ML20073S199
| ML20073S199 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 05/02/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| 82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8305060485 | |
| Download: ML20073S199 (4) | |
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UNITED STATES OF AMERICA
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD t
Glenn O. Bri Dr. James H.ght y
Carpenter James L. Kelley, Chairman In the Matter of
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Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
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50-401 OL (Shearon Harris Nuclear Power Plant,
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Units 1 ani 2)
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OL Wells Eddleman 's Contentions re CP&L Site Emergency Plan (SHNPP Operating Manual, Volume ;, Book 1)
I received this plan 3-31-83 Thus today is the last day to file contentions based on it (h-30 being a Saturday).
I have. twice contacted Hill Carron, counsel for CP&L, and he advises me there will be no major changes to this plan when CP&L provides its June 1, 1963 update referred to in John O8Neill's recent letter to the Board.
CONTENTIONS
("the plan" or "SEP" )
150.
The Site Emergency Plan does nothing to address the concerns expressed in deferred Eddleman contentions 2, 29 (deferred part) 30 (deffrred part), 55, 57, 63, 97, 99,100,117,118 or 124 BASIS:
The plan does not refer to any of the concerns listed in these contentions.
151.
The plan does not provide the medical personnel available to treat personnel injured onsite, required by NUP.E8-0737 Rev. 1, p. 17, re 10cFR 50 Appendix E, item 5 BASIS:
Annex A thereto omits this i nformation.
8305060485 830502 7
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-2 152.
The SEP fails to comply with NU9EG-0737, Rev. 1, n. 18
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item (d) which requires communications to NRC from control room, TSC and F0F to be tested monthly.
BASIS: no provision in the SEP, see page 5-5.
153 The SEP does not provide sufficient communication in the PABX event of the failure of the plant RRX telephone system.
BASIS:
The backup power to radio fixed systems is not identified, nor specified; batteries for battery-powered radio systems are not required to be tested or replaced on any schedule.
See page 3-7.
154 Plant operators are assigned to make the dose assessments (see Table 2.2 3, page 2).
These personnel are unqualified to make the detailed judgments that may be required by the procedures for dose estimating, given in Annex B of the SFP.
BASIS:
Annex B says the health physics staff should do the job.
But they are not designadated to do it initially.
The connlexity of judgment required in Annex B sneaks f or itself -- it is beyond the trahing, as far as the SEP establishes, of ordinary reactor enerators.
Moreover, there are no educational or other reouirenents for onerators that assure they will exercise good judgment in dealing with th? s complex task under the pressure of accident conditions, especially in accidents that proceed rapidly to general emerEency status.
155. the SEP fails to specify or provide the EFFIS requ'_ red by EU"rG-0737, **v.
1, on 19-20, for the TSC.
BASIS:
All it says (p. 3-7) is that the ERFIS "will be provided".
l There are no specifications or guarantees that the FDFIS provided will meet the requirements of NUREG-0737, Rev.1, e.g. iten (h) nn 19-20 that the ERFIS provide necessary meteorological and reg. guide 1.97 info.
156. The SEP fails to comply with item (1) of NUEEG-0737, Rev. 1, p.20, which requires connlete plant drawings and diagrams and records in the TSC.
Theses are not mentioned in SEP Table 3 1-1 and not
. specified as being complete and available IN the TSC, as recuired, ar.y place in the SEP.
BASIS: Included above.
157 The SFP does not comply with iten (k) of NUDEG-0737, Fev.1,
- p. 20 which requires the TSC to be designed in accord with Eood human factors engineering.
BASIS:
The SEP does not menticn.
human f actors engineering wi th resueet to the TSC and gives no analysis to show that any human factors engineering in the "SC is any Food.
158.
The ECF and TSC radiation protection is inadeouste to connly with the requirement of NUREG-0737 Rev.1 that exposure be held below 5 rem in each of these locations for the duration of an accident.
BASIS: Per pages 3-2 and 3-b of the SEP, the protection of these areas will hold exposure below 5 rem only for a design basis accident.
Accidents beyond design basis do happen, and have, e.g.
at TMI-2, a reactor of almost exactly the same power as Harris 1.
Thus, Harris should provide ability to hold personnel exnosure in the EOF and TSC below $ ren for an accident beyond design basis, at least as severe as the release from TMI-2, during its entire duration, i.e.
well into April '79, while releases still were gof ng on from TMI-2.
159.
The ECF fails to ecmoly with iten (h) p. 22 of NPDEG-0737 Rev.1 in that diagrans and infornatirn ccenlete and up te date as required thereof is not mentioned in Table 3.111 for the ErF and not established elsewhere in the SEP.
BASIS: included abcve.
160.
The initial wad later assignments of emergency personnel from the Harris plant staff in the SEP fail to a ssure that these personnel are qualified for those a ssignments.
BASIS:
Table 2.2-3 of the SEP desi nates, for example, the E
benior specialist-Electrical to run the OSC, and multi-media trained personnel to run the fire brigade.
Noth$ ng but a bald statement says that these peonle will be trained.
No plan of training, no qualification requirements, no recuirenent of when
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-h-these personnel have received training or how well they did in it or how recently they have been tra$ned or re-trcined, is mentioned in the SEP.
STATE?ENT MlY THESE CONTENTI0l!S COULD NOT HAVE BEEN MAD 9 EADLIE9 CP&L had not made this site energency plan available until 3-31-83 Intervenors are not required to fornulate snecific contentions on documents they have not yet seen.
Further, I could not have predicted CP&L's failures in 'this nlan based on the PSAR or ER or other available infornation 5-11$-82 when conteations were due in this proceeding.
CESTIFICATP OF Sm VICT:
This has been served by first class mail May 2, 1983 to:
Judges Jates Kelley, Glenn Bright and James Carpenter (1 copy each)
Atomic Safety and Licensirg Board US Nuclear Regulatory Commission Washington DC 20555 GeorEe F. Trowbridge (attorney for Anplicants)
Shaw, Pittman, Potts & Trowbridge R uthanne G. Miller 1600 M St. NW ASLB Panel Washington, DC 20036 USNRC Washington DC 2C65 5 Office of the Executive Legal Directer Phyllis Lotchin, Ph.D.
Attn Docke ts 50-400/401 0.L.
106 Bridle Run Washington DC 20555 NC 2751h USNRC Chanel Hill i
I Dan Read Docketing and Service Section CHANGE /FLP Attn Docke ts 50-h00/h01 0.L.
Box 52h l
Office of the Secretary Chapel Hill NC 2751h USNRC Washington DC 20555 Pat & Slater Newnan CAUP John Runkle Karen E. Long 2309 Weynouth Court i
Ralei h NC 27612 CCNC Public Staff Atty S
307 Granville Rd Box 991 Chapel Hill Ne 2751h Raleigh, NC 27602 Bradley W. Jones USNRC Region II
~Travi s Payne 101 Marietta St.
Edelstein & Payne Atlanta GA 30303 Box 126E3 Raleigh NC 27605 Richard Wilson, M.D.
Certified by h
729 Hunter St.
Apex NC 27502