ML20117G708

Application for Amend to Licenses DPR-33,DPR-52 & DPR-68, Eliminating License Condition 2.C.(3) on Thermal Water Quality Stds

ML20117G708
Person / Time
Site:	Browns Ferry
Issue date:	08/30/1996
From:	Abney T TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20117G709	List: ML20117G708 ML20117G712
References
TVA-PFN-TS-380, NUDOCS 9609050292
Download: ML20117G708 (6)

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Tennessee Vairey Authonty Post Office Box 2000. Decatur. Alabama 35609 l l August 30, 1996 l

TVA-BFN-TS-380 10 CFR 50.4 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555  ;

Gentlemen:

In the Matter of ) Docket Nos. 50-259 Tennessee Valley Authority ) 50-260 50-296 l

BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 1, 2, AND 3 -

l TECHNICAL SPECIFICATION (TS) 380 - LICENSE CONDITION ON COMPLIANCE WITH THERMAL WATER QUALITY STANDARDS In accordance with the provisions of 10 CFR 50.4 and 50.90, TVA is submitting a request for an amendment (TS-380) to licenses DPR-33, DPR-52, and DPR-68 to change the License Conditions for Units 1, 2, and 3. The requested change eliminates License Condition 2.C.(3) on thermal water quality standards.

Water effluent thermal limits for BFN are established by the ,

Alabama Department of Environmental Management as an authorized state for administration of the National Pollutant Discharge Elimination System (NPDES) pursuant to the Clean Water Act. As such, TVA believes that the State of Alabama and the Environmental Protection Agency (EPA) have jurisdiction over such limits, and the subject license condition is redundant and should be deleted from BFN TSs.

TVA has determined that there are no significant hazards considerations associated with the proposed change, and the change is administrative and qualifies for a categorical exclusion pursuant to the provisions of 10 CFR 51.22 (c) (17) for environmental review. The BFN Plant Operations Review Committee and the BFN Nuclear Safety Review Board have reviewed this proposed change and determined that operation of BFN Units 1, 2, and 3, in acccadance with the proposed change, will not endanger the health and safety of the public.

Additionally, in accordance with 10 CFR 50.91(b) (1) , TVA is sending a copy of this letter and enclosures to the Alabama State Department of Public Health. f

.9609050292 960030 Do30 t PDR ADOCK 05000259 p PDR

U.S. Nuclear Regulatory Commission Page 2

-August 30, 1996 Enclosure 1 to this letter provides the description and evaluation of the proposed change. This includes TVA's determination that the proposed change does not involve a significant hazards coniilderation and is categorically excluded from environmental review. Enclosure 2 contains copies of the appropriate TS pages from Units 1, 2, and 3 marked-up to show the proposed change. Enclosure 3 forwards the revised TS pages for Units 1, 2, and 3 which incorporate the proposed change.

TVA requests that the revised License Conditions be made effective within 30 days of NRC approval. If you have any questions about this change, please contact me at (205) 729-2636.

Silcerely, T. E. Abney Manager of Site. nsing  ;

and Industry Af ai s l Enclosures cc: see page 3 Subscribed and sworn Q oefore me on this 3db day of Hoous7 1996. i nom k. k

• Notary Public My Commission Expires % hW Exphe 10M98 l

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i U.S. Nuclear Regulatory Commission l Page 3 August 30, 1996 Enclosures  !

l cc (Enclosures)- ,

l Mr. Johnny Black, Chairman  !

E Limestone County Commission 310 Washington Street  :

Athens, Alabama 35611 Mr. Mark S. Lesser, Branch Chief U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Mr. Joseph F. Williams, Project Manager U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Dr. Donald E. Williamson State Health Officer Alabama State' Department of Public Health 434 Monroe Street i Montgomery, Alabama 36130-3017 l

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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT (BFN)

UNITS 1, 2, AND 3

PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-380 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I. DESCRIPTION OF THE PROPOSED CHANGE TVA is requesting deletion of License Condition 2.C.(3) for ,

Units 1, 2, and 3, regarding compliance with thermal water i quality standards. '

The specific requested change is the deletion of License Condition 2.C.(3):

l "In the operation of the facility, the licensee shall, parsuant to the Federal Water Pollution Control Act Amandments of 1972 (Public Law 92-500), comply with all applicable thermal water quality standards of the State of Alabama and the United States."

Reference TS pages 3 and 4 and page 3 for Units 1, 2, and 3, respectively.

II. REASON FCR THE PROPOSED CHANGE Water efflaent thermal limits for BFN are established by the Alabama Department of Environmental Management as an authorized state for administration of the National Pollutant Diacharge Elimination System (NPDES) pursuant to the Clean Water Act. The terms of the permit are also subject to oversight by the Environmental Protection Agency (EPA). l The NPDES permit (No. ALOO22080) for BFN prescribes limitations on the thermal discharges and other nonradiological discharges resulting from plant operations. ,

The permit was granted by the State of Alabama Ond must be ]

renewed every five years. BFN is responsible for compliance with the permit and reporting of noncoupliances.

The State of Alabama and the EPA have enforcement authority with regard to the environmental limitations in the NPDES permit.

License Condition 2.C.(3) for Units 1, 2, and 3 also specifies that the plant be operated in accordance with applicable thermal water quality standards of the State of Alabama and the United States. TVA considers that Alabama, by virtue of being an authorized' state, and the EPA have jurisdiction and authority in this area. Additionally, TVA is concerned that any inadvertent exceeding of a discharge limit could also be interpreted as noncompliance with the subject License Condition. Accordingly, TVA believes the existing subject License Condition is redundant and should be deleted.

III. SAFETY ANALYSIS The requested License Amendment deals expressly with thermal discharge limits associated with plant operation.

Plant safety analyses have no relationship to these limitations. The closest consideration is the temperature of cooling and service water (assumed a maximum of 95*F) at the plant intake. The intake is upstream of the thermal discharge points. Therefore, this change has no effects on the safe operation of the plant.

IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of BFN Units 1, 2, and 3, in accordance with the proposed change to the License conditions, does not involve a significant hazards consideration. TVA's conclusion is based c' its evaluation, in accordance with 10 CFR 50.9.1,a) (1) , of the three standards set forth in 10 CFR 50.92(c).

A. The crocosed amendment does not involve a sianificant increase in the erobability or consecuences of an accident previousiv evaluated.

The proposed License condition change is an administrative change and has no relationship to plant safety analyses. Therefore, this change does not increase the frequency of the precursors to design basis events or operational transients analyzed in the BFN Final Safety Analysis Report. Likewise, the proposed changes will not increase the consequences of an accident previously evaluated.

B. The Droposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed License condition change is an administrative change and has no relationship to plant safety analyses. Thus, the change does not create any type of new accident sequences. Likewise, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

C. The proposed amendment does not involve a sicnificant reduction in a marcin of safety.

The proposed License Condition change is an administrative change and has no relationship to plant safety analyses. Therefore, the proposed amendment does not involve a reduction in the margin of safety.

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- V. ENVIRONMENTAL IMPACT CONSIDERATION The proposed change does not involve a significant hazards consideration, a change in the types of, or increase in, the amounts of any effluent that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure. TVA considers the ,

requested change an administrative action because the I amendment is needed only to clarify that compliance aspects l of the NPDES permit are under the jurisdiction of the State l of Alabama and the EPA. Therefore, pursuant to '

10 CFR 51.22 (c) (17) , this action qualifies for a categorical exclusion.

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