ML19340A261
| ML19340A261 | |
| Person / Time | |
|---|---|
| Site: | Oconee |
| Issue date: | 09/11/1974 |
| From: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Jennifer Davis US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8001310581 | |
| Download: ML19340A261 (2) | |
Text
I ATOMIC ENERGY COMMISSION DIRECTORATE OF REGULATORY OPERATIONS
$UIT E Cl3 MEGloN il 230 PE Ace 4T REE ST RECT, NORT HWEST o
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SEP 1; 79g J. G. Davis, Deputy Director for Field' Operation's, Directorate of Regulatory Operations, Headquarters REVISION OF TECHNICAL SPECIFICATION, DUKE POWER CQ4PANY, OC Enclosed is a copy of Appendix B Technical Specificatio AND IARVAE, of the Environmental Technical Specifications for Oconce 1, 2 and 3.
This specification, as written, is inadequate as shown by the following:
In the first sentence of Item A, the count made weekly by visual inspection from the intake structure is almost mean-1.
ingless since one cannot see well enough through 50-60 feet of water to make a reasonable count.
For the count and analysis conducted when screens are pulled (second sentence of Item A), there is no time interval shown.
2.
Further, while this may. be the best method for frequent counts, it is really a count made of fish that are on the screen when it is pulled out of the water and raises the question of how many dead fish were Icst from the screen during the pulling process.
The quarte ly underwater visual inspection (third se 3.
Item A)
Further, this method may be more time-frequent we believtt..
taking and laborious considering that there are 24 of the approximate 9' x 12' fixed screens and a diver is required.
The limit of 100 shown in the second paragraph of Item A is The' licensee is pulling 4.
not related well enough to time.
screens every two weeks to meet an Environmental Protection Agency (EPA) requirement and is making counts then, but our own specification should better relate the limit to time.
800-3500 count Since early July 1974, the licensee has been in the These are being range every two weeks when the screens are pulled.
by many reported as required and since they exceed the limit of 100 Licensee repre-factors,.we are making public information releases.
due to sentativas have told us that the 100 limit was used because e
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. J. G. Davis Ie temperature stratification, they did not expect to see any impinged It is now apparent that during the hot summer months the fish.
We believe it likely expected temperature stratification breaks do'.in.
that the excessive counts will be seen until the end of the hot
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weather season.
We have told the licensee to pursue the revision of this technical specification and we have discussed this with Dino Scalletti of Licensing who agrees ti.at the specification is very poor in its present form and says that he will contact the licensee about its Based on our experience in matters like this, we are revision.
Unless there is concerned about prompt action and resolution.
prompt action and resolution, we shall be forced to continue to receive reports of excessive fish mortalities and to make press releases as a result of this specification which is inadequate to a point of projecting a poor image of the Regulatory process.
We request that you have someone expedite the revision of this The revision should include a meaningful technical specification._
method for counting and analysis and a realistic limit number based on unit time for licensee reporting.
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f.*2s<?,,g- / / L*c Norman C. Moseley Director
Enclosure:
As stated I
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