ML18029A625
| ML18029A625 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/03/1985 |
| From: | Domer J TENNESSEE VALLEY AUTHORITY |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| References | |
| TAC-63022, TAC-63023, TAC-63024, NUDOCS 8507090405 | |
| Download: ML18029A625 (8) | |
Text
REGULATORY I 'MATION DISTRIBUTION SYST 'RIDS)
ACt ESSION NBR:8507090005 DOC.DATE: 85/07/03 NOTARIZED: YES DOCKET FACIL:50-259 Browns Ferry Nuclear Power Stationi Un)t 1< Tennessee 05000259 50>>260 Browns Ferry Nuclear Power Stationi Unit 2i Tennessee 05000260 50-296 Browns Ferry Nuclear Power Stations Unit 3r Tennessee 05000296 AUTH,NAME.
AUTHOR AFFILIATION DOMERiJ ~ AD Tennessee Valley Authority RECIP ~ NAME.'ECIPIENT AFFILIATION VASSALLO~D ~ BE Operating Reactors Branch
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SUBJECT:
Requests de effluent Te DISTRIBUTION CODE:
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OL;06/26/73 NMSS/FCAF 1cy.
OL: 06/28/74 NMSS/FCAF 1cy, OL:07/02/76 lay of final approval of proposed ch Specs'ustification
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TENNESSEE VALLEYAUTHORITY CHATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II July 3, 1985 Director of Nuclear Reactor Regulation Attn:
Mr. Domenic B. Vassallo, Chief Operating Reactor Branch No.
2 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Vassallo:
In the Matter of the Tennessee Valley Authority Docket Nos. 50-259 50-260 50-296 By letters from L. M. Mills to H. R. Denton dated October 27, 1983 and August 1, 1984, we submitted proposed radiological effluent technical specifications for the Browns Ferry Nuclear Plant.
For reasons presented below we request that final approval of those technical specifications be delayed.
Justification for the delay in approval is also presented.
As explained below we believe that such a delay will have a beneficial effect on Browns Ferry operations.
Browns Ferry Nuclear Plant (BFN) unit 1 was licensed in 1973.
This unit, along with units 2 and 3, were licensed and are being operated in 'accordance with technical specifications which require that, effluent releases to unrestricted areas be kept "as low as practicable."
The limits are stated in terms of a maximum curie total for liquid effluents and instantaneous release rates for gaseous "effluents.
These limits can be quickly and easily calculated by plant'ersonnel.
Implicit with the existing technical specifications is that the radwaste system equipment and radiation monitoring instruments be maintained and operated to reduce the release of radioactive material.
A review of plant effluent data since 1980 indicates TVA's success in maintaining BFN releases "as low as practicable."
Operation of BFN has resulted in environmental doses that have been a small fraction (less than or equal to 13%) of the proposed radiological effluent technical specification (RETS) limits.
NRC NUREG 0473 (RETS) was proposed by the NRC to ensure that the construction and operation of nuclear plants resulted in environmental doses "as low as reasonably achievable."
The proposed RETS release limits are stated in terms of environmental doses and dose rates.
Requirements for radwaste equipment and radiation monitoring instrumentation operability are significantly expanded.
Associated limiting conditions for operation (LCOs) are created.
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Director of Nuclear Reactor Regulation July 3, 1985 The BFN solid radwaste system is described in the FSAR.
The daily operation of the system is not covered by existing technical specification requirements.
- However, BFN processes, packages and ships its solid radwaste in accordance with applicable DOT and burial ground requirements.
TVA internal and external audits ensure compliance and document the success of our present program.
We believe that the solid radwaste restrictions and controls in the RETS proposal will not improve the existing program.
Implementation of proposed RETS will involve extensive revisions to BFN procedures and documents, and will require personnel training in the new RETS requirements.
NRC has recently initiated with industry representatives the Technical Specification Improvement Project (TSIP),
a project designed to improve and optimize technical specifications.
It is proposed that the technical specifications requiring NRC approval for revision will be reduced.
In general the technical specifications will be simplified.
TVA supports the proposal to improve the technical specifications.
We wish to delay implementation of the RETS proposal until the NRC position on improved technical specifications is formulated.
The additional operating requirements contained in the RETS proposal do not involve critical safety functions.
Therefore, it is our belief that the Technical Specification Improvem'ent Project (TSIP) will advocate their removal from technical specifications.
Radiological environmental requirements would be included in a supplemental technical specification document or the FSAR.
Details specifying radiation monitoring calibration techniques, laboratory sampling frequencies and environmental monitoring sampling locations would not be in the technical specifications.
Requirements concerning critical safety systems and safety limits left in the technical specifications would not be diluted with these specific details concerning implementation of a radiological environmental program.
The resulting technical specifications would simply reference the supplemental RETS document and commit to comply with its requirements.
We request that implementation of the RETS be delayed until the NRC position on the need for RETS in light of the technical specifications improvement program is formulated.
This would avoid the necessity to revise plant documents and train personnel concerning requirements which might later be revised or eliminated.
Our current technical specifications contain restrictions consistent with RETS.
Because of our proven record of compliance
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l Director of Nuclear Reactor Regulation July 3, 1985 with minimizing effluent releases, the operation of BFN with our current technical specifications provides acceptable protection of the health and safety of the public.
Me will continue to operate consistent with our approved technical specifications until this matter is finalized.
If you have any questions, please get in touch with us through the Browns Ferry Project Manager.
Very truly yours, TENNESSEE VALLEY AUTHORITY y.d.
J.
A. Domer, Chief Nuclear Licensing Branch Sworn to thi an subscr b
ay of b
or me 1985.
,Notary blic My 'Co ission Expires cc:
U.S. Nuclear Regulatory Commission Region II Attn:
Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr. R. J. Clark Browns Ferry Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue
- Bethesda, Maryland 20814
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