ML20249B765

Informs That Usc Disagrees W/Denial of Request for Public Hearing Re Revocation of Operating License for Browns Ferry, Unit 1.Request for Public Hearing on Concerns Raised in 2.206 Petition Reiterated

ML20249B765
Person / Time
Site:	Browns Ferry
Issue date:	06/05/1998
From:	Lochbaum D UNION OF CONCERNED SCIENTISTS
To:	Collins S NRC (Affiliation Not Assigned)
Shared Package
ML20249B766	List: ML20249B765 ML20249B769
References
2.206, DD-99-06, DD-99-6, IEB-94-001, IEB-94-1, NUDOCS 9806240175
Download: ML20249B765 (2)

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= Gama UNION OF ctp:_gm-u CONCERNED Nony SCIENTISTS Buhe ht June 5,1998 OGc-Goldb ,0GC Mr. Samuel J. Collins, Jirector bleb/t..g)MA Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555-0001 -

SUBJECT:

PETITION PURSUANT TO 10 CFR 2.206, BROWNS FERRY NUCLEAR PLANT UNIT 1, DOCKET NO. 50-259 - REITERATED REQUEST FOR PUBLIC HEARING

Dear Mr. Collins:

By letter dated April 5,1998, the Union of Concemed Scientists submitted a petition pursuant to 10 CFR 2.206 seeking the revocation of the operating license for Browns Ferry Unit 1. We also requested a public hearing to present new information supporting our petition.

By letter dated April 29,1998, you acknowledged receipt of our petition and denied our request for a public hearing into its concerns. The basis you cited for denying our request for a public hearing was the guidance in NRC Management Directive 8.11. You stated that since our petition did not raise the potential for a significant safety issue that could lead to an occupational exposure dose equivalent exceeding 10 rem, et al, we did not provide the basis for a public hearing. We strongly disagree.

In our petition, we stated that TVA had not been addressing generic correspondence for Browns Ferry Unit I since they placed this plant on ' administrative hold' in June 1985. We feel that this omission alone could involve one or more significant safety issues. For example, on April 14,1994, the NRC issued Bulletin 94-01," Potential Fuel Pool Draindown Caused By inadequate Maintenance Practices At Dresden Unit 1," to the licensees for the Humboldt Bay Indian Point 1, Lacrosse, Rancho Seco, San Onofre 1, Trojan, Yankee Rowe, and Dresden 1 plants. This bulletin described a January 1995 event at the Dresden Unit I plant in which a pipe froze and ruptured, draining 55,000 gallons of water into the plant's unheated basement. According to the NRC's wording in this bulletin, the conditions at Dresden Unit I could have caused the irradiated fuel assemblies in the spent fuel pool to become uncovered which

...would have created onsite personnel hazards from the high radiation fields." The recipients of this bulletin were asked to review their plant designs and administrative controls to provide assurance that the Dresden event would not be replicated at their plants. ,

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Washmgton Office: 1616 P Street NW Suite 310 . Washington DC 20036-1495 e 202 332 0900 . FAX: 202 332 0905 Cambridge Headquarters: Two Brattle Square . Cambridge MA 02238-9105 617-547-5552 . FAX: 617-864-9405 Califcmia Office: 2397 Shattuck Avenue Suite 203 . Berkeley CA 94704-1567 510-843-1872 . FAX: 510-843-3785 9006240175 990622 PDR ADOCK 05000259 p PDR _

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8 June 5,1998 Page 2 of 2 TVA was not asked to conduct such a review for Browns Ferry Unit 1. Browns Ferry Unit I has not operated since March 1985. There are 1,488 irradiated fuel assemblies in the spent fuel pool at Browns Ferry Unit 1, many of which have greater decay heat levels and radioactive source term inventories than are present at Dresden Unit 1. Five of the eight (62.5%) plants which received NRC Bulletin 94-01 shut down after March 1985: Laciouc ( April 1987), Rancho Seco (June 1989), Yankee Rowe (October 1991), Trojan (November 1992), and San Onofre 1 (November 1992). As you know, both San Onofre .

Unit I and Dresden Unit I are in a very similar configuration as Browns Ferry Unit 1 - all three plants are shut down while two reactors at these sites remain operating. Thus, UCS considers the safety concern which prompted the NRC to issue Bulletin 94-01 to eight shut down plants to be directly applicable to the shut down Browns Ferry Unit 1 - yet it has not been addressed by TVA. Due to Browns Ferry Unit l's regulatory limbo which shields the plant's true status, the NRC did not issue Bulletin 94-01 to TVA, although it really should have done so.

We crigim.lly sought a public hearing to present s'ignificant safety issues such as this single example to the NRC. We feel confident that our concerns meet, or exceed, the criteria established in Management Directive 8.11 for a public hearing. 'Iherefore, we respectfully reiterate our request for a public hearing on the concerns raised in our 2.206 petition.

Sqcerely,

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hamti 0- w David A.Lochbaum Nuclear Safety Engineer h

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