ML20039E375
| ML20039E375 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/30/1981 |
| From: | Morisi A BOSTON EDISON CO. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| 81-296, NUDOCS 8201070212 | |
| Download: ML20039E375 (2) | |
Text
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y BOSTON EDISDN COMPANY GENERAL Drrscts 800 BoyLaTON STREET BO sTO N. M As 5AC Mum ETTm 02199 i
A. V. M O RI S I MANAGER NU CLEAR O PERATIONS SU F PORT DEPARTM ENT December 30, 1981 BECo Ltr # 81-296 Mr. Darrell G. Eisenhut, Director License No. DPR-35 Division of Licensing Docket No. 50-293 cp g
Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission DEF/ED Washington, DC 20555 AN 6 1982w
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REFERENCES:
(A) NRC Generic Letter 81-10, dated February 18, 1981,-
" Post TMI Requirements for the Emergency Operations Facility" 9
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(B) Boston Edison Company (BECo.) Letter 81-121, dated June 1, 1981 4
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Dear Mr. Eisenhut:
Reference (A) established a requirement for operating reactors to submit Emergency Response Facilities (ERFs) conceptual design information by June 1, 1981.
Reference (B) provided details on the Control Room, On-site Technical Support Center (TSC), On-site Operational Support Center (OSC) and near site and alternate Emergency Operations Facilities (EOF) for the Pilgrim 1 Nuclear Power Station. Reference (B) also addressed the Emergency Response Facilities' Information System (ERFIS) by stating that the existing system at the Pilgrim 1 Nuclear Power Station provides sufficient information to the Control Room, EOF and TSC for these centers to perform their emergency functions. However, we did indicate that we were evaluating options available to improve the present capabilities and would provide a detailed description of proposed modifications, if any, and a schedule for implementation by January 1, 1982.
The BECo. approach to improving the ERFIS has been to consolidate the require-for the Emergency Procedure Guidelines, Control Room Review, Post-Accident ments Instrumentation and Safety Parameter Display System (SPDS) into an integrated system which would also incorporate replacement of the existing plant process computen To assist in the development of this overall program BECo. has been and still is an active participant in the following efforts:
of 1.
BWR Owners' Group Subgroup on Assessment of Regulatory Guide 1.97, 3
Revision 2
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2.
BWR Owners' Group Subgroup on Control Room Improvements
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3.
BWR Owners' Group Subgroup on Emergency Procedures 4.
The SPDS Display Validation program being sponsored by Sandia Labs and General Electric g1070212811230 p
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l COMTON EOisON COMPANY Mr. Darrell G. Eisenhut, Director December. 30, 1981 Page Two Nuclear Safety Analysis Center (NSAC) Study on Integrated Data 5.
Acquisition Systems 6.
Coordinating Group on Emergency Preparedness Implementation (CGEP)
A significant amount of progress has been made in all of these areas despite the fact that the acceptance criteria for the associated regulations have not yet been finalized. As of this time NUREG-0801, Evaluation Criteria for Detailed Control Room Design Review; NUREG-0814, Methodology for Evaluation of Emergency Response Facilities; NUREG-0835, Acceptance Criteria for the SPDS; and NUREG-0799, Criteria for Preparation of Emergency Operating Procedures have not been issued in final form.
The necessity for combining these regulations into an overall plan has been substantiated by your commitment (Attachment A) to have the newly formed Committee to Review Generic Requirements (CRGR), chaired by Mr. Victor Stello Jr., Deputy Executive Director for Regional Operations and Generic Requirements, review and evaluate the proposed requirements for priority relative to existing requirements and for placement of unnecessary burdens on licensee and NRC resources.
In light of the aforementioned circumstances Boston Edison Company believes it would be inappropriate to submit a conceptual design and implementation schedule at this time. A more meaningful submittal would be made after the referenced acceptance criteria have been finalized and the CRGR has completed it's own evaluation of the requirements. We submit that this approach is consistent with recent developments within the NRC and await your further direction on these matters.
Fincerely yours, MVam
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Attachment i
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NUCLEAR REGULATORY COMMISSION
- y WASHINGTON, D. C. 20555 gm /
NOV 181931 Dr. Donald F. Knuth KMC, Incorporated 1747 Pennsylvania Ave., NW Washington, DC 20006*
Dear Dr. Ysnuth:
In your letter of October 6',1981, you commented on the Safety Parameter Display System (SPDS) on behalf of the Coordinating Group on Emergency Preparedness Implementation (CGEP).
The utilities comprising CGEP are working collectively in the implementation of emergency planning criteria.
Your letter stated that the industry has proceeded with the development of SPDS designs with only vague guidance from NRC and has expressed concern that the NRC has lost the perspective of the SPDS relationship to other requirements. Because of this concern, you recommend that NRC establish evaluation criteria, reestablish the relationship between the control room review and the SPDS, and establish an implementation date consistent with the intermediate steps which impact on the SPDS.
We agree with your point that the SPDS must be coordinated with the other related activities.
In the proposed rulemaking to add the SPDS to the Emergency Response Facilities rule, the staff's proposed implementation date will be based on integration of the SPDS with the detailed control room design review, guidelines for emergency operating procedures, and the Emergency Res?onse Facilities. All of these proposed requirements will be reviewed by the newly formed Committee to Review Generic Requirements (CRGR), chaired by Mr. Victor Stello, Jr., Deputy Executive Director for Regional Operations and Generic Requirements.
The CRGR will evaluate the priority of these proposed requirements relative to existing requirements and will evaluate whether the requirements would place unnecessary burdens on licensee and NRC resources.
The CRGR will obtain comments on the proposed requirements from CGEP and other industry groups as appropriate.
I appreciate your comments concerning integration of the SPDS with other control room tasks and hope I have been responsive to your concerns.
If you have further questions, please do not hesitate to contact me or Mr. Stelle.
Sincerely,
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G W 111am J. Dircks Executive Director for Operations T I qO90 39 A g
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