ML20040A177
| ML20040A177 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/15/1982 |
| From: | Howe P CAROLINA POWER & LIGHT CO. |
| To: | Vassallo D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20040A178 | List: |
| References | |
| NO-82-100, NUDOCS 8201200474 | |
| Download: ML20040A177 (2) | |
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File: BC/A-4 Serial No..
.-100 Office of Nuclear Reactor Regulation ATTENTION:
Mr.
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B. Vassallo, Chief Operating Reactors Branch No. 2 United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 REQUEST FOR LICENSE AMENDMENT APPENDIX B TECHNICAL SPECIFICATIONS
Dear Mr. Vassallo:
SUMMARY
In accordance with the Code of Federal Regulations, Title 10 Section 50.90 and Section 2.101, Carolina Power & Light Company hereby requests revisions to the Appendix B Technical Specifications for the Brunswick Steam Electric Plant (BSEP) Unit Nos. 1 and 2.
The purpose of these changes is to replace the "12 consecutive month" basis for annual releases for gaseous effluents with a " calendar year" basis.
DISCUSSION:
Our November 25, 1981 submittal requested Technical Specifications changes to revise the methodology for calculating noble gas releases from the facility.
In addition, we requested use of a " calendar year" basis for these calculations to replace the "12 consecutive month" basis.
On December 9, 1981, NRC responded by issuing Amendment Nos. 43 and 66 which clarified action requirements and reflected revised methodology based on dose factors for radioactive materials in gaseous effluents.
However, these amendments did not address the " calendar year" issue.
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Carolina Power & Light Company (CP6L) firmly believes that the
" calendar year" basis is a valid interpretation of NRC regulations and guidance.
10CFR50 Appendix I refers to " annual air dose" which should allow a " calendar year" interpretation.
In addition, NUREG-0473, Revision 2 specifically calls for a calendar year basis for Appendix I air doses due to noble gases. Also, NUREG-0133 provides mathematical relationships for implementing Appendix I, and these are specifically presented using a calendar basis.
From conversations with NRC Staff subsequent to the issuance of Amendments 43 and 66, we understand that current licensing practice for OL's is to allow use of the calendar year interpretation for annual re-leases. Therefore, CP6L is hereby reiterating its request to incorporate the " calendar year" basis into the Brunswick Appendix B Technical Specifi-cations.
ADMINISTRATIVE INFORMATION Er. closed you will find the revised Technical Specifications pages with the changes indicated by vertical lines in the margins.
In accordance with 10CFR170.22, we have determined that these changes are administrative in nature and thus constitute one Class I amendment and one Class II amendment. Accordingly, our check for $1,600 is enclosed.
We ask that issuance of these Technical Specifications be ex-pedited as much as possible. Please contact my staff should you have any questions or if you require any additional information.
Yours very truly, P. W. Ilove Vice President Technical Services PWil/ JAM /dk (5276)
Attachments cc: Messrs. C. A. Julian R. C. Lewis J. P. O'Reilly J. Van Vliet P. W. Ilowe, having been first duly sworn, did depose and say that the information contained herein is true and correct to his own personal knowledge or based upon information and belief.
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