ML19207B761
| ML19207B761 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/29/1979 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7909050231 | |
| Download: ML19207B761 (16) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 37401 400 Chestnut Street Tower II August 29, 1979 TVA BTNP Th 130 Mr. Harold R. Denton, Director Office of Nuc, lear Reactor Regulation U.S. Nuclear Regulatory Comnission Washington, DC 20555
Dear Mr. Denton:
In the Matter of the
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Docket Nos. 50-259 Tennessee Vallay Authority
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50-260 50-296 In accordance with the provisions of 10 C7R Part 50.59, we are enclosing 40 copies of the proposed changes to the environmental technical specifica-tions for the Browns Ferry Nuclear Plant unit Nos.1, 2, ad 3 (Appendix B to Facility Operating Licenses DPR-33, DPR-52, and DPR-f,8, respectively).
Enclosure A is a proposed change to Section 2.0 (Limiting Conditions for Operation), and Section 3.1.2 (Other Chemicals) which are now the respon-sibility of the EPA and are regulated by the NPDES permit. Also included are changes to Section 5.0 (Administrative controls) which reflect recent organizational changes within TVA. Enclosure B contains the basis for these changes.
In accordance with the requiremonts of 10 CFR Part 170.22, we have deter-minsd these proposed amendments to be Class III for unit 1, and Class I for units 2 and 3.
These classifications are based on the facts that the proposed amendnent involves a single environmental issue which does not 9.q t z, O e r o SW 7900050 2 3 /. F An Equal Opporturuty Employer xv
i Mr. Harold R. Denton, Director August 29, 1979 involve a significant hazard consideration for unit 1, and the proposed amendments for units 2 and 3 are duplicates of the unit 1 proposed amendment submitted by this letter. The remittance for $4800 ($4000 for unit 1, $800 for units 2 and 3) is being wired to the NRC attention: Licensing Fee Management Branch.
Very truly yours, TENNESSEE VALLEY AUTHORITY f -Ah L. M. Mills, Fanager Nuclear Regulation and Safety Subscribed sud sworn to before this t f/'. day of August 1979 m4 7
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Enclosures (40)
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ENCLOSURE A Change 1 1.0 pE_FINITIONS The following ter=s are defined for uniform interpretation of these specifications.
Adrinistrative Teminoleff Enviren= ental limiting ccnditica for operation--any li=iting condition for plant operation as stated in Section 2 of the 3rovns Ferry Nuclear Plant Environ = ental Technical Specifications.
Unusual event with the potential for a significant environ = ental impact-an event that results in nonce: pliance with an environ = ental technical specification, or an event that results in uncontrolled or unplanned releases of che=ical, radioactive, ther=al, or other discharges frc:a the Browns Ferry Nuclear Plant in excess of applicable Federal, state, and local regulations.
Ther=al Properties Themal li=its--lirlts defined for te:nperatures, spatial chances in temperature, and te= poral changes in te=perature within Vheeler Reservoir that are attributable to ther=al discharges fro: Brevns Ferry Nuclear Plant.
Inte.ke te=perature--the averose temperature at a given ti=e within the intake syste= at a point beyond the intake pu=ps.
Discharge temperature-the average te=perature at a given ti=e in the cooling vater return channel or at the condenser outlet butterfly valves.
Delta T ($ T)--the difference in temperaturen of the river at the centrol
=cnitors attributable to ther=al discharges fro = Brevns Ferry !hiclear Plant.
Instru=entatica Procerties Accursey--a =easure of the difference between the truc und =casured values of a given para =eter, hence a =easure of error.
Mini =u= detectable level-that level belev vhich a specific detector, instrument, or analysis is unable to detect the presencc of a given constituent.
Sensitivity--the =ini=u= change in the vat!able detected by a given
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. 2.0 LIMITING CO:mITIONS FOR OPERATION 2,1 THERMAL dis RARGE LIMITS Page deleted
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SCs;;y;q Figure 4.2-1 LOCAL MONITORING STATIONS BROWNS FERRY NUCLEAR PLANT 5
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3.2 Land Manage =ent 3.2.1 Power Plant Site _ - The site shall be appropriately landscaped as allowed by completion of construction. All areas which are either unpaved or not cor.,titted for specific purposes vill be provided with appropriate vegetative cover.
3.2.2 Transcission Line Right-of-Uay Maintenance
})bjective The sole purpose of this section is to provide reporting, requirements (to U3ffRC) on herbicide usage, if emy, for purposes of right-of-way maintenance regarding only those transmission lines under USNRC'r,,)urisdiction for the Drovns Ferry Nuclear Plant.
Dpecifiention A statement cs to whether or not herbicides have been used in taintaining rights of vay for those transr.ission lines. associated vith the Browns Ferry Nuclear Plant shall be provided. If herbicides have been used, a description of the types, volu=es, concentrctions, canners and frequencies of application, and tiles of right of vay that have been treated shall be included.
Peporting Pequirements Information as specified above chall be provided in the annual environ = ental cperatin6 report.
Enses Vegetation growth 1 a transtissica line right of vey cust be controlled in r.uch a tanner that it vill neither interfere vich care cnd reliable opera-tion of the line nor inpede restoration of service uhen outsges occur.
Vegetation growth is controlled by techanical c.itting and tre Jirited use of herbicidea. Selected checicals approved by ~PA for use Ls he.-bicides 6ned (by EPA) label inrtmetiens which provide Euidance on and are assi procedures for their use.
- 3. 3 onsi te !!eteorologi cal l'snitorin e The ensi te te teo. olc gical sc.itoring progrca netsu-es c-i decta.er t.
cateorologietl conditions at the site, specifically a. heights abor? ground that tilo reasonable er.ti=ctes of atmosphe--ic dispersica condition., for airborne plcat effluetta.
Ta e on s i t e prog rne s h all c en to. ;. t e t n <
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nen da t ier.s and intect o f Begulatory Guide 1.23, On n it e t'c.ec rclog. e ?
Program (February 1972), end include instrt.ents to s.e:se Jine speed cad h recticn et 1C=, L6, und 91:; to allou calculation of verticcl tenpern_
titre gradient betwee:: 10n and L6: and betveen 10m cnd 912; and to n+nsure rnbient to rpercttre t.nd dev 7010 0 at 103.
Yne locr.ticn o." sne.c;e.3rcicgical tover i s c.s specified in Secti c: 2. 3.7 of the Erovr.s Ferry Suclear Plant Finel Safety Analysis Repo-t (see A endrest 63). A qttlity casurance progras shall be in ef fect for cll teteomlo-ic.d ceasure ents c.d e
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ENCLOSURE A Channe 2 5.0 AININISTRATIVE CONTROLS Objective This section describes the administrative and management controla established to provide continuing protection to the envire a it and to implement the environ-mental technical specifications. Measures to be specified in this section include the assignment of responsibilitier, organizational structure, operating proceduras, review and audit functions, and reporting requirements.
Specifications 5.1 Responsibility 5.1.1 The power plant superintendent has responsibility for operating the plant in compliance with these technical specifications.
5.1.2 The Staf f Chief, Environmental Compliance, is responsible for the envirenmental monitoring program outside the plant.
5.2 Organiro 7
5.2.1 The organirstion of TVA management v'11ch directly relates to operation of the plant is shown on Figure 5.2-1.
5.2.2 The principal organizations within TVA which are concerned with environ-mental matters related to nuclear nower plant operations are the Otfice of Power, Office of Natural Resources, and the Office of Health and Safety. The Of fice of Power is directly responsible for operating the plant in accordance with specified requirements and conducting onsite monitoring. The Office of Natural Resources is responsihie for providing technical guidance, assistance, monitoring, and other services as needed for environmental compliance. The office of Health and Safety is responsible for independent review and audit of procedures for meeting environmental specifications and limits. The organizations above report to the General Manager as shown in F*gure 5.2.2.
5.3 Review and Audit 5.3.1 The Office of Health and Safety is responsible for independent review and audit of procedures for meeting environmental specifications and limits.
5.3.2 The Office of Power Quality Assurance and Audit Staff shall ensure that a periodic audit of the environmental monitoring crogram is conducted at least once per calendar year.
5.3.3. The office of Power and/or Office of Health and Safety conducts an interdisciplinary review of the following items:
a.
Preparation of the proposed environmental technical specifications.
b.
Coordination of environmental technical specification development with the safety technical specifications to avoid conflicts and maintain consistency, Proposed changes to the environmental technical specifications and c.
the evaluated impact of the change.
d.
Proposed written procedures, as described in Section 5.5 and nroposed changes thereto which could significantly affect the plant's environmental impact.
Proposed changes or modifications to plant systems or equip-e.
ment which could significantly affect the plant 's environ-mental impact and the evaluated impact of the changes, f.
Results of the environmental monitoring programs prior to their submittal in each Annual Operating Report. See Sections 5.6.1 and 5.6.2.
g.
Reported instances of violations of environmental technical specifications. Where investigation indicates, evaluation and formulation of recommendations to prevent recurrence.
5.4 Action to be Taken if an Environmental LCO in Exceeded 5.5 Procedures 5.5.1 Detailed written procedures for the in-plant nonradiological monitoring program, including check-off lists, where applicable, shall be prepared by DNP and approved by the plant superintendent (or nis designee) and adhered to.
5.5.2 Detailed written procedures for the environmental monitoring program outside the plant, including check-off lists, where applicable, shall be prepared, receive appropriate administrative approval and be adhered to.
A quality control program for the radiological environmental monitoring program has been established with the Alabama Department of Public Health Administration Laboratory and the Environmental Protection Agency, Montgomery, Alabama. Samples of air, water, milk, and vegetation collected around the BFNP are forwarded to these laboratories for analysis; and resulta are exchanged for comparison.
An internal quality control program for the radiological environ-mental monitoring program is being conducted whereby roughly one tenth of all samples are analyzed in duplicate. A quality control program is conducted with the Environmental Protection Agency in I.as Vegas in which spiked samples are analyzed and the results compared.
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. 5.5.3 All procedures described in Section 5.5.1 and all changes thereto shsil be reviewed and approved prior to implementation and on an annual basis thereafter by the nlant management.
Temporary changes to procedures which do not change the intent of the original procedure may be made, provided such changes are documented and are approved oy two of the following niant personnel:
Sunerintendent Assistant Superintendent Onerations Supervisor Assistant Operations Supervisor Shift Engineer 5.6 Reporting Requirements 5.6.1 A report shall be prepared by Environmental Compliance and submitted to DNP following the end of each 12-month period of operation, which shall summarize the results of the nonradiological environmental monitoring nrogram.
5.6.2 Routing Reporting a.
A summary report shall be prepared for both the inplant monitoring program and the nonradiological monitoring programs and submitted to the Director of Divisien of Operatine Reactors, NRC, as part of the Annual Operating Report within 120 days after December 31 of each year.
h.
Radioloeical Environmental Monitoring Routine Renortine Reporting Requirements:
1.
TVA shall scepare a report entitled " Environmental Radio-activity Levels - Browns Ferry Muclear Plant - Annual Report."
The report shall cover the previous 12 months of operation and shall be submitted to the Director of the NkC Region II office (with a copy to the 7trector, Office of Nuclear Reactor Regulation) within 120 days after January 1 of each vear.
The report format shown in Regulatory Guide 4.8 Title 1 shall be used.
The report shall include summaries, interpretations, and evaluations of the results of the radiological environmental surveillante activities for the report period, including a comnarison with preoperational studies and/or operational controls (as appro-priate), and an assessment of the observed impacts of the pinnt' operation on the environmenta.
If harmful effects or evidence of irreversible damage are detected by the monitoring, the licensee shall provide an analysis of the problem and a proposed course of action to alleviate the problem.
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. 2.
Results of all radiological environmental samples taken shall bc su=carized and tabulated on an annual basis.
In the event that some results are not available within the 120-day period, the report shall be submitted noting and explaining the reasons for the missing result s.
The missing data shall be submitted as soon as possibic in a cupplementary report.
5.6.3 Non-Routine Reports a.
Radiciozical Ancoalour Measurements 1.
If, during any 12-conth report period, a ocasured ;cvel of radio-ac tivity in any enviroraaental medium other thaa those associated with gaseous radiolodir.2 releases exceeds ten'tices the control station value, a written notification vill be subsitted v. thin one week advising the URC of this condition.* This' notification should include an evaluation of any release conditions, environ-cental factors, or other aspects necessary to cxplain the anosalous result.
2.
If, during any 12-nonth report pe riod, a neasured level of radioactivity in any environmental cedium other than those associated with gaseous radiciodine releaser. cxceeds four ticas the control r.tation value, a writt en notification vill be subsitted within 30 days advis.nc the NP.C of th;. conditica.
This notification should inclu.le an eveloc' ion of any release conditions, environmental factors, or other aspects necessary to explain the anocalous resul;.
3.
If individual milk saeples shos 1-131 conecntrations of 10 picoeuries par li cr or greater, a plen si.11 Le sabnitted withia 10 days advising the NRC of the p cpa:,ed act ica to ensure the plant related annual doses vill be within tbt desiga ubjective of 15 crea/yr / reactor to the thyro;d of any individual.
4.
If cilk sarples collected ever a cairn <
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concentrations of 6.0 picoci. ries per itu r u.. rec, a plar.
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shall 'te submit ted wit hin 30 d ay.. vi. o.- tne kC 0: the proposed action to ensure the plant,relcteu ennua: doses vi;.
be within the design obj ective of 15 ucec/yr/reaca.c to the thyroid of any individual.
- 1a the c a r, e of a tentatively ano.,alcua value for. ac a a a t i i.c... coa 4s-.itery r e a n a l y :. u. of the original, co;>11ca t e or a ceu su p;c o y L.,
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instaate the resu'ts of the confir story analysia she.1 b -: c ocia le c e _ c_
t r.e curliest time consistent with the c:.a ly s ; s, and if tne higa veio~
e., ', t i.e regnr-to the NRC shall be submitted within one week following thit analyats.
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If such levels as discussed in 5.t.3(a)3 and 5.6.3(a)4 can be definitely shown to result fr om sources other than the Browns Perry Nuclcar Plant, the reporting action called for in 5.6.3(a)3 and 5.6.3(a)4 need not be taken.
Justification for assigning high levels of radioactivity to sources other than the Browns Ferry Nuclear Plant must be provided in the annual raport.
h.
Nonradiological c.
Changes 1.
Where a change to the plant design, the plant operation, or to procedures is planned which could have a signiiicant adverse effect on the environment or which involves an environnental matter or question not oreviousiv reviewed and evaluated by the NRC, a request for the change shall be nade to the NRC before imolementation.
2.
Changes or additions
- .o oermits and certificates required for the r: ection of the environment shall he reported. When the required changes are submitted to the concerned agency for approval, they shall also be submitted to the Director, Division of Operating Reactors, USNRC, for information.
3.
Requests for changes in environmental technical specifications shall be submitted to the Director, Division of Operating Reactors, USNRC, for prior review and authorization.
5.7 Environmental Records 5.7.1 Operational information concerning the inplant portion of the environ-mental technical specifications shall be kept by DNP in a manner convenient for review. This includes plant records and/or logs as indicated below:
a.
Related plant operatione b.
Related maintenance activities c.
d.
Updated, corrected, and as-; uilt drawings o r the plant Item (a) through (c) above shall be retained for a veriod of at least six years and item (d) shall be retained for the life of the niant.
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. 5.7.2 Records and/or loge shall be made and retained in a manner convenient for review. This information concerning the envirc.n-mental monitoring program is indicated below:
a.
Checks, inspections, tests, and calibration of components and systems.
b.
Principal maintenance activities associated with environ-mental monitoring equipment and systems.
c.
Results of environmental monitoring surveys related to BFNP.
Items (a) and (b) shall be retained for a period of at least six years and item (c) shall be retained for the life of the plant.
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45 ItAi1AGER OF POWER
?00RDRVW i:ANAGER OF PO'<!FP OPERATICi:S DIRECTOR, DIVISI0'10F NUCLEAR POWER SUPERINTEf1DEflT,
tiUCLEAR PLAf4TS SUPERVISOR, SUPERVISOR, OPERATIONS SECTION RESULTS SECTION 795339 BRCWNS FERRY N0 CLEAR PLcNT Offic. or.
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ENCLOSURE B Change 1 Justification for Proposed ETS Change Operating requirements identified in sections 2 1, and 3.1.2 are duplicate to those conditions regulated by Browns Ferry Nuclear Plant 's NPDES Permit No. AL0022080 which was issued to TVA on June 30, 1977.
The NPDES permit specifies the specific effluent limitations for thermal, chemical, and sanitary waste discharges originating from the facilities and reporting requirements necessary to determine compliance with the effluent limitations. Any subsequent revisions in the terms of the NPDES permit will be submitted to the NRC for information.
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ENCLOSURE B Change 2 Justification for Proposed ETS Change Changes to section 5.0, Administrative Controls, were made to reflect recent reorganizations within TVA.
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