LASALLE COUNTY STATION NRC INSPECTION REPORT 50-373/01-16(DRP); 50-374/01-16(DRP) 2001016
Feb 26, 7 pm: You get it, a forced two year shutdown by the NRC beginning in 1996. A massive capitol under investment in their nuclear fleet for the first half of the 1990's and enormous problems fleet wide. So they had a huge re-think brought about by a newly serious NRC. ComEd stated massively reinvesting back in their nuclear fleet. This directly lead to the huge 1999 Chicago electric power distribution and transmission crisis. Lots of electric blackouts in this summer of 1999. They plowed monies into their nuclear fleet and started starving their transmission system
It wasn't a nuclear technology crisis...it a management crisis of one of our largest electric utilities.
What was growing on at the end of the 1990s, in the weakened end of president Clinton's era, the rabid mad dog republicans had taken over congress. They intimidated the NRC by threatening to cut their budget, the 1990 rendition of the republicans shutting down government over deficits and the new obstructionist blackmail politics.
This was when the NRC moved towards massive historic public opaqueness. The nuclear industry moved in a unparalleled historic manner towards nuclear industry deregulation. Building a hundred new nuclear plants was on the horizon. It was a boomerang from the re-regulation area, trying to gain control of the poor performing and unsafe early 1990s nuclear industry.
Right, 1999 Chicago was in a terrible drought and heat wave, terrible fear was in the air over electric deregulation and ComEd stock prices were pitifully weak. Enron and the California power crisis were just a few years away. The "Exelon" name was just a knockoff of the Enron name.
So happy days were here again on July 24, 1998.
NEWS ANNOUNCEMENT: RIII-98-46 July 24, 1998So the lights go out in Chicogo in 1999
CONTACT: Jan Strasma 630/829-9663
NRC STAFF FINDS SUFFICIENT IMPROVEMENTS FOR RESTART
OF UNIT 1 OF THE LASALLE NUCLEAR POWER STATION
The Nuclear Regulatory Commission staff has determined that
Commonwealth Edison Company has made sufficient improvements at Unit 1 of the LaSalle Nuclear Power Station for the unit to resume operations. The two-reactor facility is located near Seneca, Illinois.
The utility is planning to begin startup of the unit next week. Both units were shut down in September 1996 for refueling and maintenance and remained shut down for extensive plant modifications, staff retraining, and other performance improvement initiatives.
Comed Pays For Misspent Decades
Aging Infrastructure Now Haunting Utility
August 15, 1999|By Peter Kendall and Laurie Cohen, Tribune Staff Writers.
Like most everything at ComEd, following the trail of the problem eventually leads back to the utility's struggles with its nuclear generation program, the most ambitious in the nation.
Even a decade ago, many were warning that some of the billions of dollars spent to build the nuclear plants should have been spent on wires and transformers.
Ironically, at the point at which ComEd seems to have turned around its mismanaged nuclear plants--this summer, for the first time in years, all five plants were up and running--it is now suffering the fallout from what many say has been equally shoddy management of its more prosaic electricity delivery system.By 2001, with all the leaking safety relief valves seen throughout the Exelon fleet of nuclear power plants, particularly the six pack of SRV valves leaking at both LaSalle plants: they raising their suppression pool temp limit to 105 F to accommodate poor maintenance and quality safety parts; beginning to overload their cooling pond with plant heat; then panically trying to raise the cooling pond temperature..I thought these guys had marginally adequate systems and components at the plants, had marginally competent employees running the nuclear fleet just after a prolonged shutdown for safety reasons in the late 1990s. It was startling.
We knew we were on our way to nirvana with “balls to the wall” George Bush assuming office in Jan 2001, with LaSalle by-passing 10% of power from their turbine through their SRV valves, then demanding their suppression pool safety pumps run on continuously
...the 2002 Davis Besse head leak was frosting on the cake.
Where do we sit today. Exelon just slashed their dividend by 41% because of the cheap natural gas problem, poor electric demand...they are threatening to shutdown nuclear plants. By the grace of god and fracting, they have cancelled all the nuclear plant Extended Power uprates as too expensive. They are cutting $2.4 billion dollars from Exelon’s nuclear capital expenses. Exelon’s stock price in 1999 was $24, a massive Exelon stock price speculative bubble led to a historic high price of $91 dollars...the current price is $31 dollars. After the stock price speculative bubble burst in 2008 to about $50 dollar...the stock price has been slowly declining to today price of $31 dollar.
...Graphical Climatology of Chicago Temperatures, Precipitation, and Snowfall (1871-Present)
Right, they are planning for a extended 12% power up rate per plant by 2015 without building cooling towers.
So, the below is Aug 15, 2011 NRC request for information posed to Exelon after their May 6, 2011 LAR.
If the agency would have done a proper "due diligence" data search in the lead up to their Exelon's LAR response...they would have known the high historic cooling pond temperature of 101.33 °F occurred on August 12, 2010 and was in their Aug 12/13 daily event report page. Doesn't seem to be in the 2010004 inspection report. Maybe this was the reason for the write-up on the 2012004. It is spotty inspectors reporting on these events.
The NRC in their IR 2010004 says Lasalle was down powering through the summer of 2010 to control the high temperature of the LaSalle cooling water pond.This Aug 15, 2011 NRC document is grossly inaccurate with these NRC officials in assuming Exelon-LaSalle was "approaching the TS limit of 101.25 F" (they exceeded it with 101.34 Aug 12, 2010) and the "actual peak accident post-accident UHX temperature of 104" (it is actually 106F).
Who can you trust?
No question the agency should have demanded a voluntary thorough and detailed LER out of Exelon on the Aug 12 2010 event and certainly the NRC failed to do a immediate detailed inspection.
(Aug 15, 2011)Exelon's request for amendment to TSs dated May 6, 2011 states:Can you imagine that, this is the first or maybe the second summer after the 2000 five percent power uprate...they are already begging the NRC for a raise in the LaSalle cooling pond water temperature limits.
"High temperatures and humidity during the daytime, in conjunction with minimal cooling at night and little precipitation during the summer months, results in elevated water temperatures in the LSCS UHS. Weather conditions in the future may result in the temperature of the [Core Standby Cooling System] CSCS pond challenging the current TS limit of 101.25 F.''LSCS updated final safety analysis report (UFSAR) Section 9.2.6.3.2, "Ultimate Heat Sink Temperatures and Evaporation Losses During Shutdown Conditions," states:
"The results of the analysis for the worst-case historical weather effect on the temperature of cooling water supplied to the plant from lake/UHS indicate the peak temperature of cooling water from the lake will be 97.5 F and it occurs late in the afternoon (approximately 6 pm)."If the analysis shows that the worst case historical weather effect on the cooling water to the plant from the lake/UHS results in a peak temperature of 97.5 F.
(a) Why is the CSCS pond temperature exceeding 97.5 F and approaching the TS limit of 101.25 F?
(b) With the CSCS pond exceeding the UFSAR peak temperature of 97.5 F and the high temperatures and humidity (as stated above), discuss the validity of the 1.3 F post accident heatup in the CSCS pond and its affect on the actual peak accident post- accident UHX temperature of 104 106F
As in engineer's plant language, the "prolonged hot weather" term to totally fictitious and they know it...they are falsifying federal documents. At the least they can say, the prolonged hot weather is a minor factor, the major cause is we are overloading the lake with heat from the power unrate.
They are already overloading the cooling pond with nuclear plant heat: To a 103 degrees, not yet? This is the amendment :
August 2, 2001
RS-01-152
Subject: Application for Amendment to Technical Specifications Surveillance Requirement
for the Ultimate Heat Sink Temperature
Prolonged hot weather in the area has resulted in sustained elevated cooling water temperature supplied to the plant from the CSCS pond. High temperatures and humidity during the daytime, in conjunction with very little cooling at night and very little precipitation, have resulted in elevated water temperatures in LaSalle County Station's UHS.
The average temperature of the UHS reached 98 OF on July 21, 2001.
The current SR verifies that the temperature of the cooling water supplied to the plant from the Core Standby Cooling System (CSCS) pond is •100 °F every 24 hours. This request will modify SR 3.7.3.1 to allow continued operation of both units with CSCS pond temperature of •103 OF through September 30, 2001.The NRC's Licencing Amendments Request (LAR) requires a sworn and certified signature. It is the accepted culture of lying and half truths for self protection.
AFFIDAVITSUMMARY OF JUNE 28,2012, PRE-APPLICATION MEETING WITH EXELON GENERATING COMPANY, LLC, TO DISCUSS LICENSING AMENDMENT REQUEST FOR LASALLE COUNTY STATION UNIT 1 AND UNIT 2 ULTIMATE HEAT SINK AT AT EXTENDED POWER UPRATE POWER LEVELS (TAC NOS. ME8866 AND ME8867)
I affirm that the content of this transmittal is true and correct to the best of my knowledge, information, and belief.
K. A. Ainger (C/
Director- Licensing Mid-West Regional Operating Group
It's called magical thinking...you let them get away with it for over a decade.
Previously, the staff has reviewed LSCS UHS LARs in 2001,2006,2007, and 2011 (only the 2007 UHS LAR concluded in an NRC approval). (Ouch) The licensee stated that they did not consider the UHS LAR linked to the future EPU application.
only nuclar enginners think this inside the boxthinking is safe and wha the public wants ...wow...did not consider the UHS LAR linked to the future EPU application.
I feel sympathy for the Exelon's monsters the inspectors are dealing with...feeling sorry for these little inspector whose big bosses aren't backing them agianst the monster corporatim
...At least the 2012 flextime safety cooling pond amendment proposed 30 day worst case aligns with either 1995 drought and heatwave. The current worst case of record is in left field. The 1 day July 2001 aligns with the IR 2001010 (2001)/How come the cooling lake peak historic temperature of August 12, 2010 and the second worst on Aug 8, 2005 is totally disconnected for the worst meteorological worst case choices of Exelon's 2012 flextime amendment request. How come the severe droughts and heatwaves of 1995 and 1999 didn't challenge the 100 F limits of the LaSalle... how come in the inspection report 2010004 and the 2012004 they didn't talk about the cooling pond highest historic peak temperature wasn't in the severe droughts and heat wave of 1995 or 1999.
It is simple as hell, they overload their cooling pond with heat from the two 5% power uprates in 2000.
According to the Exelon's 2012 flextime UHX, the proposed worst 30 day weather is from July 21, 1995, 3:00 p.m. to August 20, 1995, 3:00 p.m., the great Chicago heatwave of July 12-16 1995, how come we see no record high temperature LaSalle cooling pond temperatures in the summer of 1995?
Current UHS TS Analysis
(through primitive fluid dynamic computer models:)
Period Analyzed: July 4, 1948, through June 30, 1996
Worst Temperature Weather Periods:
- 1-day: July 15 to July 16, 1995
- 30-day: July 10, 1983 to August 9, 1983
- Worst 30-Day Evaporation Weather Period: June 18, 1954, to July 18, 1954
Weather Period Analyzed: July 4, 1948, through June 30, 1996 (Peoria and Springfield, IL) January 1, 1995 to September 30, 2010 Worst Temperature Weather Periods:
- 1-day: July 24, 2001, 6:00 a.m. to July 25, 2001, 6:00 a.m.
- 30-day: July 21, 1995, 3:00 p.m. to August 20, 1995, 3:00 p.m.
- Worst 30-Day Evaporation Weather Period: June 18, 1954, to July 18, 1954"
"from the cooling water temperature from the CSCS pond reaching 101.34 °F on August 12, 2010. This was the highest inlet temperature ever reached to date and had exceeded the TS 3.7.3.1 limit of 101.25 °F. The previous highest temperature for the cooling water from the CSCS pond was 99.8 °F on August 8, 2005."
The 1999 Illinois drought and heat wave.
Drought of 1999-2000 Overview
Dry conditions began in Illinois in July 1999 due to a sudden and consistent reduction in the amount of precipitation that was falling over the state (Figure 1). Precipitation in the prior six months (January-June 1999) showed a statewide total of 22.70 inches or 22 percent above average. The other water resources of the state, soil moisture levels, streamflow amounts, and shallow well ground-water depths, reflected the above average precipitation condition, and gave no indication of concern as to the availability or status of the water resources in the state.
The Nature and Impacts of the July 1999 Heat Wave in the Midwestern United States: Learning from the Lessons of 1995
The July 1999 heat wave in the Midwest was an event of relatively long duration punctuated by extreme conditions during its last 2 days. The intensity of the heat wave on 29 and 30 July rivaled that of the 1995 heat wave that killed more than 1000 people in the central United States. In 1999, however, the death toll was about one–fourth of this amount in the same region. The 1999 heat wave 2–day maximum apparent temperature was slightly less than during the 1995 heat wave at most Midwestern first–order stations. In addition, the 2–day peak was preceded by several hot days that allowed some short–term acclimatization to occur prior to the intense final days. In Chicago, conditions during the peak of the 1999 heat wave were very similar to those during the 1995 heat wave peak, especially the extreme nocturnal conditions of temperatures and humidity. Therefore, it seems unlikely that the reduction in the heat wave death toll in Chicago from about 700 in 1995 to 114 in 1999 is due solely to meteorological differences between the two heat waves. In St. Louis, the 1999 heat wave was intense for a much longer duration than the 1995 heat wave, thus partially explaining the increase in heat–related deaths there from the 1995 event to the 1999 event.
Feb 26: Do you really think the high Illinois temperature was the cause of the tech spec change. They would be bypassing 10% of the power from their turbine though the leaks in their SRV valves...10% power was going into their suppression pool. This is what men do with with a mechanical conscience.
They just got a culture of acceptable lying...engineering lying going on. The NRC allows them to lie for protection from the public. it is still going on...they are lying to protect you. From the revising the Tech Spec from 100 F to 105 F, to the acceptance massively leaking SRV valves, this is all a huge reduction in safety margin for no good reason...
From the NRC in 1989: Specifically, the proposed change would raise the suppression pool temperature limit during normal operation from 10°0F to 105'F.This is the really bad old days (2001010) Sept 2001:
"The licensee stated that the unusually high temperatures in Illinois, the temperature of the LaSalle lake, which serves as the ultimate heat sink for the plant service water and residual heat removal (RHR) systems, have risen to the point where an insufficient differential temperature is available to maintain the suppression pool temperature below 100'F.
This revised operability evaluation identified that LaSalle Unit 1 and Unit 2 each have six leaking SRVs. The impact of this issue has been an increase in suppression pool level as well as a slow heatup of the suppression pool. To address suppression pool temperature issues, operators run the RHR system in the suppression pool cooling (SPC) mode to cool the suppression pool to maintain the suppression pool temperature below the Technical Specification 3.6.2.1 limit of 105 F.In them days, the industry was demanding less testing of the RHR components saying the operation of the system was damaging and wearing out their equipment. But using the RHR component to compensate for poor maintenance and poor quality of safety relief valves leakage does not wear out extremely important RHR components.
The operating time of the RHR system in the SPC mode is dependent upon the heat input into the pool and the LaSalle cooling lake temperature. Recently, the Unit 1 SRV leakage rate and lake temperature increased to the point that RHR operation on a daily basis was required. As a result, licensee management made a decision to operate one train of the Unit 1 RHR system in the SPC mode continuously and implemented this action on June 6, 2001. The technical basis for this decision was documented in Analysis L-002766, .GE NEDC & Continuous Operation of RHR in the Suppression Pool Cooling Mode,. Revision 0, dated May 10, 2001, and reviewed and approved by the Plant Onsite Review Committee (PORC) on June 8, 2001.
The inspectors reviewed OE00-009, Revision 2, and verified that the RHR system would automatically re-align from the suppression pool cooling mode to the injection mode within the time required to satisfy design basis assumptions.
...I mean, there is a huge disconnect with the meteorological one day worst weather and actual effects on the LaSalle cooling pond temperatures. How come the instrumented meteorological data don't line up with the plant service water inlet temperatures? Meteorological data is supposed drive pond temperatures?
How come on the amendment the proposed July 24, 2001 historic "one day worst weather" doesn't line up with the historic highest peak cooling pond temperature in IR 2012004. The highest and second to the highest pond summertime temperature peak is 101.34°F on Aug 12, 2010 and 99.8 °F on August 8, 2005. Exelon says the worst on record is July 24, 2001. You guys worried about spending a $ 1 billions on cooling towers for just three weeks in the summer? Is that what the lying and federal document falsification is all about?
In the current worst weather analysis and proposed, what it the fixation of the middle of July and the end of July with the worst one day weather, as also an inclination on the 30 day worst weather too? Why the worst weather not heavily weighted in August from your meteorological list...instead of July. Inspection report 2012004 tells us historically the highest temperature of the cooling water occurred Aug 9 and Aug 12 with LaSalle. Millstone shuts down also on Aug 12 last year...is this all a coincidence? Generally across the board on cooling water bodies nationwide, the peak summertime pond, mostly closed cooling bodies, and streams and rivers, occur mostly around mid to late August. It is the so call worst one day or 30 day weather, along with the fuel load for potential fire, that is the as is temperature load of the pond that drives risk?
I'd like to see a list of peak summertime pond temperatures and the dates for 2 decades.
Is an algae bloom taken into consideration with the Aug solar radiation and cooling pond temps?
The historic 2005 and 2010 peak summertime temperature falsifies your worst weather analysis and it questions the integrity of its predictions.
And service water temperatures are more indicative of risk than the diurnal pond temperature...a three day, week or a monthly rolling average of lake water temperatures.
Why in the world would the NRC accept a 1976 one dimensional computer model in a safety applications in 2013 for flow and thermal dynamics for a UHX? What a disgrace. Does it give you the profit calculations you want?
The computer program used to model the LaSalle UHS during the design event is LAKET-PC developed by Sargent and Lundy in 1976 as a one-dimensional thermal prediction model for bodies of water.
RS-12-084Current UHS TS Analysis
July 12, 2012
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555-0001
LaSalle County Station, Units 1 and 2
Facility Operating License Nos. NPF-1 1 and NPF-1 8
NRC Docket Nos. 50-373 and 50-374
Subject: In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) is requesting a change to the Technical
"The weather data was evaluated to determine the worst 24-hour and 30-day weather periods resulting in maximum plant intake temperature (i.e., minimum heat transfer to the atmosphere) and for the worst 30-day period of net evaporation. The following summarize the results of the limiting weather data periods.
(through primitive fluid dynamic computer models:)
Period Analyzed: July 4, 1948, through June 30, 1996
Worst Temperature Weather Periods:
- 1-day: July 15 to July 16, 1995
- 30-day: July 10, 1983 to August 9, 1983
- Worst 30-Day Evaporation Weather Period: June 18, 1954, to July 18, 1954
Weather Period Analyzed: July 4, 1948, through June 30, 1996 (Peoria and Springfield, IL) January 1, 1995 to September 30, 2010 Worst Temperature Weather Periods:
- 1-day: July 24, 2001, 6:00 a.m. to July 25, 2001, 6:00 a.m.
- 30-day: July 21, 1995, 3:00 p.m. to August 20, 1995, 3:00 p.m.
- Worst 30-Day Evaporation Weather Period: June 18, 1954, to July 18, 1954"
The inspectors reviewed AR 1101063, “Dual Unit Limiting Condition for Operation (LCO) Entered Due to High Lake Temperature,” that documented a reduction of power to approximately 80 percent for both units due to problems caused by the fish kill resulting from the cooling water temperature from the CSCS pond reaching 101.34 °F on August 12, 2010. This was the highest inlet temperature ever reached to date and had exceeded the TS 3.7.3.1 limit of 101.25 °F. The previous highest temperature for the cooling water from the CSCS pond was 99.8 °F on August 8, 2005.You guys are confusing the hell out of me. So if you used the post March 13, 2006 UHX service/ circ water temperature accuracy on the Aug 8 2005 peak temperature the indicated temperature would be °F? It is a huge jump from 98.3°F to 101.34 °F. I am drowning here, if we are using the pre March 13, 2006 instrument accuracy on Aug 12, 2010 it would really be 102.84 °Fand still a huge jump from 98.3 °F.
It still don't add up to the limit of >100°F in pre 2006 and less than or equal to 101.5°F post March 13, 2006 amendment?
1) Request a OIG investigation on the massive public lying and other fraud going on here for over a decade.
2) The NRC withdrawal all past LARs on the UHX...limit plant operation to less than 95 degrees F pond temperatures.
4) I consider the worst accident as August plant operations with severe plant heat overload, then breaking historical pond/service water intake temperatures killing many 1000s of lake fish in a historic drought or heat wave, a dike failure and then the DBA nuclear plant accident. The living, dead and dying fish all collecting in the deep water areas, the heat killing them all... it damages all traveling screens and clogs up all cooling water into the plant then leading to LOOP. Just like the pond historical temperature event in 20100004 on Aug 12, 2010 and the Oct IR 2012004.
5) Does the computer model only take into account a uniform temperature in a column of water...while the lake depths has temperature stratifications. Might we have a much higher temperature on the surface, much higher than the limits, while the plant intake sucks on a lower temperature stratification layer. Could the increasing hot surface layer quickly infiltrator the cooler layers...unexpectedly thereby spiking to inlet temperatures as we exceed the historic record temperatures.
6) So the transport time for the lake is 30 hours with two plants up at full power and full circulation water, from the discharge back to the inlet of the plant. Does anyone really know what the lake flow and thermal effects does for two shutdown plants and on emergency service water loads. The full power circulation water flow dwarfs the emergency flows. How do you know the full flow mode...the 30 hour transport time is a worst case more than much less pump drive. Obviously the transport time would be slowed down. You trust your intuitiveness on this? Request the cooling pond be three dimensionally computers modeled with a real transport time and it include all flow and temperature characteristics.
di·ur·nal
I made a lot of mistakes in my first video...
Fantastic new scientific invention by our nuclear folks...flextime nuclear plant safety limits.. Safety limits that are convenient to utility profits...
So if the cooling lake exceeds the 100.25 degree limit at 6 am, say 102 degrees. The requirements are they have to be shut down in 12 hours. They can drag their feet and they do drag their feet. So all they do is put their hand in their pockets until the graph rises at about 8:30 am past the limits. They can do that all summer long if they wish.
They keep uprating power to the nuclear power plant with a too small cooling lake leading to a reduction is safety margins and to unpredictable results.
Can dead fish lead Fukushima?
October 11, 2002: Ultimate Heat Sink
Mr. Michael Mulligan
P.O. Box 161
5 Wood Lawn Lane
Hinsdale, NH 03451
Dear Mr. Mulligan:
I have reviewed your e-mails dated June 18, July 22 and August 7, 2002, all of which were addressed to the U.S. Nuclear Regulatory Commission’s (NRC’s) Office of Public Affairs via Mr. Victor Dricks. Most of your comments were addressed in previous letters to you [specifically our letter dated February 13, 2002, which addressed your Yankee Nuclear Power Station (Vermont Yankee) November 30, 2001, petition, as supplemented on December 3, 2001; your January 4, 2002, petition on Vermont Yankee; and your LaSalle petition dated December 28, 2001, as superseded on January 4, 2002]. As discussed in our letter to you dated August 23, 2002, I am only addressing issues in the e-mails that are within NRC's jurisdiction and that warrant additional actions on our part. As stated in our letter to you on August 22, 2002, the allegations of wrongdoing by the NRC staff have been forwarded to the NRC’s Office of the Inspector General.
You requested an explanation of the sentence on page 2 in the Cooper Nuclear Station (CNS) ultimate heat sink (UHS) amendment (ADAMS Accession No. ML022060152), "Assuming 102 percent reactor power is typical and consistent with what the NRC considers to be acceptable for design-bases applications, we consider this assumption to be acceptable." The NRC staff agrees that this sentence could have been better stated. For the UHS amendment, CNS was not as conservative as their original calculations which assumed 104 percent. However, to account for instrumentation error 10 CFR Part 50 Appendix K requires that the licensee assume at least 102 percent reactor power. Therefore, the NRC staff found CNS’s assumption of 102 percent, for the UHS amendment, to be acceptable.
You asked why the UHS amendment was issued on an exigent and not an emergency basis. The NRC staff evaluated the licensee's rationale against Section 50.91(a)(5) of Title 10 of the Code of Federal Regulations (10 CFR) which requires licensees to "explain why the emergency situation occurred and why it could not avoid the situation." The licensee's letter of July 3, 2002, did not address why the emergency could not be avoided. Therefore, the NRC staff had determined not to act on the licensee's request pursuant to 10 CFR 50.91(a)(5). The NRC staff, however, recognized that for continued operation of CNS, the licensee and the Commission needed to act quickly, and time did not permit the Commission to wait for the 30 day prior public comment period. In accordance with 10 CFR 50.91(a)(6), the staff processed the two amendments concerned on an exigent basis to prevent an unnecessary plant transient.
You expressed concern that there has been an increasing trend with license amendment requests asking for higher UHS limits in the last few years. Generally, trends in license amendments have been attributed to various reasons. For instance, licensees have utilized topical reports as templates for submitting amendment requests. Therefore, related amendments are typically requested following the approval of a topical report. Other times, important inspection findings at one plant have prompted other plants to request license changes. UHS amendments have been issued to remove unnecessary restrictions in the technical specifications (TSs) on plant operators in severe weather conditions. TSs limits on UHS parameters such as temperatures and water levels are based on assumptions made in design and licensing analyses. Changes in weather patterns have resulted in many plants approaching the values assumed during original licensing reviews performed 20 to 30 years ago. In this case, the utility was able to prove that operation at higher UHS temperatures was safe. The NRC determined the licensee’s request was justified and approved the change to the TSs
You asked why additional changes were needed (beyond the heat sink limit) in related limits, if there is so much safety margin built in. Many systems are related. Therefore, in considering a change to one system’s parameters, the effect on other systems must be considered. The reactor equipment cooling (REC) system is cooled by water from the UHS, consequently the temperature of the REC system will increase as the UHS temperature increases. Therefore, an increase in the REC system temperature limit was also required.
You stated that CNS has an alcohol abuse problem. After reviewing several of the plants’ fitness-for-duty (FFD) reports over the past two years, the facts do not agree with your assertion that CNS staff has a significant problem. FFD reports are submitted by the licensee biannually per 10 CFR 26.71 to ensure a rigorous drug and alcohol screening policy is in effect. FFD reports are available in the Agencywide Documents Access and Management System (ADAMS) Public Electric Reading Room.
Finally, you stated that you believe the NRC purposely did not include your initial comments regarding the amendment request. The NRC does not purposely leave out public comments received in reference to a Federal Register notice. In this case, your comments contained in the June 18, July 22, and August 7, 2002 e-mails were not forwarded to the staff working on the amendment until after the amendment was issued. The only way to ensure your comment on an amendment is addressed is to follow the instructions outlined in the Federal Register which states:
Written comments may be submitted by mail to the Chief, Rules and Directives Branch, Division of Administrative Services, Office of Administration, U.S. Nuclear Regulatory Commission, Washington, D.C. 20555-0001, and should cite the publication date and page number of this Federal Register notice. Written comments may also be delivered to Room 6D22, Two White Flint North, 11545 Rockville Pike, Rockville, Maryland, from 7:30 a.m. to 4:15 p.m. Federal workdays.
If you have questions on this matter, please contact Mr. Brian Benney of my staff at 301-415-3764.
Sincerely,
/RA/
Stephen Dembek, Chief, Section 2
Project Directorate IV
Division of Licensing Project Management
Office of Nuclear Reactor Regulation
Docket No. 50-298
If you have questions on this matter, please contact Mr. Brian Benney of my staff at
301-415-3764.
Sincerely,
/RA/
Stephen Dembek, Chief, Section 2
Project Directorate IV
Division of Licensing Project Management
Office of Nuclear Reactor Regulation
Docket No. 50-298
DISTRIBUTION:
PUBLIC
PDIV-2 Reading
RidsNrrOD (SCollins/JJohnson)
RidsNrrAdpt (BSheron/JIsom)
WBorchardt
RidsNrrWpc (TJCarter-Gorham [YT-20020211])
LCox
RidsNrrDlpmPdiv (WRuland)
RidsNrrPMBBenney
RidsNrrLAMMcAllister
KBrockman, Region IV
GMulley
ACCESSION NO.: ML022730516 PKG: ML022270713 NRR-106
Incoming: ML022250558 d/d 08/04/02 (Attached-6/18/02)
ML022250570 d/d 7/22/02
ML022250551 d/d 8/07/02
OFFICE PDIV-2/PM PDIV-1/LA PDIV-2/SC PDIV-2/PD
NAME BBenney: MMcAllister SDembek WRuland
DATE 10/3/02 10/3/02 10/7/02 10/11/02
DOCUMENT NAME: C:\ORPCheckout\FileNET\ML022730516.wpd OFFICIAL RECORD COPY
