ML18004A526

Provides Responses to NRC Request for Specific Actions Re Emergency Operating Procedures,Per 860918 Telcon

ML18004A526
Person / Time
Site:	Harris
Issue date:	09/19/1986
From:	Zimmerman S CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
NLS-86-364, NUDOCS 8609290348
Download: ML18004A526 (8)

Text

REGULA Y INFORMATION DISTRIBUTIQ SYSTEl't (R IDS)

ACCESS I QN NBR: 8609290348 DOC. DATE: 86/09'/19 NOTARIZED:

NO DOCKET ¹ FACIL: 50-400 Sheav on Harv is Nucleav Power Plant.

Unit t> Carolina 05000400 AUTH. NANE 'UTHOR AFFILIATION ZINl~iERNANIS. R.

Cav olina Powev'c Light Co.

RECIP. NANE RECIPIENT AFFILIATION DENTQN> H. R.

Office of Nucleav'eactor Regulation~

Divectov

<post. 85f125

SUBJECT:

Provides responses to NRC request for specific actions re emergency opev ating pv oceduresi pev 860918 telcon.

DISTRIBVTIDN CODE:

A0030 CDPIES RECEIVED: LTR I

ENCL'.

SIZE:

TITLE: QR/Licensing Submittal:

Supp l 1 to NUREG-0737(Generic Ltr 82-33)

NOTES:Application for permit renewal filed.

I 05000400 REClr IENT ID CODE/NAl'lE PWR-* ADTS PWR-A EICSB PWR-A PD2 LA BUCKLEY. B PWR-A RSB INTERNAL: ADN/LFNB NRR BWR ADTS NRR PWR-B ADTS B

REG FX EXTERNAL: 'LPDR NSIC COPIES LTTR ENCL 2

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RECIPIENT ID CODE/NANE PWR-A EB PWR-A FOB PWR-A PD2 PD PWR-A PSB IE/DEPER/EPB NRR PAULSON> W NRR/DSRQ ENRIT NRR/DSRO/RSIB RGN2 NRC PDR COPIES LTTR ENCL TOTAL NUNBER OF COPIES REQUIRED:

LTTR 3l ENCL

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SERIAL:

NLS-86-364 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 SHEARON HARRIS NUCLEAR POWER PLANT UNIT NO.

1 - DOCKET NO. 50-400 EMERGENCY OPERATING PROCEDURES

Dear Mr. Denton:

Carolina Power

& Light Company (CPGL) hereby replies to specific actions requested by your staff in a conference call on September 18, 1986 concerning the Shearon Harris Nuclear Power Plant (SHNPP)

Emergency Operating Procedures (EOPs) as follows:

NRC RE UEST Provide commitment to develop expanded deviations document consistent with description in Standard Review Plan Section 13.5.2 (Appendix A.3.3.2).

CPijrL RESPONSE Carolina Power 6 Light Company will revise the Step Deviation Document in accordance with the guidance provided in Standard Review Plan (NUREG-0800) Section 13.5.2 and Appendix A.3.3.2 to that Section.

These revisions will be completed with the next update of the Step Deviation Document which is scheduled to be complete prior to the end of the first refueling outage.

NRC REQUEST Provide answers to NRC questions regarding training program by October 1,

1986.

CPSL

RESPONSE

As stated in our Letter No. NLS-86-318, dated August 29,

1986, CPGL will provide responses to NRC's audit comments concerning the training program by October 1,

1986.

8b09290348 8b0919 l

PDR ADOCK OS000400 P

PDR 411 Fayettevilte Street

~ P. O. Box 1551

~ Raleigh, N. C. 27602

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Mr. Harold R.

D ton NLS-86-364 NRC RE VEST Provide commitment to support staff's confirmatory review of "significant" items, i.e.,

as human factors review is done, EOPs should be provided for NRC to do parallel review.

Need EOPs now and results of review as they come in.

CP&L RESPONSE Carolina Power

& Light Company is providing to your staff, under separate

cover, a complete copy of the SHNPP EOPs.

In addition, CP&L will provide your staff with any "significant" items resulting from the human factors review of the EOPs as they are received by CP&L from our consultant.

NRC RE VEST Provide commitment to correct and implement EOPs completely by six months after commercial operation or justification for extended schedule.

CP&L RESPONSE Carolina Power

& Light Company's August 29, 1986 letter (NLS-86-318) identified a program which included training and implementation of the revised EOPs by February 1988.

This date was based on the approximate date for the first refueling outage for SHNPP and anticipation that the Mestinghouse (hmers'roup would issue revised guidelines in 1987 which should be included in the EOP revisions.

There are several strong bases for delaying the training and implementation until the end of the first refueling outage.

First, the program for revising the EOPs may result in a change to every EOP. It would be disruptive and counterproductive to implement the changes in the middle of a fuel cycle.

The training should precede the implementation of the EOPs, and it would take approximately two training cycles (12 calendar weeks) to familiarize each shift with the revisions in classroom training and conduct simulator training.

During a refueling outage,

however, fewer operators are required on shift and the calendar time could be compressed.

Secondly, if simulator training is conducted during normal plant operations, the whole shift may not receive simulator training simultaneously resulting in only part of the shift being aware of the revisions.

Thirdly, the change would coincide with a major plant evolution and it would be easier for the operators to remember that the changes go into effect after the refueling rather than a particular calendar date.

It is CP&L's position that it is more prudent to conduct training during the outage and, therefore, we commit to completing training on and implementation of the revised EOPs by the end of the first refueling outage.

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I Mr. Harold R.

ton NLS-86-364 If you have any questions on this information, please contact me at (919) 836-6242.

Yours very truly, JDK/ccrc (5001JDK)

S R.

Z erman nager Nuclear Licensing Section cc:

Mr. B. C. Buckley (NRC)

Mr. Brent Clayton (NRC-DPLA)

Mr. G. F. Maxwell (NRC-SHNPP)

Dr. J. Nelson Grace (NRC-RII)

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