ML20073L634
| ML20073L634 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/19/1983 |
| From: | Oneill J CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, ISSUANCES-OL, NUDOCS 8304210194 | |
| Download: ML20073L634 (10) | |
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- arov anserreto ese o E werTER S DenECT DaAL NutoGER (202) 822-1090 April 19, 1983 a
James L.
Kelley, Esquire Mr. Glenn O.
Bright l
Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Dr. James H. Carpenter Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
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In the Matter of Carolina Power & Light Company and North Carolina Eastern Municipal Power Agency (Shearon Harris Nuclear Power Plant, Units 1 and 2)
Docket Nos. 50-400 OL and 50-401 OL l
Administrative Judges Kelley, Bright and Carpenter:
i Please find enclosed a copy of Applicants' schedule for implementation of the requirements of Generic Letter 82-33, Sup-plement 1 to NUREG-0737, Requirements for Emergency Response Capa-bility, which was filed with the Director, Office of Nuclear Reactor Regulation, on April 15, 1983.
Copies of the enclosed schedule were also filed with intervenors in the above referenced proceeding on April 15, 1983.
8304210194 830419 PDR ADOCK 05000400 i
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SHAw, PITTMAN. PoTTs & TROWBRIDGE A PamTNERSoup Or peOFES$eONAL CompOR ATIONS Administrative Judges James L.
Kelley, Esq.
Mr. Glenn O.
Bright Dr. James H. Carpenter April 19, 1983 Page Two At the prehearing conference held on February 24, 1983, Applicants proposed that the Board defer ruling on certain con-tentions filed by Intervenor Dr. Richard Wilson and Intervenor Wells Eddleman on the Detailed Control Room Design Review ("DCRDR")
pending Applicants' filing the enclosed schedule for implementation of the requirements of Supplement 1 to NUREG-0737.
At the time of the prehearing conference, Applicants intended on April 15, 1983 to odo more than submit a schedule for implementing the requirements of Supplement 1 to NUREG-0737, i.e.
to' supplement the Summary DCRDR l Report previously submitted to the NRC Staff on December 7, 1982.
Applicants suggested that after reviewing the additional information provided on April 15, 1983, the intervenors might be in a position to revise, amend, or withdraw certain contentions which simply allege deficiencies in the Summary DCRDR Report.' The Board adopted Applicants' proposal, deferring its rulings on Dr. Wilson and Mr. Eddleman's Con-tentions, and providing that the Intervenors would have thirty days from receipt of Applicants' April 15, 1983 filing within which to revise, amend or renew contentions regarding the detailed control room design review.
Tr. 589-605.
Applicants now intend to file a complete supplement to the 4 Summary DCRDR Report on or before' June 1, 1983.
In light of this t
schedule, Applicants; determined that it would be_ inefficient to partially supplement'th'e Summary DCRDR Report with the enclosed April 15, 1983 filing, with a second and final supplement to be filed on or before June 1,*1983.
Counsel for Applicants have discussed thi schedule with both Mr. Eddleman and Dr. Wilson and have their concur-rence in proposing to the:Poard that the schedule for submitting re-vised, amanded or renewed contentions on the DCRDR be deferred until thirty days from receipt of Applicants' supplement to the Summary DCRDR Report.
Thereafter Applicants and the Staff would be afforded fifteen days in which to respond to any pleadings filed by intervenors and the DCRDR issue would be before thesBoard for decision.
Re bectful/y su mitte John \\H. O'Neill, Jr.
Couns'el for Applicants I()
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1 ggem Con Carolina Pow r & Light Company April 15, 1983 OClfffj50 33 p?R 20 NO 52 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission
- Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER !. ANT UNIT NOS. 1 AND 2 DOCKET NOS. 50-400 AND 50-401
'NRC GENERIC LETTER 82-33 REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY
Dear Mr. Denton:
On December 30, 1982 Carolina Power & Light Co=pany (CP&L) received Generic Letter 82-33, Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability. As a participating member of the Nuclear Utility Task Action Committee on Emergency Response Capabilities (ERC NUTAC), which includes over forty utilities and is administrative 1y supported by INPO, CP&L 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, CP&L 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 Integrated Implementation 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' Group (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
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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 Project Manager to explain in more detail, our integrated implementation plan as described in Attachment 1.
Yours very truly, Original Signed By E. E. UTLEY E. E. Utley Executive Vice President Power Supply and Engineering & Construction EEU/SRZ/lr (014CSRZh)
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 kndwledge or based upon information and belief.
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Y Notary (Seal My Commission Expires: 5[/t/g3 cc:
Mr. N. Prasad Kadambi (NRC)
Mr. Wells Eddleman Mr. G. F. Maxwell (NRC-SHNPP)
Dr. Phyllis Lotchin Mr. J. P. O'Reilly (NRC-RII)
Ms. Patricia T. Newman Mr. Travis Payne (KUDZU)
Mr. John D. Runkle Mr. Daniel F. Read (CHANGE /ELP)
Dr. Richard D. Wilson Chapel Hill Public Library Mr. G. O. Bright (ASLB)
Wake County Public Library Dr. J. H. Ctrpenter (ASLB)
Mr. J. L. Kelley (ASLB)
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ATTACHMENT 1 PLANS AND SCHEDULES FOR EMERGENCY RESPONSE CAPABILITIES l
l 1-1
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 analfsis 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 Shearon 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 E0P'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 sympt'em-based E0P'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 E0Ps using the Westinghouse Owner's Groups technical guidelines and INP0's E0P 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 L
s writers guide, and description of 'our program for verification and validation by nine months prior to fuel load.i 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.
Ohould 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 justified 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 & 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.
s 1-3
e SUBMITTALS TO NRC In summary, CP&L expects to submit the inforcation requested in Supplement 1 to NUREG-0737 for NRC-review in accordance with the following schedule:
NUREG-0737 Supplement 1 Submittal Reference Schedule 1.
SPDS Safety Analysis 4.2a 9/83 2.
CRDR Summary Report 5.2b Submitted 12/82 (To be supplemented - 6/83) 3 RG-1.97 Report 6.2 8/83 4.
WOG EOP Technical 7.2a Revision 1 (Scheduled Guidelines (Generic) for completion August 1983) 5.
E0P Procedures Gen-7.2b-nine months prior eration Package to fuel load 1
(014CSRZ1h-Ir) 1-4
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UNITED STATES.OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD' In the Matter of 20 90 52 CAROLINA POWER & LIGHT COMPANY
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Docket Nos. 50-400 OL AND NORTH CAROLINA EASTERN
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50-401 OL MUNICIPAL POWER AGENCY
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s, adt8
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(Shearon Harris Nuclear Power
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Plant, Units 1 and 2)
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SERVICE LIST James L. Kelley, Esquire John D. Runkle, Esquire Atanic Safety arri Licensing Board Conservation Council of North Carolina U.S. Nuclear Regulatory Ccmnission 307 Granville Road Washington, D.C.
20555 Chapel Hill, North Carolina 27514 Mr. Glenn O. Bright M. Travis Payne, Esquire Atanic Safety and Licensing Board Edelstein and Payne U.S. Nuclear Regulatory Carmission P.O. Box 12643 Washington, D.C.
20555 Raleigh, North Carolina 27605 Dr. Richard D. Wilson Dr. James H. Carpenter Atanic Safety and Licensing Board 729 R W Street U.S. Nuclear Regulatory remniesion Apex, North Carolina 27502 Washington, D.C.
20555 Mr. Wells FM1eman Charles A. Barth, Esquire 718-A Izedell Street Myron Kannan, Esquire Durhan, North Carolina 27705 Office of Executive Iagal Director U.S. Nuclear Regulatory Ccmnission Ms. Pa M cia T. Newman Washington, D.C.
20555 Mr. Slater E. Neanan Citizens Against Nuclear Power Docketing ard Service Section 2309 Weynouth Court Office of the Secretary Raleigh, North Carolina 27612 U.S. Nuclear Regulatory Ccmnission Washington, D.C.
20555 Richard E. Jones, Esquire Vice President & Senior Counsel Mr. Daniel F. Read, President Carolina Power & Light Ccnpany Chapel Hill Anti-Nuclear Group Effort P.O. Box 1551 P.O. Box 524 Raleigh, North Carolina 27602 Chapel Hill, North Carclina 27514 Dr. Phyllis Lotchin 108 Bridle Run Giapel Hill, North Carolina 27514
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Cercrah Greenblatt, Esgs4*e 1634 Crest Ecad Paleigh, Scd Carolina 27606
?xadley W. Jcms, Esg'ive U.S. Nuclear Regulatory O w iesion Begica II 101 MaTietta Street Atlanta, Gec gia 30303 Ruthanne G.. Miller, Esquire Atcmic Safety and Licensing Board Panel U.S. Nuclear Regulatory Cemnimsicn I W m, D.C.
20555 Karen E.
Long, Esq.
Staff Attorney Public Staff - NCUC P.O.
Box 991 Raleigh, North Carolina 27602 O
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