ML17139B561
| ML17139B561 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/09/1983 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | Curtis N PENNSYLVANIA POWER & LIGHT CO. |
| References | |
| NUDOCS 8305200091 | |
| Download: ML17139B561 (6) | |
Text
MAY 0 S 1983 Docket No.:
50-387 t
DISTRIBUTION:
Docket File NRC PDR Local PDR NSIC PRC Hr. Norman W. Curtis Vice President Engineering and Construction - Nuclear Pennsylvania Power 5 Light Company 2 North Ninth Street Allentown, Pen sylvania 18101
Dear Hr. Curtis:
LB¹2 File RPerch EHylton
- Cutchin, OELD
- ELJordan, DE(A:IE
- JHTaylor, DRP:IE Region I ACRS (16)
Subject:
Request for Additional IFIformation - Revision 6 to the Emergency Plan for Susquehanna Unit 1
The NRC staff has conduct'ed a preliminary review of the November 2, 1982 submittal by Pennsylvania Power
& Light regarding Revision 6 to the Susqqbhanna Unit 1
The NRC staff finds that additional information is needed to complete the review as indicated in Enclosure (1).
In order to complete the review in a timely manner, receipt of the additional information is requested by thy 20, 1983. If you have any questions regarding this matter, please contact R. Perch, Project Hanager at (301) 492-8136.
Sincerely,
Enclosure:
As stated Original signed byi A. Schwencer, Chief Licensing Branch No.
2 Division of Licensing cc:
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NRC FORM 3I8 (10-80) NRCM 0240 OFFICIAL RECORD COPY USGPO: 19SI~060
Susquehanna Mr. Norman W. Curtis Vice President Engineering and Construction Pennsylvania Power 8 Light Company Allentown, Pennsylvania 18101 ccs:
Jay Silberg, Esquire
'haw, Pittman, Potts 8 Trowbridge 1800 M Street, N. W.
Washington, D. C. 20036 Edward M. Nagel, Esquire General Counsel and Secretary Pennsylvania Power 5 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr; William E. Barberich Nuclear Licensing Group Supervisor Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsyl vani a 18101 Mr. G.
Rhodes Resi dent Inspector P. 0. Box 52
"-'hickshinny, Pennsylvania 18655 Gerald R. Schultz, Esquire Susquehanna Environmental Advocates P. 0. Box,1560 Milkes-Barre, Pennsylvania 18703 Mr. E. B. Poser Project Engineer Bechtel Power Corporation P. 0.'Box 3965 San Francisco, California 94119 Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801.
Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsylvania P. 0.
Box 2063 Harrisburg, Pen'nsylvania 17120 Ms. Colleen Marsh P. 0.
Box 538A, RD f4 Mountain Top, Pennsylvania 18707 I
Mr. Thomas J. Halligan Correspondent The Citizens Against Nuclear Dangers P. 0. Box 5
- Scranton, Pennsylvania 18501 Mr. J.
W. Millard Project Manager Mail Code 395 General Electric Company 175 Curtner Avenue San Jose, California 95125 Robert W. Adler, Esquire Office of Attorney General 505 Executive House P. 0.
Box 2357 Harrisburg, Pennsylvania 17120
SUSQUEHANNA REQUEST FOR ADDITIONAL INFORMATION 1.
According to Section 5.0 (Organization and Control of Emergencies) of the Emergency Plan (see last paragraph on page 5-3), the Shift Supervisor initially assumes the position of Emergency Director, (ED).
As an Emergency progresses, the.Plant Superintendent becomes the ED.
He is subsequently relieved of overall responsibility by the EOF Support Manager (EOFSM) and then the Recovery Manager (RM).
The Plant Superintendent, retains the ED title even after being relieved of command by the EOFSM and RM, as he is still responsible for maintaining the unit in a safe condition (See first paragraph of page 5-5).
The ED title should be transferred to the person who is overall in change of directing and coordinating the emergency response.
The title Recovery Manager is misleading because that individual is in charge during emergency conditions as well as for'he recovery modes.
In addition, the plan does not specify the new Emergency Assignments for the Shift Supervisor and Plant Superintendent after they have been relieved of ED duties.
Figure 5.5 mixes communications and structural relationships in the final augmentation phase.
In addition, some other titles in the organization are misleading (e.g.
Radio Coordinators and
'Communications Coordinators are actually communicators)'.
The licensee's organization alignment does not address each phase of emergency response (i.e. initial, intermediate, final, and recovery phase) and does not provide structural definition to the working level.
Request - Revise the description of the emergency organization to include a
sufficient level of detail to completely and unambiguously delineate the command hierarchy, reporting chains, and functional interrelation-ships down to the working levels.
2.
Paragraph
- 7. 1.3 of the EP defines the OSC and states that it is "to be used during initial phase of emergency."
This is contrary to fact since the OSC will be used throughout emergencies, unless it is not habitable.
OSC functions,
- however, must be available on a continuous basis during emergencies.
Request - Define the OSC in accordance to its expected response functions during accidents; specify an alternate
- OSC, and the conditions upon which transferring of personnel (from the OSC to the alternate OSC) will take place.
Habitability criteria, based on evaluation of
~ benefit versus risk, in terms of exposure doses (e.g.,
whole body and thyroid) should be established, and also the information flow and logistics needed to accomplish the same.
Susquehanna-Request for Additional Information 2
3.
Level of specificity in equipment listings (Appendix 0, Equipment Infor-mation Listing) is not internally consistent'.
Radiation instruments available, for example, are not specified in a manner which would reflect instrument response characteristics (e.g.
by model),
and thus are not unambiguously described.
The same is noted in EPIP-001.
Request - Modify Appendix 0 and EPIP-001 to provide sufficient levels of specificity in order to unambiguously describe inventory items, in particular, radiation instrumentation.
4.
The EP description of the TSC leaves parts blank concerning Habitability (Paragraph
- 7. 1.2.5).
In addition, the criteria for transferring from the EOF to the Backup EOF (e.g.
allowed exposures) and the scheme for ensuring continuity of EOF functions throughout this transfer were not described.
There was no description and layout of facilities and equipment available at the Media Center.
Request - Improve descriptions of ERFs as noted.
5.
Paragraph 7.9 in the EP describes the various information systems that will be available in the future, but is not clear whether any of these, including the "Interim ER Computer System" is presently available.
Request - Clarify descriptions of information systems by specifying when a
system is not presently available.
6.
Emergency Action Levels in the Emergency Plan were found to be consistent with - those in EPIP-001.
However, Appendix E of EPIP-001, has two sets of page numbers:
one referring to the procedure page sequence and another to the Attachment page sequence.
Two EALs do not include specific unequi-vocal criteria (e.g.. plant - specific indications or.instrument readings).
'While this may not be feasible for these
- cases, general guidance such as "Shift Supervisor's Evaluation" should be provided.
These EALs are:
EAL in Section
- 4. 1.2 Alert (Condition 14) for "a fire lasting over fifteen minutes and potentially affecting the safe shutdown of the plant",
(See NUREG 0810 "EALs for Light Water Reactors" ).
EAL in Section
- 4. 1. 1 Unusual Event (Condition 8) for a "a significant fire within the plant" calls for duration of fire longer than fifteen minutes after time of notification, without additional qualifying criteria such as "not potentially affecting plant shutdown",
(See NUREG 0810 "EALs for Light Water Reactors" ).
Request - Modify EALs to include "Shift Supervisor's Evaluation",
when specific unequivocal plant-specific indications and instruments readings are not feasible.
Susquehanna-Request for Additional Information 3
7.
State and County Emergency Plans are listed within the "Letters of Agreement" category in Appendix A of the EP in broad terms, but there is no specific reference as to expiration date of agreements and current revisions in effect.
Request - Identify the revision and expiration dates of agreements with support agencies.
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