ML20214V039
| ML20214V039 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/25/1986 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Taylor J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| References | |
| RTR-NUREG-0654, RTR-NUREG-654 NUDOCS 8610020106 | |
| Download: ML20214V039 (2) | |
Text
._.
gthggna Electric & Gas Compcny n A.
n g.
um 29218 Nuclear Operations SCE&G September 25, 1986 Mr. James M. Taylor Director, Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12
. Radiological Emergency Plan Review
Dear Mr. Taylor:
On August 13, 1986, a letter signed by Mr. Roger Walker, Director, Division of Reactor Projects Region II, addressed to South Carolina Electric & Gas Company (SCE&G) stated that the Fission Product Barrier Approach to emergency event classification, as implemented at the Virgil C. Summer Nuclear Station, was not an acceptable alternative to the NUREG-0654 event-identification method of emergency classification. This position of the NRC staff was repeated in a meeting on September 4, 1986 at the NRC's Region II offices.
During that meeting the NRC Staff asserted that verbatim conformance to the specific event listing in NUREG-0654, Revision 1. Appendix 1, was a
' regulatory requirement. SCE&G disagrees with the position taken in the August 13, 1986 letter, and requests that this issue,--namely, what constitutes a regulatory requirement in regard to emergency event classification--be resolved.
The Code of Federal Regulations (10 CFR 50.47 (b).(4) and 10 CFR 50 Appendix E, IV.C.) addresses emergency classification and emergency classes by referring to NUREG-0654/ FEMA-REP-1. All questions regarding identification 3
of the regulatory requirement in regard to emergency event classification can be effectively resolved by an answer to the following question:
Do the Regulations require specific conformance to the listing of events and initiating conditions as presented in the list of " Example Initiating Conditions" for each event class in NUREG-0654, Revision 1, or do the Regulations require that the entire spectrum of possible events be classified by a scheme which results in event classification in conformance to the class descriptions as discussed in NUREG-0654 Revision 1 Appendix 17 The adoption of the Fission Product Barrier Approach to emergency event classification results in a significant improvement over event identificr'fon based emergency classification methods. The Approach focuses operator attention on what is important to assure the safety of the public during off-normal conditions.
It also contains anticipatory features and provides a means to assess not only any possible progressive loss of function necessary to assure safety, but also errors or failures subsequent to the development of an event which are not addressed in NUREG-0654.
goo 2ggggyp fj3g If0 F
I Mr. James Taylcr September 25, 1986 Page Two Based on these conclusions and the knowledge that the NRC and FEMA had approved the use of the Fission Product Barrier Approach at Wolf Creek, a plant similar to the Virgil C. Summer Station, SCE&G believed that the provisions of 10 CFR 50.54 (q) warranted the implementation of the Fission Product Barrier Approach without prior NRC approval, and that the revision would represent an increase in the effectiveness of the Radiation Emergency Plan.
SCE&G is making preparations to revise the Radiation Emergency Plan in accordance with the requirements of the August 13, 1986 letter. However, prior to implen.entation of this revision, your timely review of this issue is requested to finally resolve these questions.
Your assistance in this matter is appreciated and if further information is needed, please let us know.
/ ry truly y))urs, t(
WW 1
hJ au n AMP / DAN:jez c:
- 0. W. Dixon, Jr./T. C. Nichols, Jr.
E. H. Crews, Jr.
E. C. Roberts
- 0. S. Bradham J. G. Connelly, Jr.
D. A. Moore W. A. Williams, Jr.
M. B. Williams J. Nelson Grace M. L. Ernst R. D. Walker Group Managers C. A. Price C. L. Ligon (NSRC)
R. M. Campbell l
K. E. Nodland R. A. Stough
(
G. O. Percival i
R. L. Prevatte J. 8. Knotts, Jr.
l NPCF File
- _.. _. _