ML15264A240
| ML15264A240 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/09/1984 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML15264A239 | List: |
| References | |
| NUDOCS 8408200424 | |
| Download: ML15264A240 (11) | |
Text
SAFETY EVALUATION REPORT, PROCEDURES GENERATION PACKAGE OCONEE NUCLEAR STATION, UNITS 1, 2 AND 3
- 1. INTRODUCTION Following the Three Mile Island (TMI) accident, the Office of Nuclear Reactor Regulation developed the "TMI Action Plan" (NUREG-0660 and NUREG-0737), which required licensees of opyeiting reactors to reanalyze transients and accidents and upgrade emergency operating procedures (EOPs) (Item I.C.1). The plan also required the NRC staff to develop a long-term plan that integrated and expanded efforts in the writing, reviewing, and monitoring of plant procedures (Item I.C.9).
NUREG-0899, "Guidelines for the Preparation of Emergency Operating Procedures,"
represents the staff's long-term program for upgrading EOPs, and describes the use of a "Procedures Generation Package " (PGP) to prepare EOPs.
Submittal of the PGP was rmade a requirement by "Supplement 1 to NUREG-0737 -
Requirements for Emergency Response Capability (Generic Letter 82-33)."
The Generic Letter requires each licensee to submit to the NRC a PGP, which includes:
(i) Plant-Specific Technical Guideline (ii) A Writer's Guide (iii)
A Description of the Program to be Used for the Validation of EOPs (iv) A Description of the Training Program for the Upgraded EOPs This report describes the review of Duke Power Company's response to the Generic Letter related to development and implementation of EOPs for Oconee 1, 2 and 3.
Our review was conducted to determine the adequacy of the licensee's program for preparing and implementing EOPs. Criteria for the review of a PGP are not currently in the Standard Review Plan (SRP).
Therefore, 8408200424 340609 PDR ADOCK 05000269 F
-2 this review was based on NUREG-0899, the reference document for the EOP upgrade portion of Supplement 1 to NUREG-07-37 (Generic Letter 82-33).
Review criteria based on this guidance will be developed for the next SRP revision. Section 2 of this SER briefly discusses the four parts of the licensee's submittal, the staff review methods, and the acceptability of the submittal.
As indicated in the following sections, our review determined that the procedure generation program for Oconee 1, 2 and 3 is acceptable with the exception of the items identified in Sections 2 and 3.
The licensee should address these items in a revision to the PGP, or provide suitable justification for why the modifications are not necessary. We will report on our review of the licensee's response to these items in a supplement to this SER. The revision of the PGP, and subsequently of the EOPs, should not impact the implementation'schedule or the use of the EOPs. The revision should be made in accordance with the licensee's administrative procedures.
- 2. EVALUATION AND FINDINGS In a letter dated April 14, 1983, from H. B. Tucker to H. R. Denton, the licensee submitted its PGP. The PGP contained the following three sections:
Writer's Guide for Emergency and Abnormal Procedures Emergency Procedure Verification/Validation Proarams Emergency Procedure Training Program.
The Oconee Abnormal Transients Operating Guidelines (ATOG), which are the plant-specific technical guidelines (PSTG) for Oconee, were not included with the PGP because the:ATOG had been previously submitted to the NRC as
-3 a generic basis for the B&W Owners Group technical guidelines. The NRC staff approved the Oconee ATOG for implementation and for use as a generic basis for the remaining B&W plants' ATOGs. The NRC staff review is documented in Generic Letter 83-31, "Safety Evaluation Report (SER) of Abnormal Transient Operation Guidelines," datead September 14, 1983.
A. Writer's Guide The writer's guide was reviewed to determine if it provided acceptable methods for accomplishing the objectives stated in NUREG-0899. The licensee described a process that will use the ATOG and writer's guide to develop one emergency procedure. The procedure will use a single column format and will contain subprocedures as separate sections.
During the review of the writer's guide, the following items were identified:
(1) The page margins used in the EOP example of Appendix 1 should be made consistent with the page margin information presented in Appendix 6, Section 7.0.
(2) The discussion on place-keeping aids (Section 2.7, page 11) states that a line to the left of major numbered steps should be used as a place-keeping aid.
As currently written, the instructions allow the place-keeping aids to be placed in the left margin, where they could be obscured by the binding. The Section 2.7 write-up should ensure that the place-keeping aids are placed within the margins.
-4 (3) Attachments, including tables, figures, flowcharts, and other decision aids, can be very useful in reducing the need for calculations and complicated logic statements. Thus, Section 2.10, "Enclosures," of the writer's guide..should contain guidance about when a table, figure, flowchart or other attachment should be used. In addltion, the writer's guide should include guidance to ensure the useability and accuracy of the attachments. (See NUREG-0899, Subsections 5.5.8 and 5.5.9.)
(4) The acronyms in Appendix 3 should be made consistent with the rules for forming acronyms in Section 3.5.2, page 18, which state that acronyms should be in all capital letters.
(5) The writer's guide shoulf contain a discussion on the use of numerals in EOPs that covers the number of significant digits and the use of decimals vs. fractions. The number of significant digits used in an EOP should be consistent with instrumentation reading accuracies. Decimals, rather than fractions, should be used for all cases except where the instrumentation is labeled with fractions.
(See NUREG-0899, Subsection 5.6.7.)
(6) Conditional statements and logic statements have been addressed in Section 3.10 and in Appendix 1. Two additional items should be covered:
(a) "OR" should be defined in either the inclusive or exclusive sense,.and the format for using "OR" in the other manner should be specified..
-5 (b) The use of "AND and "OR" in the same logic statement should be avoided. The writer's guideshould include examples of such logic statements so that it is clear to the procedure writer what logic statements to avoid.
(7) The copy quality or "legibility" of EOPs is essential so that the operator using the EOP during an emergency has no question about what is being read from the text or from an attachment.
Thus, there should be a section in the writer's guide (probably in Appendix 6) that discusses legibility. Ideally, the EOP copies should be as legible as an original copy of the master procedure, or, stated differently, copy reproduction should not adversely affect legibility. (See NUREG-0899, Section 6.2.)
With adequate resolution of the above items, the staff concludes that the Oconee writer's guide provides adequate guidance for translating the technical guidelines into EOPs that should be useable, accurate, complete, readable, convenient to use and acceptable to control room operators. The staff will confirm that the licensee adequately addresses these items, and will report its review in a supplement to the SER.
B. Validation/Verification The descriptions of the licensee's validation/verification programs were reviewed to determine if they acceptably address the objectives stated in NUREG-0899. The verification program described in the PGP has two objectives: 1) to determine that the procedures conform to the format and principles specified in the writer's guide, and 2) to determine that the procedures are technically accurate, consistent with the plant-specific technical guidelines and include all appropriate licensing commitments.. The objective of the validation
-6 program described in the PGP is to ensure that a trained operating shift can manage emergency events usingthe EOPs.
During the review of the verification/validation program, the following items were identified:
(1) It is not clear that the scenarios to be selected for use during the validation will be sufficiently comprehensive to ensure that the full complement of EOPs is exercised. Section 7.0 of the "Oconee Proposed Validation Process for Emergency Procedures" should include a description of the criteria that will be used to select the scenarios. The criteria should ensure that single and multiple (including sequential and concurrent) failures are included.
Then, a review of the capabilities and the limitations of the simulator will identify what can be validated on the simulator. For the parts of the EOPs that cannot be validated on the simulator (if this is the case), the criteria for selecting any additional scenarios that may need to be conducted by a control room walk-through or a mock-up walk-through should be described.
(2) The proposed val-idation process using the simulator is for Oconee Units-1, 2 and 3. Since the three units are different from one another, the validation/verification program description should identify the method that will be used to account for the differences among the units.
(3) The validation program description, including discussions of both the walk-through and the real-time simulations, have a.
section addressing "control room compatibility." Neither of these sections address the issue of whether the instrumentation and controls are adequate to meet the needs of the operators.
-7 This issue is related to the Function and Task Analysis described in Supplement 1 to NUREG-0737, which is required to ensure that the operators' information and control needs are met during emergency operations. The issue can be addressed as part of either the EOP upgrade, or the Detailed Control Room Design Review (DCRDR), with suitable crofi-reference, since the results of the task analysis are applicable to both efforts. The DCRDR Final Report, submitted as part of the Duke Power Company Response to Supplement 1 to NUREG-0737, has a section that discusses Task Analysis. The process described in the steps used to conduct the task analysis, provided on pages 52 through 56 of the DCRDR Final Report, do not appear to result in the identification of information and control needs of the operators as derived from the techmrcal guidelines. While there are several sections of the Duke Power task analysis description that allude to identifying the type of information the staff considers necessary, it appears that the task analysis process that is described will only identify which of the existing instrumentation and controls are used to perform the tasks in the guidelines, based on current operating experience, but will not provide the basis for determining the adequacy of these instruments and controls.
In order for the staff to more fully evaluate the extent of any deficiency in the Duke Power task analysis, the task analysis description included in the DCRDR Final Report should be expanded to address the following items:
(a) Page 50, second paragraph, second sentence - Define what is meant by "required" in the phrase "components required to perform each task."
The definition should clarify whether "required" means:
- 1) the components are selected based on which of the existing instrumentation and control parameters (and other instrument and control characteristics) are most appropriate for the task, or
- 2) the components are derivedYrom the tasks identified in the technical guidelines, based on meeting needs derived from the tasks.
(b) Describe how the Task Analysis will provide the information necessary to determine that (as described on page 50, third paragraph, second sentence), "an information item, needed for the performance of a task, might be unavailable in the control room."
Thi description should include how the task analysis will provide a basis for determining the adequacy of the selected parameters, as well as the other instrumentation and control characteristics.
(c) Page 53, Step 2 - The last sentence on the page, "the analysis will develop a listing of the interfaces (displays and controls) used by operators and an indication of the relative order in which they are employed" (emphasis added) makes it appear that the task analysis identifies existing controls and displays. This is one part of the task analysis description that leads the staff to believe that the task analysis is focused on existing instrumentation and controls, instead of deriving necessary instruments and controls from information and controls needs, and using the needed instruments and controls as a basis for evaluation of existing instruments and controls. This process, if the staff has accurately evaluated the Duke program, needs to
-9 be modified to analyze operator actions based on information and control needsderived from the guidelines, which would then be compared to the results of the current process.
(d) Page 54, "Completion of Task fi ta Forms (TDFs)," fourth sentence - The description for completing the task data forms focuses on actions that an operator takes and instrumentation and controls they use, again implying that the tasks analysis is based on existing instruments and controls, rather than on deriving the necessary instruments and controls from information and control needs.
This process will serve the purpose of identifying (i.e., a survey) existing infirumentation and controls. The Duke Task Analysis program needs to be modified to include the derivation of instrument and control needs.
(e) The interfaces between the various parts of the Task Analysis process and the interfaces with other parts of the DCRDR and EOP upgrade should be described. For example,
- 1) how are the Task Descriptive Data, as documented on the Task Data Forms, used throughout the remainder of the Task Analysis Process?
- 2) how are the data used to meet the objectives outlined in Section 4.5.1, Page 50?
- 3) what is the relationship between the Control Room Survey and the Task Analysis?
- 4) what is the relationship, if any, between the results of-the Task Analysis and the Validation/Verification program for EOPs?
10 With adequate resolution of the above items, it appears that the Oconee validation/verification programs.will acceptably address the objectives stated in NUREG-0899. The staff will confirm that the licensee adequately addresses these items, and will report its review in a supplement to this SER.
C. Training Program The licensee's description of the operators' training plan on the EOPs was reviewed to determine if they acceptably address the objectives stated in NUREG-0899. The training program as described in the PGP consists of the following three parts:
classroom instruction, demonstration, and hands-on, real-time training on the plant-specific simulator usingnormal shift operating crews.
Wri-tten and performance evaluations will be made. The training plan, as presented, adequately addresses the objectives stated in NUREG-0899 and should result in appropriate training for the operators on the upgraded EOPs.
- 3. CONCLUSIONS The PGP as submitted by Duke Power Company for Oconee 1, 2 and 3 adequately addresses the guidance of NUREG-0899, except for the items listed in Section 2. The PGP should be revised to address these items, and the revisions submitted to the NRC for review.
Based on the review, we conclude that, with the exceptions noted in Section 2 of this SER, the Duke Power Company PGP for Oconee 1, 2 and 3 meets the requirements of Supplement 1 to NUREG-0737 and describes acceptable methods for accomplishing the objectives stated in NUREG-0899.
The staff therefore has reasonable assurance that EOPs developed and implemented in accordance with the program described in the licensee's
PGP should be adequate for control room personnel to effectively mitigate the consequences of a broad range of accidents and multiple equipment failures.
Future changes to the PGP having safety significance should be brought to the attention of the NRC and will be reviewed in accordance with 10 CFR 50.59.
This review and evaluation was performed with the assistance of Battelle Pacific Northwest Laboratories personnel.