ML20093D676

Affidavit of RG Black on Eddleman Contention 144.Prof Qualifications Encl

ML20093D676
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 8410110336
Download: ML20093D676 (9)

Text

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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 )

)

CAROLINA POWER'& LIGHT COMPANY )

-and NORTH CAROLINA EASTERN ) Docket No. 50-400 OL '

MUNICIPAL. POWER AGENCY )

~

)

(Shearon1 Harris Nuclear Power )

~

Plant) )

AFFIDAVIT OF ROBERT G.

BLACK, JR. ON EDDLEMAN-144 County of Wake )

) ss.

State of North Carolina )

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

-says:

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

4 In my professional capacity, I have been personally in-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 PDR

_ _ . _ . . -_ - -. ._ . _ , ~ . _ . _ . _ . . _ . _ . . _ _ _ _ , _ - _ _ _ . . _ _ _ .

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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.

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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

-m I

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.

en.w--- w- -.y g -,,-%w- --g + .g-r+ea.-p *g.i---9 ^W' 7"'f * - * ~ "**"

' - *' '10. 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- -

w cy staff' follow the 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 ,

l 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.

Sworn to and subscribed before me this Javday of October, ,

1984.

M .

Notary Public

?

e My Commission expires: , g,g 4

- , - - - - , - , . - - , - - - - , , - - , - - - - - , - - - --m.< - - - ,

. ROBERT G. BLACK, JR.

DIRECTOR - EMERGENCY PREPAREDNESS

. CAROLINA POWER & LIGHT COMPANY i

. EDUCATION AND TRAINING:

B.S. Degree in Industrial Engineering 4

Georgia Institute of Technology (1965)

Attended various schools while in the U.S. Navy Completed EIT Registered Professional Engineer - February 1979 ~

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

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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