ML20093D701

Affidavit of RG Black on Eddleman Contention 154.Prof Qualifications & One Oversize Map Encl

ML20093D701
Person / Time
Site:	Harris
Issue date:	10/08/1984
From:	Black R CAROLINA POWER & LIGHT CO.
To:
Shared Package
ML20093D652	List: ML20093D650 ML20093D656 ML20093D662 ML20093D670 ML20093D676 ML20093D692 ML20093D696 ML20093D701
References
OL, NUDOCS 8410110343
Download: ML20093D701 (9)

Text

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• EM BN 10 A11:10 NUC R RE RY C ON ,ey,y ,y c~ .

PPIE 'INC f SEf"J:' f T

BEFORE THE ATOMIC SAFETY AND LICENSING- BOARDRANN In'the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

and NORTH CAROLINA. EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris' Nuclear Power )

Plant)' )

AFFIDAVIT OF' ROBERT G. BLACK, JR.

ON EDDLEMAN-154 County of Wake )

) ss.

State of. North Carolina ')

ROBERT G. BLACK, JR., being duly sworn, deposes and '

says:

.l. I'am.the Director..- Emergency Preparedness for Applicant, Carolina Power & Light Company.

In my. professional capacity, I have been personally in-volved in the development of the onsita 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 related professional associations, and have participated in numerous emergency exercises at op-erating nuclear plants. A current statement of my profes-sional qualifications and experience is attached hereto. My 3410110343 84100s PDR ADOCK 05000400 0 PDR w - .- = _ _ _ _ _ _ _ _ _ _ - - _ _ - . _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ - - . _ _ . _ - . _ _ _ _ _ _ - - _ - _ _ - _ _ _ _ _ - _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _

h 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 154,

2. The purpose of this affidavit is to explain that Annex B of the onsite emergency plan is not a procsdure for use.by operators performing dose projections. Operators performing dose projection calculations use step-by-step proced'ure s , which have been written to require no detailed

. operator judgment.

3. . Annex B of the onsite emergency plan explains the technical basis for the dose projection calculation methods;

-.it is not itself a procedure.for use by operators performing .

dose projections. Annex B describes the theory behind the algorithm which provides.the Pasis for the dose projection procedures which are used by operators assigned to perform dose projections.

4. The dose projection procedures for use by opera-tors at the Harris plant -- like those in use at other op-erating nuclear plants across the nation -- are written to require no detailed operator judgment.

5. NUREG-0654 provides for the classification of emergencies into one of four classes: Unusual Event, Alert, Site Area Emergency, or General Emergency. The classifica-tion is implemented through Emergency Action Levels

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("EALs"), which are sets of plant conditions and events as-sociated with one of the four emergency classes. The Site Emergency Coordinator (or the Shift Foreman when no emergen-

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cy has yet been declared) will declare the appropriate emer-gency class where EALs have been exceeded, or where the sta-tus'of the plant otherwise warrants such a declaration. ,

6. By definition in NUREG-0654, the only emergency class with significant off-site radiological. consequences (i.e. " Releases that can be reasonably expected to exceed EPA Protective Action Guideline exposure levels off-site for more than the immediate site area") is the General Emergen-cy. See NUREG-0654 (Rev. 1), at p. 1-16.

7. In Revision 2 of the Emergency. Plan (Fcbruary 1984) Figure.4.5-1, " Protective Action. Recommendations

Flowchart," was added based upon the recommendations of NRC I & E Information Notice 83-28 (May 4, 1983), and was re-viaed in Revision 3 of the onsite plan. This flow chart provides the protective actions to recommend to off-site au-thorities during a General Emergency based upon plant condi-tions as determined by EALs. No dose projection calcula-tions are necessary to make the initial recommendations.

8. After the initial recommendations are made, dose projection calculations are performed to determine if the scope of the initial protective actions should be increased.

9. Dose projection calculations may be performed by different methods. The first and primary means is by a program-inithe Emergency Response Facility Information Sys-

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Jtem ("ERFIS") computer which is linked with the meteorologi-i

,calvsystem and-the-radiation monitoring system. This pro-gram obtains the-required.information from memory, storage or. associated systems and performs the required calcula-

'tions. " Suspect", "off scale", and " bad" data is identified by the computer internally, without operator input. For ex-ample, the computer will identify a parameter as a " suspect" or " bad" parameter-if several redundant outputs don't agree 1within a close-tolerance. These " quality tags" are thus de-termined internally by the computer based upon comparison with a predetermined set of values or ranges. No operator

-judgment is necessary.

10. As a back-up,-a dose projection calculation can-be .

performed with a pocket calculator. A step-by-step

" cookbook" method is outlined in a detailed procedure. See

" Plant Emergency Procedures for SENPP" (Plant Operating Man .

ual, Volume 2, Book 5) (provided to the parties under cover letter to the NRC dated September 12, 1984), at PEP-341,

" Manual Dose Calculation." Data is recorded on a calcula-tion sheet provided as par *. of the procedure. Although some de isions are required by the user (as in most procedures),

the procedure prompts the user and assists in making the de-cisions.

11. Regardless of whether the dose projection calcula-tions are performed using the ERFIS computer or manually,

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using a1 pocket calculator, determination of the composition

.of the source terms uses default values (based upon the

'FSAR) in the absence of a sample, and thereby eliminates the need for operator judgment. The default values for ra-dionuclide mix are referenced in Annex B, page B-2. Source term activity levels are measured; if the computer " quality tags" the measurement as " bad", samples can be taken and/or direct measurements can be made using portable instruments.

All of this is called for in the procedures.

12. All personnel who may be assigned to perform dose projections receive training in the' methods used to perform those projections. This training includes working sample

. problems. The operators must demonstrate a satisfactory un-derstanding of the steps of the dose projection procedures, and provide correct answers to the problems using the proce-dures.

-13. Prior to the exercise, a number of practice drills will be conducted requiring satisfactory performance of dose projection by the operators. The'dore projection perfor-mance is evaluated by controller / evaluators knowledgeable in the subject (health physics, dose projection instructor, or emergency preparedness background plus training in the dose projection and training as a controller / evaluator).

. 14. One practice drill for the pre-licensing exercise will be a rehearsal drill in which a complete scenario will be used including release data, dose projection data, and

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complete message sheets. The rehearsal drill will be con-ducted like aus exercise, using~ controller /evcluators. Dose projections performed by the shift operators will be com-pared against the correct answers included in the drill sce-nario.

15. Prior to operation above 5% power, a pre-licensing full-scale exercise will be conducted, which will once again test the shift operators'-dose projection capabilities. The full-scale exercise will be observed and scored by federal evaluators. -

16. Controller / evaluators for the drills and the full-scale exercise will rate the " player's" performance as

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excellent,' satisfactory, or unsatisfactory (defined in Sec-tion 5.11 of PEP-406, " Performance of Exercises and ,

Drills"). Any unsatisfactory rating due to poor performance of a player will result in retraining of the individual so rated.

17. In sections 13.3.2.14 and 13.3.2.15 of Supplement 1 to NUREG-1038, the " Safety Evaluation Report t

Related To The Operation of SHNPP Units 1 & 2" (June 1984),

the NRC Staff approved the description of Applicants' drills and exercises policy and the emergency plan training pro-gram, as contained in the onsite plan.

18. In summary, Annex B of the onsite emergency plan is not a dose projection procedure. For General Emergencies, operators use Figure 4.5-1 of the onsite plan

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to make initial protective action recommendations based upon plant conditions; dose projection calculations are not re-quired. After the initial recommendation is made, operators use' step-by-step. dose projection procedures, which have been written to involve no detailed operator judgment, to project doses. All personnel 'So may be assigned to perform dose projection calculations receive training in the dose projec-t> ion procedures, and have their knowledge tested through practice problems, drills and exercises. Thus, Eddleman Contention 154 lacks merit.

/

Robert G. Black, Jr.

Sworn to and subscribed before me this day of October, 1984. '

oY.f r e n ~

'-Notary Public My Commission Expire:s: g b

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• l ROBERT G. BLACK, JR.

DIRECTOR - EMERGENCY PREPAREDNESS CAROLINA POWER & LIGHT COMPANY EDUCATION AND TRAINING:

B.S. Degree in Industrial Engineering Georgia Institute of fechnology (1965)

Attended various schcols'while in the U.S. Navy Ccmpleted EIT

-Registered Professional Engineer - February 1979 PROFESSIONAL SOCIETIES:

American Nuclear Society 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 -

t Project Engineer Nuclear Licensing Unit ,

Licensing & Siting Section J Technical Services Department CP&L j Raleigh, N.C.

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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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