A05440, Requests Addl 60 Days to Submit Response to NRC Analysis & Conclusions Re Risk of Station Blackout.Extension Needed Due to Magnitude of Effort Necessary to Respond & Current Resource Commitments to Other Regulatory Programs

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Requests Addl 60 Days to Submit Response to NRC Analysis & Conclusions Re Risk of Station Blackout.Extension Needed Due to Magnitude of Effort Necessary to Respond & Current Resource Commitments to Other Regulatory Programs
ML20136H054
Person / Time
Site: Millstone Dominion icon.png
Issue date: 12/26/1985
From: Opeka J
NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To: Harold Denton
Office of Nuclear Reactor Regulation
References
REF-GTECI-A-44, REF-GTECI-EL, TASK-A-44, TASK-OR A05440, A5440, NUDOCS 8601090183
Download: ML20136H054 (2)


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.s, wa s w., cw (203) 66s-5000 December 26,1985 Docket No. 50-423 A05440 Harold R. Denton Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Reference:

(1) Harold R. Denton letter to John Opeka, dated December 18,1985.

(2) NUREG-il52, " Millstone 3 Risk Evaluation Report" (Draf t),

August 1985, transmitted under cover from T. M. Novak to J. F. Opeka, dated October 17,1985.

Dear Mr. Denton:

Millstone Nuclear Power Station, Unit No. 3 Response to Information Request re Station Blackout in your letter of December 18,1985 (Reference 1) you requested pursuant to 10 CFR 50.54(f) that within 30 days Northeast Nuclear Energy Company (NNECO) furnish an evaluation of the NRC Staff's analysis and conclusions regarding the risk of a station blackout at Millstone Unit No. 3. NNECO hereby requests an additional 60 days (until March 18,1986)in which to respond.

NNECO anticipates that a response to the 50.54(f) request will be a significant technical undertaking. Reference (1) includes a detailed regulatory analysis for reduction of core damage frequency at Millstone Ur;t No. 3. The regulatory analysis is based upon the Millstone Unit No. 3 Probacilistic Safety Study (PSS) and the Staff's draf t risk evaluation report (RER) provided to NNECO on October 17,1985 (Reference 2). NNECO is prepared to fully address the regulatory analysis and the RER in its response to the 50.54(f) request. However,in view of the magnitude of the effort necessary to respond, and given NNECO's current resource commitments to other regulatory programs, NNECO believes an extension in order to fully respond to the request is warranted.

NNECO agrees with the Staff that this response is not a full power licensing issue for Millstone Unit No. 3, and therefore the requested extension will not impact licensing. As is acknowledged in the Staff's regulatory analysis (at page 1), Millstone Unit No. 3 currently meets all existing NRC requirements. Further, it is Commission policy that potential backfits should not be part of the licensing process. See 50 Fed. Reg. 38097, 38102 (1985). Moreover, as recently AD - J. Kh!GHT (Itr only) 78 (HALLAND) 8601090183 851226 #g DR ADOCK O 3 h rics"[g(aos*>,'d,,

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acknowledged by Mr. Thompson of 'your staff at the December 10, 1985 Commission briefing on NTOLs,(Tr. 7), analysis of specific station blackout backfits for. Millstone Unit No. 3 should proceed independently of full power licensing. ,

The requested extension is also supported by the Staff's recommendation in the RER. In the RER the Staff considered five alternatives for design improvements with respect to station blackout from events other than earthquakes. The Staff concluded (at page 105-106) that r:o immediate actions are warranted and that Millstone Unit No. 3 may be, safely operated pending generic resolution of unresolved safety issue A-44 (Station Blackout). The Staff writes:

s The staff proposes to await resolution of,A-44 and not to implement

,s 4 any of 'these alternatives nowa We believe requirements will be introduced in the near' future to resolve A-44 which should reduce the estimated frequency of station blackout indoced core melts (from non-earth pake induced s

events) by about an order of magnitude.

, 3 in summary, NNECO believes an. additional 60 days to respond to the 50.54(f) letter is appropriate, since Millstone Unit No. 3 meets all regulatory requirements. The requested extension will result in no undue safety risk.

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY et. al.

BY NORTHEAST NUCLEAR ENERGY COMPANY Their Agent

, t

&0 J.IbOpeka V

) Senior Vice President '

STATE OF CONNECTICUT )

) ss. Berlin '

COUNTY OF HARTFORD )

Then personally appeared before me J. F. Opeka, who being duly sworn, did state that he is Senior Vice President of Northeast Nuclear Energy Company, a Licensee herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensees herein and that the statements contained in said information are true and correct to the best of his knowledge and belief. s

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