ML20093D676
| ML20093D676 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 10/08/1984 |
| From: | Black R CAROLINA POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20093D652 | List: |
| References | |
| OL, NUDOCS 8410110336 | |
| Download: ML20093D676 (9) | |
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October 8,.1984
-DOCKETED U9tRC UNITED STATES-OF AMERICA NUCLEAR. REGULATORY COMMISSION
'84 00T 10 A11:10 BEFORE THE ATOMIC SAFETY AND' LICENSING BOARD In the. Matter of
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CAROLINA POWER'& LIGHT COMPANY
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-and NORTH CAROLINA EASTERN
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Docket No. 50-400 OL MUNICIPAL. POWER AGENCY
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(Shearon1 Harris Nuclear Power
)
Plant)
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AFFIDAVIT OF ROBERT G.
BLACK, JR. ON EDDLEMAN-144 County of Wake
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ss.
State of North Carolina
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~ ROBERT-G.' BLACK, JR.,
being duly sworn, deposes and
-says:
' l'.
'I am the Director.
Emergency Preparedness for Ap-plicant, Carolina Power & Light Company.
In my professional capacity, I have been personally in-4 volved in the development of the onsite emergency plan and procedures for the Harris plant for the past three and a
. half years.- Further,,I have attended numerous industrial symposiums, am active in r' elated professional associations, and have participated.in~ numerous emergency exercises at op-erating nuclear olants.
A current statement of my profes-
-sional qualifications and experience is attached hereto.
My 8410110336 841008 PDR ADOCK 05000400 G
, ~. _. _. _.. _. _.. _ _ _ _, _ -
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~ business address is Carolina Power & Light Company, P.O.
Box 1551, Raleigh,-North Carolina 27602.
I have personal knowl-edge of the matters stated herein and believe them to be true and correct.
I make this affidavit in response to Eddleman Contention 144.
2.- -The purpose of this affidavit is to demonstrate the compliance of Table 2.2-1 of revisior and 3 of the Harris onsite emergency plan with the Commission's emergency plan-ning-regulations and applicable guidance.
3.
Eddleman Contention 144 asserts that CP&L's emer-gency personnel levels do not meet the requirements of Table 2 of NUREG-0737, Supplement 1.
More specifically, Mr.
Eddleman-has asserted that "[t]he staffing levels shown in the FSAR are insufficient to meet the requirements {identi-fied by footnote 1 to Table 2] for one damaged and one undamaged unit."
At the time this contention was admitted, Applicants were constructing a sister unit to the Harris plant, -tx) be designated Harris Unit 2.
However, by letter dated December 21, 1983, Applicants have advised the Commis-sion that plans for the construction of Harris Unit 2 have been canceled.
See December 21, 1983 Letter, E.
E.
- Utley, Carolina Power & Light Company, to Director, Office of Nu-clear Reactor Regulation, NRC.
Any concerns about the ade-
- quacy of overall plant staffing in the event of an emergency at one unit of a multi-unit plant are therefore no longer relevant. u.m i
4.
Applicants' on-shift staffing and augmentation for emergencies for the remaining unit of the Harris plant were set forth in Tables 2.2-1 and 2.2-2 of 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, with'the exception of a typographical error, is identical to Table B-1 of NUREG-0654).
5..
In the " Safety Evaluation Report related to the op-
-eration of SHNPP Units 1 &
2," NUREG-1038 (November 1983).
The NRC stated:
The On-shift emergency staff and the augmented Emergency staff appear to comply with guidelines of Table B-1 of the planning standard (i.e.
NUREG-0654], but contain ambiguities that interfere with proper review of the plan * * *
- Tables 2.2-1 and 2.2-2 should be revised to be more compatible with Table B-1 of NUREG-0654.
See NUREG-1038, S 13.3.2.2 ("On-site Emergency Organization")
(emphasis supplied).
6.
In Revision 2 of the onsite plan (February 1984), CP&L revised Table 2.2-1 and 2.2-2 (of revisions 0 and 1) to be sub-stantially the same as the format of Table B-1, as requested by the NRC Staff, by incorporating both tables into a new Table 2.2-1.
' Table 2.2-1, "On-shift Staffing for Emergencies," is now nearly identical to-Table B-1 of NUREG-0654 (Table 2 to Supplement 1 of NUREG-0737).- The main difference is that t.
instead of listing augmentation times of exactly 30 minutes and 60 minutes for two categories of personnel to respond, CP&L lists times of 30-45 minutes and 60-75 minutes to allow for variations in time of arrival'due to weather conditions.
The December 17, 1982 letter transmitting NUREG-0737, Supplement 1 expressly contemplates such accomodations:
You should * *
- note that the staffing levels in table 2 * *-* are only goals and not~ strict requirements.
See. December 17, 1982 Letter, Director, Division of Licensing, Office of Nuclear Reactor Regulation, to All Licensees of Op-erating Reactors, Applicants For Operating Licenses, and Hold-ers of Construction Permits, Re: Supplement to NUREG-0737 --
Requirements.For Emergency Response Capability (Generic Letter No. 82-33).
7.
A second minor difference between the table included in NUREG-0654 and Supplement 1 to NUREG-0737, and the table now included in the Harris onsite plan is that, while the regulato-ry guidanca lists generic titles for personnel, CP&L has sub-stituted the specific position titles used at the Harris plant for personnel with~the identified job function or expertise.
18.
A typographical error was made in Table 2 of NUREG-0737, Supplement 1, when the table was transferred from NUREG-0654.
Thus, although Table 2 erroneously suggests that three persons are required in the 30-minute column under the Major Task'" Repair and Corrective Actions," Table B-1 of -.
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I fNUREG-0654 correctly indicates that only two persons are needed with the position title or expertise in Electrical Mainte-nance / Instrument and Control (I&C) Technician.
In Table 2.2-1 of the onsite plan, item 5
(" Plant Engineering, Repair and Cor-rfective Actions"), CP&L lists two Electrical /I&C maintenance personnel in the 30-45. minute column.
This satisfies the regu-
.latory standard.
9.
Under the Major Task " Repair ano Corrective Actions,"
Table B-1 of'NUREG-0654 provides for one person on shift with the position title or expertise of Mechanical Mainte-
- nance /Radwaste Operator.
The. table further indicates a re-quirement of one mechanical maintenance person and one radwaste operator at 60 minutes.
CP&L's routine non-emergency on shift staffing includes a. minimum of at least one mechanical mainte-nance person and at least one radwaste operator.
Thus, the P
Table B-1 requirement for one radwaste operator onsite at 60 minutes.will be met by normal on-shift staffing levels.
In an emergency, CP&L would bring in, if not already onsite, addi-tional mechanical maintenance personnel (rather than one main-tenance person and one radwaste operator), as identified by Table 2.2-1 of the onsite plan, since the major emergency task would be repair.
CP&L thus meets or exceeds the regulatory guidance in this area.
CP&L has also committed to a minimum on shift complement'of 10, which meets the provisions of Table B-1. >
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Fire brigade and security staffing are identified in s
Table 2.2-1.of'the.onsite plan be reference to other control-ling 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 emergency organiza-tion for on shift, 30-45 minutes, and 60-75 minutes meets or
-exceeds the provisions of Table B-l.
}
11..
Since issuance of revision 2 of the onsite plan, the
. NRC Staff'has issued Supplement No. 1.to NUREG-1038, " Safety Evaluation Report" (June 1984), addressing-existing open items.
E Under-Section-13.3.~2.2: "On-site-Emergency-Organization," three open items were addressed.-
In relation to item 2, the NRC-l Staff stated:
'The Applicant has revised Tables 2.2-1 and 2.2-2 to correspond with Table B-1 of NUREG-0654 so that they E;"
specify the' minimum On-shift-
. staffing available for emergencies and the capabil-ity for augmentation in 30 to 45 minutes with addition-al augmentation in 60 to 75 minutes.
The variations in times-of arrival are deter-
. mined by weather conditions.
The minimum staffing and augmentation of the emergen-cy staff' follow the w
guidelines of.NUREG-0654 and Supplement 1 of NUREG-0737 and are' adequate.
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- In' relation to'the'three open items discussed in the section the NRC Staff concluded:
The staff finds the appli-cants response to the above three issues is satisfactory and the staff's concerns have been fully resolved.
.1:2.
In summary, I am confident that Table 2.2-1 of the Harris onsite emergency plan complies with Table 2 of NUREG-0737, Supplement 1 (Table B-1 of NUREG-0654).
The NRC Staff concurs in this assessment.
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Robert'G.'Blackpr3r.
Jav Sworn to and subscribed before me this day of October, 1984.
M Notary Public
?
e My Commission expires:
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. ROBERT G. BLACK, JR.
DIRECTOR - EMERGENCY PREPAREDNESS
. CAROLINA POWER & LIGHT COMPANY i
. EDUCATION AND TRAINING:
B.S. Degree in Industrial Engineering Georgia Institute of Technology (1965) 4 Attended various schools while in the U.S. Navy Completed EIT Registered Professional Engineer - February 1979
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PROPESSIONAL SOCIETIES:
American Nuclear Society J
Professional Engineers of North Carolina EXPERIENCE:
-June 1969 to June 1973 -
U.S. Navy Nuclear Program September 1973 -
' Senior Engineer Environmental & Technical Services Section Special Services Department CP&L Raleigh, N.C.
January 1976 to June 1976 -
Project Engineer Licensing & Technological Services Section Special Services Department CP&L Raleigh,-N.C.
June 1976 to December 1979 -
Project Engineer Nuclear Licensing Unit Licensing & Siting Section Technical Services Department CP&L
- Raleigh, N.C.
1
December 1979 to March 1981 -
Project Engineer Nuclear Licensing Unit Licensing & Permits Section Technical Services Department CP&L Raleigh, N.C.
March 1981 to August 1983 -
Director Emergency Preparedness Technical Services Department General Office Raleigh,.N.C.
August 1983 to Present -
Director Emergency Preparedness Operations Training and Technical Services Department General Office Raleigh, N.C.
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