ML20073G594

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Forwards Response to Generic Ltr 82-33 Re Suppl 1 to NUREG-0737, Requirements for Emergency Response Capability
ML20073G594
Person / Time
Site: South Texas  
Issue date: 04/14/1983
From: Goldberg J
HOUSTON LIGHTING & POWER CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-1.D.1, TASK-1.D.2, TASK-2.F.1, TASK-3.A.1.2, TASK-3.A.2.2, TASK-TM GL-82-33, ST-HL-AE-944, NUDOCS 8304180334
Download: ML20073G594 (10)


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The Light mmPuy "e s<e tis ti 8 a

& re-er r.o. 8ex ivoo "e ste. Tex,77ooi <7is> 228.e2ii April 14, 1983 ST-HL-AE-944 File No: G3.8/G9.14 Mr. Darrell G. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, D. C.

20555

Dear Mr. Eisenhut:

South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Response to Supplement 1 to NUREG-0737 -

Requirements for Emergency Response Capability Houston Lighting & Power Company (HL&P) has reviewed your letter of December 17, 1982, entitled, " Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability (Generic Letter No. 82-33)." HL&P has attended an NRC Regional Workshop on this subject, and has additionally reviewed and incorporated in this response the information provided at the workshop.

It has been determined that, given the present status of construction at the South Texas Project, the applicable requirements of the letter to the South Texas Project will be implemented prior to the scheduled fuel load date for Units 1 & 2.

A breakdown of the requirements of the letter applicable to the South Texas Project is provided in the attachment to this letter.

HL&P's proposed response to each requirement is correspondingly indicated in the attachment.

HL&P has determined that a phased integration plan for emergency response activities, as requested in the letter, is unnecessary and inappropriate since all applicable requirements will be implemented prior to the scheduled fuel load date for Units 1 & 2.

Scheduled dates provided are subject to South Texas Project construction progress. HL&P does not anticipate any significant changes to these dates.

Very truly yours, h.

\\

e J. H. Goldberg Vice President Nuclear Engineering and Construction TAP /na h

Attachment 8304180334 830414 PDR ADOCK 05000498 A

PDR

Ifouston Lightina & Power Company April 14, 1983 ST-HL-AE-944 cc:

G. W. Oprea, Jr.

File No: G3.8/G9.14 J. H. Goldberg Page 2 J. G. Dewease J. D. Parsons D. G. Barker M. R. Wisenburg R. A. Frazar J. W. Williams R. J. Maroni J. E. Geiger H. A. Walker S. M. Dew J. T.-Collins (NRC)

H. E. Schierling (NRC)

W. M. Hill, Jr.

(NRC)

M. D. Schwarz (Baker &Botts)

R. Gordon Gooch (Baker & Botts)

J. R. Newman (Lowenstein, Newman, Reis, & Axelrad)

STP RMS Director, Office of Inspection & Enforcement Nuclear Regulatory Commission Washington, D. C.

20555

~G. W. Muench/R. L. Range Charles Bechhoefer, Esquire Central Power & Light Company Chairman, Atomic Safety & Licensing Board P. - 0. Box 2121 U. S. Nuclear Regulatory Commission Corpus Christi, Texas 78403 Washington, D. C.

20555 H. L. Peterson/G. Pokorny Dr. James C. Lamb, III City of Austin 313 Woodhaven Road P. O. Box 1088 Chapel Hill, North Carolina 27514 l

Austin, Texas 78767 J. B. Poston/A. vonRosenberg Mr. Ernest E. Hill City Public Service Board Lawrence Livermore Laboratory P. O. Box 1771 University of California San Antonio, Texas 78296 P. O. Box 808, L-46 Livermore, California 94550 Brian E. Berwick, Esquire William S. Jordan, III l

Assistant Attorney General Hannon & Weiss i

for the State of Texas 1725 I Street, N. W.

P. O. Box 12548 Suite 506 Capitol Station Washington, D. C.

20006 Austin, Texas 78711 l

Lanny Sinkin Citizens for Equitable Utilities, Inc.

Citizens Concerned About Nuclear Power c/o Ms. Peggy Buchorn l

5106 Casa Oro Route 1, Box 1684 San Antonio, Texas 78233 Brazoria, Texas 77422 Jay Gutierrez, Esquire Hearing Attorney Office of the Executive Legal Director U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Revision Date 12-20-82

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter s

s Houston Lighting & Power 9

Docket Nos. 50-498 Company, et al.,

s 50-499 6

South Texas Project 5

Units 1 and 2 5

AFFIDAVIT J. H. Goldberg being duly sworn, hereby deposes and says that he is Vice President, Nuclear Engineering and Construction of Houston Lighting &

Power Company; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached " Response to Supplement 1 to NUREG-0737 -

Requirements for Emergency Response Capability"; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge and belief.

d

'J. H. Goldberg Vice President Nuclear Engineering nd Construction STATE OF TEXAS S

5 COUNTY OF HARRIS %

Subscribed and sworn to before me, a Notary Public in and for Harris County, Texas this 14th day of April

, 1983.

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Page 1 of 7 Identified Requirements'of Supplement-1 to NUREG-0737 Applicable to the South Texas Project Units 1 & 2-Docket Nos. STN 50-498, STN 50-499 Parameter Display System (SPDS)

Safety (NUREG-0737,ItemI.D.2) t' 1.

Current Status of aPDS Design:-

The South Texas Project SPDS will be incorporated in the Emergency Response Facilities Data Acquisition and Display System. The SPDS will provide a concise display of critical plant variables identified as Type B.

Variables during the analysis performed to respond to Regulatory Guide 1.97, Revision 2.

The system conceptual design and a preliminary data base have been established, and a specification is currently being prepared for system procurement. SPDS displays will be located on the operator's console in 2

the control room, and in the Technical Support Center and the Emergency Operations Facility.

Date for Submittal of Safety February 1985.

It is expected this Analysis and Verification information will be submitted in the Validation Plan:

form of an FSAR amendment.

SPDS Implementation Schedule:

SPDS design completed - June 1984.

SPDS installed - February 1986, SPDS operational - June 1986.

i Operators fully trained on SPDS -

December 1986.

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Pre-Implementation Review:

Pre-Implementation Review by NRC is not considered necessary. Normal review of FSAR amendment of February 1985 is expected.

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Page 2 of 7 2.

Detailed Contro'l Room Design Review (DCRDR)

(NUREG-0737, Item I.D.1)

Current Status of DCRDR:

A detailed Control Room Design Review (CRDR) is being performed by Torrey

~ Pin'es Technology for Houston Lighting &

Power Company with Bechtel Energy Corporation acting as agent. The CRDR Program Plan was reviewed at a meeting with the NRC on October 5, 1982. On October 20, 1982, the CRDR Program Plan was submitted to the NRC.

The CRDR, combined with modifications to meet Regulatory Guide 1.97, Revision 2, and engineering design evolution has resulted in the re-layout of six of the main control room panels and various modifications to the remaining control room panels. An Implementation Plan Report (interim report) summarizing the CRDR, the proposed control room design changes, and the proposed methods of implementing the design changes has been prepared and was submitted to the NRC on April 7, 1983.

Verification and validation of the revised control room design will occur after design changes are completed and Regulatory Guide 1.97 upgrades are implemented. The CRDR Summary Report will then be issued to summarize the CRDR results, final control room I

l changes, conclusions and recommenda-tions. Technical details concerning the CRDR Summary Report will be found l

in the Criteria Report, the Operating l

Experience Review Report, the System Function and Task Analysis Report, the Control Room Survey Report, the Annunciator Report, and the Special l

Studies Report.

Date for Submittal of Program Plan:

October 20, 1982.

(The Program Plan has already been submitted.)

Date for Submittal of Implementa-April 7, 1983.

(The Implementation tion Plan Report with Proposed Plan Report has already been sub-Control Room Design Changes:

mitted.) NOTE: NRC review of Imple-l mentation Plan Report and in-progress l

audit of control room mock-up (in May l

1983) has been requested in this

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April 7, 1983 submittal.

e Page 3 of 7 Date for Submittal of Final October 1983.

Summary: Report with Final Control Room Design Changes:

Implementation Schedule for Control room design completed - September Control Room Changes:

1983.

Control' panels fabrication completed -

March 1984.

Control panels installation complete -

December 1985.

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Page 4 of 7 3.

Regulatory Guide 1.97, Revision 2 and Meteorological Data -

Ap lication to Emergency Response Facilities NUREG-0737, Items II.F.1 and.III.A.2.2)

Current Status of Regulatory Guide An analysis based on the Westinghouse 1.97, Revision 2 and Meteorological-general design basis was conducted to Data Programs:

develop a plant specific response to the intent of Regulatory Guide 1.97, Revision 2.

This analysis identified the appropriate variables and estab-lished appropriate design bases and qualification criteria for instrumenta-tion utilized by the control room operator during and following an accident. The upgrades identified are being incorporated into the individual systems and control room designs in a manner to support the South Texas Project construction schedule. A table of post-accident monitoring variables and the plant specific design basis ~

will be incorporated into the FSAR.

Implementation Schedule for FSAR amendment - August 1984.

Regulatory Guide 1.97, Revision 2:

Regulatory Guide 1.97, Revision 2 implementation - December 1986.

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Page 5 of 7 4.

Emergency Operating. Procedures (E0Ps)

-(NUREG-0737, Item I.C.1)

-Status of E0P Development:

The South Texas Project-EOPs are being developed utilizing the Westinghouse Generic' Guidelines. 'The E0Ps are scheduled to be completed in mid-1985 1-to allow for sufficient time for training prior to fuel load.

Submittal Date for Technical November 30, 1981. This information Guidelines:

was submitted by Westinghouse.

Submittal Date for Procedures June 1985.

_ Generation Package:

j Date to Begin Formal Operator October 1985.

Training:

Implementation Date of E0Ps:

December 1986.

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Page 6 of 7 5.

Integrated Training Plan

-Status of Training Plan:

Operator training at the. South Texas Project will include among other areas, training in the normal and post-accident use, system response, and design basis of the SPDS and instrument displays based on Regulatory Guide 1.97, Revision 2; the CRDR; the functions and capabilities of the Emergency Response Facilities; and the use of the Emergency Operating _

Procedures. Trainee performance will be evaluated during classroom and on-the-job training. The operator training program will be revised as on-the-job evaluations indicate the necessity. The operator training program is based on the program objective of developing operator ability to comprehend plant conditions and to cope with emergencies effectively.

Date for Completion of Training The Operator Training Plan completed -

Plan:

August 1985.

Operator training completed - December 1986.

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Page 7 of 7

-6.

Emergency Response Facilities (ERFs)

- -(NUREG-0737,ItemIII.A.1.2)

Status of ERFs:

The Technical Support Center (TSC) is presently under construction. The.

Operational Support Center (OSC) will

-be located in the Administration Building which has been completed.

Specific OSC facility requirements are currently under development. The Emergency Operations Facility (E0F) is currently being developed. Construc-tion of the E0F is planned to begin in the second half-1983.

Completion Dates for Fully The TSC, OSC and E0F will be fully Functional TSC, OSC and EOF:

functional by December 1986.

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