ML20053D323

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Memorandum in Response to Aslab 820517 Order.Util Failed to Serve Parties w/811103 Amended Application.Nrc Technical Staff Did Not Inquire Into Document Distribution & NRC Counsel Unaware of Document Existence.W/Certificate of Svc
ML20053D323
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 05/28/1982
From: Rawson R
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
References
NUDOCS 8206040297
Download: ML20053D323 (8)


Text

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UtilTED STATES OF AMERICA NUCLEAR REGULATORY COMMISS10tl BEFORE THE ATOMIC SAFETY AtID LICEtiSillG APPEAL BOARD

In the Matter of

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Docket Nos. 50-259, 50-260 and

'TEtitlESSEE VALLEY AUTHORITY

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50-296

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(License amendment to permit (Browns Ferry Nuclear Plant,

)

storage of low level radioactive Unit Nos. 1, 2 and 3)

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waste)

NRC STAFF MEMORAllDUM IN RESPONSE TO THE APPEAL BOARD ORDER OF MAY 17, 1982 Richard J. Rawson Counsel for NRC Staff May 28, 1982 gsto:MID On10111ALd 'V {,

Certified 37-p G (b V

40297 820528 8 l DOCK 05000259 PDR i

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the Matter of Docket Nos. 50-259, 50-260 and TENNESSEE VALLEY AUTHORITY 50-295 (License amendant to permit (Browns Ferry Nuclear Plant, stora e of low level radioactive Unit Nos. 1, 2 and 3)

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waste NRC STAFF MEMORANDUM IN RESPONSE TO THE APPEAL BOARD ORDER OF MAY 17, 1982 Richard J. Rawson Counsel for NRC Staff May 28, 1982 l

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UhlTED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD In the I1atter of Docket Hos. 50-259, 50-260 and TENNESSEE VALLEY AUTHORITY 50-296 l

(License amendment to permit (Browns Ferry Nuclear Plant, storage of low level radioactive Unit Nos. 1, 2 and 3)

)

waste)

NRC STAFF MEMORANDUM IN PESPONSE TO THE APPEAL BOARD ORDER OF ht 17, 1982 In an Order dated May 17, 1982, the Atomic Safety and Licensing Appeal Board noted that an amendment to Tennessee Valley Authority's application for the storage of low-level radioactive waste at Browns Ferry was submitted by TVA on November 3, 1981 but was not served on the Appeal Board, the Licensing Board or the petitioners until March 29, 1982 when Staff counsel served copies together with a transmittal letter. The Appeal Board requested memoranda from both TVA and Staff j

counsel explaining why this amended application was not earlier served on petitioners or brought to the attention of the Appeal Board while j

the proceeding was pending before it. This memorandum responds to the Appeal Board's request to Staff counsel.

TVA submitted its original application in this proceeding on July 31, 1980. The application sought permission to store low-level radioactive wastes generated by TVA at Browns Ferry on the Browns Ferry site for the life of the plant. On November 17, 1980, TVA amended its l

application to seek authorization for onsite storage for a period of 1

l five years only.

In the course of the Staff's review of TVA's application, the Staff sought and received additional infomation and clarification of matters contained in TVA's amended application. Specifically, on August 10, 1981, the Staff sent a letter to TVA with detailed questions and a request for additional information. (Attachment A) This letter was served on all parties. By transmittal letter dated November 3, 1981, TVA submitted a second amendment to its application which TVA said "provides an update of all new infomation that has been submitted since the original July 31, 1980 submittal." (Attachment B) Counsel for the Staff was not served with a copy of the November 3, 1981 amendment and did not become aware of its existance at that time. The undersigned had filed his notice of appearance as counsel for the Staff on October 23, 1981.

On or about November 23, 1981, counsel for the Staff received a telephone call from a secretary to the Appeal Board requesting tLt copies of TVA's July 31, 1980 application, the November 17, 1980 applica-tion amendment and TVA's environmental assessment be supplied to the Appeal Board. Counsel for the Staff forwarded these materials to Chaiman Eilperin with a transmittal letter dated November 24,1981.(AttachmentC)

Copies of the transmittal letter were served, without enclosures, on all parties. Because the request to Staff counsel was for specific documents, and because Staff counsel was not aware of the existence of the November 3, 1981 amendment at this time, Staff counsel did not include the November 3,1981 amendment in the materials sent to Chaiman Eilperin.

_ __ Counsel for the Staff, to the best of his knowledge, did not become aware of the existence of the November 3,1981 amended application until a few days before the April 1,1982 prehearing conference scheduled by the Licensing-Board after the issuance of ALAB-664.

In the course of preparation for the prehearing conference, counsel for the Staff gathered together the legal pleadings and the July 17, 1980 application and November 17, 1980 amendment to bring to the prehearing conference. Counsel for the Staff also inquired of the technical Staff members involved whether any additional materials would be useful to have at hand during the prehearing conference.

Counsel's attention was directed for the first time to the November 3, 1981 amendment and a copy was provided to counsel. Upon reviewing that document, counsel for the Staff was unable to determine whether the document had been served on all parties either by TVA or by the technical Staff members involved. The technical Staff members involved, of course, had not checked the distribution made by TVA which, as the originator of the document, had the duty to assure that appropriate service was made.

Counsel for the Staff spoke with W. Walter LaRoche, counsel for TVA, on or about March 29, 1982 and asked whether TVA had served the document on all parties appearing on the service list. Mr. LaRoche informed counsel for the Staff that such service.had not been made. Counsel for the Staff told Mr. LaRoche that the Staff believed TVA had an obligation to serve the document on all parties. When Mr. LaRoche expressed his disagreement, counsel for the Staff informed Mr. LaRoche that the Staff intended to make such service immediately. The November 3, 1981 amended application was served by the Staff by letter dated March 29, 1982.

(Attachment D)

In short, the November 3,1981 amended application was not served on the Appeal Boara, the Licensing Board and petitioners earlier because TVA did not so serve the document, NRC Staff technical personnel did not inquire into the distribution of the document made by TVA and did not realize that appropriate distribution had not been made, and NRC Staff counsel did not receive and was unaware of the existence of the document until, pursuant to his inquiries, he was informed by Staff technical personnel of the existence of the document a few days before the April 1, 1982 prehearing conference.

At that time, and after ascertaining that the document had not been served on the Appeal Board, the Licensing Board or petitioners, Staff counsel effected such service.

Upon receipt of the Appeal Board's Order of Itay 17, 1982, the November 3, 1981 amended application was compared with TVA's original application and first amended application with a view toward identifying any substantive differences in those documents. The November 3,1981 TVA amendment has been found to differ from the earlier application and amendment only with respect to the topics raised by the Staff's August 10, 1981 letter. These topics ir.cluded resin characteristics and container integrity, integrity monitoring, operational procedures, crane lift height, design basis for radiation protection, waste generation and disposal quantities, retrieval of waste, fire detection and suppression, organizational responsibilities and miscellaneous matters.

In the August 10, 1981 letter, the Staff had also asked TVA for information on volume reduction, since TVA had, for dose assessment purposes, made the assumption that volume-reduced waste would be stored.

In the revised 4

application TVA deleted the assumption that volume-reduced waste would be stored and deleted any references to volume reduction. TVA also deleted any reference to long-term storage. reflecting its November 17, 1980 letter which first amended the application from life-of-plant storage to five year storage.

The Staff also compared the facts stated in ALAB-664 with TVA's November 3, 1981 amended application to see if there were any factual errors in ALAB-664 relating to the TVA application and amendments. No factual errors in ALAB-664 relating to the TVA application and amendments were found.

Respectfully submitted, GiM-t&'.g -

Richard J.

awson Counsel for NRC Staff Dated at Bethesda, Maryland l

this 28th day of May, 1982.

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o AUG 101981 30-19102 Docket ho.

Tennessee Valley Authcrity ATT)!: 1:r. Hugh G. Parris Henager of Power 500A Chestnut Street, Tuwer II

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Chattanooga, Tennessee 37401 Gentle:Nn:

We are reviewing ycur application dated July 31, 1980 as arended Novecber 17, 1980, fcr arendment of your facility operating licenses for Browns Ferry Nuclear Plant Units 1, 2, and 3 under the provisions of lu CFP.

Part 30. We ray issue a separate Part 30 license if the required favorable l

findings are cade.

Based on our review of your submittal, a site visit end evetincs with k

TVA representatives, several ratters were found that require clarification, expansion and resolution so that our safety and environtental reviews may continue. As a result, we have prepared a list of questions and request for additional inforration that is enclosed.

We would appreciate an iten by iten response.

In addition, ycu should revise or ar:end the application as appropriate te reflect your response.

Please let re knew within two weeks the date by which you anticipate l

submitting your response and application changes.

If you have any questions or wish to rcet to discuss the list of questions and request for additional infomation, please contact Peter Lcysen (FTS-427-4205).

Sincerely, O?hinal signet v'.

% 4 C.Eouse Leland C. P.cuse, Chief Advanced Fuel and Spent Fuel Licensing Branch Division of Fuel Cycle and Material Safety Er closure:

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List of Ques'tions and F.equest for Additional Infornation l

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Service List I

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Attachment A J

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LIST OF QUESTIONS AND REQUEST FOR ADDITIONAL INFORMATION k

1.

Resin Characteristics and Container Integrity Historically,.there have been several accidents involving resins stored in a radiation field that have caused considerable damage. More recently, safe storage of TMI-EpICOR loaded resin liners for long periods of time has been questioned; with estimates of liner perforation occurring in 15 to Although these situations may not be dire.ctly applicable to your 19 months.

proposed action, we have similar concerns regarding the ability of the storage containers to maintain their integrity for the duration of storage.

Based upon the information in the application and discussions with the TVA staff (March 18 and 19,1981), there is insufficient information to support any conclusion regarding container integrity and potential problems with five-year or life-of-plant storage of wastes, in particular spent ion We therefore request you to provide us with an exchange resin liners.

evaluation of potential problems and the ability of waste storage containers to maintain their integrity during the five-year license term and life-of-plant storage.

The evaluation and its bases should consider, but not be limited to, such things as follows:

(1) physical, chemical and radiological characteristics of the wastes; (2) changes in the physical and chemical characteristics of wastes which

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may be expected to occur (i.e., decomposition, gas generation, etc.);

(3) physical and chemical characteristics of the container materials; (4) compatibility of the container materials to the waste forms and environ-mental conditions external to the containers; 1

(5) ranges of waste compositions that could be stored in the containers; provisions to minimize potential problems (i.e., containers equipped (6) with special vent designs to allow depressurization).

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. 2, In'tegrity Monitoring Periodic inspections (at least quarterly) of container integrity (swelling, corrosion products, breach) should be performed.

Use of high integrity containers (300 year lifetime design) would permit an inspection program of reduced scope.

Please provide a description of your proposed container

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monitoring program. Features to be considered might include, but not be If mited to the following:

(1) type inspection to be performed; a.

visual, b.

tv monitors, c.

inspecting and sampling designated waste containers.

(Designated Wdste Containers should Comprise a representative sample of types of waste containers stored, length of time stored and number of modules in use.)

(2) the characteristics to be monitored;

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(3) other monitoring to detect potential problems; a.

fire detection, b.

air sanpling (airborne radioactivity, explosive gases),

c.

liquids sampling.

(4) evaluation of occupational and population doses, if any, resulting from the monitoring program.

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3.

Operation of Modules In your application you provided estimates of doses from normal operations based on the assumption that the stored waste would be volume reduced by incineration.

However, since TVA has not made an application to reduce LLW by incineration, the NRC staff requires additional information. Based on the same time and motion analyses, operating conditions and site data,

'and assuming the waste stored is not volume reduced by incineration, please provide an assessment of the occupational and environmental doses for the five-year license term and life-of-plant storage.

Please provide the three additional information requirements in this area.

They are:

(1) A copy of page VI.B-2 (RMSM, dated 12/15/80, Revision 8) the time and motions estimates.

It is not in the information provided during the site visit.

(2) Confirmation that Table 3.3-1 of Design Criteria fBFN-50-D745 is currently the design basis for non-volume reduced waste. Furthernece, license limits for the total curie content of both the resin and C

miscellaneous wastes should be specified.

These limits should be large enough that they would not be exceeded, during anticipated normal operations, for the five-year durati.on of the license.

(3) A discussion of'the schedule for placement of trash and resin liner containers into the storage modules.

In particular, if batching is anticipated, please provide estimated number of containers per batch for each type of waste.

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4.

Control of crane lift height In the application, four accident's involving the dropping of a module cap are discussed.

Three of these accidents involve dropping a module cap onto another cap, and dropping the cap into or onto the module itself.

In each accident the consequence is mitigated by controlling the height that a cap can be lif ted (five feet above an open module). The type of control is admini strative.

From the control cab of the crane it would appear difficult to estimate the height of the lift by direct observation.

Please describe how an operator can comply with the administrative controls, and describe any instrumentation that an operator would use to control the lift height.

5.

Design basis for radiation protection In discussions with TVA on March 18 and 19,1981 the design considerations for analysis of modules were discussed.

Your " Design Criteria for the Long-Term Onsite Storage Facility for Low-Level Radioactive Waste" indicates that the modules are designed for conformance with 10 CFR 20. To complete a review of this design a description of the basic assumptions and methods of calculations used is necessary. This discussion should describe the assumed source term (s),

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shielding characteristics of the concrete, and the methods of calc 01ation.

6.

Volume Reduction In calculating occupational and population doses, you have assumed that all waste will be volume-reduced by incineration, trash by a factor of 36 and resins by a factor of 15. However, you have not included doses from the incineration operations nor described the operations for our review.

Is volume reduction by incineration intended to be part of the storage program? 'If so, we require additional information about its impacts.

If not, why are the doses calculated using the assumption of incinerated wastes?

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. 7.

Need for the Proposed Action Your application discusses the need for the proposed action in Section 1.3.

It states the proposed action is needed because:

Chem-Nuclear Systems, Inc. has reduced TVA's monthly allotment of burial volume, and TVA is now generating waste at other nuclear plants besides the Browns Ferry Plant and where as TVA has additional wastes to dispose of within the alloted volume.

These arguments are convincing to an informed read'r.

However for e

readers not familiar with the schedule for future,TVA nuclear plants, the volume of low-level waste generated from different reactor types, l

and TVA's historical allotment and actual volume used, these reasons may not be so convincing. Therefore, please provide specific information concerning:

(1) historical data on the allotments at various disposal sites; C ',

(2) historical data on actual volume shipped to various disposal sites; and (3) continued anticipated future utilization of ~ disposal sites for disposition of Browns Ferry low level waste; l

(4) projection of the volume to be disposed of over the next l

5 years from both the Browns Ferry Plant and other TVA plants.

This kind of specific information will put the need for the proposed action into perspective and clearly show the real requirements for ma,naging Browns Ferry Waste.

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8.

Retrieval Impacts from retrieval of waste from the storage modules at the conclusion of storage were not included in the application. Within the context of your response to questions 6 and 7, please provide estimates of how long it would take to remove the wastes at the end of the 5-year license term as well as at the end of life-of-plant storage, and an evaluation of the occupational and population doses from retrieval.

In these estimates and evaluation, you should also consider the availability of the following items:

(1) container handling equipment (2) shipping casks and vehicles (3) clement weather (4) anticipated disposal capacity 9.

Organizational Please identify those organizations within TVA and BFNP having responsibility for radiological safety and discuss how these organizations meet the requirements of 10 CFR 33.13(c). This may be described by reference to the appropriate portions of the reactor operating license if applicable.

10. Fire Detection and Suppression C~%

Please explain the basis for your decision not to incorporate automatic fire detection and fire suppression systems into the design of the storage modules.

11. Miscellaneous The following is a list of information pertinent to the analysis in support of the TVA low-level waste storage request provided verbally during the site visit of March 18 and 19,1981. Please confirm or clarify the l

following:

(1) The water table under the waste storage site is between elevation 530 and 550 feet (i.e., 30 to 50 feet below the grade of the storage area).

(2) The metal gratings are to be used on the floor of each module as well as between layers of containers.

(3) The fire hydrant water can be taken from two independent sources.

(4) All applicable features, practices, and procedures described in your facility operating licenses, Scluding FSAR's and EIS's will apply to construction and operation of the low-level waste storage modules (i.e., health physics practices, monitoring, etc.).

BEFORE THE ATOMIC SAFETY AND LICENSING BOAkD In the Matter of

)

TENNESSEE VALLEY AUTHORITY Docket No. 030-19102 4

(Brown Ferry Nuclear Plant)

)

)

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'erbert Grossman, Esquire.

Mrs. Elizabeth B. Johnsor.

Dr. Quentin J. Stober

hairman Member, Atomic Safety &

Member, Atomic Sa,fety &

Licensing Boaro

.tomic. Safety & Licensing Board Licensing Board 1.5. Nuclear Regulatory Oak Ridge National Laboratory Univers1!y ci hrch. Institute Fisherie Rese s

ashington Conaission P.O. Box X Bldg. 3500 Seattle, Weshington 93195 stshington, D C.

20555 Dat. Ri,dge c, Tennessee.- 37830.

(r. Charles R. Christopher Ira L. Myers, M.D.'

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Director. 0#fice of Urban &

haiman, Limestone County State Health Officer Federal Affairs Cc tr.i s s i or.

State Department of Public Health 108 Parkway Towers

' 0. Box 185 State Office Building 404 James Robertson Way

thens, Alabama 35511 Montgomery, Alabama 36104 Nashville, Tennessee 37219 tr. Jchr. F. Ccx Mr. Robert F. Sullivan Atcmic Safety & Licensing

. err.essee Val'.sy Authority U.S. Nuclear Regulatory Scard

9-5 207 Com.ission U.S. Nuclear Regulatorv
~~ '-: er:e *ve.us F.O. 5::: 1E52 C:=iss :n n

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~79:2 Decatur, Alabama 25502

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20555 Mr. H. N. Culver tomic Safety & Licensinc Secretary 249 HEU Aapeal Far.el

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U.S. Nuclear Regulatory h,C ier{,e]

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' Si Nuclear Regulatory Commission Commission ATTH: Chie,, Docketing and Kncxville, Tennessee 379'02 sasnincton, D.C.'

2055:,:

Service Branch Wash.ington,.D.C.

20555

i. S. Sanger, Jr., Esq.

Mr. O a Rogers Mr. Herbert Abercrombie 3:neral Counsel Tennessee Valley Authority Tennessee Valley Authority h{ennessee Valley Authority 400 Chestnut Street F.O. Box 2000 lB [f

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Chattanooga, Tennessee 37401 Decatur, Alabama

  • 35602

'noxville, Tennessee 37902

.eroy O. Ellis III, Escuire Robert B. Pyle, Escuire

21 Cnarie::e Avenue 4220 Nolensville Road

.ashville, TN 37219 Nashville, TN 37211 h

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TENNESSEE VALLEY AUTHORITY N 01/ 2 7,g g,

es43rasooo4, rensessec 374oi 789t3thnm 400 Chestnut Street Tower II

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November 3, 1981

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Director, Office of Nuclear Material Safety

'[O and Safeguards 2

Nov Attention:

Mr. L. C. Rouse, Chief tl-

  1. hueg 8 /Sgj &

Advanced Fuel and Spent Fuel to

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D J Licensing Branch g g% ce, U.S. Nuclear Regulatory Commission Washington, DC 20555 o>

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Dear Mr. Rouse:

In the Matter of the

) Docket No. 30-19102 Tennessee Valley Authority

)

In response to your letter to H. G. Parris dated August 10, 1981, we are submitting an updated amendment to TVA's July 31, 1980 application for the storage of low-level radioactive waste at the Browns Ferry Nuclear Plant. The amendment requests authorization for TVA to store the low-level radioactive waste generated from the operation of Browns Ferry for a period of five years. The amendment is enclosed and provides an update of all new 4

information that has been submitted since the original July 31, 1980 submittal. We believe that this submittal includes all information requested by your August 10, 1981 letter.

If there is any additional information ncqessary to co:plete the review of TVA's low-level storage application, pleat. t let us know.

Very truly yours, TENNESSEE VALLEY AUTHORITY I

L. M. Mills, P ager Nuclear Regulation and Safety gi y f

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.~O b'e'schi -day of b 1981 Sub d nd sworn to before this !

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Notary Public My Cocnission Expires g(ya" s

h EncAos.tro cc: See page 2 gg gggi3 (fM-

'i Wlv w a Attachment B

Director, Office of Nuclear Material November 3, 1981 Safety and Safeguards oc (Enclosure):

Mr. Charles R. Christopher Chairman, Limestone County Commission P.O. Box 188 Athens, Alabama 35611 Cffice of Nuclear Reactor Regulation Attention: Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Comm_ission Washington, DC 20555 Mr. K. D. Fagan,-Supervisor - Nuclear General Electric Company 832 Georgia Avenue Chattanooga, Tennessee 37402 Dr. Ira L. Myers State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36104 6

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flovember 24, 1981 Stephen F. Eilperin, Esq.

Chairman Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commission Uashington, D.C. 20555 In the Matter of TENNESSEE VALLEY AUTHORITY (Browns Ferry Nuclear Plant, Unit Nos.1, 2.and 3)

Docket Hos. 50-259, 50-260 and 50-296

Dear Mr. Chairman:

As your secretary requested, I enclose for the Appeal Board records copies of the following documents:

1.

TVA's application, dated July 31.1980, for an amendment to the operating licenses for Browns Ferry Nuclear Plant; 2.

TVA's amended applic'ation, dated November 17,1980; and 3.

TVA's Environmental Assessment, dated February 28,1980, of low-level radioactive waste management for the Browns Ferry Nuclear Plant.

These documents were previously supplied to the Atomic Safety and Licensing Board by letter dated April 15, 1981 at the request of its then-chairman, Herbert Grossman.

I Sincerely, Richard J. W. & ~ ~

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Rawson Counsel for ilRC Staff i

Enclosures as stated cc (w/o encl.):

Service list Attachment C l

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![*g* ** co,]o, UNITED STATES g

NUCLEAR REGULATORY COMMISSION y.

1l WASHINGTON, D. C. 20555 March 29, 1982 John H. Frye, III, Esq., Chairman Mrs. Elizabeth B. Johnson Administrative Judge Administrative Judge Atomic Safety and Licensing Board Oak Ridge National Laboratory U.S. Nuclear Regulatory Comission P.O. Box X, Building 3500 Washington, DC 20555 Oak Ridge, TN 37830 4

Dr. Quentin J. Stober Administrative Judge Fisheries Research Institute University of Washington Seattle, WA 98195 In the Matter of TENNESSEE VALLEY AUTHORITY (Browns Ferry Nuclear Plant, Unit Nos.1, 2 and 3)

Docket Nos. 50-259, 50-260 and 50-296

Dear Administrative Judges:

It has been brought to my atten' tion that a November 3,1981 updated amendment to TVA's July 31, 1980 application in this proceeding, together with cover letter, was not served on the Licensing Board or the petitioners' counsel. A copy is enclosed.

It is my understanding that this updated application amendment reflects TVA's responses to questions posed by the NRC Staff.

Sincerely, d f }.. d. -

Richard J. Rawson Counsel for NRC Staff cc:

(w/ enclosure)

Robert B. Pyle, Esq.

Leroy J. Ellis, III, Esq.

Atomic Safety and Licensing Appeal Board Panel Docketing and Service Section (w/oenclosure) remainder of service list Attachment D

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t UNITED STATES OF AMERIJA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD

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In the Matter of

)

)

Docket Nos. 50-259, 50-260 and TENNESSEE VALLEY AUTHORITY

)

50-296

)

(License amendment to permit onsite (Browns Ferry Nuclear Plant,

)

storage of low level radioactive Unit Nos. 1, 2 and 3)

)

waste)

CERTIFICATE OF SERVICE I hereby cerfity that copies of "NRC STAFF MEMORANDUM IN RESPONSE TO THE APTEAL BOARD ORDER Of MAY 17, 1982" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Comission's internal mail system, this 28th day of May,1982:

Stephen F. Eilperin, Chainnan Dr. Quentin J. Stober Atomic Safety & Licensing Appeal Board Administrative Judge U.S. Nuclear Regulatory Commission Fisheries Research Institute Washington, D. C.

20555 University of Washington Seattle, Washington 98195 Dr. John H. Buck Atomic Safety & Licensing Appeal Board Mr. Ron Rogers U.S. Nuclear Regulatory Commission Tennessee Valley Authority Washington, D. C.

20555 400 Chestnut Street, Tower II Chattanooga, Tennessee 37401 Gary J. Edles l

Atomic Safety & Licensing Appeal Board H.S. Sanger, Jr., Esq.

U.S. Nuclear Regulatory Comission General Counsel

  • lashington, D. C.

20555 Tennessee Valley Authority 400 Comerce Avenue John H. Frye, III, Chairman 3 llB 33C Administrative Judge Knoxville, Tennessee 37902 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Mr. Richard L. Freeman Washington, D. C.

20555 429 Calhoun Drive Florence, Alabama 35630 Mrs. Elizabeth B. Johnson Administrative Judge Mr. John Martin Oak Ridge National Laboratory Route 1, Box 949 P.O. Box X, Building 3500 Sheff W]d, Alabama 35660 Oak Ridge, Tennessee 37830 Mr'. Robert W. Beck T. O. Box l'.

Florence, Alabama 35631

l.

4 Mr. Gregory' Robert Brough Mr. Thomas Wayne Paul 1726 McCullough Avenue 1120 Pratt Avenue Huntsville,' Alabama 35801 Huntsville, Alabama 35801 Mr. Michael D. Pierson Mr. Richard W. Jobe 736 tily Plagg Road S.E.

1134 Halsey Avenue Huntsville, Alabama 35802 Huntsville, Alabima 35801 Mr. David Ely Ms. Mariorie L. Hall 1500 Sparkman Drive 1134 Halsey Avenue Apartment 6G Huntsville Alabama 35801 Huntsville, Alabama 35805 Ms. Debbie Havas 517 0'Shaughnessy Huntsville, Alabama 35801 Ms. Uvonna J. Curott Leroy J. Ellis, III, Esq.

1201 Ingleside Omer, Ellis, Brabson, McNutt, Florence Alabama 35630 l

Stephenson and Tomlin l

411 Charlotte Avenue Ms. Nancy Muse l

Nashville, Tennessee 37219 205 Edgewood Drive Florence. Alabama 35630 Robert B. Pyle, Esq.

P.O. Box 16160 Ms. Alice N. Colcock Chattanooga, Tennessee 37416 305 Mitchell Court Sheffield, Alabama 35660 Ms. Noel M. Beck 426 North Wood Florence. Alabama 35630

  • Atomic Safety & Licensing Board l

Panel Mrs. Betty Martin U.S. Nuclear Regualtory Commission Route 1. Box 949 i

Washington, D. C.

20555 Sheffield, Alabama 35660

  • Atomic Safety & Licensing Appeal Board Panel l*

U.S. Nuclear Regulatory Cortraission l

Washington, D. C.

20555

  • Docketing and Service Section U.S. Nuclear Regulatory Commission i

l Washington, D. C.

20555 8 ? U h (A REhipf d T. Rawson Counsel for NRC Staff l

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