ML20050B864

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Provides Addl Response to Generic Ltr 81-10 Re Emergency Response Facilities.Formal Implementation Schedule Will Be Submitted W/Acceptance Criteria Finalized & Committee to Review Generic Requirements Evaluation Completed
ML20050B864
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 04/01/1982
From: Bayne J
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To: Vassallo D
Office of Nuclear Reactor Regulation
References
GL-81-10, JPN-82-34, NUDOCS 8204070501
Download: ML20050B864 (2)


Text

POWER AUTHORITY OF THE STATE OF NEW YORK 10 CoLUMeus CIRCLE NEW YORK. N. Y. loo 19 t212) 397-6200 G EO RG,,E,T BERRY p g CMtEF rRustres

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Director of Nuclear Reactor Regulation O, 'i, U.S.

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20555 ll Rii G...J Attention:

Mr. Domenic B. Vassallo, Chief 9

Operating Reactors Branch Nc, 2 T

APR O G 1982 * ;

Division of Licensing I U Rat rRMa rm 8207 Nmi u 8

Subject:

James A. FitzPatrick Nuclear Power t

d Docket No. 50-333 3d \\ e Emergency Response Facilities - Concep Design and Schedule

Reference:

1. NRC Generic Letter No. 81-10, dated February 18, 1981, Post TMI Requirements for the Emergency Operations Facility
2. PASNY November 6, 1981 letter - J.P. Bayne (PASNY) to D.G. Eisenhut (NRC) regarding Emergency Response Facilities (JPN-81-89)

Dear Sir:

NRC Generic Letter No. 81-10 (Reference 1) established the requirement that licensees of operating reactors provide conceptual design information for Emergency Response Facilities (ERFs) by June 1, 1981.

Via Reference 2, the Authority transmitted this information and committed to supplying a formal implementation schedule during the first quarter of 1982.

Although the NRC has not yet finalized acceptance criteria for regulations associated with emergency response capabilities and facilities, significant progress has been made.

None of the following criteria documents have been promulgated in final form as of this date: NUREG-0801

(" Evaluation Criteria for Detailed Control Room Design Review"); NUREG-0814 (Methodology for Evaluation of Emergency Response Facilities j, and NUREG-0835

(" Acceptance Criteria for the SPDS").

However, as part of the E

Authority's integrated approach towards developing ERFs, we are O

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actively involved in the following industry groups:

1. BWR Owners' Group - Subgroup on Assessment of Regulatory Guide 1.97, Revision 2
2. BWR Owners' Group - Subgroup on Control Room Improvements
3. BWR Owners' Group - Subgroup on Emergency Procedures
4. SPDS Display Validation Program - General Electric Co.

and Sandia Laboratories

5. Consortium of Northeastern Utilities for the Development of Nuclear Plant Data Systems The necessity for integrating these regulations into a single plan has been substantiated by Mr. Dircks's commitment (Attachment 1) to.have the newly formed committee to Review Generic Requirements (CRGR) chaired by Mr. Victer Stello Jr., (Deputy Executive Director for Regional Operations and Generic Requirements) to evaluate the proposed requirements.

In light of these circumstances, the Authority believes it would be inappropriate to submit a formal implementation schedule at this time.

A more meaningful submittal will be made after the acceptance criteria have been finalized and the CRGR completed it's evaluation.

This approach is consistent with recent developments within the NRC.

The Authority will continue to participate in the industry programs listed above and awaits your further direction on these matters.

If you have any questions, do not hesitate to contact us.

l Very truly yours, i

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. Bayne en or Vice President Nu ear Generation L

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i NOV 1 8 1981 Dr. Donald F. Knuth DiC, Incorporated 1747 Pennsylvania Ave.. NW Washington. DC 20005*

Dear Dr. Knuth:

In year letter of October 6*,1931, you commented on the Safety Parameter Display System (SPDS) on behalf of the Coordinating Group on Emergency Preparedness Implementation (CGEP). The utilities comprising CGEP are working colle::tively in the implementation of emergency planning criteria.

Your letter stated that the industry has proceeded with the development of SPDS designs with only vague guidance from NRC and has expressed concern that the NRC has lost the perspective of the SPDS relationship to other requirements.

Because of this concern, you recommend that NRC establish evaluation criteria, reestabitsh the relationship between the control room review and the SPDS, and establish an implementation date consistent with the intermediate steps which impact on the SPDS.

We agree with your point that the SPDS must be coordinated with the other related activities.

In the proposed rulemaking to add the SPDS to the Emergency Response Facilities rule, the staff's proposed implementation date will be based on integration of the SPDS with the detailed control room design review, guidelines for emergency operating procedures, and the Emergency Response Facilities.

All of these proposed requirements will be reviewed by the newly formed Committee to Review Generic Requirements (CRGR), chaired by Mr. Victor Stello, Jr., Deputy Executive Director for Regional Operations and Generic Requirements.

The CRGR will evaluate the priority of these proposed requirements relative to existing requirements and will evaluate whether the requirements would place unnecessary burdens on ifcensee and NRC resources. The CRGR will obtain comments the proposed requirements from CGEP and other industry groups as appropriate.

I appreciate your comments concerning integration of the SPDS with other control room tasks and hope I have been responsive to your concerns.

If you have further questions. please do rot hesitate to contact me or Mr. Stello.

Sincerely.

1A W 11 am J. Dircks Executive Director for Operations q1110903C/a

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