ML20080G723
| ML20080G723 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/15/1983 |
| From: | Eddleman W EDDLEMAN, W. |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20080G726 | List: |
| References | |
| 82-468-01-OL, 82-468-1-OL, ISSUANCES-OL, NUDOCS 8309200333 | |
| Download: ML20080G723 (2) | |
Text
5 2
00CKETED USNRC UNITED STATES OF AMERICA Septegerf5g 1og NUCLEAR BEGULATORY COMMISSION CFFICE OF SECRtTAi <
00CKETING & SERvtu BEFORE THE ATOMIC SAFETY AND LICENSING BOAED Glenn O. Bright Dr. James H. Carper.ter James L. Kelley, Chairman In the Matter of J
Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
)
50-401 OL (Shearon Harris Nuclear Power Plant,
)
Units 1 ani 2)
)
AStar we. 8a-1468-o1
)
OL Wells Eddlenan's Res,onse to CP&L's Sentember 6 Control Roon (9.G.1.97) filing & Welated Arguments On Sentenber 6, CPEL filed a document (serial TJ.P-83-h05) with the Director of NRC*s Office of Nuclear Reactor Feguint?on a_ddressing (it clains) NUREG-0737 Sunnlenent I requirements.
This document is tentative, e.g. at page 2
it savs that "'if the selection of n
it is determined that thegT;rpe A variables should be ncdified, the table (listing then) will be revised.
Tvne A variables, it says, include some tyne 3,0 and D variables (p.?)
It goes on to sav that SENPP category 2 instrumentation "nay actually neet the recui enents i
L of Category 1 or may neet the intent of the regulatory guide as justified."
l (p.2).
At page 3, it says that some couirment is being upgraded or orocured and some infornation is currently unavailable on the instruments, n85
~
go-Further, "It is anticipated that 'nstrunentation will be innlenented prior to connercial oneration.
If it becomes apparent that such a ngg schedule cannot be net, then the NRC will be notified as to the =evised 00
@Q irmlenentation date."
o-8$
It is apparent fran the above that CP&L in : cill failing to comply with the SPDS human factors analysis requirenenta of 3)SO t
r.
2 00CKETED USNRC UNITED STATES OF AMERICA 1g Septcg' er p5 g j g NUCLEAR REGULATORY COMMISSION CFFICE OF SECREThii s 00CKETING & SERV;rJ BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
Glenn O. Bright Dr. James H. Carpenter James L. Kelley, Chairman In the Matter of
)
Dockets 50 400 OL CAROLINA POWER AND LIGHT CO. et al.
)
50-401 OL (Shearon Harris Nuclear Power Plant,
)
Units 1 and 2)
)
ASLBP No. 82-h68-01
}
OL Wells Eddlenan's Res onse to CP&L's Sentenber 6 Control Roon (9.G.1.97) filing & Melated Argunents On Sentenber 6, CPEL filed a document (serial LAP-83-h05) with the Director of NRC's Office of Nuclear Peactor Regulat' on a_ddressing (it clains) NU9EG-0737 Sunnlenent I requirenents.
This doc ument is tentative, e.g. at page. 2 it savs that "if the selection of n
it is determined that theg Fpe A variables should be nodified, the T
table (listin5 then) will be reviced.
Tyre A variables, it says, include sone tyne B,C and D variables (p.2)
It goes on tv sav that j
SENPP category 2 instrumentation "nay actually neet thn recui=enents of Category 1 or nay neet the intent of die regulatory guide as justified.
(p.2).
At page 3, it says that scne eouirnent is being upgraded or orocured and sene infornation is currently unavailable on the instruments.
nSE
"$1 Further, "It is anticipated that instrunentatien will be innlenented bo 08 prior to connercial oneration.
If it becones apparent that such a ngg schedule cannot be net, then the NRC will be notified as to the "evised 00
@Q inelenentation date."
85 It is apnarent from the above that CP&L is still failing to comply with the SPDS human factors analysis requirements of TSD3
o
, NUREG-0737 $Unplement 1, e.g.
numbers 3 1, 3.he, 3.5 (requiring
" Specific ulans and reasonable, achievable schedules), 3.8 h
O t ?2 E8' ta qm a,b;:c,'d a'nd e and 4.1, k.2 and h.3 re SPDS recuirements,
and integration. bfdh biQb
/( Bdb documentation,SPDS scha.dule'skd be im/rvvd 10 pt asa(nhos o prablev*
a f 2., S 4tts Th@sc $tt additional reasons not to believe Applicants '
clains that they "
will innlenent" the SPDS in accord with hUREG-0737 Revision 1.
The issue I have been raising nost strongly re the SPDS is that the human factors analysis recuirements, and analysis of what should be in the SPDS, have not been connlied with so far by CP&L and there is no Sood reason to believe they will.
Applicants address this issue in a pleading dated 9-9-83 (Resocnse to $ factors re DCRDR) at pages k and 5
- There, they state t hat something nore than just dcubt need be shown re whether Applicants will perform what they say they will.
Applicants ' own record of not keening connitnents is such an additional reason.
Applicants, for exannle, were fined $600,000 by NRC earlier this year for having failed for several years to keep connitments to test the Brunswick plant containments for leak-tight oneration and canability to seal in an accident.
These failures to keen connitnents continued for about 3 years af ter the NRC Staff incuirad about the leak tests in 1979.
This outrageous failure to carry out connitnents to safety is only one of nany such failures by CP2:L.
- See, e.g., testinony of F.S. Cantrell in Harris (Docket 50-400)
CP remand hearing of 1979; numbers of other CP&L fines as detailed in Dr. Wilson's nanagement centention, for failure to follow rules, which CP&L as a nuclear licensee is cornitted to follow.
CP&L's failure to yet nake the connitnent it nronised when I withdrew Contention 152 is another incident that nakes it clear that the SPDS issue (including CP&L's failure to yet conply with ITUREG-0737 Rev. 1 as detailed above) includes real doubts about CP&L's reliability in neeting connitnents.
(END)
_-