ML18025B183

Requests Reconsideration of NRC Issuance of Amends 60,55 & 32 to Licenses DPR-33,DPR-52 & DPR-68 Respectively.Amends Authorize Temporary Storage of Low Level Radwaste in Pavilions Not Designed to Withstand Winds Over 80 Mph

ML18025B183
Person / Time
Site:	Browns Ferry
Issue date:	10/28/1980
From:	Ely D, Horn S, Paul T SAFE ENERGY ALLIANCE
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NUDOCS 8011120280
Download: ML18025B183 (14)

Text

REGULA'IJRY 0I 0 VFOR~ATI J'1 OISTRIBUTIO'4 SYSTE'H (R IOS)

ACCESS IUM VoR : 80111202'30 OOC ~ OA TE: 80/10/28 4OTARIZEO: '40 OOCKET F AC IL:50 259 3rowns Ferry Vucl.ear ~ower Stations Jnit lg Tennessee 05000259 SO-2bo 3ro~ns Ferry Vuclear Power Stations Unit 2i lennessee 0 50-296 Brawls Ferry .'Nuclear Power Station< Jnit 3i Tennessee 000296 A VT H ~ iVAi~E AU'TtjQR AFF IL [AT IQ'V P AUL i T.,~. Safe Energy Al i ance 1

HORN g.S ~ Safe Energy A i ance 1 1 ELYpO ~ Safe Energy Alliance REC IP ~ "f 4."IE RECIPIENT I AFFILIA I ION OENTOV,t~.R. Office of nuclear Reactor Regulationi director mohan SU8JECT: Requests reconsideration of QRC issuance of Amenas 60g55 32 to. Licenses OPR 35iOPN 52

• OPR 68 'mends authorize tempo,rary storage of low level radwaste in oavilions not designed to withstand winds over 80 DISTR IHUT IOV CDOE: XE03S COP IES RECEI'VEO:LTR E'lCL O SIZE:

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Ik October 28, 1980 Safe Energy Alliance of Alabama Huntsville Chapter Suite 407, Terry Hutchins Blvd.

102 Clinton Ave.

Huntsville, AL. 35801

~ A Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D .C . 20555 Dear Mr. Denton; This letter is a request for reconsideration of the issuance, by the NRC, of amendments No.'s. 60, 55 8e 32 to Facility Licenses No's. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant, units No's. 1, 2, 8c 3 dated March 17, 1980. These amendments authorize the temporary storage of low-level radioactive waste in an existing covered pavilion situated'n the site of BFNP .

This request for reconsideration is motivated by the fact that the approved temporary Low Level Naste Storage (LLNS) pavilion is not designed to withstand tornado winds of over 80 mph velocities.

BFNP is located in an area of North Alabama that has come to be known as "Tornado Alley". On April 3rd and 0th 1974 a series of tornadoes associated'ith a storm that caused 315 deaths and more than $ 600 million in damage passed within 2 miles of BFNP .

Fifty-eight (58) 500 KV linetransmission towers earring power from BFNP were snapped causing over a million dollars worth of damage As a result of the loss of these power lines unit one

@ BFNP was forced to shut down due to the sudden drop in demand the tornadoe's destructive activity had 'brought about.

Despite this history of very recent serious tornado activity, TVA, in the application for an amendment to BFNP's operating license which would allow the Agency to Store LLRN onsite, clearly states that the probability of a destructive tornado occuring at this facility was considered to be so small. as to be negligable.

0 Mr. Harold R. Denton, Director October,28, 1980 Edward Epstein the associate administrator for Environmental Monitoring 8c Predication of National Oceanic 8c Atmospheric Administration. on a field visit to North Alabama after the April 1974 tornadoes estimated that the rotational speed of such tor-nadoes was between 200 and 250 mph.

This dismissal of the need to design. LLRN structures capable of withstanding tornado winds in an area that has recently suffered from a devasting tornado puts TVA in direct conflict with the Code of Federal Regulations Title 10 Chapter 1, Part 50, Appendix A .,

P. 361 Criterion 2 Desi n Basis for Protection A ainst Natural Phenomena which states~

Structures, systems, and components important to safety shall be designed'o withstand. the effects of natural .phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions. The design bases for th'ese structures, systems, and components shall reflects (1) Appropriate consideration of the most severe of the natural phenomena-that have been historically reported for the site and surround-ing area, with sufficient margin for the limited accuracy, quantity, and period of time in which the historical data been accumulated. (2) appropriate combinations of the 'ave effects of normal and accident conditions with the effects of the natural phenomena and.(3) the importance of the safety functions to be performed.

Despite later claims to have adhered to the CFR noted above, TVA in its Plan for Temporary Onsite Storage of Low-Level Radio-active Waste @ BFNP Units 1, 2, 3 dated January 21, 1980 in Section 0 General Considerations Part G Sub 2 states: "The probability of a tornado with maximum wind speeds higher than the 95 mph value striking the plant in any one year is 7 x 10 This is considered to be small enough to be neglected."

ib ~I Mr. Harold R. Denton, Director October 28, 1980

'n effect TVA has chosen to neglect the possibility of a tornado re-occurring in an area that has already suffered severe damage from a series of tornados with wind velocities more than twice those that TVA has planned for. TVA is gambling on the possibility that another severe storm will not strike BFNP or its environs. The people of North Alabama will suffer the consequences of such negligence and it is for this reason that we requestto the NRC to direct TVA to adhere to the CFR which calls on them be prepared for the "most severe of the natural phenomena that have been historically reported for the site and surrounding area."

Sincerely yours, Thomas W. Paul tewart Horn cj; David, Ely The Safe Ener y Alliance of Alabama, Huntsville Chapter

UNITED STATES NUCLEAR'REGULATORY COMMISSION WASHINGTON D.G. 20555 November 3, 1980 Docket No. 50 259 50-260 and 50-296~

See attached lfst of addressees.

subject: Brotfns Ferr Nuclear Poorer Statfon Vnfts 1 .2, and 3 Tennessee Va ey Atithorfty The following documents concerning our review of the subject facility are transmitted for your information:

G Notice of Receipt of Application.

Draft/Final Environmental Statement, dated Safety Evaluation, or Supplement No.,dated Notice of Hearing on Application for Construction. Permit.

1 Notice of Constderation of Issuance of Facility Operating License.

Application and Safety Analysis Report, Vol.

Amendment No. to Application/SAR, dated Construction Permit No. CPPR- ,date Facility Operating License No. DPR-, NPF- , date C3 Amendment No. to CPPR- or DRR-,dated er 1980.

Office of Nuclear Reactor Regulation ORB 82

Enclosures:

DL As stated cc; OFFICE p-suANAME ~

DATE ~

ti RC-2 I (6.76)

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t ORB III2 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON D.C. 20555 October 31, 1980 Docket, No. 50-259 50-260

. and. 50-296~

See attached 1fst of addressees.

subject: Brogans Ferr Nucl'ear Power Station Units 1, 2 and 3 Tennessee a ey ut or ty The following documents concerning our review of the subject facility are transmitted for., your information:

Notice of Receipt of Application.

Draft/Final Environmental Statement, dated Safety Evaluation, or Supplement No.,dated Notice of Hearing on Application. for Construction Permit.

Notice of Consideration of Issuance of Facility Operating License.

Cl Application and Safety Analysis Report, Vol'.

Amendment No. to Application/SAR, dated Construction Permit No. CPPR- ,date Facility Operating License Nn. DPR- ', NPF-, date Amendment No. to CPPR= or DRR-,dated l3 Other: nW<aste disposal semiannual report for 1978.

Office of Nuclear Reactor Regulation ORB 02

Enclosures:

DL As stated cc:

~ ORB j/2 OFFICE SURNAME SNorris:kf DATE ~ 4 ttg/80 Fg RC 2t (6-16)

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ORB. b2 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON D.C. 20555 October 30, 1980 Docket No. 50-259 5>>2t2 and 50-296 See attached 1ist of addressees.

Subject:

Brot<ns Ferr Nuclear Potier Station Units 1 '2 and 3 Tennessee a ey Aut or ty The following documents concerning our review of the subject fa'cility are transmitted for your information:

Q Notice of Receipt of Application.

Draft/Final Environmental Statement, dated Safety Evaluation, or Supplement No.,dated Notice of Hearing on Application for Construction Permit.

Notice of Consideration of Issuance of Facility Operating License.

Application and Safety Analysis Report, Vol.

CI Amendment No. to Application/SAR, dated

'Construction Permit No. CPPR- ,date Facility Opcratinp License No. DPR-, NPF-, date Amendment No. to CPPR- or DRR-,dated H Other: pBFilkIJl~ 80.

Office of Nuclear Reactor Regulation ORB 4'2

Enclosures:

DL As stated cc:

ORB 02 OFI:K,'E p SNonrTs:kf suRNAM6 oArc ~ ] ~3-88~-

NRC 2I (676)

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