ML20214N346

Advises That Util Takes Exception to Any Item Listed on 870403 Draft Rev 3 to IE Insp Procedure 82412, Emergency Response Facilities Appraisal, That Requires plant-specific Data Input to Emergency Operations Facility

ML20214N346
Person / Time
Site:	Farley
Issue date:	05/21/1987
From:	Mcdonald R ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-NUREG-0737, RTR-NUREG-737 NT-87-0185, NT-87-185, NUDOCS 8706020144
Download: ML20214N346 (2)

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I Alabuna Pcwer Company 600 North 18th Street :

' Post Office Box 2641 Birmingham. Alabama 35291-0400 1-Telephone 205 2501835 M"*c',';Lon,-

AlabamaPower J

the southem electrc system May 21, 1987 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washingtoni D. C. 20555

. Gentlemen:

Alahnma Power Company received from the Nuclear _ Regulatory Commission (NRC) on April 3, 1987 a transmittal of the draft IE Inspection Procedure 82412, entitled " Emergency Response Facilities Appraisal," Rev. 3.

We cover letter from David M. Verrelli stated that the procedure will be used to verify that our Baergency Response Facilities (ERFs) " meet the requirements of 10 CFR 50.47(b), Appendix E of 10 CFR Part 50 and orders and license conditions issued to Supplement 1 to NUREG -0737." Within this procedure are check list items that will be used by NRC inspectors to verify that the ERFs comply with the requirements referenced above.

W ere are certain items listed in the IE' Inspection Procedure that appear to be inconsistent with the requirements. Alabama Power Company takes exception to any item that requires plant specific data input to the

. Emergency Operations Facility (EOF) other.than " radiological and meteorological data and containment conditions necessary to determine protective measures [ emphasis added)," and tiecessary to allow the EOF -

to "be used to evaluate the magnitude and effects of actual or potential radioactive releases from the plant and to determine dose projections."

h is EOF requirement is stated in paragraph 8.4.l(a) of Supplement 1 to NUREG-0737.

I.E. Inspection Procedure 82412 makes reference in paragraphs 3.2.1.3.b through 3.2.1.3.f to a large number of plant parameters -

associated with the EOF determining the integrity, operability, capacity-and/or extent of damage to various systems independently from the control Room or TSC staff. Paragraphs 3.2.4.1.b through 3.2.4.1.d under Reactor Technical Support reference data analysis of specific parameters related to reactor status, display of parameters for easily determining deviations

'from normal and data analysis in a manner easily related to EAL criteria.

We mandated availability and analysis of such data is not consistent with the EOF functions described in Supplement 1 to NUREG-0737 and it would be inappropriate to expand EOF responsiblities to include independent evaluation of parameters other than meteorological data, effluent radiological data and containment radiological conditions.

3 gemy 3

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o U. S. Nuclear Regulatory Commission May 21, 1987 Page 2 The TSC by design is assigned the task of following and evaluating plant operational status and making operational decisions.

Individual parameters and what they reflect regarding plant conditions can be effectively assessed only in the overall context of on-going operating evolutions and other information such as instrument in-service /out-of-service status, other plant monitors, severe environment effects influencing instrument accuracy, measurements from test equipment, physical damage assessments, and other subtle contextual information.

This is possible only in the control room and the TSC, due to its close proximity to the control room. As a practical matter, data available at the EOF for monitoring or evaluating system integrity, status, operability or off-normal condition would necessarily be incomplete as it relates to total plant accident status. Making total plant status available at the EOF is simply impractical. Any set of data selected for predesignated independent EOF evaluation would have to be supplemented by additional information, further burdening TSC and/or control room personnel during an emergency.

Alabama Power Company feels that the duties of the EOF and TSC should remain focused on their respective missions by personnel who are trained and qualified to perform the respective missions without the distractions that would be caused by inputs of superfluous data.

If information regarding system integrity is required by the EOF, the TSC should be contacted to provide the best analysis available.

If the TSC desires specific data beyond effluent radiological data, meteorological data and containment radiological data to be trended or analyzed, the EOF should be contacted, provided with the data and specifically requested to provide the desired support.

In conclusion, Alabama Power Company believes that the EOF only requires verbal comunication links with the TSC for information other than radiological, meteorological and specific containment radiological data.

Any additional specific data is not needed to " determine protective measures" and, moreover, could distract from a focused, timely and appropriate emergency response.

Please advise if you have any questions concerning th request.

Yours ve

,truly, l l

/

R. P. Mcdonald RPtyFMJ:emb xc: Mr. David M. Verrelli Mr. K. W. McCracken File A29.13.2.7