ML19343B574
| ML19343B574 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/17/1980 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Diggs R NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| NUDOCS 8012240265 | |
| Download: ML19343B574 (2) | |
Text
400 Chestnut Street 'Icwer II December 17, 1980 g
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3 Ms. Reba M. Diggs Facilities Program Coordinator License Fee Management Branch Office of Mministration U.S. Nuclear Regulatory Cctr:cission Washington, DC 20555
Dear Ms. Diggs:
'Ihis is in response to your letter to me dated December 3, 1980, concerning final fee determinatien for Browns Ferry Nuclear Plant technical specification changes. We do not contest the fee determination for TS 153, and supplement to TS 140 and TS 148 and have made arrangements for pay: tent of the fees.
However, we do not agree with the NPC's classification and fee determination for TS 145 and TS 151. We continue to believe that no additional payment is required for these technical specification changes. Enclosed are our reasons why we believe the fees are incorrect.
Very truly yours, TEIMSSEE VAT.f?Y PUHORITY f
or l} lt l,dLy ',,Q L. M. ? dills, Panager Nuclear Regulation and Safety Ehclosure 4
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TS 145 - letter dated August 13, 1980--We not agree with the classification of this request for license amenement as a Class III. %e license contains values of Maximum Average Planar Linear Heat Generation Rate (MAPLHGR), a core operating parameter, versus exInsure of the reactor fuel in megawatt-days per tonne (ED/t). % e license, as originally issued, contained values of MAPIER out to a fuel exposure of 30,000 MSD/t. 7te requested license amendment only sought to extend the values of MAPLEGR beyond 30,000 MWD /t by adding a value for 35,000 and 40,000 MWD /t. "he license amendment was needed for continued facility operation because the fuel was reaching and exceeding 30,000 MWD /t exposure. %e acceptability of higher exposure in B1R fuel was being reviewed generically by the NFC staff before sutraittal of TS-145. IE Information, Notice 80-04 documents that similar license amendments had been previously approved. Since this license amendment only extended the exposure values of an accepted core operating parameter, we do not believe that it involved a safety issue. We continue te believe this to te an administrative Class II amendment.
2.
TS 151 - T7A letter dated September 24, 1980--his request for license amendment requested revisions to the technical specification bases regarding the time delays normally experienced in the control rod drive system scram solenoid circuitry. % e existing specifications state that a 390 millisecond time delay would be allowed in the analytical treatment of operational transients. We received notification fran the General Electric Ccepany (GE) that _ the technical specification bases were incorrect in that a time delay of 290 milliseconds is used in the Erm ns Ferry transient analyses. %e requested license amendment corrects this value for circuitry time delay. Historically, GE has performed all transient analyses for Browns Ferry. Recording the time delay in the bases is dene only to provide general information. No safety concerns or limits arise directly frcm the technical specification bases. All safety-related limits, which the operating facility must cceply with, are given in the technical specification Limiting Conditicns for Operation (IrO's);
in this case the control rod insertion times. We existing insertien time Iro's include the actual time delays which the plant actually experiences. By car. plying with the appropriate Iro's, safe operation of Browns Ferry is assured. Because no changes were proposed to the Iro's, no safety issues were involved. We believe the the Class II amendment fees provided with the September 24, 1980, letter are apprcpriate.
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