ML20042C368
| ML20042C368 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 03/19/1982 |
| From: | Clayton F ALABAMA POWER CO. |
| To: | Goodman M Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0899, RTR-NUREG-899 NUDOCS 8203310300 | |
| Download: ML20042C368 (2) | |
Text
Mdling Address Alabama Power Company 6C0 North 18th Street Post Office Box 2641
\\
Birmingham, Alabama 35291 Telephone 205 783-6081 F. L. Clayton, Jr.
Senior Vice Prendent Alabama Power Fisntndge Building the southem dwinc system March 19, 1982
/C Docket Nos. 50-348 s
50-364 D
p j.y cy 40 Mr. Michael Goodman gp3S O ggg1W" 1
U. S. Nuclear Regulatory Commission a
Of fice of Nuclear Reactor Regulation U
M Division of Human Factors Safety Procedures and Test Review Branch th fg Washington, D. C.
20555 aw-Alabama Power Company Comments on NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures"
Dear Mr. Goodman:
Alabama Power Company has reviewed the draft version of NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures," and would like to provide some comments.
NUREG-0899 is a replacement for NUREG-0799 which we commented on in our letter dated February 8, 1982.
Overall, NUREG-0899 adequately addresses most of Alabama Power Company's comments on NUREG-0799.
Addi-tionally, we believe NUREG-0899 is a significant improvement over NUREG-0799 in giving adequate guidance for preparing Eme. jency Operating Procedures (E0Ps) while at the same time it is not overly prescriptive.
One comment concerns the technical guidelines to be used in preparing the E0Ps.
In Section 5.0 of NUREG-0899, the statement is made that, "For those plants using generic guidelines, the plant-specific technical guidelines will consist of a description of the planned method for developing plant-specific E0Ps from the generic guidelines..."
This is the approach planned by Alabama Power Company and we concur with this approach.
However, in Section 3.3 of NUREG-0899, the statement is made that, " Applicants who have generic guidelines would use these as a basis for plant-specific technical guidelines and E0Ps."
This thought is reinforced by Figure 5.1.
This approach is unacceptable to Alabama Power Company since it involves an unnecessary step of generating a plant specific technical guideline before preparing the E0Ps.
We recommend that throughout NUREG-0899, the idea be consistently presented that if generic technical gcidelines are used, plant-specific technical guidelines are not required; f
I
- f00, 8203310300 820319 h[
PDR NUREG 0899 C PDR
's Mr. Michael' Goodman
. March 19, 1982 Office of Nuclear Reactor Regulation Page 2
-Another comment concerns the use of task analysis in the development of'the E0Ps.
Alabama Power Company plans to conduct.
control room walk-throughs and/or desk top ' reviews of the draf t E0Ps to satisfy the task analysis review requirements.
This approach differs from the guidance given in Section 5.3.3 but accomplishes the goal of. refining the plant-specific EOPs.
It is therefore recommended that the.above alternative approach be i
incorporated in the guidelines.
i INP0 and the four Industry Owner's Groups are currently developing a generic plan for preparing plant-specific E0Ps.
This 3
industry effort will provide a workable plan which will accomplish i
the goal of producing the highest quality E0Ps and meet the applicable NRC requirements.
Since an integrated approach to 1
address all emergency response issues is desirable, a coordinated plan to prepare E0Ps, perform the main control room review, address Regulatory Guide 1.97 and address the Safety Parameter Display System is needed.
It is recommended that this approach be included in the guidelines to allow the most ef ficient use of industry and NRC resources and, at the same time, assure the best possible emergency response capability.
If you have any questions concerning these comments, please 3
contact us.
J Yours very truly, L. Clay
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Mr. R. A. Thomas Mr. E. A. Reeves Mr.-W. H. Bradford j
Mr. Dennis Fadden 1
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