ML20003F477
| ML20003F477 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 04/08/1981 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0578, RTR-NUREG-0696, RTR-NUREG-578, RTR-NUREG-696 GL-81-10, P-81116, NUDOCS 8104210356 | |
| Download: ML20003F477 (3) | |
Text
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/t Mr. Darrel G. Eisenhut, Director tol l N Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington D.C.
20555
Subject:
Fort St. Vrain Unit No. 1 Post TMI Requirements Emergency Operations Facilities Ref: USNRC Generic Letter 81-10
Dear Mr. Eisenhut:
In response to the above referenced letter we offer the following:
1.
NRC Position NUREG-0696 is to be issued shortly to provide more detailed design and functional criteria.
PSC Response We are in receipt of NUREG-0696 and are presently evaluating the criteria proposed by this document. Based on our preliminary review, the new criteria for the EOF will in all probability eliminate the facility we were planning to utilize for the EOF.
In this respect it may be somewhat difficult for us to meet the June 1, 1981 date for the conceptual design of the EOF.
In addition, we proceeded v L.. "< ec atruction of our TSC based on the limited guidance of NUliE3-0578, and that facility is essentially complete with the exception of various instrumen-tation and displays. As we indicated in previous correspondence (see P-79312, Item 2.2.2.6.; P-80318, comments on NUREG-0696) our TSC does not meet the physical size reqrirements of the new ON criteria, and does not specifically provide separate facilities for the NRC.
Since the facility is essentially complete, it is not possible for us to recover to meet some of the new criteria.
As you indicated in the regional meetings, the NRC will most I
certainly evaluate exceptions for those utilities who responded and proceeded in good f aith to meet previously scheduled requirements. / O 810.421o2fg
y Mr. Darrel Eisenhut P-81116 2.
NRC Position Table III. A.1.2-1 (Table B-1 to NUREG-0654, Revision 1), establishes staffing levels for emergency situations. The revision of NUREG-0654 establishes stcging of staffing for 30 to 60 minutes rathe than requiring capability for required augmentation at 30 minutes. The implementation schedule for licensed operators and STA on shift shall be as specified in Task Action Item I.A.1.3.
Any deficiencies in the other staffing requirements of the table must be capable of '
augmentation within 30 minutes by September 1, 1981 and such deficiencies must be fully removed by July 1,1982.
PSC Response In our letter P-80288, August 28, 1980, we responded to the staffing requirements set forth by Table B-1-of NUREG-0654.
Although some minor changes have been made to Table B-1 since our response the basic concerns of our response remain unchanged.
Following the August 28, 1980 submittal we arranged a meeting 1
with the Emergency Preparedness group (Brian Grimes) and NRR Special Projecte (Jim Miller) in an attempt to resolve some of the many issues involving Fort St. Vrain. The meeting which sas held on December 10, 1980 brought essentially no results, and to this date we are still awaiting NRC's reply to P-80288. For your convenience please find attached an excerpt of P-80288 which addresses this subject. Until we receive a response to this correspondence we cannot address Table III.A.l.2-1 on the implementation dates of September 1, 1981 and July 1, 1982.
3.
NRC Position The implementation schedule has been changed for ERF's to be operational by October 1, 1982.
PSC Response PSC intends to meet the implementation date of October 1, 1982 for the ERF's, 4.
NRC Position Emergency Response Facility conceptual design information is to be submitted by June 1, 1981.
PSC Response PSC intends to submit conceptual design information for the ERF's by June 1, 1981, with the exception of the EOF.
As indicated in Item 1. above we are in a position in which we must evaluate other facilities for use as our EOF because new
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r Mr.~Darrel Eisenhut P-81116 4
criteria i= posed by NUREG-0696 may well eliminate the facility we intended to use.
Our conceptual design for the EOF will therefore be delayed until July 15, 1981.
We are continuing our efforts to be responsive to various TML-2 action requirements, but we are finding it increasingly difficult to meet. planning and schedule require =ents wittorit response fros the NRC to previously submitted positions. We are rapidly approaching the ti=e when we will be unable to meet ecmsitzents and schedules set forth without resolution of many of the issues 5ased on criteria that does not appear to be 2
applicable to Fort Saint Vrain.
We realize how difficult it must be to evaluate Fort St. Vrain in many areas, but without that evaluation we are unable to acco=plish :he volume of front end work that is required to meet the various established' schedules and co=mit=ents, in fact, because of our peculiar situation and'the unti=ely response to our submittals we are already past the point of recovery in =any areas should the NRC choose to refuse to accept our t
evaluations and the positions we have taken.
We trust that you will take these matters into consideration in terms of the schedules that have been established.
Very truly yours, Wwtc d Don Ware = bourg DWW/lb 4
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