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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217D5211999-09-30030 September 1999 Informs That Remediating 3D Monicore Sys at Pbaps,Units 2 & 3 & 3D Monicore/Plant Monitoring Sys at Lgs,Unit 2 Has Been Completed Ahead of Schedule ML20216J3981999-09-29029 September 1999 Submits Comments for Lgs,Unit 1 & Pbaps,Units 2 & 3 Rvid,Rev 2,based on Review as Requested in GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity ML20212J6561999-09-29029 September 1999 Informs of Completion of mid-cycle PPR of Limerick Generating Station on 990913.Identified No Areas in Which Licensee Performance Warranted Addl Insp Beyond Core Insp Program.Historical Listing of Plant Issues Encl ML20212H6401999-09-24024 September 1999 Forwards Revised Epips,Including Rev 11 to ERP-101 & Rev 18 to ERP-800.Copy of Computer Generated Rept Index Identifying Latest Revs of LGS Erps,Encl ML20212E7941999-09-22022 September 1999 Requests Authorization for Listed Licensed Operators to Temporarily Suspend Participation in Licensed Operator Requalification Program at LGS ML20212E8081999-09-22022 September 1999 Provides Notification That Listed Operators Have Been Permanently Reassigned to Duties That Do Not Require Maintaining Licensed Operator Status,Per 10CFR50.74 ML20212F5481999-09-20020 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing, for Pbaps,Units 2 & 3 & Lgs,Units 1 & 2 ML20212F8991999-09-17017 September 1999 Provides Written Confirmation That Thermo-Lag 330-1 Fire Barrier Corrective Actions at Lgs,Units 1 & 2 Have Been Completed 05000353/LER-1999-010, Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl1999-09-16016 September 1999 Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl ML20216F7821999-09-16016 September 1999 Forwards Insp Repts 50-352/99-05 & 50-353/99-05 on 990713-0816.One Violation Noted & Being Treated as NCV, Consistent with App C of Enforcement Policy.Violation Re Inoperability of Automatic Depression Sys During Maint ML20212A8751999-09-13013 September 1999 Forwards Safety Evaluation of First & Second 10-year Interval Inservice Insp Plan Request for Relief ML20211N5061999-09-0909 September 1999 Forwards TSs Bases Pages B 3/4 10-2 & B 3/4 2-4 for LGS, Units 1 & 2,being Issued to Assure Distribution of Revised Bases Pages to All Holders of TSs ML20212A0091999-09-0909 September 1999 Provides Notification That Licenses SOP-11172 & SOP-11321, for SO Muntzenberger & Rh Wright,Respectively,Are No Longer Necessary as Result of Permanent Reassignment ML20211P8571999-09-0808 September 1999 Forwards Reactor Operator Retake Exams 50-352/99-303OL & 50-353/99-303OL Conducted on 990812 ML20211P3891999-09-0303 September 1999 Informs That During 990902 Telcon Between J Williams & B Tracy,Arrangements Were Made for NRC to Inspect Licensed Operator Requalification Program at Plant.Insp Planned for Wk of 991018 05000352/LER-1999-009, Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed1999-09-0101 September 1999 Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed ML20211H2571999-08-26026 August 1999 Informs of Individual Exam Result on Initial Retake Exam on 990812.One Individual Was Administered Exam & Passed ML20211E9191999-08-24024 August 1999 Forwards fitness-for-duty Program Performance Data for Jan-June 1999 for PBAPS & LGS IAW 10CFR26.71(d).Data Includes Listed Info ML20211E9731999-08-23023 August 1999 Forwards LGS Unit 2 Summary Rept for 970228 to 990525 Periodic ISI Rept Number 5, Per TS SRs 4.0.5 & 10CFR50.55a(g) ML20211D6761999-08-20020 August 1999 Forwards non-proprietary Revised Emergency Response Procedures (Erps),Including Rev 29 to ERP-110, Emergency Notification & Rev 17 to ERP-800, Maint Team & Proprietary App ERP-110-1.App Withheld Per 10CFR2.790(a)(6) ML20210T4271999-08-13013 August 1999 Informs That NRC Revised Info in Rvid & Releasing Rvid Version 2 as Result of Review of 980830 Responses to GL 92-01 Rev 1,GL 92-01 Rev 1 Suppl 1 & Suppl Rai.Tacs MA1197 & MA1198 Closed ML20210U2211999-08-10010 August 1999 Forwards Insp Repts 50-352/99-04 & 50-353/99-04 on 990525-0712.One Violation Occurred & Being Treated as NCV, Consistent with App C of Enforcement Policy.Violation Re Late Performance of off-gas Grab Sample Surveillance 05000353/LER-1999-005, Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint1999-08-10010 August 1999 Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint ML20211B7881999-08-10010 August 1999 Transmits Summary of Two Meetings with Risk-Informed TS Task Force in Rockville,Md on 990514 & 0714 ML20210M7571999-08-0404 August 1999 Forwards Response to Requesting Addl Info Re Status of Decommissioning Funding for Lgs,Pbaps & Sngs. Attachment Provides Restatement of Questions Followed by Response ML20210P4191999-08-0404 August 1999 Forwards Initial Exam Repts 50-352/99-302 & 50-353/99-302 on 990702-04 (Administration) & 990715-22 (Grading).Six of Limited SRO Applicants Passed All Portion of Exam NUREG-1092, Informs J Armstrong of Individual Exam Results for Applicants on Initial Exam Conducted on 990702 & 990712-14 at Facility.All Six Individuals Who Were Administered Exam, Passed Exam.Without Encls1999-08-0303 August 1999 Informs J Armstrong of Individual Exam Results for Applicants on Initial Exam Conducted on 990702 & 990712-14 at Facility.All Six Individuals Who Were Administered Exam, Passed Exam.Without Encls ML20210L2011999-07-28028 July 1999 Forwards Final Personal Qualification Statement (NRC Form 398) for Reactor Operator License Candidate LB Mchugh ML20211F2641999-07-27027 July 1999 Forwards Three Copies of Rev 12 to LGS Physical Security Plan, Rev 4 to LGS Training & Qualification Plan & Rev 2 to LGS Safeguards Contingency Plan. Without Encls 05000352/LER-1999-008, Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator1999-07-23023 July 1999 Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator 05000353/LER-1999-004, Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs1999-07-23023 July 1999 Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs ML20210E6211999-07-22022 July 1999 Submits Rev to non-limiting Licensing Basis LOCA Peak Clad Temps (Pcts) for Limerick Generating Station (Lgs),Units 1 & 2 & Pbaps,Units 2 & 3 ML20216D3081999-07-19019 July 1999 Requests Renewal of OLs for Listed Individuals,Iaw 10CFR55.57.NRC Forms 398 & 396,encl for Applicants.Without Encl ML20216D8041999-07-19019 July 1999 Submits Summary of Final PECO Nuclear Actions Taken to Resolve Scram Solenoid Pilot Valve Issues Identified in Info Notice 96-007 05000352/LER-1999-006, Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error1999-07-12012 July 1999 Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error ML20209F6341999-07-0909 July 1999 Submits Supplemental Response to GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs, for Unit 2.Rev 0 to 1H61R & GE-NE-B13-02010-33NP Repts & Revised Pages to Summary Rept Previously Submitted,Encl ML20209G9121999-07-0909 July 1999 Informs That Ja Hutton Has Been Appointed Director,Licensing for PECO Nuclear,Effective 990715.Previous Correspondence Addressed to Gd Edwards Should Now Be Sent to Ja Hutton ML20209C9041999-07-0808 July 1999 Forwards Monthly Operating Repts for June 1999 for Limerick Generating Station,Units 1 & 2 & Revised Monthly Repts for May 1999 ML20210B4441999-07-0808 July 1999 Forwards Preliminary NRC Form 398 & NRC Form 396 for Reactor Operator for License Candidate LB Mchugh.Candidate Failed Category B Portion of Operating Exam Given at LGS During Week of 990315.Tentative re-exam Has Been Scheduled 990812 05000353/LER-1999-003, Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure1999-07-0707 July 1999 Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure ML20209D8821999-07-0707 July 1999 Submits Estimate of Number of Licensing Actions Expected to Be Submitted in Years 2000 & 2001,as Requested by Administrative Ltr 99-02.Renewal Applications for PBAPS, Units 2 & 3,will Be Submitted in Second Half of 2001 ML20209D2671999-07-0202 July 1999 Responds to NRC 990322 & 0420 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves ML20196J6301999-07-0101 July 1999 Requests Addl Info Re Status of Decommissioning Funding for Limerick Generating Station,Units 1 & 2,Peach Bottom Atomic Power Station,Units 1,2 & 3 & Salem Nuclear Generating Station,Units 1 & 2 05000352/LER-1999-004, Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys1999-07-0101 July 1999 Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys ML20209B7001999-06-30030 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20212J5401999-06-28028 June 1999 Discusses Completion of Licensing Action for NRC Bulletin 96-003, Potential Plugging of ECC Suction Strainers by Debris in Bwrs. Bulletin Closed for Unit 2 by NRC ML20207H8271999-06-24024 June 1999 Informs NRC That Util Has Completed Core Shroud Insps for LGS Unit 2.Proprietary Rept GE-NE-B13-02010-33P & non-proprietary Rev 0 to 1H61R,encl.Proprietary Rept Withheld,Per 10CFR2.790(a)(4) ML20196G7041999-06-24024 June 1999 Forwards Insp Repts 50-352/99-03 & 50-353/99-03 on 990413- 0524.No Violations Noted.Nrc Concluded That Licensee Staff Continued to Operate Both Units Safely ML20196A5641999-06-15015 June 1999 Provides Info Re Util Use of Four Previously Irradiated LGS, Unit 1,GE11 Assemblies in Unit 2 Cycle 6.Encl 990518 GE Ltr Provides Objective of Lead Use Assemblies Program & Outlines Kinds of Measurements That Will Be Made on Assemblies ML20195J6831999-06-11011 June 1999 Provides Proprietary Objectives for Lgs,Units 1 & 2,1999 Emergency Preparedness Exercise Scheduled to Be Conducted on 990914.Licensee Identifies Which Individuals Should Receive Copies of Info.Proprietary Info Withheld 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217D5211999-09-30030 September 1999 Informs That Remediating 3D Monicore Sys at Pbaps,Units 2 & 3 & 3D Monicore/Plant Monitoring Sys at Lgs,Unit 2 Has Been Completed Ahead of Schedule ML20216J3981999-09-29029 September 1999 Submits Comments for Lgs,Unit 1 & Pbaps,Units 2 & 3 Rvid,Rev 2,based on Review as Requested in GL 92-01,rev 1,suppl 1, Reactor Vessel Structural Integrity ML20212H6401999-09-24024 September 1999 Forwards Revised Epips,Including Rev 11 to ERP-101 & Rev 18 to ERP-800.Copy of Computer Generated Rept Index Identifying Latest Revs of LGS Erps,Encl ML20212E7941999-09-22022 September 1999 Requests Authorization for Listed Licensed Operators to Temporarily Suspend Participation in Licensed Operator Requalification Program at LGS ML20212E8081999-09-22022 September 1999 Provides Notification That Listed Operators Have Been Permanently Reassigned to Duties That Do Not Require Maintaining Licensed Operator Status,Per 10CFR50.74 ML20212F5481999-09-20020 September 1999 Forwards Response to NRC Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing, for Pbaps,Units 2 & 3 & Lgs,Units 1 & 2 ML20212F8991999-09-17017 September 1999 Provides Written Confirmation That Thermo-Lag 330-1 Fire Barrier Corrective Actions at Lgs,Units 1 & 2 Have Been Completed 05000353/LER-1999-010, Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl1999-09-16016 September 1999 Forwards LER 99-010-00,re Manual Actuation of Esf.Main CR Ventilation Sys Was Placed in Chlorine Isolation Mode Due to Rept of Faint Odor of Chlorine in Unit 2 Reactor Encl ML20212A0091999-09-0909 September 1999 Provides Notification That Licenses SOP-11172 & SOP-11321, for SO Muntzenberger & Rh Wright,Respectively,Are No Longer Necessary as Result of Permanent Reassignment 05000352/LER-1999-009, Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed1999-09-0101 September 1999 Forwards LER 99-009-00,providing 30-day Written follow-up Rept Re Performance of Maint That Affected Safeguard Sys for Which Compensatory Measures Had Not Been Employed ML20211E9191999-08-24024 August 1999 Forwards fitness-for-duty Program Performance Data for Jan-June 1999 for PBAPS & LGS IAW 10CFR26.71(d).Data Includes Listed Info ML20211E9731999-08-23023 August 1999 Forwards LGS Unit 2 Summary Rept for 970228 to 990525 Periodic ISI Rept Number 5, Per TS SRs 4.0.5 & 10CFR50.55a(g) ML20211D6761999-08-20020 August 1999 Forwards non-proprietary Revised Emergency Response Procedures (Erps),Including Rev 29 to ERP-110, Emergency Notification & Rev 17 to ERP-800, Maint Team & Proprietary App ERP-110-1.App Withheld Per 10CFR2.790(a)(6) 05000353/LER-1999-005, Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint1999-08-10010 August 1999 Forwards LER 99-005-00,re Actuation of Primary Containment & Reactor Vessel Isolation Control Sys,Esf.Fuse Failed Due to Mechanical Failure of Cold Solder Joint ML20210M7571999-08-0404 August 1999 Forwards Response to Requesting Addl Info Re Status of Decommissioning Funding for Lgs,Pbaps & Sngs. Attachment Provides Restatement of Questions Followed by Response ML20210L2011999-07-28028 July 1999 Forwards Final Personal Qualification Statement (NRC Form 398) for Reactor Operator License Candidate LB Mchugh ML20211F2641999-07-27027 July 1999 Forwards Three Copies of Rev 12 to LGS Physical Security Plan, Rev 4 to LGS Training & Qualification Plan & Rev 2 to LGS Safeguards Contingency Plan. Without Encls 05000352/LER-1999-008, Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator1999-07-23023 July 1999 Forwards LER 99-008-00 Re 990623 Failure of Plant HPCI Sys to Start Due to Failure of HPCI Turbine,Hydraulic Actuator 05000353/LER-1999-004, Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs1999-07-23023 July 1999 Forwards LER 99-004-00 Re 990701 Discovery of Pressure Setpoint Drift of Thirteen Mss SRV Due to Corrosion Induced Bonding within SRVs ML20210E6211999-07-22022 July 1999 Submits Rev to non-limiting Licensing Basis LOCA Peak Clad Temps (Pcts) for Limerick Generating Station (Lgs),Units 1 & 2 & Pbaps,Units 2 & 3 ML20216D3081999-07-19019 July 1999 Requests Renewal of OLs for Listed Individuals,Iaw 10CFR55.57.NRC Forms 398 & 396,encl for Applicants.Without Encl ML20216D8041999-07-19019 July 1999 Submits Summary of Final PECO Nuclear Actions Taken to Resolve Scram Solenoid Pilot Valve Issues Identified in Info Notice 96-007 05000352/LER-1999-006, Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error1999-07-12012 July 1999 Forwards LER 99-006-00 Re 990614 Discovery That Grab Sample of Plant Offgas Sys Was Not Obtained within Time Limit Required by TS 3.3.7.12,Action 110 Due to Personnel Error ML20209F6341999-07-0909 July 1999 Submits Supplemental Response to GL 94-03, Intergranular Stress Corrosion Cracking of Core Shrouds in Bwrs, for Unit 2.Rev 0 to 1H61R & GE-NE-B13-02010-33NP Repts & Revised Pages to Summary Rept Previously Submitted,Encl ML20209G9121999-07-0909 July 1999 Informs That Ja Hutton Has Been Appointed Director,Licensing for PECO Nuclear,Effective 990715.Previous Correspondence Addressed to Gd Edwards Should Now Be Sent to Ja Hutton ML20210B4441999-07-0808 July 1999 Forwards Preliminary NRC Form 398 & NRC Form 396 for Reactor Operator for License Candidate LB Mchugh.Candidate Failed Category B Portion of Operating Exam Given at LGS During Week of 990315.Tentative re-exam Has Been Scheduled 990812 ML20209C9041999-07-0808 July 1999 Forwards Monthly Operating Repts for June 1999 for Limerick Generating Station,Units 1 & 2 & Revised Monthly Repts for May 1999 05000353/LER-1999-003, Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure1999-07-0707 July 1999 Forwards LER 99-003-00,re Bypass of RW Cleanup Leak Detection Sys Isolation Function on Three Separate Occasions.Bypass of Safety Function Was Caused by Inadequate Review & Approval of Change to Procedure ML20209D8821999-07-0707 July 1999 Submits Estimate of Number of Licensing Actions Expected to Be Submitted in Years 2000 & 2001,as Requested by Administrative Ltr 99-02.Renewal Applications for PBAPS, Units 2 & 3,will Be Submitted in Second Half of 2001 ML20209D2671999-07-0202 July 1999 Responds to NRC 990322 & 0420 RAI Re GL 96-05, Periodic Verification of Design-Basis Capability of Safety-Related Motor-Operated Valves 05000352/LER-1999-004, Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys1999-07-0101 July 1999 Forwards LER 99-004-00,re Inoperability of Automatic Depressurization Sys Portion of Eccs.Condition Resulted from Incomplete Impact Review of Isolating Portion of ADS Nitrogen Backup Supply on Operability of ECCS Sys ML20209B7001999-06-30030 June 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Nuclear Power Plants ML20207H8271999-06-24024 June 1999 Informs NRC That Util Has Completed Core Shroud Insps for LGS Unit 2.Proprietary Rept GE-NE-B13-02010-33P & non-proprietary Rev 0 to 1H61R,encl.Proprietary Rept Withheld,Per 10CFR2.790(a)(4) ML20196A5641999-06-15015 June 1999 Provides Info Re Util Use of Four Previously Irradiated LGS, Unit 1,GE11 Assemblies in Unit 2 Cycle 6.Encl 990518 GE Ltr Provides Objective of Lead Use Assemblies Program & Outlines Kinds of Measurements That Will Be Made on Assemblies ML20195J6831999-06-11011 June 1999 Provides Proprietary Objectives for Lgs,Units 1 & 2,1999 Emergency Preparedness Exercise Scheduled to Be Conducted on 990914.Licensee Identifies Which Individuals Should Receive Copies of Info.Proprietary Info Withheld ML20195G4591999-06-10010 June 1999 Forwards MORs for May 1999 & Revised Repts for Apr 1999 for LGS Units 1 & 2 ML20195H0531999-06-0909 June 1999 Forwards Revised Bases Pages B3/4 10-2 & B3/4 2-4 for LGS Units 1 & 2,in Order to Clarify That Requirements for Reactor Enclosure Secondary Containment Apply to Extended Area Encompassing Both Reactor Enclosure & Refueling Area ML20195E7701999-06-0707 June 1999 Provides Notification of Change to NPDES Permit PA0052221, for Bradshaw Reservoir Facility Which Supports Operation of Lgs,Units 1 & 2,per EPP Section 3.2 ML20195C7631999-06-0101 June 1999 Notifies NRC That PECO Energy Has Completed Installation of New Large Capacity,Passive Strainers on RHR & Core Spray Sys Pump Suction Lines at Lgs,Unit 2,in Response to Ieb 96-003 ML20195D5381999-05-26026 May 1999 Forwards 1998 Occupational Exposure Tabulation Rept for LGS Units 1 & 2. Encl Is Diskette & Instructions.Rept Is Being re-submitted to Reset 12 Month Time Period.Without Disk ML20195B2821999-05-24024 May 1999 Requests That NRC Distribution Lists for LGS Be Updated. Marked-up Distribution List Showing Changes Is Attached ML20196L2891999-05-20020 May 1999 Provides Status Update of Thermo-Lag 330-1 Fire Barrier Corrective Actions,Iaw Commitments Made in ML20195B2951999-05-20020 May 1999 Forwards Rev 0 to LGS Unit 2 Reload 5,Cycle 6 COLR, IAW TS Section 6.9.1.12.Values Listed Have Been Determined Using NRC-approved Methodology & Are Established Such That All Applicable Limits of Plants Safety Analysis Are Met 05000352/LER-1999-003, Forwards LER 99-003-00,re Rps,Pcrvics Actuations.Ler Contains Special Rept Info for HPCI & Reactor Core Isolation Cooling Sys Injections Into Rv1999-05-19019 May 1999 Forwards LER 99-003-00,re Rps,Pcrvics Actuations.Ler Contains Special Rept Info for HPCI & Reactor Core Isolation Cooling Sys Injections Into Rv 05000353/LER-1999-002, Forwards LER 99-002-00,automatic Actuations of Primary Containment & Reactor Vessel Isolation Control Sys & Other Common Plant ESF Due to Loss of Power to a Rps/Ups Power Distribution Panel on 9904191999-05-18018 May 1999 Forwards LER 99-002-00,automatic Actuations of Primary Containment & Reactor Vessel Isolation Control Sys & Other Common Plant ESF Due to Loss of Power to a Rps/Ups Power Distribution Panel on 990419 ML20206E2001999-04-28028 April 1999 Forwards 1998 Annual Environ Operating Rept (Non- Radiological) for Limerick Generating Station,Units 1 & 2. Rept Submitted IAW Section 5.4.1 of App B of Fols,Epp (Non- Radiological) & Describes Implementation of EPP for 1998 ML20206D8801999-04-27027 April 1999 Forwards Rev 2 to LGS Unit 1 Reload 7,Cycle 8 COLR, IAW TS Section 6.9.1.12.COLR Provides cycle-specific Parameter Limits for Noted Info ML20206A5461999-04-21021 April 1999 Responds to Conference Call Between Util & NRC on 990420,re TS Change Request 98-07-2,revising TS Section 2.0 to Incorporate Revised MCPR Safety Limits.Attached Ltr Contains Info Requested ML20205T0441999-04-17017 April 1999 Forwards 1998 Annual Radiological Environ Operating Rept 15, IAW TS Section 6.9.1.7.REMP for 1998,confirmed That LGS Environ Effects from Radioactive Release Were Well Below LGS TSs & Other Applicable Regulatory Limits ML20205Q7581999-04-15015 April 1999 Forwards Response to RAI Re ISI Program First & Second 10-Yr Interval Relief Requests.Revs to Identified by Vertical Bar in Right Margin 1999-09-09
[Table view] Category:UTILITY TO NRC
MONTHYEARML20059K3671990-09-14014 September 1990 Informs of Revised Commitments Re Crud Induced Localized Corrosion Related to Fuel Cladding Failures.Deep Bed Demineralizers Installation Activities Will Be Performed in Unit 1 Subsequent to Third Refueling Outage ML20065D4421990-09-14014 September 1990 Responds to Generic Ltr 90-07, Operator Licensing Natl Exam Schedule. Proposed Schedules for Operator Licensing Exams, Requalification Exams & Generic Fundamental Exams Encl ML20064A5831990-09-0707 September 1990 Responds to Violations Noted in Insp Repts 50-352/90-17 & 50-353/90-16 Re Differential Pressure for Pumps.Corrective Actions:Licensee Will No Longer Use Expanded Ranges as Acceptance Criteria for Inservice Testing Program Tests ML20064A4821990-08-31031 August 1990 Forwards Rev 20 to Emergency Plan.Changes Necessitated by Annual Emergency Plan Update & Administrative in Nature ML20059E6071990-08-29029 August 1990 Forwards Semiannual Effluent Release Rept,Jan-June 1990 & Rev 8 to Odcm ML20059B0751990-08-24024 August 1990 Forwards Rev 0 to Updated FSAR for Limerick Generating Station,Units 1 & 2,Vols 1-19.W/one Oversize Encl. Proprietary Vol 7A (App 3B) Withheld (Ref 10CFR2.790) ML20064A6471990-08-24024 August 1990 Forwards Public Version of Revised Epips,Consisting of Rev 10 to EP-101,Rev 2 to EP-112,Rev 13 to EP-208,Rev 11 to EP-230 & Rev 22 to EP-291 ML20059E9861990-08-24024 August 1990 Provides Justification for Applicability of Reload Methodology Topical Repts to Facility & Requests NRC Approval for Application of Reload Analysis Methodologies ML20058N9591990-08-13013 August 1990 Forwards Revised Response to Violations Noted in Insp Repts 50-352/90-13 & 50-353/90-13.Corrective Actions:Ltr Issued to All Plant Personnel Providing Instructions on Proper Use & Handling of Controlled Documents in Controlled Locations ML20058N1771990-08-10010 August 1990 Responds to NRC Re Unresolved Items Noted in Insp Repts 50-352/90-80 & 50-353/90-80.Plant-specific Technical Guideline Has Been Revised to Ref Contingency Numbers Rather than Transient Response Implementation Plan Procedures ML20063P9461990-08-10010 August 1990 Provides Plans for Ultimate Disposition of Recirculation Inlet Nozzle to Safe End Weld Indication.Alternative Corrective Actions to Disposition Nozzle to Safe End Weld Indication Include Repair by Weld Overlay W/O Monitoring ML20058N1281990-08-0909 August 1990 Forwards Correction to Rev 10 to EPIP EP-234, Obtaining Containment Gas Samples from Containment Leak Detector During Emergencies ML20058N1991990-08-0909 August 1990 Advises of Change of Address for Correspondence Re Util Operations.All Incoming Correspondence Must Be Directed to One of Listed Addresses ML20058P1261990-08-0909 August 1990 Forwards Monthly Operating Repts for Jul 1990 for Limerick Units 1 & 2 & Rev 1 to June 1990 Rept ML20058M9951990-08-0808 August 1990 Responds to NRC Re Violations Noted in Insp Repts 50-352/90-15 & 50-353/90-14.Corrective Actions:Personnel Counseled on Importance of Procedure Compliance & Operations Manual Revised ML18095A3761990-07-26026 July 1990 Forwards Decommissioning Repts & Certification of Financial Assurance for Plants ML20055J0241990-07-26026 July 1990 Forwards Response to NRC Regulatory Effectiveness Review Rept for Plant.Response Withheld Per 10CFR73.21 ML20056A9731990-07-25025 July 1990 Forwards Facility Written Exam Comments for NRC Insp Repts 50-352/90-10 & 50-353/90-11.Written Exam for Reactor Operator & Senior Reactor Operator Considered Comprehensive & Thorough ML20055H8511990-07-24024 July 1990 Responds to NRC 900720 Request for Addl Info Re Util 900516 Request for Exemption from Full Participation During 1990 Onsite/Offsite Emergency Exercise.Nrc Region I & FEMA Support Feb 1991 Exercise,Per 900718 Telcon ML20055H8331990-07-20020 July 1990 Submits Change of Addresses for Correspondence Re Util Nuclear Operations ML20055H0231990-07-12012 July 1990 Forwards Public Version of Revised Epips,Including Rev 10 to EP-210,Rev 19 to EP-231 & Rev 13 to EP-237 ML20044A1041990-06-22022 June 1990 Forwards Application for Amends to Licenses NPF-39 & NPF-85, Consisting of Tech Spec Change Requests 90-03-0 & 90-04-0, Revising Surveillance Requirement 4.9.6.1 for Section 3.9.6 Refueling Platform Re Main Hoists/Auxiliary Hoists ML20043J0371990-06-20020 June 1990 Forwards Description,Scope,Objectives for Plant 1990 Annual Emergency Exercise Scheduled for 900920,per 890809 Ltr.Util Will Submit Revised Objectives for Exercise to Reflect Limited Participation,If Exemption Request Approved ML20043H6081990-06-19019 June 1990 Corrects 900427 Response to Generic Ltr 87-07, Info Transmittal of Final Rulemaking for Revs to Operator Licensing - 10CFR55 & Conforming Amends. ML20055C7621990-06-18018 June 1990 Informs NRC of Plans Re Licensing of Senior Reactor Operators (Sros) Limited to Fuel Handling at Plants.Util in Process of Implementing New Program for Establishment & Maint of Licensed SROs Limited to Fuel Handling at Plants ML20055C7471990-06-15015 June 1990 Requests That Listed Operator Licenses Be Discontinued ML20043G1331990-06-14014 June 1990 Responds to NRC 900614 Ltr Re Violations Noted in Insp Repts 50-352/90-13 & 50-353/90-12.Corrective Actions:Boxes of Completed Procedures Improperly Stored Shipped to Util Storage Vault by 900406 ML20043G9981990-06-12012 June 1990 Forwards, Core Operating Limits Rept for Unit 1 Reload 2, Cycle 3 & Core Operating Limits Rept for Unit 2,Cycle 1. Repts Submitted in Support of Tech Spec Change Request 89-13 Re Parameter Limits,Per Generic Ltr 88-16 ML20043G7311990-06-0808 June 1990 Provides Addl Response to Generic Ltr 88-01, NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping. Welds Examined During Last Refueling Outage Addressed ML20043G7501990-06-0808 June 1990 Requests Withdrawal of 900516 Tech Spec Change Request 90-11-1 Re Extension of Snubber Visual Insp Period.Change No Longer Needed Since Unit Shutdown on 900605 & Visual Insp of Three Affected Snubbers Performed on 900607 ML20043F8021990-06-0808 June 1990 Forwards Monthly Operating Repts for May 1990 for Limerick Units 1 & 2 & Revised Pages to Mar 1990 Rept for Unit 2 & Apr 1990 Rept for Units 1 & 2 ML20043D8101990-05-29029 May 1990 Forwards Application for Amends to Licenses NPF-39 & NPF-85, Consisting of Tech Specs Change Request 89-07 to Relocate Radiological Effluent Tech Specs to ODCM or Process Control Program,Per Generic Ltr 89-01 ML20043E6571990-05-25025 May 1990 Forwards Public Version of Rev 135 to Epips,Including Rev 11 to EP-202,Rev 14 to EP-282,Rev 12 to EP-284,Rev 8 to EP-312 & Rev 9 to EP-410.W/DH Grimsley 900607 Release Memo ML20055C5121990-05-18018 May 1990 Provides Info Inadvertently Omitted in Re Property Insurance Coverage for Plants.Limerick Generating Station Unit 2 Should Have Been Ref as Being Included Under Insurance Coverage ML20043A7881990-05-16016 May 1990 Requests Exemption from Requirement to Perform Biennial full-participation Onsite/Offsite Emergency Exercise for Plant During 1990 ML20055C4851990-05-15015 May 1990 Forwards Annual Financial Repts for 1989 for Philadelphia Electric Co,Pse&G,Atlantic Energy,Inc & Delmarva Power & Light Co ML20043B1501990-05-14014 May 1990 Forwards Public Version of Rev 134 to Epips,Consisting of Rev 10 to EP-230,Rev 4 to EP-255,Rev 1 to EP-302,Rev 7 to EP-304 & Rev 3 to EP-314.Release Memo Encl ML20043A2361990-05-14014 May 1990 Responds to NRC 900413 Ltr Re Violations Noted in Insp Repts 50-352/90-07 & 50-353/90-06.Corrective Actions:Sampling Review of Plant Baseline Data Will Be Performed to Ensure Product Code Number Correctness for Components ML20042F4481990-05-0101 May 1990 Advises That Plant Transient Response Implementing Plan Procedures & Related Ref Matls Provided to Dj Florek,Nrc Region I,On 900430.Documents Provided in Response to NRC 900327 Ltr Re Preparation for Planned NRC Insp of Procedure ML20042E8741990-04-27027 April 1990 Responds to Generic Ltr 87-07, Info Transmittal of Final Rulemaking for Revs to Operator Licensing. Certifies That Limerick Operator Requalification Training Program Renewed on 900125 & Peach Bottom Subj Program Renewed on 890622 ML20042E0881990-04-0909 April 1990 Forwards Addl Info Re 891011 Tech Spec Change Request 89-09 to Reduce Number of Suppression chamber-to-drywell Vacuum Breakers Required to Be Operable ML20042E0201990-04-0606 April 1990 Forwards Vols 1-3 to Preservice Insp Summary Rept, & Books 1-3 to Form NIS-2 for Preservice Insp Interval 1985-1990, Per 10CFR50.55a(g) & ASME Code Section Xi,Paragraph IWA-6230 ML20012E2151990-03-20020 March 1990 Responds to Generic Ltr 89-19, Request for Action Re Resolution of USI A-47, 'Safety Implication of Control Sys in LWR Nuclear Power Plants,' for Peach Bottom.Response for Limerick Generating Station Will Be Provided by 900504 ML20012C2931990-03-12012 March 1990 Responds to Generic Ltr 90-01, Request for Voluntary Participation in NRC Regulatory Impact Survey, Per 900118 Request ML20012D9511990-03-0909 March 1990 Forwards Public Version of Revised Epips,Including Rev 10 to EP-203,Rev 12 to EP-317 & Rev 18 to EP-292.W/DH Grimsley 900322 Release Memo ML20012A3631990-03-0101 March 1990 Responds to NRC 900131 Ltr Re Violations Noted in Insp Rept 50-353/89-32 on 891211-15.Corrective Action:Util Will Document Both Receipt & Shipment of Fuel Loading Chambers on Next Semiannual Doe/Nrc Form 742 ML20012A1151990-02-28028 February 1990 Forwards Semiannual Effluent Release Rept 11,Jul Through Dec 1989 & Annual Tower 1 Joint Frequency Distributions of Wind Direction & Speed by Atmosphere Stability,Rept 5 for 1989. W/O Annual Tower 1 Rept ML20012A2621990-02-16016 February 1990 Forwards Public Version of Revs 124 & 125 to Epips, Consisting of Rev 9 to EP-201,Rev 20 to EP-291 & Rev 21 to EP-291 ML20006E7731990-02-16016 February 1990 Requests Discontinuation of Listed Operator Licenses ML20006E6511990-02-15015 February 1990 Discusses & Forwards Results of Field Verification Testing of Unit Spds,Per Licensee Commitment to Submit Rept within 30 Days After Unit SPDS Declared Operational.No Significant Problems Encountered W/Spds During Power Ascension Testing 1990-09-07
[Table view] |
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lln%,$Q[db~ lob 0 law orrscss CONNER & WETTERHAHN. P.C. 00CMETED 17 4 7 P E N N S Y LVA N I A AV EN UE. N w. UNC WA S H I % O TO N. D. C. 2 0006 mioS T wien oS June 13, 1986 '87 JAN -7 P3 54 CERN Ah S SCH NOS F S R
C ASLS ADOSSSS; ATOseLaw Mr. Darrell G. Eisenhut Acting Director Office of Nuclear Reactor .
Regulation 1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 In the Matter of Philadelphia Electric Company (Limerick Genarating Station, Units 1 and 2) ,~
Docket Nos. 50-352 and 50-353 Dear Mr. Eisenhuts
~ on June 2, 1986, the NRC noticed in the Federal'Regis-ter at 51 Fed. Reg. 19803 its receipt of a petition filed by Robert L. ' Anthony on March 5, pursuant to 10 C.F.R. 1986 with the Commission 550.100. The petition requested that the NRC suspend the operating license issued to Philadelphia Electric Company for its Limerick Generating Station, Unit-
- 1. In a letter from you to Mr. Anthony, dated May 27, 1986, you stated that the matter had been referred to you for 'a response pursuant to 10 C.F.R. 52.206.
\ttached are the Licensee's comunents in response to Mr.
Anthony's request. For the reasons stated therein, Mr.
Anthony quires action under has wholly failed to assert any matter which re-Section 2.206. There has been no violation of the Environmental Protection Plan for Limerick inasmuch as none of the recent revisions to the docket 4 decisions of the Delaware River Basin Commission cited by Mr. Anthony involves an unreviewed environmental question regarding operational s
affect the environment.
activities which may significantly As discussed in the attached comments, two of the three provisions for interim supple-i mental cooling water supplies in 1986 recently granted by DRBC in its docket revisions (substitution of dissolved
' oxygen monitoring for temperature constraints and availabil-ity of water allocations from other generating units on the Schuylkill) were previously granted in 1985.
1 The third provision for interim supplemental cooling water supplies recently granted by DRBC for 1986 (releases from Borough of 8702120614 860613 PDR
! P ADOCK 05000352 PDR -
7 Bo a-
. - s- ,
Darroll G. Eiconhut June 13, 1986 Page 2 Tamaqua Reservoirs). None of these revisions involves an unreviewed environmental question regarding operational activities which may significantly affect the environment.
As also explained in the attached comments, DRBC itself determined that the temporary changes in its docket de-cisions for Limerick would have no significant environmental impact. Our analysis also shows that no significant en-vironmental impact reportable under the Environmen t.a1 Protection Plan would occur under the revised docket de-cisions. As always, the Licensee will provide any further information desired by the Staff in reviewing this matter.
Accordingly, Mr. Anthony's petition under Section 2.206 should be denied.
Sincerely, D
, j S G ,2 > < W > .. 't .
t Troy 6nner, Jr.
Counsel for Philadelphia Electric Company TBC/dlf Enclosure cc: Eugene J. Bradley, Esq.
i i
9 l
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i I
_ . - . - _ . . _ . . _ . - . - . , _ _ _ _ , , , _ _ _ , _ . , , _ _ _ _ . _ . , . _ , . .m., ,, . . _ _ _ _ _ -_.,_..,_,,m, , , , , _ , , _ _ _ _ . , _ , _ . , _ , - _ , _ , , , _ , _ , . _ _ _ . , , , _ _ . . - . , _ _ _ _ , _ - . , , ,
COMMENTS OF PHILADELPHIA ELECTRIC COMPANY ON PETITION BY ROBERT L. ANTHONY UNDER 10 C.F.R. $2.206 RELATING TO REVISED DOCKET DECISIONS OF THE DELAWARE RIVER BASIN COMMISSION FOR TEMPORARY SUPPLEMENTAL COOLING WATER SUPPLIES IN 1986 FOR THE LIMERICK GENERATING STATION This is the third in a series of petitions under 10 C.F.R. 52.206 filed by Robert L. AnthonyM with the Nuclear Regulatory Commission ("NRC") with regard to temporary supplemental cooling water supplies for the Limerick Gen-erating Station, Unit 1 (" Limerick"), owned and operated by Philadelphia Electric Company (" Licensee").
Mr. Anthony alleges in his most recent petition, as he I
has in the past, that certain applications filed by Licensee with the Delaware River Basin Commission ("DRBC") have violated license conditions contained in Facility Operating License NPF-39, Appendix B, known as the Environmental
~
1/ Mr. Anthony states that he is filing his petition on behalf of Friends of the Earth (" FOE") , but gives no evidence that (1) any particular member of FOE has expressly authorized that organization to represent the member's interests in the petition filed by Mr. Anthony or that (2) FOE has ' authorized Mr. Anthony to represent
, the organization in the same matter. See Houston Lighting and Power Company (Allens Creek Nuclear Generating Station, Unit 1), ALAB-535, 9 NRC 377, 390 I
(1979); Texas Utilities Generating Company (Comanche Peak Steam Electric Station, Units , and 2), LBP-79-18, !
9 NRC 728 (1979); Detroit Edison Com)any (Enrico Fermi
'tomic A Power Plant, Unit 2), LBP-79-;., 9 NRC 73, 75-77 (1979).
I i
Protection Plan ("EPP"). On this basis, Mr. Anthony has requested the NRC to suspend the operating license.
The first in this series of requests under Section 2.206 by Mr. Anthony was filed on October 1, 1985, asking the NRC to require Licensee to withdraw an application then pending before DRBC- which sought temporary changes in existing docket conditions for the withdrawal and consump-tive use of water for Limerick Unit 1, during the remainder of 1985, when existing docket conditions would otherwise preclude withdrawal. Specifically, Licensee had sought permission from DRBC, for the balance of 1985, to withdraw water from the Schuylkill River for consumptive use at Limerick Unit I when.the flow at the Pottstown gage exceeds 415 cfs and dissolved oxygen ("Do") levels exceed values incorporated in Docket No. D-69-210 CP (Final) (Revised)
(May 29, 1985).O Subject to various conditions to ensure water quality for downstream users, DRBC approved the
~
2/ The license was issued by the NRC to Licensee on August 8, 1985 for Lime' rick Unit 1.
3,/ See Petition to Require PECo to Comply with the nequirements of License NPF-39, Appendix B, Para. 3.1 and 5.3 and to Withdraw an Application to DRBC to Lower
, Schuylkill Flow Restraint and to Permit Releases from i
, Beechwood Pit (October 1, 1985).,
~
4/ The application submitted to DRBC on September 20, 1985 was furnished :to the NRC by Licensee's counsel on i
I September 23, 1985.
I l .
1
request for a temporary (balance of 1985) reduction in the Schuylkill flow limitation to 415 cfs.E subsequently, the Acting Director denied the relief
, requested by Mr. Anthony in his petition of October 1, 1985.
In that decision, the Acting Director stated his expectation that the Licensee would examine any docket revision "in light of the terms of the license conditions set out above[,) . .
._make the appropriate determinations" required by the EPP and "should the activity involve an unreviewed environmental question, . . . obtain prior NRC approval.b/
Mr. Anthony filed the second in this series of Section
- 2.206 requests on January 17, 1986, similarly contending that an application filed by Licensee with DRBC on' December 16, 1985 violated certain EPP provisions.2/ That applica-tion sought, for 1986, the withdrawal of Schuylkill River water for consumptive use at Limerick Unit 1 by (1) tempo-rary substitution of in-stream monitoring of Do levels in 1
lieu of the existing 59'F temperature constraint and (2) i i
) ' ~
5/ See Docket No. D-69-210 CP (Final) (Rev. No. 4)
(October 30, 1985).
6/ Philadelphia Electric Company (Limerick Generatinq
! Station, Units 1 and 2), DD-85-18, 22 NRC 870, 872 (1985), quoting Limerick, supra, DD-85-8, 21 NRC 1561, 4
1566 (1985).
l 1
2/ *See Appeal by R.L. Anthony / FOE to the Director, NRR, to
! Requ'.re (Licensee] to Comply with the Requirements of >
l License No. NPF-39, Appendix B, in Applying to DRBC
, (January 17, 1986).
t '
's
. -4 _
transfer of the existing consumptive use allocations of l Titus Generating Station, Units 1, 2 and 3 and Cromby j Generating Station, Unit 2 to Limerick Unit 1. These alternative sources would be utilized when existing docket limitations would otherwise preclude the consumptive use of Schuylkill water for Limerick.8_/
In his January 17, 1986 petition, Mr. Anthony asserted, inter alia, that the application involved an unreviewed environmental question and required NRC approval prior to submission. By letter dated January 28, 1986, Licensee replied to the petition, noting that an evaluation "to 1
, determine whether DRBC's authorization involves any unre-viewed environmental question . . . cannot be performed until the Licensee has had an opportunity to review DRBC's ,
analysis in its decision, if favorable, as well as any 1 l conditions imposed in granting the requested au-thorization."EI '
- In dismissing the January 17, 1986 petition and finding no need for a formal decision, the Director stated that Mr.
Anthony "had failed to allege any present violations by PECo F
<i .
i j 8_/ A copy of this application was furnished to the NRC by Licensee's counsel on January 24, 1986.
i 9/ Letter from Troy B. Conner, Jr., counsel for the Licensee, to Harold R. Denton, Director, Office of Nuclear Reactor Regulation at 3 (January 28, 1986).
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4 of any NRC requirements including license conditions."UI The Director observed that "the requirements of EPP are triggered at the time PECo would take any proposed actions and so there could be no non-compliance until the actions were taken."NI The Director therefore concluded that "there is no need for the NRC to act" or issue a formal decision on the matter.NI Following his two earlier petitions, Mr. Anthony filed a third petition on this subject on March 5, 1986, which the Staff is now considering. Mr. Anthony contends that Licens-ee violated the Limerick EPP by implementing the docket revisions granted by DRBC for temporary relief in 1985 and by applying for similar relief for 1986. In particular, Mr.
Anthony alleges that the Licensee's operation of DO moni-toring equipment to obtain data in compliance with the i
revised DRBC docket decision for Schuylkill withdrawals required prior approval by the NRC under the EPP.
ImplementasIan of the relief granted by DRBC in its revised docket decisions has, of course, required Licensee to consider the potential applicability of the EPP's report-4 ing and approval provisions under EPP 13.1. On the basis of M/ Letter from Harold R. Denton, Director, Office of Nuclear Reactor Regulation to Robert L. Anthony j (February 26, 1986).
11/ Id. e
- 1 12/ Id.
4 l
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its analysis discussed below, Licensee concluded that no provision of the Limerick EPP had been triggered by the temporary DRBC docket revisions. Mr. Anthony apparently claims, however, that yny revision of the DRBC dockets, no matter how environmentally insignificant, would necessarily trigger the EPP's provisions. His interpretation is plainly wrong because it conflicts with the unambiguous text of the EPP.
Thus, EPP 13.1 states in relevant part:
Before engaging in additional con-struction or operational- activities which may significantly affect the environment, the licensee shall prepare and of record such an environmental evaluation activity. . . . When the evaluation indicates that such activity involves an unreviewed environmental question, the licensee shall provide 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 i
environmental question if it concerns:
(1) a matter which may result in a significant increase in any
' adverse environmental impact previously evalu-
!' ated in the FES-OL, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board; or (2) a significant change in affluents 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 i
adverse environmental impact. (Emphasis added.]
l
4 In other words, the reporting and prior approval requirements of EPP 13.1 are not triggered unless there is some "significant adverse" impact on the environment, regardless of whether the impact under consideration is a significant increase in some environmental impact previously evaluated or a significant new environmental impact not previously evaluated.
Under this standard, Licensee did consider the appli-cability of EPP 13.1 with respect to the 1985 docket re-visions by DRBC before it implemented each revision and has done so for the 1986 revisions, which it intends to imple-ment once the plant is returned to service. b The DRBC j docket decisions and underlying record of the applications themselves reflect that agency's environmental analysis of the proposed changes to facility operation and demonstrate l that the revised dockets do not contain any matter which I i
will have a significant adverse environmental impact.
The most recent docket decision contains two provisions for Schuylkill withdrawals in 1986 which constitute, in essence, the same temporary relief granted for the latter part of 1985.
In Docket No. D-69-210 CP (Final) (Revised) 1 (May 29, 1985), DRBC approved temporary substitution of DO monitoring in lieu of the 59'F temperature restriction on
~13/ Limerick Unit I was taken off line on May 2, 1986 for
. routine tests and maintenance.
I I
,,p-.-..,-r---- ., ,me,.+..--,,m__
.g Schuylkill withdrawals contained in the original docket.E l The purpose of the temperature constraint was explained as follows in that decision:
Exhibits introduced into the hearing record . . . addressed the rationale for the 59'[F] trigger restriction. In those exhibits, it is pointed out that DRBC's reason for the 59 ' (F] limitation relates to protection of an acceptable dissolved oxygen standard; and further, that higher water temperatures increase f the biological demand rate which in turn reduces the dissolved oxygen concen-tration.M/
Thus, substituting a DO restriction on Schuylkill withdrawals produces a result environmentally consistent with DO levels achievable by the existing temperature constraint. In choosing the Do standard, DRBC not only ensured compliance with water quality standards, but also applied more restrictive standards for protection of fish and aquatic -life in the Schuylkill. This two-tiered Do standard for Limerick withdrawals was recommended by the Pennsylvania Fish Commission.E Moreover, because DO varies over the day, and a number of hours are required to shut down plant operations if the DO criteria were M/ The request for the release of varying amounts of water from other Schuylkill water supply storage was denied.
~ 15/ DRBC Docket No. D-69-210 CP at p. 5 (Final) (Revised)
(May 29, 1985).
16/ Id. at 7.
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- , - _ r.-- - - , , __
triggered, DRBC created a margin of safety by adding an incremental value to each of the DO values established. E !
On this basis, DRBC concluded:
The objective of the 59' temperature limitation contained in the docket decision, original i was to prevent the '
Limerick project from dissolved oxygen conditions in the aggravating Schuylkill ods. The River during critical peri-temporary substitution of direct each critical dissolved oxygen monitoring at downstream location is consistent with that objective.
In addition, the dissolved oxygen monitors will provide data, not otherwise avail-able to the water resource agencies, for better management of the Schuylkill l
River.H/
DRBC therefore approved the temporary (balance of 1985) substitution of DO standards for the existing 59'F tempera-ture constraint and a monitoring system for recording DO data within 200 feet of each dam on the Schuylkill River located below the Limerick intake.N# As DRBC's analysis demonstrates, no increase in previously evaluated impacts or any new impact resulted from this docket revision because it merely provided a more direct means to achieve desired DO I
levels in the Schuylkill River.
- Subsequently, DRBC issued Docket No. D-69-210 CP (Final) (Rev. No. 2) (August 13, 1985). That decision f
- 17/ Id. at 8.
I 18/ M. at 11.
19/ Id. at 12.
l
f approved the transfer, through the balance of 1985, of the existing consumptive use allocations of Schuylkill basin waters from currently operating generating stations on the Schuylkill (Titus Units 1, 2 and 3 and Cromby Unit 2) to Limerick Unit 1. This transfer would be operative whenever existing flow constraints on Schuylkill withdrawals for Limerick Unit I would otherwise preclude such withdrawals.
Like the earlier docket revision, this approval by DRBC did not involve any increase in any previously evaluated en-vironmental impacts or any new impacts.
As DRBC noted, the purpose of the then existing flow constraint on withdrawalsM was two-fold, .i.e., "to protect water quantity and water quality below the Limerick Station."M# DRBC found that " operation of all units will be coordinated and the total consumptive use will not exceed the consumptive use that is currently available for the existing operating units."M I Thus, no change in the volume of consumptive use resulted.
2_Of The originally approved docket provided that Schttylkill water (not may be used for consumptive use only when flow including future augmentations of flow from Commission-sponsored projects) at the Pottstown gage
, exceeds two units.
530Docket cfs forNo. one Limerick unit and 560 cfs for D-69-210 CP at p. 3 (Final)
,Rev.
( No. 2) (August 13, 1985).
l 21/ id.
22/ Id. at 2.
4
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In evaluating impacts of the transferred consumptive uses on downstream users, DRBC found that the 23-mile stretch of the Schuylkill between the Titus plant and the downstream Limerick plant would be enhanced by the increase l
in stream flow over that distance. The decrease in otream '
flow from Limerick to the Cromby plant, nine miles below Limerick, would amount to only one percent of the Q 7-10 fl0" for that stretch.EI Accordingly, transfer of the Titus/Cromby consumptive use allocations to Limerick result-ed in negligible changes upon the Schuylkill flow regime.
As to impacts on water quality in the affected stretch-es of the Schuylkill, DRBC found that only minor fluc-tuations in the level of total dissolved solids ("TDS")
would result:
The transfer of the location of the consumptive use from Titus to Limerick will result in a slight lowering of total dissolved solids level in the Schuylkill River between Titus and Limerick. At a flow of 360 cfs and with the Titus units operating, the TDS level averages about 375 mg/l and calculations indicate that if the three units were shut down, the TDS should drop to 370 mg/1. At Limerick, when operating with a consumptive use of 5.2 mgd, the TDS would increase from 370 mg/l to 378 mg/l and below Cromby there should be no change in TDS resulting from the proposed transfer.M/
-23/ Id. at 4 O flow is a low daily flow which equals T seven c.onsdebkive day flow so far below average that its expected recurrence is ten years.
24/ Id.
I i i i
--12-- -
Accordingly, DRBC determined that impacts upon water quality were likewise insignificant.
In response to an application by Licensee submitted December 16, 1985, DRBC considered and approved, through December 31, 1986, essentially the same docket revisions it had previously approved for the latter part of 1985, i.e.,
temporary substitution of DO monitoring for the 59'F temper-ature constraint and the transfer of consumptive use allo-cations from other Schuylkill generating units.EI This approval entailed a review of its previous analyses and ap-provals and the adoption of additional conditions appropri-ate to Licensee's request. Specifically, DRBC approved DO monitoring for 1986, subject to an enhanced DO standard to provide special protection for spawning areas during the period of March 1 to June 15, 1986.EI Similarly, DRBC approved transfer of the Titus/Cromby consumptive use allocations for Limerick during 1986, subject to conditions restricting withdrawals based on the time those units had been shut down. E These temporary docket revisions for 1986 were based upon DRBC's review of its earlier evaluation of 25/ See Docket No. D-69-210 CP (Final) (Rev. No. 5) (April E 1986). A copy of this decision was furnished to the NRC by Licensee's counsel on May 13, 1986.
26/ Id. at 6.
1 27/ Id. at 7-8.
4
- 13 = -
environmental impacts 'with respect to the 1985 applica-t' ions.El Therefore, the temporary approvals for 1986, like the 1985 approvals, did not result in any significant adverse impact to the environment.
At the same time, DRBC approved Licensee's request for the releases of water fron the Still Creek and Owl Creek Reservoirs, for 1986, into the receiving streams for subse-quent withdrawal and consumptive use by Limerick Unit 1.EI These reservoirs are owned by the Borough of Tamaqua and are used for municipal water supply. Releases from the Tamaqua reservoirs will be used for Limerick when existing flow or dissolved oxygen constraints restrict the consumptive use of Schuylkill River water !
DRBC analyzed potential environmental impacts resulting from the release of water for Limerick from the Tamaqua reservoirs. It found that the water to be released would be M/ DRBC's revised docket decisions also considered the
_, environmental benefits of approving the changes, principally, permitting Licensee to continue the ascent-to-power program and commercial operation of Limerick. These benefits are not discussed at length j
here because environmental benefits are not relevant to the requirements of EPP 13.1.
29/ DRBC Docket No. D-69-210 CP (Final) (Rev. No. 6) (April
, 29, 1986). A copy of this decision was furnished to i
i the NRC by Licensee's counsel on May 13, 1986.
- 30,/ DRBC denied another aspect of Licensee's application
! which sought approval for releases from the Beechwood Pool, a former strip mine controlled by Reading Anthracite. Company, which is presently unused and f filled with approximately 2.2 billion gallons of water.
within the capacity of the receiving streams 'such that no erosion or _ other adverse effects are expected.EI It also found that the water quality of the Tamaqua reservoirs is very good and would actually improve water quality above Limerick. For the stretch of the Schuylkill below Limerick, DRBC determined that Tamaqua releases would have nearly the same impacts as using the approved Point Pleasant diver-sion.N Finally, DRBC found that drawdown of the reser-voirs would not adversely affect embankment stability or the aquatic environment.El on the basis of the evaluation discussed in DRBC's docket revisions as well as its own analyses, Licensee determined that the . temporary changes approved by - DRBC did not trigger any applicable provision of the Limerick EPP.
EPP 13.1 states that Licensee "may make changes in station design or operation . . . affecting the environment provided such activities do not involve an unreviewed environmental question and do not involve a change in the EPP." (Footnote omitted.) As noted, EPP 13.1 defines such a proposed
" change" as follows:'
A proposed change . . . shall be deemed to involve an unreviewed environ-mental question if it concerns: (1) a 31,/ DRBC Docket No. D-69-210 CP at p. 5 (Final) (Rev. No.
.6) (April 29, 1986).
32/ Id. at 7, 10.
33/ Id. at 7-8.
i t
i
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 signifi-cant change in effluents or power levels; or (3) a matter, not previously reviewed and evaluated in the documents specified in (1) of this Subsection, which may have a significant adverse i
environmental impact.
Licensee reviewed the approvals granted by DRBC against these criteria. As discussed, the temporary substitution of
(
Do monitoring for the existing 59'F temperature constraint on Schuylkill withdrawals is essentially the same (modified only slightly for the spawning season of March 1 through June 15) as previously approved by DRBC for the latter
. portion of 1985. Similarly, the transfer of consumptive use allocations from the Titus/Cromby units to Limerick for 1986 is essentially the same (slightly modified to take into account shutdown times of the other Schuylkill units) as approved by DRLC for the latter portion of 1985. These
, revisions had only an inconsequential effect on previously analyzed environmental impacts, as DRBC determined in granting Licensee's applications, and therefore did not trigger any EPP provision requiring prior NRC approval.
Nor did releases from the Tamaqua reservoirs for 1986 i
involve an unreviewed environmental question with signifi-
, cant adverse ,
impacts. Tamaqua releases are merely the equivalent of Schuylkill flows which have already been analyzed. Withdrawal impacts upon Schuylkill water quality i
I, t
16 -
and aquatic environment have already been evaluated by the NRC, including Schuylkill withdrawal impacts during the summer months.UI Potential impacts of the releases upon the Tamaqua reservoirs and their aquatic environments were analyzed by Licensee in its application to DRBC and by DRBC in approving the application. These evaluations, as re-flected in the docket revisions, amply demonstrate that no significant adverse environmental impact to the Tamaqua reservoirs and their aquatic environment will result from the releases.
For the foregoing reasons, Licensee determined that there was no requirement under the Limerick EPP to provide a written evaluation to the NRC seeking prior approval for the changes approved by DRBC. Thus, there is no basis for the
- relief sought by Mr. Anthony.
j In his petition of March 5, 1986, Mr. Anthony does not state anything to the contrary. He merely recites that Licensee requested and DRBC approved the temporary substi-i tution of DO monitoring for the existing temperature con-straint on Schuylkill withdrawals and the temporary transfer i
34/
~~
See Final Environmental Statement Related to the Operation of Limerick Generating Station, Units 1 and i
2, NUREG-0974, at pp. 5-3 to 5-4, 5-9 to 5-17 and 5-28 l .to 5-29 (April 1984) ("FES"). See also Environmental Report - Operating License Stage T'EROL") at pp. 5.1-1 to 5.1-9. Licensee's EROL at 5.1-5, notes that its analyses of impacts upon the aquatic environment are
- . applicable to low flow periods, i.e. , sum
- ner months .
l
of consumptive use allocations from other Schuylkill units for Limerick.25,/ Mr. Anthony has failed, however, to furnish any supporting evidence that any applicable pro-vision of the EPP for Limerick has been triggered. He erroneously assumes, without any underlying scientific or technical evidence, that the temporary docket revisions-for 1986 would " result in a significant increase in any adverse environmental impact previously evaluated" or some new "significant adverse environmental impact. 26,/
, Thus, his petition fails to " set forth the facts that constitute the basis for the request."$1/ Absent an adequate showing to pursue the matter, the Director has no obligation to do 35/ Mr. Anthony notes that Licensee requested DRBC to approve withdrawals based upon DO values at five of the six monitoring stations below Limerick. Licensee does not believe that this request, if granted, would have I been reportable under EPP 13.1 or required prior NRC approval under EPP 15.3. Nevertheless, DRBC did not approve this particular aspect of the application, thereby mooting the question raised by Mr. Anthony.
36,/ EPP 13.1.
5 l 32/ 10 C.F.R. $2.206. As the Acting Director previously advised Mr. Anthony in denying a separate Section 2.206 I request, "[a] corollary of the requirement is that the ,
i Petition muret show something more than merely recite facts which the agency has itself developed through inspections, adjudications or notifications. In these latter instances, in the absence of some specific showing to the contrary, it may be presumed that the agency response was adequate." Letter from Darrell G.
Eisenhut, Acting Director, Office of Nuclear Reactor i
Regulation, to Robert L. Anthony (April 16, 1986).
i i
a E- so .El The Director should therefore deny Mr. Anthony's request for relief under 10 C.F.R. 52.206.
5 t
I 38/
See generally Limerick, supra, DD-82-13, 16 NRC 2115, 2171 n.12 and accompanying text (1982). Specifically, the Director "is not required to accord presumptive validity to [Mr. Anthony's] assertion of fact,
. irrespective of its degree of substantiation, or to
. convene an adjudicatory proceeding in order to determine whether an adjudicatory proceeding is warranted." Northern Indiana Public Service Company
~
(Bailly Generating Station, Nuclear-1) , CLI-78-7, - 7 NRC 429, 432 (1978).
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