B15372, Provides Response to Requests for Submittal of Plans & Schedule for Emergency Operating Procedures Upgrade Program Insp Rept 50-336/95-21

Provides Response to Requests for Submittal of Plans & Schedule for Emergency Operating Procedures Upgrade Program Insp Rept 50-336/95-21

ML20092L790
Person / Time
Site:	Millstone
Issue date:	09/21/1995
From:	Debarba E, Opeka J NORTHEAST NUCLEAR ENERGY CO., NORTHEAST UTILITIES
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
B15372, NUDOCS 9509280187
Download: ML20092L790 (15)

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" 107 Selden Street, Berlin, CT 06037 ggg Utilities System .wtheot utaitie, se,*e coing.ny P.o Box 270 Ilartford, CT 06141-0270 (203) 665-5000 September 21, 1995 Docket No. 50-336 B15372 Re: IR 50-336/95-21 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Millstone Nuclear Power Station, Unit No. 2 Reply to a Request for Submittal of Plans and Schedule for Emergency Operating Procedures Upgrade Program Insoection Reoort 50-336/95-21 In a letter dated August 10, 1995,(" the NRC Staff transmitted the results of a safety inspection of the Millstone Unit No. 2 revised Emergency Operating Procedures (EOPs) and the ability of the control room operators to use them to safely operate the unit.

During the EOP inspection, Northcast Nuclear Energy Company (NNECO) noted that a second revision of the EOP Upgrade Program is planned to address human factors and other concerns. Subsequently, in the report dated August 10, 1995, the Staff requested that we submit a listing of those additional items which Millstone Unit No. 2 plans to address in the continuing EOP upgrade program, along with an estimated timetable for completion. Attachment 1 to this letter provides the EOP Upgrade Program Plan Summary, Attachment 2 provides the Program Task Summary and Attachment 3 provides the Program Timeline.

The following NNECO commitment is made within the attachments to this letter. Other statements within this letter and the attachments are provided as information only. ,

B15372-1 The upgraded EOPs are scheduled to be implemented by July 1, 1997.

e (1) G. W. Meyer letter to J. F. Opeka, " Millstone, Unit 2, EOP Inspection - Report No. 50-336/95-21," dated August 10, 1995.

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'.If there are any questions regarding the information'provided in this. submittal, please contact Mr. Philip J._Lutzi at (203) 440-2072.-

Very truly yours, NORTHEAST NUCLEAR ENERGY COMPANY FOR: -J . F. Opeka Executive Vice President BY: m E. A. DeBarba Vice President Attachments cc: T. T. Martin, Region I Administrator G. S.-Vissing, NRC Project Manager, Millstone Unit No. 2 P. D. Swetland, Senior Resident Inspector, Millstone Unit Nos. 1, 2, and 3

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Attachment 1 Millstone Nuclear Power Station, Unit No. 2 Reply to a Request for Submittal of Plans and Schedule for Emergency Operating Procedures Upgrade Program Program Plan Summary l

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September 1995

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1995 - 1997 EOP UPGRADE PROGRAM PLAN

SUMMARY

I. FORMATION AND TRAINING OF THE EOP UPGRADE TEAM EOP Unorade Team Formation The-Emergency Operations Procedure (EOP) upgrade team will consist of program administrator (s), EOP writers, and support department '

points of contact. In addition, the team will enlist the aid of other independent organizations (e.g., technical reviewers, human

' factors reviewers, peer reviewers, etc.) as appropriate.

EOP Uoorade Team Trainino The EOP writers and support department-points of contact will be requested to attend . training on the Combustion Engineering Emergency Procedures Guidelines (CEN-152). This will ensure that

.the entire. team starts out with the same basic understanding of CEN-152. _The support department supervisors and managers will also be invited to attend.

The EOP writers will also be required to attend training on the Unit 2 EOP Upgrade Writer.'s Guide. All other EOP upgrade team members will be invited to attend this training.

II. EOP ADMINISTRATIVE CONTROLS NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures", recommends an EOP development and verification and validation (V&V) process which will result in technically accurate and usable EOPs. The V&V process is addressed by this program

-plan. The following administrative control procedures will be specifically designed for the Millstone Unit No. 2 EOP Upgrade Program:

MP2 EOP Upgrade Writer's Guide (OP-2259-U)

MP2 EOP Upgrade User's Guide (OP-22 60-U)

MP2 EOP Upgrade Program Administration (OP-2261-U)

MP2 EOP Upgrade Verification Program (OP-2262-U)

MP2 EOP Upgrade -

Validation Program (OP-2263-U)

MP2 EOP Upgrade Procedures Generation Package OP 2259-U. "MP2 EOP Uoorade Writer's Guide" - This document will provide the guidance for the' composition, layout, formatting and writing style used in.the EOPs. It will also provide a listing of approved. verbs, with their meanings defined for EOP purposes, along with acronyms and system names which may be used within the EOPs.

OP 2260-U. "MP2 - EOP Uoorade User's Guide" - This document will provide guidance to the operator for'EOP usage, and will delineate the responsibilities of the EOP users. This document will reflect the method by which the upgraded EOPs are intended to be used.

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l OP 2261-U. "MP2 EOP Uoorade Procram Administration" - This document

• will. describe the' specific process used to upgrade the Millstone Unit No. 2 EOPs.and their supporting documentation ~. It will be.the core procedure for establishing the structure of the EOP program. ,

OP-2262-U. "MP2 EOP Ucarade Verification Procram" - This document will describe the program used to verify that the EOPs are technically correct, that there is consistency between the EOPs and the plant hardware, and that the EOPs adhere to the-guidance in OP 2259-U.

OP-2263-U. "MP2 EOP Uoorade Validation Procram" - This document will describe the process used to ensure that each EOP is usable, that the language is appropriate for the personnel using the EOP, and that the procedure functions as intended.

MP2 EOP Unarade Procedures Generation Packace - NUREG-0899 requires that each licensee submit a procedures generation package (PGP) to the NRC staff at least three months prior to initial operator

' training on new or upgraded EOPs. This document will describe the way in which the plant's EOPs are developed and implemented. r III. INITIAL EOP. DEVELOPMENT AND DEVELOPMENTAL VERIFICATION CEN-152' Mark-Uo The first step in the EOP Upgrade process will determine the degree to which the CEN-152 mitigative strategies can be implemented at Millstone Unit No. 2. A copy of CEN-152 will be entered into Microsoft Word format, and will contain appropriate Millstone Unit No. 2 plant-specific setpoints and system characteristics. It will serve as a mark-up of CEN-152. This " mark-up" will be specified as draft 1.0, and will contain both the procedure title and the EOP number.

4 After the mark-up of each EOP has been completed, it will be  ;

t exercised on the Millstone Unit No. 2 simulator to determine if any I step, strategy, or flow path changes are necessary to accommodate l Millstone Unit No. 2 plant specific differences. If any modifications to the steps, mitigative strategy, or flow of CEN-152 are determined to be necessary, this will be documented, along with an explanation of the reasons the modification is necessary.

Develoo Plant-Soecific Guidelines

After each of the CEN-152 mark-ups has been exercised, the plant-specific EOP guidelines will be developed. These guidelines will be based on the simulator runs of the marked-up CEN-152 procedures and the current EOPs. These guidelines will be developed in procedure format similar to CEN-152, and will be specified as draft ,

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Develcomental EOP Draft Once the plant-specific guidelines have been developed, an initial developmental draft of each of the EOPs will be produced. This draft will be specified as draf t 3.0. It will be based on the plant-specific guidelines and the current EOP steps, and will be written to comply with the Unit 2 EOP Writer's Guide.

Standard Accendices Instead of using support procedures within the EOP space, in most

-cases, Millstone Unit No. 2 will excerpt the appropriate information from the support procedures and assemble an appendix which will be customized for EOP use. These " standard appendices" will' be draf ted during the development 'of the EOP (s) .

Develcomental Verification This developmental verification process consists of two major tasks called " Developmental Verification Walkdown," and " Developmental Simulator Verification."

Developmental ~ Verification Walkdown The purpose of the developmental verification walkdown is to verify, by mock performance, that local plant operations can be successfully performed as written in the standard appendices and any EOP support procedures. In addition, this task provides an estimate of the time required to perform the local operations necessary to support the EOPs. This is necessary to provide input to the developmental simulator verification process, such that the estimated time to complete each supporting local operation can be accounted for during the exercising of the EOPs.

Developmental Simulator Verification Developmental simulator verification will be used to ensure )

that each developmental EOP draft provides adequate mitigative strategies for each event, and that the plant specific steps are accurate and can be performed as presented. A draft of each EOP, specified as draft 4.0, will be prepared from the results of the previous developmental tasks. Each of these drafts will then be brought to the Millstone Unit No. 2 simulator for a developmental simulator verification.

IV. EOP VERIFICATION Once the developmental verification is complete, a draft of each EOP- will be produced accounting for developmental verification findings. This draft will be specified as draft 5.0.

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, 1 Each! of the; procedure drafts _ will undergo a formal verification I

~' process in~.accordance with OP 2262-U. EOP verification will be (

accomplished-through a series of reviews as follows:

multi-discipline review human' factors review

. label consistency review ,

technical review  !

Multi-Discioline Review A multi-discipline review (MDR) will be performed on each of the EOPs. This multi-discipline approach is taken to allow the various '

specialty skills of the participants to be utilized in the review of.the EOPs. The MDR will be performed using personnel from.the following organizations:

licensing independent safety engineering group operations engineering safety analysis .

t training Human Factors Review A human factors review of each EOP will be performed to ensure that the EOP conforms to the requirements of the Millstone Unit No. 2 EOP Upgrade Writer's Guide. -This review will also consist of a check that, nomenclature, grammar, structure and style are .

consistent throughout the EOPs.

Label Consistency Review The details regarding label consistency review is provided in section VI.

Technical Review A techn.' review will be performed to verify the technical adequacy the EOPs, and the correspondence between the upgraded EOPs and LEN-152.

V. EOP SUPPORT DOCUMENTATION DEVELOPMENT EOP Technical Basis Documents

'A Technical Basis Document will be developed for each EOP and will explain the reasons for each EOP step, lists the reference  ;

documents used~to support'the basis, and lists any NRC commitment being fulfilled by the step. It is intended to be used as -

reference for training on the EOPs prior to their implementation, i and asia reference for future EOP revisions.

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Steo Deviation Documents Step: Deviation Document will be developed for each EOP that compares each step of the EOP to the CEN-152 steps. In accordance j with NUREG-0800, NUREG-0899, NUREG-1358, and NUREG-1358 Supplement 1, 'all safety significant deviations will be identified and justified.

Trainina Excectations Documents i A Training Expectations Document will be developed for each EOP i that describes how the operations department expects the training t

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_ department to train the operators on the implementation of each EOP. The purpose of this' document will be to describe the unique expectations that will be associated with certain steps.

Therefore, not all steps will have an associated training expectation.

Safety Evaluations The NNECO Safety Analysis Branch will perform an Integrated Safety Evaluation on the EOPs in accordance with department procedures.

EOP Setooint Document This document will provide a basis for all plant specific numerical values listed in the EOPs, including reference to the appropriate supporting calculations. This EOP Setpoint Document will contain values which account for both harsh containment, and non-harsh containment instrument uncertainties in accordance with CE-NPSD-925, and the report which will be generated as a product of current Combustion Engineering Owners Group Task 884.

, VI. CONTROL ROOM AND LOCAL OPERATIONS LABEL PROGRAM

, In conjunction with the development of the upgraded EOPs, the control room labels and the labels on local equipment associated with local EOP operations will be evaluated for clarity, display attributes, conformance to " normal" plant nomenclature, location, and completeness. A human factors expert, a licensed or previously i

licensed operator, and a member of the EOP upgrade development team as a minimum, will comprise the labeling design, evaluation, and

verification team.

. VII. SPDS UPGRADE i

In conjunction with the development of the upgraded EOPs, the Safety Parameter Display System (SPDS) monitoring and display software will be modified. This modification will be performed by the SPDS computer group working with technical support engineering,

'and the EOP team. This development will commence once the final I EOP verification drafts have been produced and will continue through the end of the program. l j

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. j VIII.- EOP VALIDATION Simulator Val'idation Once the verification process has been completed as specified in section IV-of this Program Plan, each EOP will ~ be validated in accordance'with OP 2263-U. The validation process will commence with the' development of_a draft EOP incorporating all documented

. verification concerns. This draft will be designated as draft 6.0. .

NRC Review NNECO personnel will continue to maintain communication, regarding the' progress of the EOP Upgrade Program, with the NRC through the Region I, Operations Branch. In the course of this communication the Staff has been invited to review the progress of the EOP Upgrade Program at any time. However, we - believe the Staff's review during the simulator validation phase would be beneficial in our. assessment of the initial products of the EOP Upgrade Program.

IX. EOP TBAINING MP2 EOP Trainers Prior to the commencement of operator training on the EOPs, the EOP development team will provide to the training department with (approximately two weeks of) " Upgraded EOP Indoctrination" presentations on the new EOPs. These presentations will take the form of classroom seminars, and simulator sessions, and will allow the EOP Development Team to familiarize the trainers with the upgraded EOPs, and the reasoning behind the EOP strategies.

Millstone Unit No. 2 operators will be trained on the upgraded EOPs following completion of the validation phase of the development program, and the upgraded EOP indoctrination training of the trainers. A draft, designated as draft 7.0, will be produced incorporating all validation and upgraded EOP indoctrination session findings. This draft will be used during the operator training phase of the project. Each crew will be trained on the new EOPs prior r.o their implementation. Comments, concerns and suggestions will be solicited from the operators and will be evaluated and addressed.

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. PROCEDURE FINALIZATION AND APPROVAL Final ~ Reviews A ~. final' ' human factors review of the EOPS will be conducted

- following completion of the EOP validation. This review will be performed using' draft 7 of the: upgraded EOPs. The purpose of this review will be to evaluate how well the earlier comments from the reviews were understood, incorporated and resolved, and to ensure &

that 'the EOPs meet all of the requirements of the EOP Upgrade Writer's~ Guide.

> A final technical review will be conducted following completion of 4 the EOP validation. This review will be performed using Draft 7 of the upgraded ~EOPs. The purpose of this review will be to evaluate-how well the earlier comments from the Technical reviews were '

understood, incorporated and resolved.

1 EOP Finalization Once- the final human factors and technical reviews have been completed, a final draft of the EOPs will be prepared. This draft

- will be designated as draft 8.0. The EOP development team will incorporate the comments from the final human factors review and technical review, and will perform a final consistency check to ensure that the steps are presented consistently throughout the

. EOPs, and that the EOP standard appendices are consistent as appropriate.

PORC Review. Unit Director's Acoroval and Imolementation Each EOP will be reviewed by the Plant Operations Review Committee (PORC) in accordance with Station Procedure OA-3. All comments and concerns will be resolved as appropriate. Following this PORC review and approval, the new EOPs will be presented to the Unit Director for approval prior to implementation.

XI. EOP UPGRADE PROGRAM SCHEDULE I' The EOP upgrade program commenced in August, 1995 and will take approximately two years to complete. It is anticipated that the

2. new EOPs will be implemented by July 1, 1997.

XII. EOP UPGRADE PROGRAM RECORD CONTROL All EOP upgrade program supporting documentation will be kept in

thefEOP upgrade program project-file, by Millstone Unit No. 2 EOP team members. The documentation.will be separated by the EOP it supports, to the extent possible, and will be available for audit purposes. .

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' B15372 Attachment 2 Millstone Nuclear Power Station, Unit No. 2 Reply to a Request for Submittal of Plans and Schedule for Emergency Operating Procedures Upgrade Program Program Task Summary September 1995 l

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-EOP Unorade Procram Task Su==arv

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. 1. - Assemble EOP Upgrade Team

2. Train EOP Upgrade _ Team

3. Develop EOP Upgrade Administrative Controls

- MP2 EOP Upgrade Writer's Guide (OP-2259-0).

- MP2 EOP Upgrade User's Guide (OP-22 60-U)

MP2 EOP Upgrade Program Administration '(OP-2261-U)

' - ICP;2 EOP Upgrade Verification Program (OP-2262-U)

- MP2 EOP Upgrade Validation Program (OP-2263-U)

MP2_EOP Upgrade Procedures Generation Package

4. Develop CEN-152 Mark-up

_ Develop CEN-152 Mark-up

- Exercise CEN-152 Mark-up on the MP2 Simulator

5. Develop Plant-Specific Guidelines

6. Develop Initial EOP Drafts Develop Standard Appendices

- Perform Developmental Verification Walkdown Perform Developmental Simulator Verification

7. Perform Full EOP Verification Multi-Discipline Review Human Factors Review Label Consistency Review Technical Review .

8. Develop EOP Support Documentation EOP Technical Basis Documents Step Deviation Documents Training Expectations Documents Safety Evaluations EOP Setpoint Document p

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19. .  ; Implement! Control Room and:LocaliOperationsiLabel(Program'

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10.;: Perform SPDS Upgrade-i

11. . Validate EOPs: ,

Simulator validations- ~

NRC-review Conduct'EOP! Training

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Indoctrinate MP2 EOP Trainers on the Upgraded EOPs ,

- Train-the MP2 Operators on the Upgraded EOPs

13. . Final'izefand: Approve EOPs

' Final HumaniFactors' review'and' Technical review

,.- -- EOP Finalization PORC- Review,' Unit Director!s Approval and-Implementation 1

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Attachment 3 Millstone Nuclear Power Station, Unit No. 2 Reply to a Request for Submittal of Plans and Schedule for Emergency Operating Procedures Upgrade Program Program Timeline September 1995

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. 1995 1996 1997 ID Task Nam.) Otr 2 l Otr 3 l Otr 4 Otr 1 l Otr 2 l Otr 3 l Otr4 Otr 1 l Otr 2 l Otr 3 l Otr4 1, , , Assembl3 EOP Upgrade Tocm 7/3 l 9/18 l 5

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) 6 Train EOP Team 4

7/9 PS 10/6 l 11 4

12 Develop EOP Admin. Procedures 7,3 g i

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41 Develop CEN 152 Mark-Up 8/11 M 10/31 49 i

50 Develop Plant-Specific Guidelines 10/2 i M 12/19 54 55 Develop initial Drafts 1 I/28 5/10 65 66 Develop Deviation Documents y 6/18 l 3/1 y )

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77 Develop Technical Basis Documents 6/17 3/15 y y 89 90 Develop Training Expectations y 6/17 3/15 y 100 101 Develop EOP Setpoing Document y 5/21 3/15 y

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113 Verification !3/20 2/15 126 2

127 Validation 4/5 12/4 i 135 136 EOP Training 3/26 8/8 I  !

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l i 147 Finalization and Approvals 12/9 6/23 i

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162 Perform Label Upgrade 10/2 I 8/9 169 170 Determine EOP instrument Uncertainties 11,1 10/18

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179 Support Departments Technical Assistance 1 l/28 y . , y 2/10 I l '

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j 183 Upgrade SPDS  ! 5/7 y y 6/23 i

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198 EOP Implementation 7/157/1