ML19347B352

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Requests Addl Clarification Re NRC Role at Various Emergency Facilities.Includes Function Description of Role Each NRC Member Is to Perform at Technical Support Ctr & How Each Is to Respond to Util Nuclear Operations Mgt
ML19347B352
Person / Time
Site: Rancho Seco
Issue date: 10/02/1980
From: Mattimoe J
SACRAMENTO MUNICIPAL UTILITY DISTRICT
To: Reid R
Office of Nuclear Reactor Regulation
References
NUDOCS 8010140468
Download: ML19347B352 (2)


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SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 S Street, Box 15830, Sacramento, California 95813; (916) 452-3211 October 2, 1980 Director of Nuclear Reactor Regulation Attention:

Mr. Robert W. Reid, Chief Operating Reactors, Branch 4 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Docket No. 50-312 Rancho Seco Nuclear Generating Station, Unit 1 Emergency Planning The NRC's Role At Emergency Facilities

Dear Mr. Reid:

Our emergency planning efforts have progressed to the stage where we need a clear definition of the role the NRC staff will perform at the various emergency facilities. The basic functional descriptions are provided in NUREG-0696; towever, additional clarification is necessary.

As stated in NUREG-0696, "... the NRC may direct that certain operations be performed at the nuclear facility." How does the NRC plan to address the legal and financial liabilities when specific actions or nonactions are directed by the NRC Regional Director or NRC Headquarters?

Based on our upgraded Emergency Plan, the Technical Support Center (TSC) will handle all onsite responsibilities, the offsite Emergency Operations Facility (EOF), which will be located 10 miles from the nuclear plant site, will handle all the offsite responsibilites. The TSC will perform the duties of the EOF until it becomes operational. However, once the EOF is operational, the lines of authority are clear and distinct.

The TSC may send radiological monitoring teams offsite and they will report to and take direction from the TSC. The TSC will transmit offsite monitoring results to the E0F. The E0F will have no authority over the onsite radio-logical monitoring teams. The EOF, through the Offsite Support Center, may arrange access for people and material to the onsite organization, but will offer no technical advice pertaining to the plant operation, control, or recovery.

It is our understanding that the NRC will act as a third party to insure that the various aspects of the emergency response are not averlooked, and furthermore to provide technical input to decisions regarding the operation 8 G10140ll(,6 C

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Mr. Robert W. Reid October 2, 1980 of the plant. SMUD asks that the NRC staff assigned to our TSC be of high technical competence, be familiar with our NSSS design, and obtain a level of pre-accident credibility with our Nuclear Operations management such that their judgments not be subject to questions in an emergency situation.

It is important that you provide us with a fur.,: tion di-c.riptien of the role each NRC member is to perfonn at the TSC and how each is to respond to our Nuclear Operations management.

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California law clearly states that the County agencies have the primary responsib1'ities of the health and safety of their constituency. Sacramento County is planning on having their key decision and control officers at our EOF. Their Emergency Operations Center (E0C) will be downgraded to a support location. The county officers would therefore become the top level of manage-ment at the E0F. The SMUD E0F Coordinator would provide administrative assis-I tance to those in charge of the offsite emergency response.

No technical guidance to the plant site will be provided from the EOF.

Under this arrangement, the necessity of having a complete set of plant drawings, plant procedures, the Nuclear Data Link (NDL), the Health Physics Network (NPN), and the Emergency Notification System (ENS) i s in question.

SMUD and the counties envision the NRC acting as a third party to ensure that i

all aspects of the emergency response are adequately addressed, to provide the counties with technical guidance pertaining to protective actions for the general public, and to be represented at all press conferences along with SMUD l

and various public officials.

It is important that you provide us with a func-I tional description of the role each NRC member is to perform at the E0F and how l

each is to respond to the county officials and the E0F Coordinator.

l SMUD realizes its responsibility to release timely, accurate, and understandable j

information to the public through the media. Tc satisfy this requirement, and to prevent any conflicting statements, it is impcrtant that the NRC define for us its role relating to the release of information to the public.

If the NRC feels the need to hold a separate news conference, it should be held at the same location as the County /SMUD press releates, and assurances made that repre-sentatives from the counties and SMUD are available for comment and clarification.

Sincerely,

( L # b2C4 John Mattimoe Assistant General Manager and Chief Engineer l

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