ML20073P189
| ML20073P189 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/15/1983 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 3F-0483-12, 3F-483-12, GL-82-33, TAC-51153, NUDOCS 8304250058 | |
| Download: ML20073P189 (9) | |
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Power CORPORA 7 Oes April 15,1983 3F-0483-12 Director of Nuclear Reactor Regulation Att mtion: Mr. Darrell G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Generic Letter 82-33, Supplement 1 to NUREG-0737 Requirements for Emergency Response Capability
Dear Sir:
Florida Power Corporation (FPC) has received and reviewed the subject letter. As required, FPC is furnishing a proposed schedule for completing each of the basic requirements for the items identified in the enclosure to the subject letter. In addition, a description of our plans for phased implementation and integration of the emergency response activities is being submitted as requested.
While FPC is committed to implementing the requirements of the subject letter, there are several programmatic philosophies that must be understood to fully recognize the intent of the management of FPC in that implementation. First, the schedule being proposed is a long range schedule of approximately five (5) years. Due to pressures and influences beyond our control, we realistically expect this schedule to change over that period of time. Therefore, FPC is committed to implement that part of the enclosed schedule from April 15,1983, to April 15,1984. At that time and annually thereafter, we will revisit the schedule as it has unfolded and make future schedular commitments as necessary.
Secondly, this schedule has not been developed with a narrow view of only these regulatory requirements. Over the next year, the requirements to be implemented have been determined to be schedularly feasible in conjunction with other regulatory requirements. In the long term, the schedule must be coordinated with known regulatory requirements (e.g., remote shutdown panel, Emergency Feedwater Initiation and Control system, and inadequate Core Cooling Instrumentation) and with regulatory requirements that are not presently known. This represents another need to revisit the proposed schedule in the future.
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8304250058 830415 PDR ADOCK 05000302 t
F PDR General Office 3201 Thirty-fourtn street soutn. P O. Box 14042, st. Petersburg. Ronda 33733 813-866-5151
'3F-0483-12 Page 2 FPC is proposing that some requirements be implemented in parallel. Specifically, the Detailed Control Room Design Review will be started in the near term. The Emergency Operating Procedures (EOP's) will be implemented within a year. It is not necessary to wait for this implementation as the EOP's are ' revised when plant modifications are implemented.
Finally, the FPC training program is an integral part of the Nuclear Operations modification system. As with the EOP's, training takes place when any modification is implemented during the normal operator requalification program. Therefore, training is listed for each item and one separate but fully integrated training program for the
- requirements for emergency response capability is neither proposed nor necessary.
Attachment I to the letter presents a cross-reference table between the NUREG-0737 Items and the Supplement 1 -to NUREG-0737 Items. Attachment 2 is a tabular schedule inr each item in Supplement I to NUREG-0737. Attachment 3 is a line schedule for each item in the subject letter broken down into the phrases of each item and with the specific requirement for each item listed in the appropriate phase. Attachment 3 also contains the estimated refueling schedules for Crystal River Unit 3 as well as the annual schedule
- revisit in April of each year.
Sincerely, G. R. Westafer Manager Nuclear Licensing and Fuel Management Attachments RMB:mm
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STATE OF FLORIDA COUNTY OF PINELLAS G. R. Westafer states that he is the Manager, Nuclear Licensing and Fuel Management, of Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.
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- A G. R. Wes~tafer '
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Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 15th day of April,1983.
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Notary Public Notary Public, State of Florida at Large, TAbPUSUC STATE OF FLOR!DA' C
8CNDED m UNNERAL INSURANCE E Fiq5 ngy g91986 My Commission Expires: November 19,1986 h%
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NUREG-0737 Supplement I to Subject Item NUREG-0737 Item Guidance for the Evaluation and Development I.C.1 7.1 of Procedures for Transient and Accidents Control Room Design Reviews I.D.1 5.1 Plant Safety Parameter Display Console I.D.2 4.1, 6.1.b Upgrade Emergency Support Facilities II.A.I.2 6.1.c, 6.1.d,'
8.2, 8.3,' 8.4 Meteorological Data III.A.2.2 6.1.b 1
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1 Tabular Schedule for NUREG-0737 Supplement 1 Revision 0, April 15,1983 Item Number
Response
Activity Number 4.1.a The general requirements for SPDS listed in this paragraph will be 932 incorporated at FPC by the engineering documents used to procure and install our system. There is no reportable milestone for this activity.
4.1.b Same as 4.1.a 932 4.1.c Same as 4.1.a 932 4.1.d Same as 4.1.a 932 4.1.e Same as 4.1.a 932 4.1.f Same as 4.1.a 932 4.2.a The written safety analysis for the SPDS shall be prepared during 932
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f the Engineering Phase of the project and shall be submitted by the end of the 3rd Quarter of 1984.
4.2.b Appropriate Technical Specification change request will be sub-936 mitted at least 90 days prior to the completion of installation.
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4.3 SPDS design shall be used as an input to the assessment phase of 932,914 the DCRDR. The design shall also be considered as an input to and 922 l
revision of the EOP's for use after implementation.
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5.1.a The objective of the control room design review will be utilized 910 in the FPC plan scheduled to be completed in the 3rd Quarter of 1983.
5.1.b FPC will conduct a control room design review. This is scheduled 912 to be completed during the 2nd Quarter of 1984.
5.1.c.
FPC will assess which engineering discrepancies are significant 914 and should be corrected. This is scheduled to be completed during the 1st Quarter of 1985.
5.1.d FPC will verify that each selected design improvement will provide 914 the necessary correction and can be safety introduced into the control room. This is scheduled to be completed during the 1st Quarter of 1985.
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.. Item Number.
- Response.
Activity Number
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FPC will submit a program plan within two (2) months after the
-912 5.2.a.
start of the Review.1 This is scheduled for the 4th Quarter of 1983.
J5.2.b FPC will submit a summary report of the completed review.-
914 This is scheduled for the.2nd Quarter of 1985.
916 and 5.2.g :
. FPC will g begin the control room upgrade until the staff has issued an SER and FPC has addressed any open items. This 922 is scheduled to begin in the 3rd Quarter of 1985. ~
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6.1.a The requirements of Regulatory Guide 1.97 will be considered 950 and during the Compliance Study and Systems Study Phase of this 952 i-project. There is no reportable milestone for these activities-dictated by this item.
6.1.b l FPC will provide the report listed in Item 6.2 to satisfy the.
952 requirements of this paragraph.
t 952 6.1.c
' Same as 6.1.b 932 6.1.d
'Same as 6.1.b 6.2 :
FPC shall submit a report satisfying the specifications of this para-952 graph and showing FPC's position on all items in Regulatory Guide 1.97 in the 3rd Quarter of 1984.
7.1.a FPC is committed to using human factored, function oriented EOP's.
Complete i
7.1.b FPC has prepared Technical Guidelines.
Complete 7.1.c -
FPC is currently writing the upgraded EOP's consistent with the 920 Technical Guidelines and the Procedures Generation Package pre-l viously submitted to the NRC. Activity completion scheduled for the end of the 3rd Quarter of 1983.
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7.1.d Training on the upgraded EOP's is scheduled to be completed during 920 the 1st Quarter of 1984.
920 7.1.e
. Implementation scheduled for the end of the 1st Quarter of 1984.
.7.2.a FPC has submitted Technical Guidelines Complete 7.2.b FPC has submitted the Procedures Generation Package Complete 8.2.1.a The general requirements for the TSC have been included in the Complete
' design of the TSC.
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Response
Activity Number.
8.2.I'.b The location requNement'of the TSC has been included in the Complete design of the TSC.
8.2.1.c The accommodations requirement of the TSC has been included in the Complete
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design of the TSC.
8.2.1.d The TSC was structurally built in accordance with the Uniform -
Complete Building Code.
8.2.1.e
. The controlled environment requirement of the TSC has been included Complete '
in the design of the TSC.
8.2.1.f The radiological protection and monitoring equipment requirement Complete has been included in the design of the TSC.
8.2.1.g The communications requirement for the TSC has been included in the Complete design of the TSC.
8.2.1.h
. The data requirement for the TSC has been included in the design 964 of the TSC. The data display equipment is scheduled to be completed in the 1st Quarter of 1984.
8.2.1.1 The records requirement for the TSC has been included in the design Complete of the TSC.
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= The staffing requirement for the TSC has been included in the design Complete of the TSC.
8.2.1.k The human factors engineering principle requirement for the TSC has Complete been included in the design of the TSC.
8.3.1.a The general requirements for the OSC have been included in the Complete design of the OSC.
8.3.1.b The location requirement for the OSC has been included in the Complete design of the OSC.
8.3.1.c The communication requirement for the OSC has been included in the Complete design of the OSC.
.8.4.1.a The general requirements for the EOF have been included in the Complete design of the EOF.
8.4.1.b The location requirement for the EOF has been included in the Complete design of the EOF..
8.4.1.c The accommodation requirement for the EOF has been included in the Complete
' design of the EOF.
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- Attachment 3' Item Number
Response
Activity Number'
-8.4'l.d The EOF was' structurally built in accordance with the Uniform Complete Building Code. -
8.4.1.e The controlled environment requirement for the EOF has been Complete included in the design of the EOF.
8.4.1.f.
The communications requirement for the EOF has been included 960 in the design of the EOF. This is scheduled to be completed in the 3rd Quarter of 1983.
8.4.1.g The data requirement for the EOF has been included in the 964 of the EOF. This is scheduled to be completed in the 1st Quarter of 1984J 8.4.1.h The records requirement for the EOF has been included in the -
' Complete design of the EOF.
t 8.4.1.i '
The staffing requirement for the EOF has been included in the Complete design of the EOF.
8.4.1.) ~
. The security requirement for the EOF has been included in the Complete design of the EOF.
8.4.1.k The human factors engineering principles requirement for the EOF Complete has been included in the design of the EOF.
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