ML20080N482

Forwards Summary of Design Stds & Criteria for Technical Support Ctr Encompassing Human Factors Engineering, Per Eddleman Proposed Contention 157.Contention Should Be Rejected.Related Correspondence

ML20080N482
Person / Time
Site:	Harris
Issue date:	02/17/1984
From:	Hollar D CAROLINA POWER & LIGHT CO.
To:	Bright G, Carpenter J, Kelley J Atomic Safety and Licensing Board Panel
Shared Package
ML20080N488	List: ML20080N482 ML20080N494
References
ISSUANCES-OL, NUDOCS 8402220267
Download: ML20080N482 (2)

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COCKETED Carolina Power & Light Company "

POST OFHCE BOX 1551 Raleigh, North Carolina 27602 04 8 21 All :31 IEGAL DEPARTMENT

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Writer's Direct Dial Number February 17, 1984 (919)s36.8161 Telecopier (919) 8M 7678 James L. Kelley, Esq. Mr. Glenn O. Bright Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing Board U. S. Nuclear Regulatory Comm.

U. S. Nuclear Regulatory Comm. 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. 20555 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 and 50-401 OL Administrative Judges Kelley, Bright and Carpenter:

In accordance with counsel for Applicants' letter to the Board dated January 31, 1984, enclosed is a document describing generally the consideration given to good human factors engineering principles in the design of the SHNPP Technical Support Center ("TSC") , which is the subject of Mr. Eddleman's proposed Contention 157. Addition-al information regarding human factors engineering considerations is contained in the materials referenced in this document. ,

While Applicants have prepared the enclosed documentation pursuant to the request of the Board, Applicants are constrained to note that NUREG-0737, Supplement 1 does not require the submittal of any documentation of the consideration given to human factors engineering in the design of a TSC. Applicants have recently con-firmed their understanding on this matter with the NRC Staff._*/

Accordingly, Applicants reiterate that proposed Contention 157--

premised, as it is, on the Harris onsite emergency plan--is wholly lacking in basis. See " Applicants' Response To Eddleman Proposed Contentions on Harris Emergency Plan" (July 11, 1983), at 29-30.

In support of his contention that Applicants had not designed the 8402220267 840217 PDR ADOCK 05000400

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4 Administrative Judges Kelley, Bright and Carpenter February 17, 1984, Page Two TSC in accord with good human factors engineering principles, Mr. Eddleman argued only that the Harris plan "does not mention human factors engineering with respect to TSC" and does not otherwise indicate that human factors engineering principles have been considered in the design of the TSC. To the contrary, as Applicants pointed out, section 3.3.1 of the plan (" Technical Support Center (TSC) --

Characteristics") expressly provides that the TSC has been "[d]esigned taking into account good human factors engineering principles." P oposed Contention 157 should therefore be rejected.

Respectfully submitted, b b-Dale E. Hollar DEH:ew Associate General Counsel cc: Service List attached

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The Board may have been led to believe otherwise by the Staff's recommendation, in its response to proposed Contention 157, that the contention be deferred pending submittal to the NRC of Applicants' " human engineering documents." Compare " Memorandum and Order (Ruling on Wells Eddleman's Proposed On-Site Emergency Planning Contentions)" (November 1, 1983), at 6, with "NRC Staf f Response To Wells Eddleman's Contentions Dated May 2, 1983 Pertaining To Applicants' On-Site Emergency Plan" (July 11, 198 3) ,

at 6-7.

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