accordance with GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs,1999-05-18018 May 1999 Notifies of Completion of Plant Core Shroud Insp in Accordance with GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs, PY-CEI-NRR-2394, Forwards Application for Order & Conforming License Amend for Transfer of Interest in OL NPF-58 for Pnpp.Authorization of Ceic to Possess Dl 13.74% Undivided Ownership in Pnpp, Requested1999-05-0505 May 1999 Forwards Application for Order & Conforming License Amend for Transfer of Interest in OL NPF-58 for Pnpp.Authorization of Ceic to Possess Dl 13.74% Undivided Ownership in Pnpp, Requested PY-CEI-NRR-2397, Forwards Revised COLR Cycle 8, & Rev 1 to J11-03371SRLR, Supplemental Reload Licensing Rept for Pnpp,Unit 1 Reload 7,Cycle 8, IAW TS Section 5.6.51999-04-30030 April 1999 Forwards Revised COLR Cycle 8, & Rev 1 to J11-03371SRLR, Supplemental Reload Licensing Rept for Pnpp,Unit 1 Reload 7,Cycle 8, IAW TS Section 5.6.5 PY-CEI-NRR-2396, Provides post-examination Results of Weld Overlay Repair for FW Nozzle to safe-end Weld at Pnpp.Info Supplements Licensee 990325 & 0401 Ltrs Submitted to NRC That Requested Approval of Repair Plan for 1B13-N1C-KB FW Nozzle to safe-en1999-04-28028 April 1999 Provides post-examination Results of Weld Overlay Repair for FW Nozzle to safe-end Weld at Pnpp.Info Supplements Licensee 990325 & 0401 Ltrs Submitted to NRC That Requested Approval of Repair Plan for 1B13-N1C-KB FW Nozzle to safe-end Weld 05000440/LER-1999-002, Forwards LER 99-002-00, LCO 3.0.3 Entered Due to TS Bases Statement Interpretation. Action Occurred After RHR Pump Failed to Start.Plant at No Time Was in Condition Where Required Decay Heat Removal System Were Not Available1999-04-26026 April 1999 Forwards LER 99-002-00, LCO 3.0.3 Entered Due to TS Bases Statement Interpretation. Action Occurred After RHR Pump Failed to Start.Plant at No Time Was in Condition Where Required Decay Heat Removal System Were Not Available PY-CEI-NRR-2388, Forwards Annual Environ & Effluent Release Rept for Pnnp Unit 1 for 1998. Pnpp Had No Liquid Effluent Discharges in 1998 & All Other Release Points Were Well Below Applicable Limits1999-04-22022 April 1999 Forwards Annual Environ & Effluent Release Rept for Pnnp Unit 1 for 1998. Pnpp Had No Liquid Effluent Discharges in 1998 & All Other Release Points Were Well Below Applicable Limits PY-CEI-NRR-2371, Provides Suppl Response to Violations Noted in Insp Rept 50-440/98-18.Corrective Actions:Two Condition Rept Investigations Were Performed to Evaluate Issues Re Fire Protection Program & Addl Training Was Conducted1999-04-21021 April 1999 Provides Suppl Response to Violations Noted in Insp Rept 50-440/98-18.Corrective Actions:Two Condition Rept Investigations Were Performed to Evaluate Issues Re Fire Protection Program & Addl Training Was Conducted PY-CEI-NRR-2382, Forwards 1998 Annual Rept for Firstenergy Corp, for Perry Nuclear Power Plant & Davis-Besse Nuclear Power Station.Form 10-K Annual Rept to Us Securities & Exchange Commission for FY98 Also Encl1999-04-21021 April 1999 Forwards 1998 Annual Rept for Firstenergy Corp, for Perry Nuclear Power Plant & Davis-Besse Nuclear Power Station.Form 10-K Annual Rept to Us Securities & Exchange Commission for FY98 Also Encl PY-CEI-NRR-2392, Forwards Diskette Containing Pnpp Thermoluminescent Dosimeter Doses in Format Requested by Reg Guide 8.7.Without Diskette1999-04-19019 April 1999 Forwards Diskette Containing Pnpp Thermoluminescent Dosimeter Doses in Format Requested by Reg Guide 8.7.Without Diskette PY-CEI-NRR-2387, Documents Telcon Held Between NRC Staff & Members of Perry Nuclear Power Plant Staff on 990406,re Safety Evaluation for License Amend 1051999-04-14014 April 1999 Documents Telcon Held Between NRC Staff & Members of Perry Nuclear Power Plant Staff on 990406,re Safety Evaluation for License Amend 105 PY-CEI-NRR-2386, Forwards Copy of Application Submitted to FERC Proposing Transfer of Jurisdictional Transmission Facilities of Firstenergy Corp Operating Companies to American Transmission Sys,Inc.With One Oversize Drawing1999-04-0606 April 1999 Forwards Copy of Application Submitted to FERC Proposing Transfer of Jurisdictional Transmission Facilities of Firstenergy Corp Operating Companies to American Transmission Sys,Inc.With One Oversize Drawing ML20206N3361999-04-0505 April 1999 Informs NRR of Continued Events Re Transfer of Generation Assets Between Duquesne Light Co & Firstenergy.No Negotiated Settlement Between Firstenergy & Local 270 Pertaining to Generation Asset Swap Has Been Reached PY-CEI-NRR-2384, Provides Supplemental Info Re 990325 Request for Approval of Repair Plan for Feedwater Nozzle to safe-end Weld. Clarification Provided on Listed Three Items,Per 990329 Telcon with NRC1999-04-0101 April 1999 Provides Supplemental Info Re 990325 Request for Approval of Repair Plan for Feedwater Nozzle to safe-end Weld. Clarification Provided on Listed Three Items,Per 990329 Telcon with NRC PY-CEI-NRR-2383, Withdraws Inservice Exam Relief Requests IR-036 & IR-041, Submitted in Licensee to Nrc.Relief Request IR-041 Is Being Clarified with Respect to Alternative Proposed1999-04-0101 April 1999 Withdraws Inservice Exam Relief Requests IR-036 & IR-041, Submitted in Licensee to Nrc.Relief Request IR-041 Is Being Clarified with Respect to Alternative Proposed L-99-052, Forwards Info Concerning Dls Decommissioning Planning for Bvps,Units 1 & 2 & Pnpp Unit 1.DL Is Continuing to Utilize External Sinking Funds to Provide Financial Assurance for Nuclear Decommissioning Funding1999-03-30030 March 1999 Forwards Info Concerning Dls Decommissioning Planning for Bvps,Units 1 & 2 & Pnpp Unit 1.DL Is Continuing to Utilize External Sinking Funds to Provide Financial Assurance for Nuclear Decommissioning Funding ML20205H6171999-03-29029 March 1999 Forwards Util Consolidated Financial Statements for Twelve Month Period Ending 981231 & Internal Cash Flow Projection, Including Actual 1998 Data & Projections for 1999 PY-CEI-NRR-2377, Submits Decommissioning Repts for Bvps,Units 1 & 2,Davis- Besse Nuclear Power Station,Unit 1 & Perry Nuclear Power Plant,Unit 1,per 10CFR50.75(f)(1)1999-03-29029 March 1999 Submits Decommissioning Repts for Bvps,Units 1 & 2,Davis- Besse Nuclear Power Station,Unit 1 & Perry Nuclear Power Plant,Unit 1,per 10CFR50.75(f)(1) PY-CEI-NRR-2380, Requests Approval of Attached Repair Plan for Feedwater Nozzle to safe-end Weld N4C-KB.Proposed Weld Overlay Design & Installation Plan Details Included in Attachment 1. Attachment 2 Provides Applicable Preliminary Weld Procedure1999-03-25025 March 1999 Requests Approval of Attached Repair Plan for Feedwater Nozzle to safe-end Weld N4C-KB.Proposed Weld Overlay Design & Installation Plan Details Included in Attachment 1. Attachment 2 Provides Applicable Preliminary Weld Procedure 1999-09-09
[Table view] |
Text
_ _ _
ENCL 0SURE I
lNEA idehe National Engineering Lsboratory i
April 26, 1989 Mr. Wayne Meinke Radiation Protection Branch Mail Stop 1]D23 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 FINAL LETTER REVIEW OF THE PERRY ODCM REVISION 3 - SIM-53-89
Dear Mr. Meinke:
Attached is the review of ODCM Revision 3 for Perry Nuclear Power Plant -
(PNPP) submitted by The Cleveland Electric Illuminating Company (CEI). '
- Revision 3 was submitted as Attachment 8 to the Licensee's semiannual
. effluent report for Jan-Jun 1988. This submittal was apparently in
' partial response to a letter from the NRC requesting that a new revision of the ODCM be submitted incorporating temporary changes to Revision 2 and addressing the items identified in the Conclusions. section of the Technical Evaluation Report (TER), EGG-PHY-8032, concerning Revision 2.
The Licensee's response to the items identified in the review TER were transmitted to the NRC separately from the revised ODCM, with a letter from A. Kaplan (CEI) to Document Control Desk (NRC), dated September 20, 1988. The Licensee's responses to these items were considered when preparing the discussions in the attached review of ODCM Revision 3. The ODCM Revision 3 reviewed was updated through Temporary Change No. 4, submitted with the Licensee's semiannual effluent report for the Jul-Dec 1988 period. Changes to the ODCM made in response to the items identified in the review TER were submitted as part of Temporary Change No. 4 to ODCM Revision 3.
The only additional changes that appear to be needed in the ODCM are discussed under " Major Discrepancies (#2)" and " Additional Discrepancies
(#9)" in the attachment. The first involves addition of a small amount of information to the ODCM, and the second involves specification of a milk sampling control location in the environmental monitoring program.
Very trul yours, 6 h 'Nrp)ppyw
. B. Simpson Nu lear Sciences TEY/lkw Attachments N cc: G. L. Jones, DOE-ID l As stated 1
hEGtG,,,,,,>.. p.v. sox 1ses Idsho faits. to exts
EVALUATION OF PERRY ODCM UPDATED THROUGH REVISION 3 - SIM-53-89
(
The Cleveland Electric Illuminating Co. (CEI), the Licensee for Perry Nuclear Power Plant, Unit 1 (PNPP) submitted a complete ODCM for PNPP, updated through Revision 3 and Temporary Changes 1 and 2 (TCN-1 and TCN-2) to the NRC with the Semiannual Radioactive Effluent Release Report for Jan-Jun 1988, with a letter from A. Kaplan (CEI) to Document Control Desk (NRC), dated August 30, 1988. The updated ODCM included some changes made in response to a letter from T. Colburn (NRC) to A. Kaplan (CEI), dated March 9, 1988. Specifically, TCN-1 through TCN-8 to Revision 2 of the ODCM were incorporated in Revision 3. Also, a number of radiological environmental monitoring locations were added by Revision 3, including sevetal in addition to those required by Technical Specification Table 3.12.1-2. Except for these two types of additions, Revision 3 was essentially unchanged from Revision 2. Therefore, no additional deficiencies were identified due to the issuance of Revision 3.
The NRC letter of March 9,1988 also requested that CEI address the items identified in the Conclusions section of the Technical Evaluati.on Report (TER), EGG-PHY-7731, which consisted of a review of the complete PNPP ODCM, updated through Revision 2 and TCN-1 through TCN-5. The Licensee's specific response, addressing each item in the Conclusions section of the
- review TER, was transmitted to the NRC separately from ODCM Revison 3,
- with a letter from A. Kaplan (CEI) to Document Control Desk (NRC), dated
- September 20, 1988. A copy of the Licensee's response, which includes verbatim copies of the recommendations from the review TER, is attached for convenient reference. This response was reviewed by EG&G at the INEL and the results of the review were transmitted to the NRC wjth a letter from W. Serrano (EG&G) to W. Meinke (NRC), dated October 13, 1988.
Changes to the ODCM made by CEI in response to the items identified in the review of ODCM Revision 2 were transmitted to the NRC as part of TCN-4 to ODCM Revision 3 as an attachment of the Licensee's semiannual eff3uent release report for Jun-Dec 1988 with a letter from A. Kaplan (NRC) to Document Control Desk (NRC), dated March 1, 1989.
The following discussions address items in the Conclusions section of the review TER for ODCM Revision 2 to which the Licensee did not respond essentially as recommended, except those items discussing ODCM methodology that is more conservative than recommended by NUREG-0133, NUREG-0473, and Regulatory Guide 1.109, Revision 1. These discussions include l consideration of the explanations given in the Licensee's response (in the September 20, 1988 letter referenced above) to the points raised in the review TER, and the changes made by TCN-4 to ODCM Revision 3 to correct l
deficiencies identified in the TER.
Maior Discrepancies (1). This item in the review TER (EGG-PHY-7731) for i Revision 2 of the ODCM expressed concern that the inclusion of the factor l
"fma / fact" in Equation 2.1-7 for the liquid effluent radioactivity mondorsetpointmayresultinthepossibilityofinadvertentlyreleasing a tank having higher activity than the intended tank. The Licensee's response stated that " Administrative controls are in place to preclude the chance of inadvertent release of an unintended tank." The Licensee's response also stated that " procedural guidance includes an additional factor of two conservatism by reducing the specified liquid radwaste tank discharge flow I
rate to half the calculated allowable value." This statement apparently means that fmax/ fact is normally 2.0, in which case the radioactivity monitor setpoint in combination with the radwaste flow monitor setpoint would restrict the release rate so the offsite concentration would be no more than 20% of the 10 CFR 20 values. Therefore, the Licensee's methodology insures that the concentration of radioactive materials in liquid effluents does not exceed the limits of Technical Specification 3.11.1.1.
3.11.1.1.Maior Discrepancies (#2). This item concerned the use of the product M F in the denominator of Equations 2.3-1, 2.3-2, and 2.3-3 whereas 10e corresponding equations in NUREG-0133 limit the the use of the equivalent of the product (Mo F) to 1000 cfs except for the potable water pathway. The Licensee's response indicates that the dose calculation methods given in Regulatory Guide 1.109 are used in the Perry ODCM. These methods include use of a " mixing ratio" (M p ) which is the inverse of the
" dilution factor" (M )n used by the Licensee. The Final Environmental Statement (JJH, NUREG-0884, for the Perry plant indicates that the total liquid blowdown for one unit is approximately 50 cfs (although there appears to be some inconsistency in the values in the FES). Using 50 cfs for the value of F and ODCM Table 2.3-10 for the values of M in Equations 2.31,2.3-2,and2.3-3leadstotheconclusionthEtthe . -
Licensee's dose calculation methodology would conform to the
, recommendations of NUREG-0133 if the calculations were rewritten in the format and terminology of that document. However, for clarity and completeness of the ODCM, the value of the flow rate, F, should be given and the values of Mp should be referenced or justified. ,
Maior Discrepancies (#3. #4 and #6). These items expressed concern about parts of the Licensee's methodology in ODCM Sections 3.2.3 and 3.3.3 that allowed some confusion concerning the period of time for which dose rates and doses are calculated. The Licensee's' responses explained how the methodology is applied, and TCN-4 to Revision 3 of the ODCM included minor changes to these sections that make it more clear that the proper dose rates and doses are calculated using the methodology described.
Additional Discrepancies (#4). The discussion for " Major Discrepancies
(#3, #4, and #6)" above apply (i.e., the methodology is slightly confusing on first reading, but the dose rates and doses are being determined correctly).
Additional Discrepancies (#5 and #6). The Licensee realizes that some data tables in the ODCM are duplicates, but prefers to retain the present format so each ODCM section is complete within itself.
Additional Discrepancies (#8). This item concerned lack of a simplified diagram illustrating the solid waste treatment system in the ODCM. The Licensee's response states that all matters pertaining to solidified waste treatment are contained in Perry's Process Control Program (PCP).
Figure 2 of the PCP is a simplified diagram of the solid waste processing system. -
Additional Discrepancies (#9). This item in the review TER erroneously referred to REMP Location #28 instead of #29. The particular discrepancy 2
4 intended to be noted (the omission of Location #29 from ODCM Table 5.1-1) has been corrected in the ODCM. However, the previous milk control location (REMP Location #33) was deleted by TCN-3 to ODCM Revision 3 and no other control location was designated. A control location should be designated, as required by Technical Specification Table 3.12.1-2. (One of the milk sampling locations, REMP Location #51, very nearly meets the criteria for the required control location since it is located at 9.2 miles [14.8 kilometers), whereas the requirement for the control location is that it be between 15 and 30 kilometers).
Successions (#2). The Licensee noted the suggestion thut.the bioaccumulation factor of 1.0E+05 for phosphorous be replaced by 3.0E+03, but stated that identification of the source of the lower value would be !
appreciated. The reference for the lower value is: E. F. Branagan, C. R.
Nichols and C. A. Willis, "Importance of P-32 in Nuclear Reactor Liquid Effluents, " Health Physics Society Annual Meeting, June 1982.
Successions (#3). This item concerned the dilution ratios given in ODCM Table 2.3-10 for liquid effluents, and noted that it may be possible to eliminate this table if the ODCM inethodology for dealing with the dilution i of liquid effluents were changed somewhat. The Licensee prefers to retain the present methodology for calculations relating to dose wmmitments due. .
to releases of radioactive material in liquio effluents. The subject of dilution of liquid effluents is discussed under " Major Discrepancies (#2)"
' above.
In general, the methodology used in the Licensee's ODCM updated through TCN-4 to Revision 3 meets all the requirements of NUREG-0133 and other NRC guidance. The only changes that may be needed are the miner additions recommended under " Major Discrepancies (#2)" and " Additional Discrepancies
(#9)" above. ,
This review was performed by T. E. Young.
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3
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+ . -
, ATTACHMENT 1 PY-CEI/NRR-0912L RESPONSE TO NRC REVIEV C0KMEhTS ON TEE FNPP OFFSITE DOSE CALCULATION MANUAL i
Major Discrepancies
- 1. In Section 2.1.1.4, it is' uncertain if the ratio f -to-f should be included in the e::pression for determining the IIIpoint act If the ratio is not included, then the monitor could guard against inadvertently releasing an incorrect tank. If the ratio is included, it may be possible to inadvertently release a tank having higher activity than the intended tank and still be within the limiting radiation setpoint calculated for the intended tank.
Response: ODCH Section 2.1.1 4 Honitor Alarm Setpoint.
Determination, was written and is. implemented to ensure Technical Specification 3.11.1.1 (10 CFR Part 20, Appendix B) compliance.
Furthermore, ODCH calculations limit liquid radvas+e releases to . .
1/10 of these Technical Specification limits. The primary means
, of limit control is provided by the liquid radvaste discharge flov monitor alarm setpoint (for which procedural guidance includes an additional factor of two conservatism by reducing the specified liquid radvaste tank discharge flow rate to, half of the calculated allovable value.) The f -to-f factor was includedintheliquidradvastedisE$arger$0ationmonitor setpoint as an adjustment factor (to account for the difference between the actual radvaste discharge flow rate to be used and the maximum allovable radvaste discharge flow rate) in order to allow operational flexibility, i.e., minimization of setpoint changes, and to eliminate spurious alarms. Administrative controls are in place to preclude the chance of the inadvertent release of an unintended tank.
- 2. 'The product M F in the denominator of Equations 2.3-1, 2.3-2, and l 2.3-3shouldEereplacedwithF,whereFisdefinedastheaverage dilution flov during the reporting period times an adjustment I
factor.
I Response: The evaluation section of the Technical Evaluation Report for the Evaluation of ODCH Revision 2, discusses agreement of liquid dose calculation methodologies between the ODCH and NUREC-0133. The F term used in our ODCH includes the actual dilution flow provided by the Service Vater and Emergency Service Vater Systems during the period of liquid radvaste release. This term does not exceed the 1000 cfs limit included in NUREG-0133.
The H term (as outlined in Regulatory Guide 1.109) accounts for thedilution'thatoccursoncetheeffluentleavestheareaofthe plant discharge structure, as covered in Section 4.3.1 of NUREG-0133 (term y D of the dose factor equation).
-- -___------ ------ _ J
ATTACHMENT 1 PY-CEI/NRR-0912L
- 3. The definition for 0 3in Section 3.2.3 should be defined as the average release rate based on the analysis of charcoal and particulate samplers that are collected on a weekly basis as required by Technical Specification Table 4.11.2.1.2-1 instead of being defined as the annual average release rate.
Response: The Og term in ODCH Equation 3.2-1 is the release rate of radionuclides i in uCi/s. The actual values used for calculations are those of the actual release period. For the purpose of calculating an annual dose rate, the release rates for the sample period are assumed to continue at the respective Icvels for a year, hence the wording " annual average" release rate.
- 4. The equations in Sections 3.3.3.a and 3.3.3.b calculate air dose rate in mrad / year instead of dose in mrad. A time factor must be included in the equations to calculate the monthly dose.
.s Response:_ Sections 3.3.3.a and 3.3.3.b calculate gamma and beta air dose to evaluate 10CFR50 Appendix I compliance. 10CTR50 Appendix I limits are based on an ennual period, i.e., dose -
- limits are iri the units of mrad per year. (Per 10CFR50, Appendix -
. I, quarterly values one half the annual limits require written notification.) These equations are written to evaluate this annual limit. Doses are actually calculated for the period of release, using meteorological conditions concurrent vjth that release and the duration of release, and that dose is then compared to the annual limit. These calculations are performed at least monthly, as required by Technical Specifications. The- ;
equations are written, however, to tvaluate the annual limits.
- 5. X/0 in Sections 3.3.3.a and 3.3.3.b is defined as the normal relative dispersion factor which is the product of the highest ,
annual average X/0 for the point of concern times the occupancy :
factor. For these calculations, the occupancy factor must be set to 1 to calculate the maximum dose to air. Therefore, the X/0 term must be redefined as the highest annual average relative dispersion factor.
Response: The X/0 term in Sections 3.3.3.a and 3.3.3.b is defined as "the normal relative dispersion factor". These X/0 values are )
calculated using conditions present during the period of release. l as stated in the response to the preceding discrepancy.
Occupancy factors are not applied here. Confusion, related to I occupancy factors, may have been caused by the discussion in Section 4.3, Dose to Hembers of the Public vhile Onsite, where a
" relative X/0* term is used. The " relative X/0" used in Section 4.3 calculations, which incorporates an occupancy factor correction to an ennual average X/0. is not the same X/0 as that j
used in Section 3.3.3.a and 3.3.3.b calculations. The X/0 term used in Sections 3.3.3.a and 3.3.3.b is the X/0 term that is defined in Appendix A. A reference to Appendix A vill be added to the Section 3.3.3a and b. X/0 terms, to clarify this point. )
J l
l
s .
ATTACHMENT 1 PY-CEI/NRR-0912L' ,
- 6. In Section 3.3.3, the method for time integration should be explained for converting dose rate to dose for I-131, I-133, tritium and radionuclides in particulate form with half-lives greater than 8 days. ,
Response: Annual dose rates resulting from the release of I-131, I-133, tritium and radionuclides in particulate form with half-lives greater than 8 days, as well as noble gas gamma and beta air dose, are calculated using the equations specified in the text. Dose values are obtained by applying the dose rates over the appropriate surveillance or sampling period. The ODCM is in the process of being revised to reflect this wording.
Additional Discrepancies
- 1. Figure 3.0-1 (probably page 29) shoving the gaseous effluent release
. points is missing from the ODCM.
Response: As noted in the NRC cover letter forwarding this TER, -
Figure 3.0-1 was found by the NRC and was reviewed. The NRC ~
requested that this complex figure be replaced with a simplified '
block diagram. This figure has therefore been redrafted, for
% inclusion in the ODCH, to improve clarity. This redrafted figure is enclosed for your information as Attachment 2 to this letter.
- 2. Section 3.2.2 states that the controlling location for the dose rate limit due to the release of I-131 I-133, tritium, and radionuclides in particulate form with half-lives greater than eight days is a function of the highest relative depos,ition, D/0. Since the dose rate is via the inhalation pathway as. stated in the bases statement for Technical Specification 3.11.2.1.b then the dose rate is dependent on the X/0 and not D/0.
Response: Dose rate calculations for the release of I-131, I-133, tritium, and radionuclides in particulate form with half-lives greater than eight days include contributions from several pathways. Per ODCM Table 3.2-3: these pathvays include ground shine, vegetables, meat, milk and inhalation. Calculations for all pathvays other than inhalation use D/0; inhalation pathvay calculations use X/0. Section 3.2.2 o' the ODCM is in the process of being revised to include X/O in this discussion.
I
- 3. Section 3.2.2 contains Equation (3.2-1), a general equation for the dose rate via several pathvays. The section vould be considerably simpler, if the dose rate calculation vere limited to the child's thyroid via inhalation pathvay for consistency with the bases 1 statement of Technical Specification 3.11.2.1. !
Response: Dose rates are calculated for several pathways, age ;
groups, and organs (specified in Tables 3.2-1 through 3.2-3): one combination of which is the thyroid dose rate to child via the inhalation pathvay. By calculating other dose rates, ve are ensuring more complete Technical Specification compliance
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w i
.. ATTACHMENT l'
, PY-CE1/NRR-0912L
, assessment. This combination was taken from the text of -
NUREG-0473 as part.of an attempt to remain as consistent as possible to wording in that Guide. Dose rate compliance is evaluated for.the above mentioned combination, among others, in
.the calculations outlined in this section. ,
4.- 04 in Sections 3.3.3.a and 3.3.3.b should be defined as the average r61 ease rate of radionuclides i during the reporting period instead of the release rate of radionuclides i.
Response: As stated above, doses, per Sections 3.3.3.a and
' 3.3.3.b. are calculated for the period of release (and concurrent meteorological conditions) and those doses compared to the annual limit. Hence, the actual release rate for isotope "1" is used.
The data in Table 3.2-5 referenced in DFG U in Section.3.2.3.c are 5.
identical to'the data in Table 2.3-9.
.. Response: External dose factors are used for liquid and gaseous -
calculations. Tables of these factors are included in both sections for esse of user reference and to keep each section . .
(liquid and gaseous) separate, yet ' complete entities.
. 6. The data in Tables 3.2110 through 3.2-13 referenced in DTI in Section3.2.3.dareidenticaltothedatainTables2.3-5INough 2.3-8, respectively. It is not clear why two sets of identical tables are included in the ODCH.
Response: See r'esponse to Additional Discrepancy 5.
- 7. A simplified diagram illustrating the discharge pathways for the radioactive gaseous vaste systems is not included in the ODCH.
See response to Additional Discrepancy 1.
Response
- 8. A sirnplified diagram illustrating the solid vaste treatment system is not included in the ODCM.
Response: All matters pertaining to solidified vaste treatment (and devatering) are. contained in Perry's Process Control Program (PCP) which has been previously submittad under a separate cover.
- 9. Table 5.1-1 of the ODCH does not include control location 28 for the milk sample.
Response: REMP Location 28, a vater sample control, is contained in the waterborne sampling media portion of Table 5.1-1.
- 10. Figures 5.1-1, 5.1-2, and 5.1-3 containing Temporary change 5 to the !
Environmental' Moni'oring Program map are missing in the ODCM. The )
available maps, updated through Temporary Change 4, do not identify j sample locations 29, 44, 48, 52 S3, 54, 55, and 56. l I
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l ATTACHMENT 1 PY-CEI/NRR-0912L Response: As noted in the NRC cover letter forwarding this TER, Figure.= 5.1-1, 5.1-2, and 5.1-3 vere found by the NRC and have been reviewed. The REMP figures in the current version of the ODCM are up to date and include all locations listed in the REMP tabler. -
Suggestions
- 1. In Equation 2.3-3 the exponential buildup term 1,neludes a 20 year value for t the period of time for which the sediment is exposed to the contIm,inated vater. The 20 years is a conservative value and could probably be replaced with a lesser value which would be increased 3r the plant ages. ,
Responsc: The twenty year exponential build up term was incorporated at the request of our original NRC (NRR) ODCM revievers. ,
- 2. In Table 2.3 4, the bioaccumulation factor of 1.0E+05 for phosphorous could be replaced with a lesser value of 3.0E403. , .
'- Response: The bioaccumulation factor of 1.0E405 for phosphorous was taken f rne Regul~atory Guide 1.109 Revision 1, Table A-1,
, f reshre.t e: fish. Ve vere not avare of the 3.0E.03 value and 4 vould(appreciate identification of its source. .
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- 3. Table 2.3-10 lists current values for the dilution ratios M . If the adjustment f actor allowed by NUREG 0133 is included in Ehe dilution terms in the equations of Section 2.3.1, then Table 2.3-10 can be deleted from the ODCH.
Response: Perry plans to use the dilution ratios specified in Table 2.3-10 for liquid radioactive effluent dose calculations.
See the response to Major Discrepancy 2 for elaboration.
- 4. If the ne::t revision to the ODCM includes only the inhalation pathvay fe: the dose rate calculation in Section 3.2.3, then a better location for all the dose rate expressions of Section 3.2.3 vould be in Section 3.3 vhere they are used in the dose calculation due to the release of I-131, I-133, tritium and radionuclides in particulate form with half-lives greater than eight days.
Response: Perty opts to use the organs. age groups, and pathvays
~ specified in Tables 3.2-1, 3.2-2, and 3.2-3, respectively, f or dose rate compliance assessment. This approach is considered l more conservative, see the response to Additional Discrepancy 3 for elaboration.
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