ML17298A423

Responds to Generic Ltr 82-33 Re Suppl 1 to NUREG-0737 Concerning Requirements for Emergency Response Capability. Unit 1 Selected as Backup Emergency Operations Facility. Exemptions from 10-mile Criteria Requested

ML17298A423
Person / Time
Site:	Palo Verde
Issue date:	06/16/1983
From:	Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
To:	Knighton G Office of Nuclear Reactor Regulation
References
ANPP-24102-ACR, GL-82-33, NUDOCS 8306270447
Download: ML17298A423 (8)

Text

GL, REGULAT INFORMATION DISTRIBUTION STEM (AIDS)

ACCCSSIQN NBR:8306270047 DOC.DATE: 83/06/16 NOTARIZED:

NO DOCKET ¹ FAGIL:STN 50<<528 Palo Verde Nuclear 'Station~ Unjt 1~ Arizona Publi 05000528

'STN"50 529 Palo Verde Nuclear Station~

Uni.t 2~ Arizona Publi 05000529

STN-50-.530 Palo Verde Nuclear Station~

Uni~t ~3~ Arizona Publi

-05000530 AUTH,NAME AUTHOR AFFILIATION VAN BRUNT'-.E ~

Arizona Pub l i c Ser vice Co ~

'EiCIP ~ NAME RECIPIENT AFFILIATION KNIGHTONzG o Licensing Branch 3

SUBJECT:

Responds

-to Generic Ltr 82~33 re Suppl

.1 'to NUREG 0737 concerning requirements -for emergency response capabili,ty ~

Unit 1 selected

=as backup emergency operations facility, Exemptions from 10 mile criteria requested'I'STRIBUTION

'CODEe A003S COPIES RECEIVED:LTR.J ENCL, P SIZE:

.'ITLE:

OR/Licensing Submittal:

Suppl 1 to NUREG 0737(Generic Ltr 82~33)

II NOT/S:Standardized plant

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Standardized plant.

Standardized plant ~

05000528 05000529 05000530 REC IP IEN T ID CODE/NAME

'NRR LB3 BC INTERNAL+ IE/DEPER/EPB NRR/DL/ORAB NRR/DSI/CPB NRR/DS I/METB NRR/DS I/RSB ORBS PAULSONgW RGN5 EXTERNAL; LPDR NSIC

.COPIES LTTR EN L

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RECIPIENT ID CODE'/NAME NRR/DHFS/PSRB NRR/DL/ORB5 NRR/DSI/ICSB NRR/DS I/RAB NR NgW RE, L

NRC PDR NTIS COPIES LTTR ENCL 1

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TOTAL NUMBER OF COPIES REQUIRED:

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Arizona Public Service Company P.O. BOX 21666

~

PHOENIX, ARIZONA 65036 June 16, 1983 ANPP-24102 ACR/WFQ Director of Nuclear Reactor Regulation Attention:

Mr. George Knighton, Chief Licensign Branch No.

3 Division of Licensing U.

S. Nuclear Regulatory Commission Washington, D. C.

20555

Subject:

Palo Verde Nuclear Generating Station (PVNGS) Units 1, 2 and 3

Docket Nos.

STN-50/528/529/530 File:

83-056-026'.1.01.10

References:

1.

Letter from E.

E.

Van Brunt, Jr. to F. Miraglia, NRC, dated March 19, 1981 (ANPP-17579 JMA/WFQ),

Subject:

Emergency Operations Facility Design.

2.

Memorandum to all operating reactor and ILicensing Branch Chiefs from S. L. Ramos, dated October 16, 1981,

Subject:

Modification of the Location and Habitability Criteria for Emergency Operations Facilities.

3.

Letter from E.

E. Van Brunt, Jr.

to R. L. Tedesco, dated January 27, 1982 (ANPP-19996 JMA/JRM),

Subject:

Emergency Operations Facility.

4.

Supplement l; to NUREG-0737 Requirements for Emergency

Response

Capability (Generic Letter No. 82-'33) dated December 7,

1982.

Dear Mr. Knighton:

Reference (1) described the design and construction of the PVNGS Emergency Operations Facility (EOF) to the NRC staff.

Modification to the original NRC criteria was provided by Reference (2).

The Reference (2) concerns were addressed by APS in Reference (3).

Reference (3) stated that the PVNGS EOF met condition 1 of Reference (2) and also stated that APS will use the Palo Verde Inn (PVI) as our backup EOF.

The PVI was selected as the backup EOF based on the following (Re'fer to the Reference (4), Table

1) requirements.

No separate, dedicated facility-The PVI is a facility that is used to house construction personnel working at PVNGS.

In looking for a backup EOF this building was chosen because it was an existing building that is serving a useful function and is not so~ dedicated as a backup EOF.

This building is one of very few in the PVNGS area that is large enough and can support (sleeping quarters, food, etc.),

the EOF personnel in the event that the EOF were to be evacuated.

Since this facility is used to support PVNGS on a normal basis, this facility is the best backup choice to support PVNGS during an emergency condition.

The only other buildings of sufficient size are schools which would not only lead to contract problems, but would lead to other problems, such as evacuation of children, communication equipment, etc.

~00 T

8306270447 830616 PDR ADOCK 05000528,;

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-PDR'l~

Mr. G.

W. Knighton Page 2

June:~16, 1983 ANPP-24102 ACR/WFO Arrangement for portable backup equipment The PVI has installed and in operation, all communication equipment needed for,the EOF personnel to perform their functions with the TSC, State and local authorities.

Contingencies exist which allow for the

'continuity of dose projections and decision~~rmaking capability.

Strongly recommended location be coordinated with offsite authorities The PVI is located such that it has ready access to a highway. It is in a well defined and known location (across the street from a local fire station).

Between 10 20 miles The PVI is located approximately 8 miles from the PVNGS.

APS there-fore, requests an exemption

. from this requirement based on the following justification:

Other locations were evaluated to perform this backup function but based on the fact that the equipment required in NUREG-0737 Supp.

1 is installed and working and based on contract agreements and other concerns PVI is the most ideal location for the PVNGS backup EOF.

The only NUREG-0737 Supp 1 criteria PVI does. not meet is the 10 20 mile requirement.

PVI is located approximately 8 miles from PVNGS.

This does not cause us concern as our EOF is environmentally isolated based on the design of our EOF.

Some of these EOF features are as follows:

l.

Our EOF is designed using a ventilation system that can be isolated using a HEPA System to recirculate air..

2.

Airloc capabilities to isolate the EOF.

3.

Backup power supply (emergency diesel)dedicated to the EOF.

Based on the design of our EOF, it would be extremely unlikely that we would have to evacuate the facility. If the conditions were such that the EOF were to be evauated, it is not a'pparent to us that having a building at 10 miles would be more beneficial than a building such as we have at apprbzimately 8 miles.

Based on the above discussion and justification we believe that our backup EOF a'ddresses the intent of Reference (4) and that an exemption to the 10 mile criteria can be granted.

Please advise us within two weeks from the date of this '-letter when you plan to respond to the acceptability of the PVNGS EOF.

Please contact me if you have any questions.

Very truly yo s,

EEVBJr/WFQ/sp GU E. E.

Van Brunt, Jr.

APS Vice President, Nuclear Projects ANPP Project Director

cc:

E. L. Licitra E. F. Williams, Jr.

(EWN 359)

A. C.

Gehr

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