ML19254F900

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Responds to Requesting Alternate Method of Compliance W/Epa U Fuel Cycle Std (40CFR190).Commits to Comply W/Radiological Effluent Tech Spec 3.8.1
ML19254F900
Person / Time
Site: Pilgrim
Issue date: 11/08/1979
From: Andognini G
BOSTON EDISON CO.
To: Gammill W
Office of Nuclear Reactor Regulation
References
79-232, NUDOCS 7911190375
Download: ML19254F900 (1)


Text

BOSTON EDISON CPMPANY GENERAL Orricts 800 BovLaTON ST9ECT SOETON. M AESACHUSETTs 0 2199 G. camL ANOQ3 NIM 6 SWPEDIINTENDENT NUCLEAm QPEmaTIONS DEPARTMENT November 8, 1979 BECo. Ltr. #79-232 Mr. William Gammill, Acting Assistant Director for Operating Reactors Projects Division of Operating Reactors U.S. Nuclear Regulatory Commission Washington, D. C.

20555 License No. DPR-35 Docket No. 50-293

Dear Sir:

Your letter dated September 27, 1979, stated that our proposed Radiological Effluent Technical Specification (RETS) would not be processed prior to the December 1, 1979 effective date for implementation of the EPA Uranium Fuel Cycle Standard, 40 CFR Part 190, and as a result you requested that Boston Edison Company propose an alternate method of demonstrating compliance with 40 CFR Part 190 until such time as our proposed RETS' are issued by t.he Commission.

Therefore, pursuant to your request Boston Edison Company hereby commits to comply with Specification 3.8.L of the proposed RETS as submitted on February 21, 1979 in BEco. Ltr. #79-45 from Mr. J. E. Howard to Mr. T. A. Ippolito as an alternative method of demonstrating compliance with 40 CFR Part 190.

Specifically, this is a commitment to limit doses to twice the values specified in Section 3.8.C.1.a. 3.8.F.1.a, 3.8.G.1.a and 3.8.G.1.b of the BECo. submittal.

Should the dose limits in these specifications be exceeded by a factor of two, Boston Edison Company will prepare and submit the "Special Report" as referenced in Specification 6.9.B.2 provided that the Commission has issued guidance which identifies an analytical method which is acceptable to the staff for demonstrating compliance with 40 CFR 190.

If such guidance is not issued prior to the need for the "Special Report", Boston Edison Company will submit the "Special Report" within 90 days of the date on which the NRC issues such guidance.

We trust this method of demonstrating compliance with 40 CFR 190 is acceptable to you.

Should you require any additional information, please contact us at your convenience.

Very truly yours,

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