ML020800280
| ML020800280 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah  |
| Issue date: | 03/18/2002 |
| From: | Burzynski M Tennessee Valley Authority |
| To: | Collins S Office of Nuclear Reactor Regulation |
| References | |
| Download: ML020800280 (2) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 March 18, 2002 Mr. Samuel J. Collins, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001
Dear Mr. Collins:
In the Matter of
)
Docket Nos.
50-259, 50-260 Tennessee Valley Authority
)
50-296, 50-327 50-328, 50-390 REQUEST FOR EXTENSION OF TIME TO SUBMIT AN ANSWER AND REQUEST A HEARING Section IV of the NRC's February 25, 2002, Order Modifying Licenses ("Order") states that, in accordance with 10 CFR 2.202, a Licensee must submit an answer to the Order and may request an extension of time in which to submit an answer or to request a hearing on the Order within 20 days of the date of the Order. In addition, the Order states "[w]here good cause is shown, consideration will be given to extending the time to request a hearing."
For the following reasons, the Tennessee Valley Authority (TVA) hereby requests an extension of time to supplement the Answer to the Order submitted March 18, 2002 and to request a hearing.
As required by Condition C.1. of the Order, TVA's response identifies specific actions to be taken to comply with each applicable requirement and provides a schedule for implementation. We have responded to Conditions B.1. and B.2. by identifying requirements with which (1) TVA is unable to comply; (2) compliance is unnecessary in TVA's specific circumstances; (3) compliance would cause TVA to be in violation of a Commission regulation or the facility license; or (4) implementation would adversely impact safe operation of the facility.
Pnnted on recycled paper
Mr. Samuel J. Collins Page 2 March 18, 2002 In a few instances, as detailed in TVA's March 18, 2002 submittal to the NRC, we are unable to complete the necessary evaluations to determine what actions are appropriate and what an appropriate schedule for implementation would be within the required response time. Because we will be unable to ascertain what actions would be appropriate in the context of meeting the NRC's intent for these measures, we will be unable to determine whether it is necessary to request a hearing until certain analyses described in our March 18, 2002 submittal are completed.
Because of the unique nature of the situation that precipitated issuance of the Order, pursuant to Section IV of the Order, TVA requests (1) an extension of time to file an answer for Interim Compensatory Measures (ICM) B.2.a(1), B.2.a(2), B.2.b, and B.4.g until the dates identified for completing the analyses and actions with respect to these ICMs, and (2) a comparable extension of time to file a request for hearing with respect to those matters.
Good cause exists for this request. Several complex analyses are being performed related to the above-mentioned ICMs. Until these analyses required to respond to the Order are complete, TVA cannot know if it is able to comply with the Order in these respects, if compliance is necessary in the circumstances, or if compliance would cause TVA to be in violation of NRC regulations or a facility license. Accordingly, TVA cannot know at this time how its interests will be affected by the Order and cannot determine at this time whether a request for a hearing would be appropriate. Thus, as noted above, TVA requests an extension of time to file an answer to certain ICMs, and similarly requests an extension of time for requesting a hearing on that portion of the Order that relates to these ICMs.
Sincerely, Ma urzynski Manager Nuclear Licensing