ML20010J168
| ML20010J168 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 09/24/1981 |
| From: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Fay C WISCONSIN ELECTRIC POWER CO. |
| References | |
| NUDOCS 8109290659 | |
| Download: ML20010J168 (3) | |
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1 September 24, 1981 N
g Docket No. 50-266
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0' Docket No. 50-301 Alj Sepg8 Wisconsin Electric Power Company p g%. Jgg/A,
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Mr. C. W. Fay, Director
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Nuclear Power Department
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g Centleren:
Your letter of July 20, 1981 contains replies to the comunents and guidance provided by our letter of June 3, 1981, regarding the reporting requirements of 10 CFR 50.72. Our responseo to the specific comments in your letter are provided below.
1.
Your responses to comments Nos. 1 and 9 of our June 3, 1981 letter appear to take exception to our reminder that the clock for the one hour reporting requirement starts upon discovery, and not following internal notifications and diseassions.
IE Information Notice 80-06, which transmitted the subject reporting requirements, states in part that "NRC has an important obligation to collect facts quickly and accurately about significant events, assess the facts, take necessary i
action, and inform the public about the extent of the threat,,1,J_ any (emphasis added), to public health and. safety." That statement gives l
clear recognition to the fact that events may occur whose potential for threat is not immediately known. In order to promptly assess the potential threat from events, NRC must be promptly notified.
Therefore, we cannot accept a relaxation of the one-hour notificction requirement. As noted in our June 3, 1981.'.etter, the clock starts upon discovery.
2.
Your response to coceent No. 4 of our letter does not answer the intent of the comument.
10 CFR 50.72(a)(1) requires the reporting of "The exceeding of any Technical Specification Safety Limit." Techni-cal Specification 15.2.1 states that "The combination of thermal power level, coolant pressure, and coolant temperature shall not exceed the limits shown in Figure 15.2.1."
Adherence to the limits of Figure i
l 15.2.1-1 ensures that the allowable DNBR limit is not violated.
i Since DNBR is not a directly observable parameter, Figure 15.2.1-1 should be referenced.
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Wisconsin Electric Power September 24, 1981 Company b
3.
Your response to comment No. 6 of our letter is acceptable, provided that all reporting requirements of 10 CFR 73.71 are covered in other procedures.
4.
Your response to comment No. 7 of our letter is acceptable. The conditions specified in our comment were intended as examples, and were not meant to be all-inclusive.
5.
Your response to our comment No. 10 is incorrect. You refer to paragraph (b) of 10 CFR 20.403 as requiring only 24-hour notifica-tion. Please notethhat paragraph (d) of 10 CFR 20.403 states "for nuclear power reactore licensed under section 50.21 or section 50.22 j
the incidents included h paragraph (a) and paragraph (b) in this section shall in addition be reported pursusnt to section 50.72."
6.
Your response to our comment No. 12 assumes that the dedicated emergency vehicle is always operable and available. That may not be a valid assumption. Your procedure should reflect 10 CFR 50.72 and include any means of transport to an off-site medical facility.
I 7.
Your responses to our comments Nos. 8, 11 and 13 are acceptable.
We feel that the above clarifications should provide sufficient guidaneo with regard to the current reporting requirements of 10 CFR 50.72. In addition to your conuments, the NRC has received many other comments on rection 50.72, and the staff is currimtly revisi% that section to reflect those comments.
I espect the revised version to be issued in the near future. The revisions should correct some of the most burdensome parts of that section.
You recommend that all the NRC reporting requirements be consblidated in a single list. The NRC is aware of the need for some method of assembling the reporting requisements of various Parts and Sectioas of 10 CFR. Regulatory Guides 1.16 and 10.1 were issued to provide focal points which idsntify the locations of various reporting requirements.
Regulatory Guide 1.16 is for operating power reactors, while Regulatory Guide 10.1 lists reporting requirements of general applicability, and applicability to other categories of licensees. These documents are currently under NRC review.
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tie recognize the need and wish, as you do, to collate and clarify the various reporting requirements.
In the interim, we will work with you to reach on a case by case basis, a mutual understanding of the NRC reporting requirements.
Sincerely, (ph.
James.G. Keppler Director cc:
G. A. Reed, Manager D.3/ Document Control Desk (RIDS)
Resider
- nspeccor, RIII John J. Duffy, Chief Boiler Inspector Peter Anderson, Wisconsin's Environmental Decade Stanley York, Chairman Public Service Commission
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