ML20093D670
| ML20093D670 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/08/1984 |
| From: | Ridgway D CAROLINA POWER & LIGHT CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20093D652 | List: |
| References | |
| OL, NUDOCS 8410110334 | |
| Download: ML20093D670 (4) | |
Text
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October 8, 1984 DOCKETED USNRC UNITED STATES.OF AMERICA NUCLEAR REGULATORY COMMISSION 14 GH 10 A11:10 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFICE OF EClt :te 00CKETitiu & SEPv:ci BRANCH-In the Matter of
)
)
CAROLINA POWER AND LIGHT COMPANY
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and NORTH CAROLINA EASTERN
)
Docket No. 50-400 OL MUNICIPAL' POWER AGENCY
)
)
- (Shearon Harris Nuclear Power
)
Plant)
)
APPLICANTS STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE
' ISSUE TO BE HEARD ON EDDLEMAN-144 Pursuant to 10 C.F.R.
S.2.749(a), Applicants state, in support of their Motion For Summary Disposition of
'Eddleman-144, that there is no genuine issue.to be heard withLrespect to the following material facts:
1.
Plans for the construction of Harris Unit 2 have been' cancelled.- Black Affidavit, f 3.
22.
Applicants' on-shift staffing and augmentation for emergencies for the remaining unit of the Harris plant were documented in-Tables 2.2-1 and 2.2-2 of revisions 0 and 1 of the onsite plan.
Black Affidavit, 1 4.
3.
SAs set forth in revisions 0 and 1 of the onsite plan, the information in these tables was not in the same format as Table 2 of NUREG-0737, Supplement 1 (which is
' identical, with the exception of a typographical error, to Table B-1 of NUREG-0654.)
Black Affidavit, f 4.
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i4. LIn the'" Safety Evaluation Report Related to The Op-eration'of SHNPP Units-1 & 2," NUREG-0138 (November 1983),
-the NRC Staff recommended that Tables 2.2-1 and 2.2-2 of the onsite plan be revised to be more ' compatible with Table B-1 of NUREG-0654.
Black Affidavit, 1 5.
- 5.. In~ Revision 2 of the onsite plan (February 1984),
~
Tables 2.2-l'and 2.2-2 (of revisions 0 and 1) were revised
_ to be substantially the same as'the format of Table B-1, by incorporating'both-tables into a new Table 2.2-1, as re-quested by the NRC: Staff.
Black Affidavit, 1 6.
6.
~ Table 2.2-1, "On-shift Staffing for Emergencies,"
is now nearly identical to Table B-1 of NUREG-0654.
The main difference is that instead of listing augmentation times of exactly 30.and 60 minutes for two categories of personnel, CP&L lists times of 30-45 minutes and 60-75
-minutes, to allowLfor variations in time of arrival due to weather conditions.
Black Affidavit, 1 6.
7.
-The December 17, 1982 letter from the Nuclear Regu-
~1atory Commission transmitting NUREG-0737, Supplement 1, ex-
- pressly noted that'"the staffing-levels in table 2 * *
- are
- only goals and not strict requirements."
Black Affidavit, $[
6.
3 8.
A-second' minor difference between NUREG-0654, Table B-1 and the table now included in the Harris' onsite plan is that,-while Table B-1 lists generic titles for personnel, i;
CP&L has substituted the specific position titles used at I
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.a the Harris plant for personnel with the identified job func-tion cn: expertise.
Black Affidavit, 1 7.
9.
A typographical error was made when Table B-1 of NUREG-0654 was transferred to NUREG-0737, Supplement 1.
Table B-1 correctly indicates that only two persons are needed with the position title or expertise in Electrical Maintenance / Instrument and Control Technician in the 30-minute column under the Major Task " Repair and Corrective Actions."
As indicated in Table 2.2-1 of the onsite plan, CP&L meets this regulatory standard.
Black Affidavit, 1 8.
10.
CP&L's routine non-emergency on shift staffing in-cludes a minimum of at least~one mechanical maintenance per-son and at least one radvaste operator.
Table B-1 only
~
identifies the need.for one person on shift in the category of Mechanical Maintenance /Radwaste Operator, and identifies personnel augmentation requirements as one additional me-chanical maintenance person and an additional radwaste oper-ator after 60 minutes.
In an emergency, CP&L would bring in,_if not already onsite, additional mechanical maintenance personnel (rather than one maintenance person and one radwaste operator), as identified by Table 2.2-1 of the onsite plan, because the major emergency task would be re-pair.
Since CP&L has radwaste expertise on shift, and therefore already onsite, CP&L meets or exceeds the regula-tory guidance in this area.
Black Affidavit, 1 9.
'a 11.
Fire brigado and security staffing are identified in Table 2.2-1 of the onsite plan by reference to other con-trolling documents, exactly as indicated in Table B-1 of NUREG-0654 (Table 2 of NUREG-0737, Supplement 1).
The total number of personnel reflected in Table 2.2-1 for the emer-gency organization for on shift, 30-45 minutes, and 60-75 minutes meets or exceeds the provisons of Table B-1.
Black Affidavit, 1 10.
12.
The NRC Staff has reviewed Applicants' Table 2.2-1, as revised, and has approved it.
Black Affidavit, 1 11.
Respectfully submitted, M
Thomas' A. Baxt5r, P.CV G
Delissa A. Ridgway SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 and Richard E.
Jones Samantha F.
Flynn Dale E.
Hollar Hill Carrow CAROLINA POWER & LIGHT COMPANY P.O.
Box 1551 Raleigh, North Carolina 27602 (919) 836-7707 Counsel for Applicants Dated: October 8, 1984
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