ML20205S932

Submits Comments on RAI for Emergency Response Technical Manual Supplements.Licensee Is Confident That NRC Will Concur That Info in Environ Evaluation Rept & in Licensee Annex Provides Sufficient Detail for Intent of Supplements

ML20205S932
Person / Time
Site:	Westinghouse
Issue date:	04/14/1999
From:	Goodwin W WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP.
To:	Ten Eyck E NRC OFFICE OF NUCLEAR MATERIAL SAFETY & SAFEGUARDS (NMSS)
References
CON-NRC-99-016, CON-NRC-99-16 TAC-L20002, TAC-L31060, TAC-L31079, TAC-L31095, TAC-L31096, TAC-L31097, TAC-L31104, TAC-L31110, TAC-L31138, TAC-L31155, TAC-L31164, TAC-L31167, NUDOCS 9904270087
Download: ML20205S932 (2)

Text

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Westinghouse Commercial Nuclear Drawer R Electric Corporation Fuel Division fjgasgnpa%na2825a ep NRC-99-016 April 14,1999 U. S. Nuclear Regulatory Commission ATTN: Ms. Elizabeth Q. Ten Eyck Director, Division of Fuel Cycle Safety and Safeguards Office of Nuclear Material Safety and Safeguards Mail Stop T-8 A33 Two White Flint North 11545 Rockville Pike Rockville, Maryland 20852-2738 Ref: 1) Emergency Response Technical Manual (RTM) Supplements (TAC No. L20002)

2) NRC License SNM-1107, Docket 70-1151 Dear Ms. Ten Eyck; The Westinghouse Electric Company's Columbia Fuel Fabrication Facility (Docket 70-1151) staff has reviewed the REQUEST FOR ADDITIONAL INFORMATION FOR

\\ p RESPONSE TECHNICAL MANUAL SUPPLEMENTS (TAC NO. L20002) and submits the following comments for your consideration.

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We believe that the substance of the six parts of your request is (as it should be) best provided in two of our existing regulatory documents -- the " Environmental Evaluation Report" (referenced in Section 10.4 of our SNM-1107 License Application) and the

" License Annex"(referenced in License Condition S-2 of SNM-1107, and Chapter 4.0 of the License Application).

The Environmental Evaluation Report contains mostly unchanging information relating to the Site environment, structures, systems and components; that is updated, if necessary, for each License Renewal. The License Annex, referred to as an " Integrated Safety Assessment (ISA) Summary" in the ongoing draft 10 CFR Part 70 nile, contains information subject to change that is kept current in accordance with the previously referenced lice.ase commitments. L date, the following parts of the License Annex have been sun.nitted for docketing:

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NRC-99-016 Page 2 i

April 14,1999 ADU Conversion (TAC No. L31097);

ADU Bulk Powder Blending (TAC No. L31155);

e ADU Pelleting (TAC No. L31167);

i ADU Fuel Rod Manufacturing (TAC No. L31096);

e IFBA Fuel Rod Manufacturing (TAC No. L31095);

e Cylinder Washing (TAC No. L31110);

e URRS Dissolver(TAC No. L31138);

e Uranyl Nitrate Bulk Storage (TAC Nos. L31079, L31104);

Hoods and Containments (TAC No. L31164); and, e

j Plant Ventilation Systems (TAC No. L31066).

e Your Staff's acknowledgments of these submittals state that they have been filed awaiting future review.

Following the review of the License Annex, we are confident you will concur that the information in the Environmental Evaluation Report and in the License Annex provides sufficient details for the intent of the Response Technical Manual Supplements.

Whenever possible, we encourage the use of existing documents to meet diverse regulatory needs, as opposed to reformatting existing information into new documents.

Such approach seems to promote more efficient utilization of scarce and valuable resources - both licensee and NRC Staff.

Thank you for this opportunity to constructively participate in the NRC regulatory I

process.

Sincerely, WESTINGHOUSE ELECTRIC COMPANY l

W. L3oixlwin, Manager Regulatory affairs Columbia Fuel Fabrication Facility cc:

Charles W. Emcigh. Acting Chief Licensing Branch Division of Fuel Cycle safety and Safeguards, NMSS Mail Stop B Dl4 Two White Flint North 11545 Rockville Pike Rockville, MD 20852-2738

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