ML20215E629

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Requests Clarification of 10CFR50.72 Immediate Notification Requirements Re Major Loss of Offsite Response Capability. Three Questions Listed
ML20215E629
Person / Time
Issue date: 01/18/1984
From: Nelson R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To: Jackiw I
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20215E579 List:
References
FOIA-86-729 NUDOCS 8612230036
Download: ML20215E629 (1)


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MEMORANDUM FOR: I .N. JACKIW, CHIEF, PROJECTS SECTION 2B FROM: R.L. NELSON, SENIOR RESIDENT INSPECTOR, KEWAUNEE NUCLEAR POWER PIANT I

SUBJECT:

10CFR 50.72 IMMEDIATE NOTIFICATION REQUIREMENTS 50.72 (b) (1) states, in part, "..:.the licensee shall notify the NRC as soon as practical and in all cases within one hour of the occurrence of any of the following:". 50.72(b) (1) (v) states, in part, "Any event that results in a major loss of off-site response capability." 4 0n. page 50-SC-106 of the Statements of Consideration, under Paragraph 50.72(b) (f) (v), it is stated, in part, " Notifying the NRC of these events may permit the NRC to take some compensating measure and to more completelp assess the consequences of such a loss should it occur during an accident or emergency."

The above raises three questions for which I am requesting clarification.

(1) Does the loss of response capability apply only to licensee personnel?

(2) What is considered a major loss? and (3) How does an inspector or the licensee determine that a major loss has or had occurred? It is fairly common knowledge that 6"-12" snowfalls with drifting conditions, ice storms, etc.

are not uncommon occurrences north of the " Mason-Dixon Line" and these type of conditions have and will continue to occasionally reduce response capability.

It would seem that adverse weather and/or road conditions would be the most common type of occurrence to reduce off-site response capability and would have been a significant part of the basis,,for initiation of the rule, and therefore. consideration would have been given.to objective enforceability criteria i.e. definition of rnajor loss. ,

In summary, please provide me with what. constitutes a major loss, if this is given in (X) percent of plant personnel, then provide me with a method to determine what percent can or would have been able to respond under various adverse weather and road conditions.

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R.L. Nelson 3 Senior Resident Inspector Kewaunee Nuclear Power Plant cc: W.P Shafer, RIII .

'. Norelius, RIII 8612230036 861219 PDR FOIA REPKA86-729 PDR gNN Q

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