ML20216G800
| ML20216G800 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 03/18/1998 |
| From: | CENTERIOR ENERGY |
| To: | NRC (Affiliation Not Assigned) |
| References | |
| NUDOCS 9803200094 | |
| Download: ML20216G800 (2) | |
Text
- MAR-88 98 88
- 48 FR*lMNUCLEAR L8CENSIX3 41@-249-2302 TO:913014853068 PAGE:02 bs
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FORINFORMATION ONLY
SUMMARY
OF REOUIREMENTS REGARDING AN EXCEP'ITON ALLOWING l
AN ALTERNATE EMERGENCY RESPONSE FACILITY REQUIREMENTS FROM WHICH RFT JFC IS REQUESTED:
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NUREG-0737, Supplement 1, (Generic letter 82-33, dated December 17,1982),
Table 1 lists only two options for an EOF: 1) A close-in Primary EOF (within 10 miles of the plant) with a Backup EOF (located between 10-20 miles), or 2) A single EOF (located at or beyond 10 miles).
An Alternate EOF is not listed in NUREG-0737, Supplement 1. Therefore, the use of one would constitute an " exception" to the NUREG.
REGULATORY GUIDANCE FOR RELIEF:
SECY-96-170, page 2, second paragraph: Use of a hardened, close-in EOF still needs a Backup EOF, unless the licensee has an Alternate EOF. The NRC staff can
" accept" this type of exception.
SECY-96-170, page 4, third paragraph: 7he recognition that an Altemate EOF or its location is an exception, when the primary EOF is hardened,is provided here.
SECY-96-170, Attachment 2, Note A: Commissioners authorized NRC staff to
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" approve" the Altemate EOF if located between 10-20 miles of plant.
Note: Not defined as air or driving miles.
i SECY-96-170,page 5, third paragraph: NRC Commissioners "have authorized the staff to approve an alternate location in place of a backup EOF when the licensee had built an EOF with a high degree of habitability protection within 10 miles df the plant" Exception could be granted provided 1) the emergency plan identified an alternate location where utility and govemmental officials could meet to discuss plant status and public protective actions, and 2) that the emergency plan indicated that contingency arrangements had been made to provide equipment for necessary communication with the TSC in the event of an emergency.
SECY-96-170, page 8: NRC staff can approve exceptions to NUREG-0737 Supplement I with an additional 5 miles, so revised distance criterion is now anywhere between 5-25 miles for a Backup EOF. Altemate EOF is not specifically i
addressed,but previously the distance used in locating an Alternate EOF was the same as that for a Backup EOF (and the Alternate EOF is being used in lieu of the Backup EOF combined with a hardened, close-in EOF).
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MAR-18 98 88:41 FROM: NUCLEAR LICENSING 419-249-2302 TO:913014153068 PAGE:03 PLANNED LOCATION:
Bay Shore location for the Alternate EOF is 18 miles by air and 25 miles by driving Therefore, it meets the original distance criterion (10-20 miles) if considering it to be by air, and the revised distance criterion (5-25 miles) if considering it to be by air or by driving (assuming that the revised criterion also applies to the Alternate EOF)..
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