Information Notice 1986-64, Deficiencies in Upgrade Programs for Plant Emergency Operating Procedures

Deficiencies in Upgrade Programs for Plant Emergency Operating Procedures

ML031250068
Person / Time
Site:	Beaver Valley, Millstone, Hatch, Monticello, Calvert Cliffs, Dresden, Davis Besse, Peach Bottom, Browns Ferry, Salem, Oconee, Mcguire, Nine Mile Point, Palisades, Palo Verde, Perry, Indian Point, Fermi, Kewaunee, Catawba, Harris, Wolf Creek, Saint Lucie, Point Beach, Oyster Creek, Watts Bar, Hope Creek, Grand Gulf, Cooper, Sequoyah, Byron, Pilgrim, Arkansas Nuclear, Three Mile Island, Braidwood, Susquehanna, Summer, Prairie Island, Columbia, Seabrook, Brunswick, Surry, Limerick, North Anna, Turkey Point, River Bend, Vermont Yankee, Crystal River, Haddam Neck, Ginna, Diablo Canyon, Callaway, Vogtle, Waterford, Duane Arnold, Farley, Robinson, Clinton, South Texas, San Onofre, Cook, Comanche Peak, Yankee Rowe, Maine Yankee, Quad Cities, Humboldt Bay, La Crosse, Big Rock Point, Rancho Seco, Zion, Midland, Bellefonte, Fort Calhoun, FitzPatrick, McGuire, LaSalle, 05000000, Zimmer, Fort Saint Vrain, Shoreham, Satsop, Trojan, Atlantic Nuclear Power Plant, Skagit, Marble Hill
Issue date:	08/14/1986
From:	Jordan E NRC/IE
To:
References
IN-86-064, NUDOCS 8608120028
Download: ML031250068 (4)

118 ORIGINAL UNITED STATES

IN No.:

86-64 SSINS 6835 NUCLEAR REGULATORY COMMISSION

OFFICE OF INSPECTION AND ENFORCEMENT

WASHINGTON, DC 20555 August 14, 1986 IE INFORMATION NOTICE NO. 86-64: DEFICIENCIES IN UPGRADE PROGRAMS FOR

PLANT EMERGENCY OPERATING PROCEDURES

Addressees

All nuclear power reactor facilities holding an operating license or a

construction permit.

Purpose

This notice is to alert recipients to problems found in reviews and audits of

Procedures Generation Packages (PGPs) and emergency procedures for operating

reactors and license applicants. Indications are that many utilities have not

apropriately developed or implemented upgraded emergency operating procedures

(EOPs). Deficiencies have been identified in the development and implementation

of each of the four major aspects of the upgrade programs for utility procedures.

It is expected that recipients will review the information for applicability

to their facilities and consider actions, if appropriate, to preclude similar

problems occurring at their facilities. However, suggestions contained in this

notice do not constitute NRC requirements; therefore, no specific action or

written response is required.

Background:

As required by the TMI Action Plan, NUREG-0737, the industry developed

technical guidelines based on re-analysis of transients and accidents to

support upgrading EOPs. In addition, the staff developed a long range program

for upgrading EOPs in the industry. Development and implementation of upgraded

EOPs were requested by the NRC staff in Generic Letter 82-33, (NUREG-0737, Supplement 1, Requirements for Emergency Response Capability), pursuant to

10 CFR 50.54f. "Guidelines for the Preparation of Emergency Operating

Procedures" (NUREG-0899), was identified as the reference guidance document

for the EOP upgrade effort.

NUREG-0737, Supplement 1, specifies submittal of a PGP that describes a

licensee's program for upgrading and implementing EOPs by addressing four

ma4or areas: the technical bases of the procedures, the procedures writer's

guide, the program for validation of the procedures, and the operator training

program for the upgraded procedures. The NRC staff had planned to review and

approve generic technical guidelines and plant-specific PGPs and had not

planned to routinely review,the EOPs. The PGP review may be performed after

8608120028

IN 86-64

.'- i August 14, 1986 an operating reactor has implemented its upgraded EOPs so as not to delay their

implementation. PGPs for applicants are reviewed as part of their FSAR submittal

before licensing. The PGP review for operating reactors and applicants is

conducted in accordance with NUREG-0800, Standard Review Plan, Section 13.5.2, revised July 1985. PGPs for 89 plants have been received by the staff, 79 have

been implemented by plants, and reviews of PGPs for 48 plants have been conducted.

Description of Circumstances

The NRC staff has collected information on the quality of the upgraded EOPs

throughout the industry. This information has come from several sources

including: (1) in depth audits of EOP upgrade programs at four plants, (2)

reviews of PGPs, (3) the review of procedures as a part of operating event

analyses, (4) reviews of detailed control room design review program plans and

summary reports, (5) examiners' experiences during operator license examinations,

(6) industry comments on procedure-related research efforts, and (7) other

interactions with licensees. The assessment of this information indicates that

significant deficiencies in implementing the EOP upgrade programs exist.

Specifically:

1. Licensees have not followed commitments they made in their PGPs. That is, the emergency operating procedures, the verification and validation program, and/or the operator training program was not found to adequately adhere to

the PGP at any of the four plants audited.

2. Undocumented deviations from the Owners Groups' generic technical guidelines J

have been found at all four plants audited. Deviations are expected, but

Generic Letter 82-33 requests that they be identified, and a technical

justification provided in the PGP. In addition, programs have been found

deficient where deviations were identified after the PGP had been submitted, reviewed and approved by the NRC. NUREG-0899 provides guidance in processing

sUch deviations.

3. Failures to appropriately adapt the Owners Groups' generic technical guide- lines have been found at some of the plants audited. There are also

instances in which the generic technical guidelines are technically

inappropriate to the particulars of individual plants so that deviations

are necessary but have not been made in the emergency operating procedures

and/or documented in the PGP or plant records. In addition, some licensees

have neither adopted nor deviated from the generic technical guidelines, but

have used them verbatim as emergency operating procedures. The NRC review

and approval of the generic technical guidelines has been limited to assessing

their suitability as technical guidelines; not as procedures for typical

plants.

4. Failures to adhere to the PGP writer's guide have been found at all four

plants audited. The purpose of following an approved writer's guide is

to assure that potentially confusing or error-prone writing styles, nonmenclature, formats, conventions, or inconsistencies are avoided.

Failure to adhere to the approved writer's guide in the PGP has resulted

in instances of safety significant problems in the EOPs at some of the

plants audited.

IN 86-64 August 14, 1986 5. Failures to adhere to PGP commitments on the verification and validation

(V&V) of emergency operating procedures have been found at all plants

audited. The implementation of V&V programs has not been successful in

identifying and correcting the types of deficiencies cited in this notice

at any of the plants audited. Approved PGPs generally include commitments

to use multidisciplinary teams in conducting the V&V programs. Single

individuals rather than multidisciplinary teams performed the V&V function

at most plants audited.

6. Training programs at some plants audited have been found deficient in areas

such as (a)providing adequate instruction in the philosophy behind the

function orientation of upgraded EOPs, (b) training all operators on all

EOPs before they are implemented, and (c) evaluating operator knowledge

and performance after they have received training on the upgraded EOPs.

Discussion:

While the above findings do not necessarily represent the situation at any single

plant, their occurrence across the plants contacted suggests that the overall

quality of EOPs may not meet the requirements of NUREG-0737, Supplement 1, and

may need to be Improved. To address these potentially safety significant

deficiencies, the NRC staff is (1) issuing this information notice to alert

licensees to the deficiencies, (2) continuing the audit program on a priority

basis to determine the scope and safety significance of these deficiencies, and

(3) planning inspections at all plants to evaluate the implementation of the

licensees' commitments to develop and implement upgraded EOPs.

No specific action or written response is required by this information notice.

If you have any questions.about this matter, please contact the Regional

Administrator of the appropriate NRC regional office or this office.

Jordan, Director

Divisio f Emergency Preparedness

and E gineering Response

Office of Inspection and Enforcement

Technical Contacts: J. Bongarra, NRR

(301) 492-4882 W. G. Kennedy, NRR

(301) 492-4578 H. Bailey, IE

(301) 492-9006 Attachment: List of Recently Issued IE Information Notices

Attachment a

IN 86-64 August 14, 1986 LIST OF RECENTLY ISSUED

IE INFORMATION NOTICES

information Date of

Notice No. Subject Issue Issued to

86-63 Loss Of Safety Injection 8/6/86 All PWR facilities

Capability holding an OL or CP

86-62 Potential Problems In West- 7/31/86 All power reactor

inghouse Molded Case Circuit facilities holding

Breakers Equipped With A an OL or CP

Shunt Trip

86-61 Failure Of Auxiliary Feed- 7/28/86 All power reactor

water Manual Isolated Valve facilities holding

a CP

86-60 Unanalyzed Post-LOCA Release 7/28/86 All power reactor

Paths facilities holding

an OL or CP

86-31 Unauthorized Transfer And 7/14/86 All NRC general

Sup. 1 Loss Of Control Of Industrial licensees that possess

Nuclear Gauges and use industrial

nuclear gauges

86-59 Increased Monitoring Of 7/14/86 All NRC licensees

Certain Patients With authorized to use

Implanted Coratomic, Inc. nuclear-powered

Model C-100 and C-101 cardiac pacemakers

Nuclear-Powered Cardiac

Pacemakers

86-58 Dropped Fuel Assembly 7/11/86 All power reactor

facilities holding

an OL or CP

86-57 Operating Problems With 7/11/86 All power reactor

Solenoid Operated Valves At facilities holding

Nuclear Power Plants an OL or CP

86-56 Reliability Of Main Steam 7/10/86 All PWR facilities

Safety Valves holding an OL or CP

86-55 Delayed Access To Safety- 7/10/86 All power reactor

Related Areas And Equipment facilities holding

During Plant Emergencies an OL or CP

XL = Operating License

CD = Construction Permit