ML19344E710

Forwards Draft 3 of Radiological Emergency Response Plan, Including Response to NRC .Requests Meeting W/Nrc to Evaluate &/Or Accept Util Position as Soon as Possible

ML19344E710
Person / Time
Site:	Fort Saint Vrain
Issue date:	08/28/1980
From:	Warembourg D PUBLIC SERVICE CO. OF COLORADO
To:	Tedesco R Office of Nuclear Reactor Regulation
Shared Package
ML19281D290	List: ML19344E710
References
P-80288, NUDOCS 8009100240
Download: ML19344E710 (2)

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August 28, 1980 Fort St. Vrain Unit No. 1 P-80288 Mr. Robert L. Tedesco, Assistant Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.

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SUBJECT:

Fort St. Vrain Unit No. 1 Emergency Response Plan

REFERENCE:

NRC Letter July 23, 1980

Dear Mr. Tedesco:

We are transmitting herewith three (3) copies of our revised emergency response plan. This revised plan includes changes as a result of the May 21,

1980, plant site review meeting as well as certain changes that resulted from comments contained in your July 23,

1980, letter.

In addition to the revised plan, we are providing our response as Attachment A to this letter to address your July 23, 1980, letter.

As we indicated in the May 21, 1930, meeting as well as in various correspondence submitted as a part of the TMI-2 Lessons Learned Tasks, we believe Fort St. Vrain is a completely different reactor concept.

This reactor concept coupled with the size of the reactor negates many of the requirements setforth by NUREG's 0654 and 0610 which were developed primarily on the basis of 1,000 MW(e) light water reactor. technology.

It is imperative, therefore, that our Emergency Plan be evaluated on the basis of our reactor design and

size, and that generic requirements be evaluated on,the basis of specific technical, safety, and environmental differences ~.

We have had to essentially develop our own criteria for Fort St.

Vrain utilizing water reactor criteria setforth by various Nuclear Regulatory Commission documents.

On this basis our criteria is necessarily different from that published and we have taken justifiable exception to the NUREG's.

These exceptions were supported in various corres,.wodence (see reference list attached) and are further supported by Attachment A of this letter.

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In the May 21, 1980, meeting we were informed by the Nuclear

' Regulatory Commission review team that many of the items were a matter of policy ~, and that the review team did not have the authority to make exceptions on policy -

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regardless of the technical matters justification.

We cannot accept this position, and we request that as soon as you have had the opportunity to _ review our revised emergency plan and our response that we be given the opportunity to meet with you and other personnel who do have the authority to evaluate and/or accept our positions on the basis of the technical e

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justification provided.

I'n the interest of time it is requested that such a meeting be astablished at the earliest possible date so that we may finalize our

' plans to meet the various commitment dates setforth. We will be available to meet with you at your convenience and are looking forward to hearing from you shortly.

Very truly yours, W Otf*M @$

Don W. Warembourg F

Manager, Nuclear production Fort St. Vrain Nuclear Generating Station DWW/alk

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Attachments

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