ML20039G520

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Recommends NRC Use of Draft NUREG-0814 Be re-evaluated.Draft NUREG Adds Numerous Requirements & Penalizes Utils Who Are Making Good Faith Effort to Upgrade Emergency Response Facilities
ML20039G520
Person / Time
Site: Fort Calhoun 
Issue date: 01/11/1982
From: William Jones
OMAHA PUBLIC POWER DISTRICT
To: Clark R
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0814 LIC-82-014, LIC-82-14, NUDOCS 8201180356
Download: ML20039G520 (1)


Text

Omaha Public Power District 1623 HARNEY e O M AH A.

NEBRASMA 68102 e TE LEPHON E 530-4000 ARE A CODE 402 January 11, 1982 LIC-82-014 9

O Mr. Robert A. Clark, Chief U. S. Nuclear Regulatory Commission REEVG Office of Nuclear Reactor Regulation g.

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Division of Licensing 2

JAN1'51982> G

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Operating Reactors Branch No. 3 Washington, D.C.

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Reference:

Docket No. 50-285 o3 en

Dear Mr. Clark:

The Commission's letter to the Omaha Public Power District, dated November 23, 1981, detailed the results of the staff's evaluation of the Fort Calhoun Station Emergency Response Facilities (ERF). The staff used the draft NUREG-0814, " Methodology for Evaluation of Emergency Response Facilities." As one of the twenty-seven (27) utility members of the " Coordinating Group on Emergency Preparedness" (CGEP), the District has previously expressed its concerns regarding the draf t NUREG-0814, as addressed in the CGEP letter dated November 9, 1981 from Mr. D. F. Knuth of KMC to Mr. Samuel J. Chilk.

The staff's use of the draft NUREG-0814 for evaluating the Fort Calhoun Station ERF has heightened the District's concerns.

The draft NUREG-0814 adds numerous new require-ments beyond that provided by previous Commission guidance in NUREG-0696, which provided the basis for the Fort Calhoun Station ERF design.

Additionally, much of what is included in the draft NUREG-0814 is very prescriptive (e.g., the ERF display device hardware has very specific details such as a requirement that any CRT screens must have a minimum capacity of "80 characters by 24 lines").

The District has, as have many other utilities, commenced con-structica or issued contracts for the ERF. To issue new guidance, adding numerous new requirements, penalizes those utilities who are making a good faith effort to upgrade their ERF's. Accordingly, the District recommends that the staff's use of the draf t NUREG-0814 be reevaluated.

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Division Manager Production Operations WCJ/KJM/TLP/RWS:jmm I

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