ML18018A499

Forwards Plans & Schedules for Emergency Response Capabilities Per Generic Ltr 82-33 Re Suppl 1 to NUREG- 0737, Requirements for Emergency Response Capability. Meeting to Discuss Plan in Detail Expected Shortly

ML18018A499
Person / Time
Site:	Harris
Issue date:	04/15/1983
From:	Utley E CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8304190518
Download: ML18018A499 (14)

Text

REGULATOR NFORMATION DISTRIBUTION

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ACCESSION NUR:8304190518 DOC ~ DATE: 83/04/15 NOTARIZED; YES FACIL:50-400 Shearon Harris Nuclear power Plant~

Unit 1< Carolina 50-401 Shearon Harris Nuclear Power Plant~

Unit 2~ Carolina AUTH,NAME AUTHOR AFFILIATION UTLEYrE ~ ED Carolina Power L Light Co REC IP. NAME RECIPIENT AFFILIATION DENTONgH ~ R, Office of Nuclear Reactor Regulationi Director

SUBJECT:

Forwards plans 5 schedules for emergency response capabilities per Generic Ltr 82-33 re Suppl 1 to NUREG 0737(

"Requirements for Emergency

Response

Capability ~

Meeting to discuss plan in detail expected shortly.

DISTRIBUTION CODE ~

A003S COPIES RECEIVED:LTR ENCL SIZE:

TITLE: OR/Licensing Submittal:

Suppl 1 to NURE( -0737(G neric Ltr 8 NOTES:

DOCKET 05000400 05000401 fW OO MMWIw

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RECIPIENT ID CODE/NAME NRR LB3 BC INTERNAL: IE/DEPER/EPB NRR/DHFS/PSRB NRR/OL/OR85 NRR/DSI/ICSB

-L EXTERNAL: LPDR NSIC

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TOTAL NUMBER OF COPIES REQUIRED:

LTTR 29 ENCL 29

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Carolina Power & Light Company April 15, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NOS.

1 AND 2 DOCKET NOS. 50-ti00 AND 50-ti01 NRC GENERIC LETTER 82-33 REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY

Dear Mr. Denton:

On December 30, 1982 Carolina Power 5 Light Company (CPSL) received Generic Letter 82-33, Supplement 1 to NUREG-0737, Requirements for Emergency

Response

Capability.

As a participating member of the Nuclear UtilityTask Action Committee on Emergency

Response

Capabilities (ERC NUTAC), which includes over forty utilities and is administratively supported by INFO, CPKL is developing an integrated implementation program which responds to the requirements of Generic Letter 82-33 as follows:

PROGRAM PLAN AND SCHEDULE Due to construction schedule requirements, CP8L decided to make early commitments on emergency response capabilities in advance of the issuance of Supplement 1 to NUREG-0737.

However, where appropriate, CP&L is using the ERC NUTAC's draft Guidelines for an Inte rated Im lementation Plan, as an input for remaining plant-specific integration planning.

In developing the remaining SHNPP integration criteria, other guidelines prepared by the NUTAC's, and the Westinghouse Owners'roup (WOG)

, will be evaluated.

With Commission approval of Supplement 1 to NUREG-0737, we have now finalized schedules for completion of these activities.

Attachment 1 pro-vides plans and schedules for each activity, integrated with our current pDR A~90518 Bgp

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411 Fayetteville Street

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Mr. Denton April 15, 1983 engineering, construction and startup schedule.

As proposed by Generic Letter 82-33, we will meet shortly with our NRC Pro)cot Manager to explain in more detail, our integrated implementation plan as described in Attachment 1.

Yours very truly, EEU/SRZ/lr (010CSRZh)

E. E. Utley Executive Vice President Power Supply and Engineering 4 Construction E. E. Utley, having been first duly sworn, did depose and say that the information contained herein is true and correct to his own personal knowledge or based upon information and belief.

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Notary (Seal My Commission Expires:

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Mr. N. Prasad Kadambi (NRC)

Mr. G. F. Maxwell (NRC-SHNPP)

Mr. J.

P. O'Reilly (NRC-RIl)

Mr. Travis Payne (KUDZU)

Mr. Daniel F.

Read (CHANGE/ELP)

Chapel Hill Public Library Wake County Public Library Mr. Wells Eddleman Dr. Phyllis Lotchin Ms. Patricia T. Newman Mr. John D. Runkle Dr. Richard D. Wilson Mr. G. 0. Bright (ASLB)

Dr. J.

H. Carpenter (ASLB)

Mr. J. L. Kelley (ASLB)

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ATTACHMENT 1 PLANS AND SCHEDULES FOR EMERGENCY RESPONSE CAPABILITIES 1-1

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0 SAFETY PARAMETER DISPLAY SYSTEM (SPDS)

Although the SPDS was procured prior to issuance of Generic Letter 82-33, the SPDS will meet the requirements of Supplement 1 to NUREG-0737.

A Purchase Order to provide the hardware,

software, and analysis for an SPDS has been placed and the conceptual design will be completed by May 1983.

Carolina Power

& Light Company anticipates submittal of the SPDS safety analysis by September 1983.

SPDS is expected to be operable, and training will be complete by April 1985, before fuel load in June, 1985.

As requested by Generic Letter 82-33, CP&L does not desire an NRC pre-implementation review.

DETAILED CONTROL ROOM DESIGN REVIEW (DCRDR)

The Detailed Control Room Design Review (DCRDR) was conducted between April 1980 and January 1981 with the final summary report titled "Human Factors Design Evaluation Report for the Shear on Harris Unit 1 Control Room" (summary report) issued in September 1981 and submitted to the NRC on December 7, 1982.

The summary report was prepared and submitted to the NRC prior to promulgation of the requirements of Supplement 1 to NUREG-0737.

In general, the summary report demonstrates that the DCRCR conducted by CP&L meets the requirements set forth in Supplement 1 to NUREG-0737.

During a meeting held with the NRC staff on March 25,

1983, CP&L agreed to provide additional information to facilitate the staff assessment of the DCRDR.

This additional information will be supplied to the staff by June

1983, and will consist of (1) a more detailed description of the SHNPP-1 DCRDR methods and procedures, (2) a description of the review team composition and qualifications, and (3) a description of resolution of the recommendations in the summary report.

A task analysis was performed on H. B. Robinson Unit 2 Emergency Operating Procedures (EOP's) adapted to the SHNPP-1 design.

SHNPP-1 symptom-based EOP's are currently under development and will be task analyzed prior to implementation.

The design improvement verification and validation will be performed when the control room is functional with SPDS and RG-1.97 instrumentation installed and the symptom-based EOP's implemented.

REGULATORY GUIDE 1.97 Carolina Power

& Light Company will consider the NUTAC guidance documents on RG-1.97 in developing a final plan for RG-1.97 compliance.

A report describing RG-1.97 compliance plans will be submitted to NRC by August, 1983.

SHNPP will meet the RG-1.97 requirements consistent with the stipulations provided in Supplement 1 to NUREG-0737, prior to fuel load in

June, 1985.

UPGRADE EMERGENCY OPERATING PROCEDURES (EOPs)

Carolina Power

& Light Company is drafting EOPs using the Westinghouse Owner's Groups technical guidelines and INFO's EOP Writing Guideline.

In accordance with Supplement 1 to NUREG-0737, we will submit a procedures generation

package, including plant-specific technical guidelines, and plant-specific 1-2

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writers guide, and description of our program for verification and validation by nine months prior to fuel load.

Upon completion of SPDS, RG-1.97 and CRDR activities, we will complete operator training prior to Fuel Load in June, 1985.

EMERGENCY RESPONSE FACILITIES The EOF and TSC are scheduled to be functional by October, 1984.

In addition, when the Emergency Response Facility Information System (ERFIS) is implemented along with the SPDS in the

EOF, TSC, and Control Room, we anticipate training using these systems will be completed by April 1985.

We anticipate being able to meet NRC requirements listed in Supplement 1 to NUREG-0737 for construction of Emergency Response Facilities with the exception of one item shown on Table 1.

Our EOF is located 2.2 miles from the plant and will meet the same radiation protection criteria as the TSC and control room.

No occupant of the EOF will receive more than 5

REM (or equivalent) during the design basis accident.

In addition, the state and local agencies will not be using our EOF for their State Emergency

Response

Team Headquarters, but have elected to use the State Administration Building in Raleigh, N.C.

Should utility, local, federal or state personnel wishing to travel to the EOF elect not to do so because of radiological protection

reasons, an alternate facility is available at the State Administration Building in Raleigh, 20.6 miles from the plant, for their use in communicating with the TSC and EOF.

As described in the draft NUTAC Guideline on ERFs, we believe that an exception to the Commission's requirement for a backup EOF is

)ustified because:

( 1)

There are no situations whereby evacuation of the primary EOF would be required.

(2)

State and local agencies will not use the primary EOF but will establish reliable communications from their Emergency Center at the State Administration Building.

(3)

Emergency response will be enhanced by remaining in the primary EOF and not by retreating to a backup EOF with less reliable communications, facilities and training.

(4)

An alternate communication facility exists at Raleigh, N.C.

As provided in Paragraph 3.7 of Supplement 1 to NUREG-0737, NRC will make allowances for work already done by licensees in good-faith to meet previous NRC guidance.

We feel that planning and training to remain in the primary EOF is a more reliable and enhanced emergency response

position, and is consistent with the positions of many other licensees that are in a similar situation of having proceeded to construct these close-in facilities in good faith.

Carolina Power 4 Light Company, therefore, requests written confirmation from the Commission that our reasoning is sound and a backup EOF would not enhance our emergency response capability nor those of the federal, state, or local agencies.

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SUBMITTALS TO NRC In summary, CP8L expects to submit the information requested in Supplement 1

to NUREG-0737 for NRC review in accordance with the following=schedule:

Submittal 1.

SPDS Safety Analysis 2.

CRDR Summary Report 3.

RG-1.97 Report 6.2 4.

WOG EOP Technical Guidelines (Generic) 5.

EOP Procedures Gen-eration Package NUREG-0737 Supplement 1

Reference 4.2a 5.2b 7.2a 7.2b Schedule 9/83 Submitted 12/82 (To be supplemented - 6/83) 8/83 Revision 1 (Scheduled for completion August 1983) nine months prior to fuel load (014CSRZ1h-lr) 1-4

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