ML20205A302
| ML20205A302 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/20/1988 |
| From: | Withers B WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 WM-88-0268, WM-88-268, NUDOCS 8810250460 | |
| Download: ML20205A302 (4) | |
Text
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i WQLF CREEK NUCl. EAR OPERATING CORPORATION Bari D. W4hers gg%
October 20, 1988 WM 88-0268 U. S. Nuclear Regulatory Comnission ATTN Doc urn e nt Control Desk Mall Station Pl-137 Washington, D. C. 20555
Reference:
Letter dated August 19,1988 f rom P. V. O'Connor, NRC, to B. D. Withers, WCNOC Subjects Docket No. 50-482 :
Eisergency Plan Applicability to the Site Boundary Centlement The purpose of this letter is to provide Wolf Creek Huclear Operating Corporation's (WCNOC) response to Mr. Paul O'Conaor's regt.est for changes to l
the Wolf Creek Radiological Emergency Response Plan (RERP).
The reference identified a concern that the current RERP does not provide adequate protection for individuals who intentionctly trespass and engage in (Megal fishing on the Wolf Creek Cooling Lake.
i WCNOC has thoroughly reviewod ',he RERP, regulatory requirersent s applicable l
to the Wolf Creek Generating Station (WCCS) and the degree of trespassing on
(
the Wolf Creek Cooling Lake.
It is WCNOC's position that the current RERP provides a high degree of protection to the health and safety of tha public p
and meets all of the regulatory requirements applicable to WCGS.
WCl!0C has i
previously addressed this issue in a letter dated May 24, 1988 from Mr. Bart Withers, VCNOC to the Nuclear Regulatory Consission. Excerpta fros that letter as well as additional inforruation to support this position are provided below.
l Figure 1 identifies the WCCS site boundary.
The WCCS site boundary for the most part consists of a 4 or 5 strand wire fence and posted signs indicating 1
private property.
Figure 2 identifies the Owner-Controlled Area barriers and the exclusion area.
The approved WCCS RERP Section 3.3.1.1 (which i
follows the guidance of NUREC-0654 Section J.l.D) provides for evacustion, i
if appropriate, of personnel from the esclusion area based on the Emergency Action Level schetse and potential for further degradation and i=sediate hasards to personnel.
Security personnel are directed to conduct an inspection of thu lake and land area within the exclusion area but outside the Protected Area to ensure that au non-essential personnel are evacuated from the exclusion area.
There are no public access areas within the she baundary with the exception of the Owner-Controllod Area in which access is monitored and restricted as appropriate by security personnel.
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/ g PO Bos dit s pursrvon, KS 66639 / Phone. (316) 364-e631 aa Ew cwcrvw, t"Tt'rer 64* Mc.%1Y
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VM 88-0268 Page 2 of 2 Oc?.ober 20, 1988 WCN00 believes the number of people engaged in the illegal act of t respass ing is very small
- and, for those rare occasions when people do
- tresposa, the duration is very short.
The probability of an event oesurring that would require evacuation is extremely low.
Therefore, VCNOC believes that the increased benefit from providing protection to those intentionally engaged in
[Ilegal trespassing would be extr uely small and the cost of providing that increased protaction would be high.
Therefore changrs wculd not be cost beneficial.
'EN00 believes that emergency planning is extremely important and has put tremendous effort into the development and implementation of the emergency response plan.
WCNOC believes that the RERP is in compliance with 10 CFR 50.47(b)(10) and :he guidance of NOREC-0654 Section J.l.D.
Furthermore, WCNOC believes it is inappropriate to require extra emergenc) planning measures for trespassers, especially when the increase in overall I
safety is extremely s taall and the cost / benefit does not warrent implementation of such measures.
WCNOC does intend to take additional actions to assure that the number of trespassers is kept low.
In the past, i
of fenders have typically been given a warning.
In the future, WCNOC intends to file formal charges of criminal trespassing against anyone caught trespassina.
This new policy should provide a stronger deterrent to would-be offenders.
In March 1985, the NRC issued NUREC-0881, Supplement No.
5, "Safety Evaluation Report Related to the Operation of the Wolf Creek Generating Station".
In Section 13.3.2 the Staff concluded that "...on the basis c. f I
inf ormation in Revision 15 of the emergency plau and EPP 01-10.1, and on the applicant's demonstrated performance in the November 1984 exercise, the applicant is in conformance with the ete e rge nc y planning standard for protective r e s p o n s e*. "
WCNOC recognizes that the Staff can and will periodically change its technical interpretation concerning what is i
acceptable.
- However, if the Staff changes its interpretation af te r its I
initial acceptance, the plant specific backfit provisions of 10 CFR 50.109 l
anJ NRC Manual Chapter 0514 are applicable und should be complied with prior to imposing the changes on the utility.
If you have any questions concerning this matter, please contact me or Mr. O. L. Maynard of my staff.
Very truly yours,
\\
Bart D. Withers Fresident and l
Chief Executive Officer i
15 DW/ j ad l
l Attachment ect
- 5. L. Bartlett ( NRC). w/a D.
D. Chataba rlain ( NRC), w/a R. D. Martin (NRC), w/a D. V. Pickett ( N RC ), w/a (2)
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