ML17272A775

Requests Agreement on Modified Topical Manual Approach to Emergency Plan & Mar 1981 Resubmittal Approval

ML17272A775
Person / Time
Site:	Columbia, Washington Public Power Supply System
Issue date:	12/31/1979
From:	Renberger D WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Vassallo D Office of Nuclear Reactor Regulation
References
NUDOCS 8001090408
Download: ML17272A775 (7)

Text

ACCESSION NBR ~ 8001090408 DOC ~ DATE 79/12/31 NOTARIZED ~

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lfas6fngton t ubi'fc Power Supply System RECAP ~ NAME "

RECIPIENT AFFIL'IATION VASSA'CLOUD,B.

Division of Project Management S UBJECT: Requests agreement=

on modified topical manual approach to emergency'planar 1981'esubmitt'al" approval.

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Washington Public Power Supply System A JOINT OPERATING AGENCY P. O. BOX 968 3000 GEO. WASHINOTON WAY RIOHLANO, WASHINOTON 99352 PHONE (509) 375.5000 December 31,, 1979 Hr. Domenic B. Vassallo, Acting Director Division of Project Hanagement Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

UPGRADED EHERGENCY PLANS

Reference:

Letter, D. B. Vassallo to applicants for operating licenses and licensees of plants under construction, dated November 21,

1979, same subject.

Dear Hr. Vassallo:

The referenced letter advising of present requirements regarding emergency planning was received and the Supply System is initiating necessary actions for upgrading the Hanford Site Emergency Plan (WNP-2 FSAR Section 13.3).

Purpose of this letter is twofold:

1.

To negotiate a resubmittal date, other than the stipulated June

1980, which will be beneficial to N.R.R., outside agencies and the Supply

System, and 2.

to request agreement on a modified topical manual approach to the Hanford Site Emergency

Plan, which will also mitigate the workload of all organizations involved.

Rationale and suggested action plans for these two requests are outlined in the following paragraphs.

Resubmittal Date Approval of a resubmittal date of Harch 1981 for the Hanford Site Plan is requested based on anticipated realistic fuel load dates and the following:

a.

The original submittal was developed to the criteria of Regulatory Guide 1.101, the first round of questions were minimal and have been responded to.

b.

The State of Washington and Benton-Franklin Counties Plan have previously received N.R.C. concurrence, cooperation by these agencies has been +i slgl 1001 090

Washington Public Power Supply System Mr.

D. B. Vassallo Page 2

December 31, 1979 Upgraded Emergency Plans promised to meet the upgraded criteria and assist in working with the seven additional counties encompassed by the 50 mile ingestion pathway.

c.

Discussion with an N.R.R. staff member indicates this date would be realistic for your review due to priorities for operating plants and that an earlier submittal date would probably not result in an expedient review.

d.

The Supply System is sincerely interested in preparing a quality response/recovery plan that will function, as well as meet the new requirements.

This suggested resubmittal date will allow time for thorough planning with all agencies involved and for commitment of the necessary resources to do so.

It will also allow time to develop a

plan with adequate detail to minimize questions, additional reviews, amendments and the other time consumers that impact N.R.R., outside agencies and the Supply System.

To ical Manual A

roach The Hanford Site Plan was originally titled such because it must necessarily consider interactions between

'lJNP-2, WNP-1 and WNP-4 regardless of whether they are in a construction or operational mode.

Using the present method of individual FSAR submittal for each facility, a very complex and confusing system will prevail for all agencies involved.

a.

The WNP-2 FSAR Section 13.3 (WNP-2 operational, WNP-1/4 under construc-tion) would be submitted after the WNP-1 submittal based on present schedule.

b.

With WNP-.2 operational, the WNP-1 FSAR Section 13.3 would also have to become an amendment to the 1JNP-2 plan at time of WNP-1 fuel load, this would be repeated with WNP-4, etc.

c.

The FSAR scheduled for May 1980 is a joint WNP-1/4 submittal.

This is not possible for an emergency plan since it must be site specific and consider adjacent facilities.

d.

All of these reiterations would require unnecessary reviews, re-

reviews, amendments, approvals and reprinting of a document that is for the most part generic in content.

A more practical approach would be to submit changes necessary for WNP-1 becoming operational as amendments to a topical manual, with review of only the changes necessary and not all of the previously approved generic content.

Your approval of this approach and procedure will considerably lessen the

P SS Washington Public Power Supply System Mr. D. B. Vassallo Page 3

December 31, 1979 Upgraded Emergency Plans administrative load of all responsible organizations, as well as minimize confusion to a document that must not be confusing to the users.

As you are awar e, outside support agencies must have a copy of Section 13.3 in possession and this requires a controlled distribution additional to the normal FSAR distribution.

Only one version at a time should be out to these organizations to prevent misunderstanding.

Please be awar e that if we submit a topical Hanford Site Emergency Plan in March of 1981, our WNP-1/4 FSAR submittal in May 1980 will not contain a

Section 13.3.

We would require your assurance that this approach will not jeopardize the acceptability of our WNP-1/4 FSAR for docketing.

~Summa'he proposals contained in this letter would provide capability for higher quality emergency preparedness, minimize the workload of all organizations involved and be cost effective. If there is any clarification or discussion required prior to your approval of this request, please contact J.

W.

Shannon, Manager, Health, Safety and Security Division, telephone number (509) 375-5825.

Very truly yours, DLR:JWS:sa D. L. Renberger Assistant Director, Technology cc:

Olan D. Parr, N.R.C.

Lester Rubenstein, N.R.C.

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