ML19350C922

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Submits Implementation Schedule for Items Affected by NUREG-0696,in Response to Generic Ltr 81-10.Requirements for Emergency Response Facilities,Per TMI Action Plan Item III.A.1.2,to Be Implemented Via License Application Process
ML19350C922
Person / Time
Site: Haddam Neck, Millstone  File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 04/06/1981
From: Counsil W, Fee W
NORTHEAST NUCLEAR ENERGY CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0696, RTR-NUREG-0737, RTR-NUREG-696, RTR-NUREG-737, TASK-3.A.1.2, TASK-TM A01551, A1551, GL-81-10, TAC-46246, NUDOCS 8104100299
Download: ML19350C922 (3)


Text

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April 6,1981 7'

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Docket Nos. 50-213 50-245

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'8 50-336 50-k23 A01551 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555

References:

(1)

D. G. Eisenhut letter to All Power Reactor Licensees, dated October 10, 1979 (2)

W. G. Counsil letter to D. G. Eisenhut, dated December 28, 1979 (Docket No. 50-213)

(3)

W. G. Counsil letter to D. G. Eisenhut, dated December 28, 1979 (Docket Nos. 50-245 and 50-336)

(4)

W. G. Counsil letter to H. R. Denton, dated December 31, 1979.

(Docket Nos. 50-213, 50-245, and 50-336)

(5) NUREG-0654/FB4A-REP-1, " Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated January, 1980.

(6)

W. G. Counsil letter to D. L. Ziemann and R. Reid, dated February 8, 1980.

(Docket Nos. 50-245 and 50-336)

(7)

D. G. Eisenhut letter to W. G. Counsil, dated April 16, 1980.

(8)

D. G. Eisenhut letter to All Power Reactor Licensees, dated April 25, 1980.

(9)

W. G. Counsil letter to D. M. Crutchfield and R. A. Clark, dated June 30,1980.

(Docket Nos. 50-213, 50-245, and 50-336)

(10) NUREG-0696, " Functional Criteria for Dnergency Response Facilities,"

dated July,1980.

(11)

W. G. Counsil letter to D. G. Eisenhut, dated October 14, 1980.

(Docket No. 50-213)

(12)

W. G. Counsil letter to D. G. Eisenhut, dated October 14, 1980.

(Docket Nos. 50-245 and 50-336)

(13)

W. G. Counsil letter to D. G. Eisenhut, dated February 13, 1981.

(Docket Nos. 50-213, 50-245, and 50-336)

(14)

D. G. Fisenhut letter to All Licensees of Operating Plants and Holders of Construction Permits, dated February 18, 1981.

l (Generic Letter 81-10) 1 81041008N

/0

r Gentlemen:

Hadden Neck Plant Millstone Nuclear Power Station, Unit Nos. 1, 2, and 3

'IMI Action Plan Item III.A.1.2 - Upgrade Energency Support Facilities Reference (14) states that the " Commission has now finalized its position with respect to location and habitability requirements for the Emergency Operations Facility and staffing levels for emergency situations.

Clarification of these issues is enclosed. In the near future, we expect to issue further guidance for emergency response facilities in connection with finalization of NUREG-0696.

Implementation schedules for related items affected by the issuance of NUREG-0696 will be set forth at that time." In addition, Connecticut Yankee Atomic Power Company (CYAPCO) and Northeast Nuclear Energy Company (NNECO) have been informed via telephone conversations with members of the NRC Staff that implementation of NUREG-0696 requirements will be required independently from the requirements in Reference (14). Therefore, the requirements of NUREG-0696 will not be addressed by CYAPCO and NNECO as part of any response to Reference (14). The purpose of this letter is to confirm, as requested in Reference (14), that the following implementation schedule is planned.

The Technical Support Center (TSC), the Energency Operations Facility (EOF), and the Operational Support Center (OSC), collectively known as Emergency Response Facilities (ERFs), which will support the Station Bnergency Plans (SEPs) that are scheduled to be implemented by July,1981 as indicated in Reference (13),

are scheduled to be operational by July, 1981. Therefore, CYAPCO and NNECO will be in compliance with the required October 1, 1982 operational date. Any differences between the information submitted in Reference (13) and the re-quirements for ERFs indicated in Reference (14) can be construed to be exceptions to the requirements. Specifically, CYAPC0 and NNECO take exception to the re-quirement of Part B of Option 1 in Table III.A.1.2-2 in Reference (14) and do not intend to construct back-up EOFs.

CYAPCO and NNECO have essentially com-pleted the construction of EOFs at a distance of approximately h mile fran the Haddam Neck Plant reactor building and approximately 1 miles from the Millstone Nuclear Power Station reactor buildings, respectively. Both EDFs have a protection factor greater than 500 from a semi-infinite cloud airborne source and a ven-tilation system that consists of HEPA and charcoal filters. These design features significantly surpass the requirements of Part A of Option 1 in Table III.A.1.2-2 in Reference (1h).

The EOF structures were designed and constructed in accordance with the NRC re-quirements specified in References (1), (5), (7), (8), and (10), at a total cost, to date, of approximately $3.8 million. It has always been CYAPCO's and NNECO's understanding that those licensees who acted in good-faith and constructed new facilities to meet the NRC requirements would not be penalized. If CYAPCO and NNECO had not acted in good-faith, only one EOF, which could have been utilized during emergencies at either the Haddam Neck Plant or the Millstone Nuclear 8

Power Station, could have been constructed to ccanply with the requirements of Option 2 of Table III.A.1.2-2 in Reference (14). In c.ddition, this single EOF could have been constructed at further substantial savings since there would not have'seen any requirements for shielding or ventilation protection.

Furthermore, the Northeast Utilities Service Company (NUSCO) Emergency Operations Center (EOC), which is located in Berlin, Connecticut, is used to coordinate the emergency NUSCO support as indicated in Reference (13). The NUSCO EOC has com-munication links with the Control Room and TSC at both the Haddan Neck Plant and the Millstone Nuclear Power Station. It is CYAPCO's, NNECO's, and NUSCO's determination that our present approach for the implementation of the requirements for ERFs is justifiably the best option for us.

CYAPCO and NNECO have continually provided information to the NRC Staff regarding ERFs in References (2), (3), (4), (6), (9), (11), (12), and (13). A significant portion of the conceptual design information requested in Reference (14) to be submitt,ed by June 1,1981 has already been sulmitted to the NRC Staff. Additional information not previously submitted in the above-mentioned References needed to address the requirements of Reference (14), vill be sutaitted by June 1,1981.

This information will only apply to the ERFs as required to support the SEPs which are scheduled to be implemented by July,1981.

In Reference (13), CYAPCO and NNECO previously addressed the requirements of Table III.A.1.2-1 of Reference (14) (Table B-1 in NUREG-0654, Revision 1). Therefore, no further submittals are planned by CYAPC0 and NNECO.

Since the Millstone Unit No, j operating license is expected to be issued after October 1,1982, the requirements for ERFs will be implemented through the operating license application process.

We trust that the above information adequately addresses the 45-day response re-qairements of Reference (14).

Should you have any questions, please feel free to contact us.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY NORTHEAST NUCLEAR ENERGY COMPANY W. G. 66unsil l

Senior Vice President 2 e-By:

W. F. Fee s

Executive Vice President

.