ML20093D670

Statement of Matl Facts as to Which There Is No Genuine Issue Re Eddleman Contention 144

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: ML20093D650 ML20093D656 ML20093D662 ML20093D670 ML20093D676 ML20093D692 ML20093D696 ML20093D701
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 )

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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~: l 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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...,..,_v., ,--,ev,-,,,.-.,,_,,_,,-.-.,.~~,-r-. .,--..,_c

.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.

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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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