ML20049H235
| ML20049H235 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Rancho Seco |
| Issue date: | 12/31/1981 |
| From: | Mattimoe J SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20049H237 | List: |
| References | |
| FOIA-82-216 NUDOCS 8201130240 | |
| Download: ML20049H235 (3) | |
Text
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" $su SACRAMENTO MUNICIPAL UTILITY DISTRICT C 6201 s street, som 15830, Sacramento. California 95813;(916) 452 3211 O
December 31, 1981 n,
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DIRECTOR OF NUCLEAR REACTOR REGULATION
""[$-IUSSEu ATTENTION DARRELL G EISENHUT DIRECTOR ttC DIVISION OF LICENSING g
U S NUCLEA9 REGULATORY COMMISSION o'
y WASHINGTO:t D C 20555 l
l DOCKET 50-312 3
l RANCHO SEC0 NUCLEAR GENERATING STATION l
UNIT NO. 1-PROMPT' NOTIFICATION SYSTEM REQUEST FOR EXEMPTION
References:
10 CFR 50 Appendix E Section IV.D.3 District letter of June 30, 1981 District letter of July 24, 1981 l
Federal Register Vol. 46, No.182 p46587 '
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The District is requesting an exemption from the requirements of 10CFR 50 Appendix E Section IV.D.3 and the Federal Register notice in Vol. 46, No.182 l
p46587 that requires the completion of a Prompt Notification System within the plume exposure pathway EPZ by February 1,1982. The District has experienced unforeseen difficulties in the design and procurement of the system.
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The major unforeseen difficulty cxperienced was in the design of the system and i
our desire to work with the counties into which the system would be installed.
Draft reports of the design of the Prompt Notification System were distributed to the Deputy Director, Office of Emergency Services in Amador County, the Coordinator, Emergency Operations Division in Sacramento County, and the Coordi-nator, Office of Emergency Services in San Joaquin County for their review and coments. Meetings were also conducted between the cconties and our consultant to discuss the design.
FEMA was also asked to provide cements on the initial L
design. The comments resulted in the scope of the contract with the consultant to change such that the contract needed to be expanded twice before the ccm-pletion of the final design.
The following is a schedule of our system design, procurement and completion of the Prompt Notification System:
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' )?980 Init.ialcontractwithconsvJtanttodesignthe Prcmpt Notification System. '
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May 1981 /
Meeting with the' counties and the consuRant -
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I July 1981 Meetingwiththecountigd. and the consultant -
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second contract change. c
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1 August 1981 Final Design of the Prompt Notification System.
o September 9, 1981 Issued a Request for Bid and Specification for the i
purchase of Warning Sirens and Accessories.
September 30, 1981 Issued a Negative Declaration of Environmental Impact for public and rfate review.
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October 9, 1981-Opened bids -
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October 20, 1981 1ssued a Request for P'roposals for consulting and i -
I testing of the siren system.
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li Novemb e.$ 1981 Rejected siren bids because they did not meet the 7
technical requirements.
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Noverber 11, 1981
' Issued a Request for Bid and Specifications for the purchase of Werning Sirens and Accessories.
December 1, 1981 Opened bids on the sirens.
December 3, 1981 District Board of Directors approval of the Negative Declaration of; Environmental Impact of the sirens.
',,t December 17, 1981 District Board of Directors award of contract for the purchase of the sirens and accesscries.
Tentative Schedule January 7, 1982 District Board of Directors award of contract for consulting and testing of the siren system.
March 25, 1982 Final delivery date of the sirens and accessories.
February - April 1982 Installaticn April, May 1:s82 Testing May 1982 Siren system operational.
5, DARRELL G EISENHUT December 31, 1981 Until the District is in compliance with the requirements of 10 CFR 50, Appendix E Section IV.D.3 and the Federal Register notice in Vol. 46, No.182.
P46587, the County of Sacramento has informed us of the availability of two Sheriff's Department helicopters equipped with loud speakers that would be used in the alerting process. An additional helicopter is available through the California Highway Patrol. The County of Sacramento also has a number of Sheriff Department patrol cars equipped with loud r.peakers that may be utilized.
Please advise if the District needs to provide any additional information.
ll YIiTA John J. Mattimoe Assistant General Manager and Chief Engineer t
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JAN 5 1982 > Q Nuclear Reactor Regulation 1
U.S. Nuclear Regulatory Commission I:n:ns tImn m Washington, D.C.
20555 E83 NW H M
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Dear Sir:
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Subject:
Oyster Creek Nuclear Generating System Docket No. 50-219 Early Warning Public Notification System With regard to the 10 CFR 50 Appendix E requirement and the proposed change of the completion date (Federal Register dated September 21, 1981),
at the present time it has been determined that the Oyster Creek installation will be delayed beyond the required February 1,1982 date.
Since this delay is beyond the control of the company, an exemption from the requirements of 10 CFR 50 Appendix E concerning installation of the prompt notification system by February 1, 1982 is requested.
On October 23, 1981, we responded to the Notice of Violation contrined in Mr. Victor Stello's letter of September 22, 1981.
In that response, we indicated that all actions within the control of the company were being taken to meet the required installation date.
Accordingly, all necessary equipment for the installation has been received; installation personnel are currently assembling as much of the equipment as possible prior to actual erection at the site; a blanket exemption from the Municipal Zoning Ordinances has been filed with the Bu: au of Public Utilities and was approved on December 17, 1981; and we are actively pursuing the attainment of individual rights-of-way for each installation.
To date, approximately 30% of the 46 required rights-of-way have been obtained; however, we anticipate that for approximately 30% of the sites we j
will encounter objections which <.ill significantly delay installation.
Considering our potential capability of erecting 1 or 2 sirens per l
day and assuming the most optimistic progress in obtaining the necessary rights-of-way, we estimate that 30 sirens can be installed by February 1, l
1982.
The remaining installations will most probably be completed by July 1,1982 based on previous experiences in resolving rights-of-way problems.
The operational availability of the system will only exist after i
all sirens are installed.
l As we feel that every effort has been made to complete the l
installation by the required date and the delay is due to circumstances beyond our control, an extension of the completion date is justified. We have been and will continue to proceed with the installation of this system as expeditiously as possible; however, realistically there is a very low probability of meeting the February 1, 1982 requirement.
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Page 2 A copy of this request has been sent to the office of Inspection and Enf orc ement in accordance with our commitment to provide systems status update information and the projected completion date as delineated in our response to the Notice of Violation.
As per 10 CFR 170.22, we have determined that this is a class III request and a check for $4,000.00 will follow under separate cover.
If your should have any questions, please contact Mr. Michael Laggart at (609) 693-6931.
Very trul7 yours
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R. C.' rnold Sr. Vice President cc:
Director Of fice of Inspection and Enforcement U S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Ron Haynes, Administrator Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, New Jersey 08731 9
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JAN151982* 'L 8
January, 8, 1982
-I u ma nusur usun Fort St. Vrain l-IE88 ""'a u Unit #1 P-82006 O>
8' cn Mr. Brian Grimes, Director Emergency Preparedness Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C.
20555
SUBJECT:
Fort St. Vrain Unit No. 1 Early Warning Alert System
Dear Mr. Grimes:
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On December 3, 1981, we were informed orally during an on-site i,
meeting with the Nuclear Regulatory Commission and ORNL that our request for relief from the Early Warning Alert (EWA) requirements had been denied. We were further informed ^that on the basis of this denial that the February 1,
- 1982, date for implementation of the Early Warning Alert System presently proposed by 10CFR50 would be applicable to Fort St. Vrain.
This oral communication was of serious concern to us, and as you are aware, prompted our request for the December 15, 1981, meeting with the Emergency Preparedness Group as well as other Nuclear Regulatory Commission representation.
We came to the December 15, 1981, meeting with two main concerns:
1.
The basis for the oral communication was not clear in that we have received nothing in writing. We were interested in determining the extent of the review of our position as well as the basis for denial.
2.
The late date of the denial places us in an untenable l
position with reference to meeting a February 1,
- 1982, implementation date.
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8201180366 820108 PDR ADOCK 05000267 g
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4 With reference to our first concern we are still of the opinion that our position was not adequately considered on a technical basis.
Accident situations at Fort St. Vrain are very predictable and take much longer to develop than similar accidents in light water reactor technology. ORNL reached this same conclusion in their report on the applicability of NUREG 0737 to Fort St. Vrain and, although ORNL did not make any specific time recommendation, they did specifically state that we should be afforded more time in an alert situation than that allowed for light water reactors.
Because we have a first-of-a-kind plant our original accident analysis went far beyond l
those accidents considered to be credible and many of the analyzed accidents were non-mechanistic.
In spite of all these accidents, coupled with conservative assumptions, we were able to show that exposures from all accidents remained well below 10CFR100 limits.
These accidents were based on expected and design circulating activities and conservative fuel failure models.
In our meeting on December 15, 1981, we were placed in a class of small light water reactors similar to the classification for EPZ's.
This classification is erroneous and is based only on size-of plant considerations with no consideration to the time required for i
development of accidents.
Although we still believe that the Nuclear Regulatory Commission has been remiss in the evaluation of our position we believe that further action on our part would no doubt prove fruitless as the Nuclear l
Regulatory Comisison appears unwilling to evaluate the technical merits of our request.
On this basis we are proceeding with the installation of a tone alert system to meet the Early Warning Alert j,
requirements.
However, we are not waiving any rights we have to appeal the imposition of the February 1,1982 deadline.
l Given that we are proceeding with the implementation of an Early Warning Alert system brings us to our second concern, the February 1,
- 1982, implementation date.
As we stated in the December 15, 1981, meeting we believe the Nuclear Regulatory Commission has been irresponsible and remiss in their action concerning our repeated efforts to resolve this matter.
Our position was first setforth in September, 1979, followed by many more letters and several meetings.
Over two (2) years later we still had not received any response to our position, and finally on December 3, 1981, we were informed that our request for relief from the Early Warning Alert system had been denied.
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i It is requested, therefore, that we be given relief from the February 1,1982, date based on the following:
1.
We initially set forth our general position on the Early Warning Alert system as ear.ly as September 10, 1979, in our letter P-79205 to Mr. Jack Roe who was then assigned as the leader of our Emergency Planning Review Team.
We did not receive any response to this letter. On March 18, 1980, we submitted our proposed Radiological Emergency Response Plan via letter P-80083 and once again we indicated our position on the Early Warning Alert system.
Following the Nuclear Regulatory Commission on-site review team visit on May 21,
- 1980, and subsequent receipt of Nuclear Regulato ry Commission comments in the Nuclear Regulatory Commission's letter of July 23, 1980, we resubmitted our Radiological Emergency Response Plan along with our response to the.
Nuclear Regulatory Commission comments via our letter P-80288, dated August 28, 1980, which again set forth our position on the Early Warning Alert system.
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2.
This round of correspondence was followed by a meeting on 1
December 10, 1980, with the Nuclear Regulatory Commission at Public Service Company's request.
We found during this meeting that our letter P-80288 submitted in August had not been reviewed by the Emergency Preparedness Group. We even were informed that we would receive comments on this letter by Februa ry,
- 1981, comments which we finally received on December 17, 1981.
3.
Following the December 10, 1980, meeting we submitted our initial response to NUREG 0737 in our letter P-80438, dated December 20,
- 1980, and once again expressed our concern about the lack of resolution to our previous correspondence.
4.
Recognizing that time was becoming a major factor we then wrote directly to the Nuclear Regulatory Commissioners.
In our letter P-81009, dated January 9, 1981, we set forth a detailed technical justification for relief frem the Early Warning Alert requirements.
5.
On February 27,
- 1981, we submitted cur Radiological Emergency Response Plan, Implementing Procedures, and the State Radiological Emergency Response Plan, via letter P-81074, and again expressed cuncern about the lack of Nuclear Regulatory Commission response.
. 6.
On April 8,
- 1981, (reference P-81116) we responded to Nuclear Regulatory Commission Generic Letter 81-10 and once again we expressed concern for the lack of Nuclear Regulatory Commission response with reference to the various time tables that had been established to implement the various requirements.
7.
On July 13,
- 1981, in response to a letter from Nuclear Regulatory Commission Region IV on the Early Warning Alert again set forth our position on the Early system, we once Warning Alert system in letter P-81184 8.
Following publication of the 10CFR50 rule extending the Early Warning Alert system implementation to February 1, 1982, we immediately expressed our concern to the Nuclear Regulatory Commission via letter P-81243, dated October 5, 1981.
In this letter we indicated we could not meet the February 1,1982, date and requested that the time tables and schedules for Fort St. Vrain be based on completion of the ORNL review. We were informed verbally that the Nuclear Regulatory Commission was preparing a letter to that'effect, f
but we did not receive such a letter.
9.
On September 30, 1981, we received ORNL's evaluation of the applicability of NUREG 0737 to Fort St.
- Vrain, and on October 22, 1981, we provided our comments to ORNL via letter P-81263.
10.
In this entire period we received no comments from the Nuclear Regulatory Commisison in response to correspondence in spite of our many attempts to obtain resolution.
Then on December 3, 1981, we were informed of the denial which we still have not received in writing, and were informed that the February 1,1982, date would be applied to Fort St.
Vrain.
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It should be noted that during this time we were making preparations to install an Early Warning Alert system should our requests be denied.
Early in 1980 we had an EPZ study cono'ucted by Federal Signal Corporation to define a siren system.
We obviously had major concerns about a siren system because of the turkey farms in the area as well as other concerns; however, at that time the National Weather Service did not have sufficient NOAA weather radio coverage in our area for us to consider a tone alert system.
The siren study was completed and the location and size of the sirens were defined.
Preliminary investigations were therefore completed to permit us to proceed with the installation as expeditiously as possible should our appeal be denied.
Later, in our work with the National Weather Service, we learned that a NOAA weather station was to be installed near Mead, Colorado, by mid 1981.
This station, however, only provided marginal coverage in our area and a second station was planned for Point of Rocks.
These two stations provided more than adequate coverage and we
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proceeded with the design of a tone alert system.
We were out for bid on the system in November, 1981. Again our
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actual purchase to allow us to proceed as expeditiously as efforts here were to complete all preliminary work short of l
possible should our request be denied.
We believe the items described above clearly demonstrate our efforts to resolve this issue, and clearly demonstrate our efforts of preparation for implementing an Early Warning Alert system should our request be denied.
In spite of these efforts, however, we do not l
feel we can be expected to respond in implementing a system in less l
than two (2) months when it has taken the Nuclear Regulatory Commission almost twenty seven (27) months to give us a response.
l We recognize that the proposed 10CFR50 rule calls for enforcement action to be taken against those utilities that are not in compliance by February 1, 1982, but this action must consider timely action by the Nuclear Regulatory Commisison.
It is obvious that timely action i
by the Nuclear Regulatory Commission did not take place.
As we l
indicated in the December 15, 1981, meeting we not only believe that it is unrealistic to apply the February 1, 1982, implementation date to Fort St. Vrain, it is also unreasonable to apply enforcement t
action for failure to comply when the Nuclear Regulatory Commission played a very responsible role in leading to our failure to comply.
. We have purchased the weather radios (tone alert radios), and we expect delivery early in January.
We are proceeding with the development of public information brochures providing instructions for use and care of the radios, and we are proceeding with our plans for distribution of the radios.
Procedures are being developed in concert with the State, local government, and the National Weather Service.
Based on our present schedule we believe we can have most of the radios distributed by mid Februa ry.
This schedule, however, is extremely optimistic and contains very rough estimates as to the numbers of personal contacts that can be made in a given day.
It does not allow much time for situations such as people not at home, or additional time that may be required due to a lack of understanding.
Further, we have spent a lot of time and effort in developing the confidence of the public in Fort St. Vrain and it is extremely important that we implement our program properly to maintain this confidence.
These are areas which are very difficult to estimate.
Our schedule depends on procedural development by governmental agencies which are not under our control.
We believe a more realistic schedule, given the many tasks to be accomplished and the many unknowns associated with these tasks would be April 1,1982., for total implementation. We intend to proceed as expeditiously as possible, and we will keep our NRR project management informed as to our progress.
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Optimistically we are proceeding on schedule of implementation by mid February. We are, however, requesting relief to April 1, 1982, as a more realistic basis and we are further requesting a waiver of any Nuclear Regulatory Commission enforcement action until April 1,1982.
We believe our request is justified and we request your consideration and timely response.
Very truly yours,
/7 /Y Don W. Warembourg
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Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station DWW/alk cc:
B. Clark G. Kuzmycz J. Collins
'1' DeYoung Dickes D. Eisenhut i
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