ML16342B638
| ML16342B638 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 01/19/1990 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML16341F514 | List: |
| References | |
| NUDOCS 9001260038 | |
| Download: ML16342B638 (16) | |
Text
Safety Evaluation Regarding the Procedures Generation Package for Diablo Canyon Nuclear Power Plant Units 1 and 2
1.
Introdu ction Following the Three Mile Island (THI) accident, the Office of Nuclear Reactor Regulation developed the "TtII Action Plan" (NUREG-0660 and NUREG-0737), which required licensees of operating 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 Preparation of Emergency Operating Procedures,"
represents the staff's long-term program for upgrading
Submittal of the PGP was made 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 )
P lant-speci fic techni ca 1 guidelines (ii)
A writer's guide (iii)
A description of the programs to be used for the validation and verification of EOPs.
(iv)
A description of the training program for the upgraded EOPs.
This report describes the review of Pacific Gas and Electric Company's (PGSE) response to the Generic Letter related to the development and implementation of EOPs for Diablo Canyon Nuclear Power Plant (DCPP) (Section 7 of Generic Letter 82-33).
Our review was conducted to determine the adequacy of the licensee's program for operating and implementing EOPs.
This review was based on NUREG-0899, "Guidelines for the Preparation of Emergency Operating Procedures,"
the reference document for the EOP upgrade portion of Supplement 1 to NUREG-0737 (Generic Letter 82-33).
Review criteria based on this guidance has been included in Section 13.5.2 of the Standard Review Plan.
Section 2 of this SER briefly discusses the licensee's submittal, the staff review methods, and the acceptability of the submittal.
Section 3 contains the conclusions of this review.
The staff determined that the procedure generation program for DCPP has several several items that must be satisfactorily addressed before the PGP is acceptable.
PG8E should address these items in a revision to the PGP.
This revision and/or justification should not be submitted, but should be retained for subsequent review by the NRC staff.
The revision of the
- PGP, and subsequently of the
The revision should be
~
made in accordance with the DCPP administrative procedures and 10 CFR 50.59.
5'001260038 5'00115'DR ADOCK 05000275 P
Deviations from and additions to the generic technical guidelines that are of safety significance must be identified in the PGP.
In addition, analyses or other technical justification supporting these deviations and additions must be documented.
2.
Where there are additions to or deviations from the generic technical guidelines, the corresponding operator actions should be verified/
validated to confirm their technical adequacy.
The method DCPP plans to use to conduct this verification/validation should be described in the PGP.
3.
In Subsection II.D.6.d, on page 5, the licensee states that ERG steps may be rearranged to streamline the procedure.
The numbered steps in the ERGs are intended to be followed in order, and.only the bulleted steps or substeps have no required sequence.
(Westinghouse Owner's Group Emergency
Response
Seminar, Training Package, Vol.
1 tab 5, rules c, d, and 3 on Page 2, Sept.
1981.)
Therefore, departing from a numbered step sequence of the ERGs should be considered a deviation from the generic guidelines, which requires analysis or technical justification to ensure the actions proposed for the DCPP EOPs procedures results equivalent to those of the ERGs.
A list of these deviations should be included in the PGP.
4.
The list of source documents in Section II.C, on page 4, includes a
"P lant-Speci fic Techni ca 1 Guidelines", but the program description does not state that a P-STG will be produced.
This discrepancy should be corrected.
b.
Each licensee and applicant, on a plant-specific basis, must describe the process for using the generic guidelines and background documentation to identify the characteristics of needed instrumen-tation and controls.
For the information of this type that is not available from the ERGs and background documentation, licensees and applicants must describe the process to be used to generate this information (e.g.,
from transient and accident analyses) to derive instrumentation and control characteristics.
This process can be described in either the PGP or DCRDR Program Plan with appropriate cross-referencing.
For potentially safety-significant, plant-specific deviations from the ERG instrumentation and controls, each licensee and applicant must provide in the PGP a list of the deviations and their justification.
These should be documented'n the plant-specific technical guideline portion of the PGP, along with other technical devi ations.
c ~
For each instrument and control used to implement the emergency operating procedures, there should be an auditable record of how the needed characteristics of the instruments and controls were determined.
These needed characteristics should be derived from the information and control needs identified in the background documentation of Revision lA of the ERG or from plant-specific information.
2.
Evaluation and Findings The licensee submitted its PGP in a letter dated July 1, 1983, from J. 0.
Schuyler (PGSE) to Darrell G. Eisenhut (NRC).
The PGP contained a
introduction and the following sections:
Plant-Specific Technical Guidelines Writer's Guide for EOPs, including an attachment:
EOP Verification and Validation Program EOP Training Program A discussion of these section follows.
A.
Plant-Specific Technical Guidelines (P-STG)
The plant-specific technical guidelines program was reviewed to determine if it provided acceptable methods to meet the objectives of NUREG-0899.
The licensee described a process that will take the Westinghouse Owner's Group (WOG) generic emergency response guidelines (ERGs) that were developed for a Westinghouse 4-loop plant and, with appropriate
The licensee identified the following source documents for use in generating DCPP's EOPs:
Writer's Guide for EOPs WOG generic guidelines and background document DCPP Electrical Drawings DCPP Piping and Instrumentation Drawings Administrative Procedures Licensing Commitments relating to EOPs FSAR Derivations for Calculated Mathematical Values Used in EOPs P 1 ant-Speci fi c Techni ca 1 Gui de 1 ines Company Operating Orders Westinghouse Bulletins and Memos Plant System Description List of Differences Between Generic Plant and DCPP The licensee stated that the EOPs will be developed by following the ERGs in a step-by-step fashion.
Plant-specific information, details, and nomenclature will be added as required and steps that cannot be performed as DCPP will be modified or deleted.
EOP steps that deviate from the ERGs will be entered in a Step Deviation Document along with justification of the difference.
Except for the items listed below, the process descr ibed for converting the generic guidelines into EOPs appear adequate.
Our review of the plant-specific technical guideline program, identified the following concerns:
With adequate resolution of the above items, the DCPP P-STG program should meet the objectives of NUREG-0899, and provide adequate guidance for translating the ERGs into the DCPP's EOPs.
B.
Writer's Guide The writer's guide was reviewed to determine if it provided acceptable methods to meet the objectives of NUREG-0899.
The licensee states that the DCPP writer's guide is based on the INPO EOP writing guidelines (INPO 82-107) and Westinghouse Owners Group writer 's guide.
The EOPs wi 11 follow a two-column format with action or expected responses presented in the left-hand column, with the right-hand column being reserved for contingency actions when the expected response is not obtained.
Each procedure will have a foldout page that summarizes the information that is continually required for operator guidance.
Our review of the writer's guide identified the following concerns:
l.
Information should be presented in procedures so that interruptions in its flow are minimal.
To achieve this, each procedure should be written so that an action step is complete on one page.
This guidance should be included in the writer's guide (similar to the instructions for Notes and Cautions in Subsection II.C.5.h, on page 8 of 15}.
2.
Place-keeping aids can assist the operators in keeping track of their position within a procedure.
They are of particular importance when performing concurrent steps or procedures and in the situations where the user's attention is diverted.
The writer's guide should specify the use of some type of place-keeping aid.
3.
Instructions should be written for various types of action steps that an operator may take to cope with different plant situations.
Thus, the writer's guide should address the definition of and formatting for the use of the following types of action steps:
a.
Steps that are used to verify whether the objective of a task ot sequence of actions has been achieved.
'See NUREG-0899, Subsection 5.7.2 for additional guidance.
b.
Steps of a continuous or periodic nature.
See NUREG-0899, Subsection 5.7.3 5 5.7.5 for additional guidance.
c.
Steps for which a number of alternative actions are equally acceptable.
See NUREG-0899, Subsection 5.7.4 for additional guidance.
d.
Steps performed concurrently with other steps.
See NUREG-0899, Subsection 5.7.7 for additional guidance.
A
4.
To minimize confusion, delay, and errors in execution of EOP steps, the following concerns should be addressed in the writer's guide:
a.
The EOPs should be structured so they can be executed by the minimum shift staffing and minimum control room staffing required by the facility Technical Specifications.
b.
The instruction for structuring the EOPs should be consistent with roles and responsibi lities of the operators.
See NUREG-0899, Subsection 5.8.2 for additional guidance.
c.
Action steps should be structured to minimize physical conflicts between personnel and to minimize the amount of movement needed for carrying out the steps.
d.
The action steps should be structured to avoid unintentional duplication of tasks.
5.
It is important that an operator be able to quickly access the relevant EOPs, or portions of EOPs.
The writer's guide should address the accessibility of the EOPs and their various parts and sections.
6.
All copies of the EOPs should be legible, therefore the quality of reproduced copies of the EOPs should be addressed in the writer's guide.
7.
Abbreviations, acronyms and symbols are discussed in Subsection II.F.6, on pages 13 and 14 of 15.
To ensure that these items are recognizable by the operators, a list of acceptable abbreviations, acronyms and symbols should be included in the writer's guide.
Unfamiliar abbreviations and acronyms should not be used in any EOP.
8.
The writer's guide prescribes that equipment,
- controls, and displays will be identified in common usage terms, but that these terms may not always match engraved names on panels.
Since the operators may need to refer to the actual name tag, the writer's guide should be revised to include instructions that the EOPs include both the common usage terms and the name plate data.
9.
To provide consistency among and within EOPs, the headings to be used for the various sections of the
- EOPs, and their sequences, format and method of emphasis should be addressed in the writer's guide.
10.
The use of logic terms is discussed in Subsection II.C.4, on page 7 of 15.
However, this section should be revised to include examples of logic terms or sequences that should be avoided because the statements can be confusing and ambiguous, such as combinations of AND and OR.
ll.
The writer's guide indicates, in Subsections II.C.1.j. on 4 of 15, and II.C.3.b, on page 6 of 15, that obvious contingency actions and the expected results of routine tasks need not be included.
In order to ensure consistent application of this guidance the writer's guide should be expanded to include examples of the types of information that can be excluded from the EOPs.
12.
Figures and Tables can be important sources of information in procedures.
In or der to increase their usefulness the writer's guide should be expanded to include instruction for identification and location of graphs,
- charts, tables and figures.
(NUREG-0899, Subsection 5.5.8)
With adequate resolution of the above items, the DCPP writer's guide should provide acceptable methods to meet the objectives of NUREG-0899 and should provide adequate guidance for translating the technical guidelines into EOPs that will be usable,
- accurate, complete,
- readable, convenient to use and acceptable to control room operators.
C.
EOP Verification/Validation Program The verification and validation program was reviewed to determine if adequate methods are described for accomplishing the objectives of NUREG-0899.
The verification and va'lidation program described in the PGP has six objectives:
(I) Are the EOPs technically correct, (2) Are the EOPs written correctly, (3)
Are the EOPs usable (4), Is there a correspondence between the procedures and the control/plant hardware, (4) Are the language and level of information pr esented in the EOPs compatible with minimum number, qualifications, training and exper ience level of the operating staff, and (6) Is there a high level of assurance that the procedures will work.
The verification/validation program will include table-top reviews, generic simulator exercises and control room walk-throughs.
Our review of the verification and validation program identified the following concerns:
1.
The verification/validation program should include the numbers and types of personnel that will be involved and what their roles will be to ensure that technical and human engineering adequacy of the EOPs is achieved.
2.
The validation part of the program should address how the EOPs will be validated with the minimum control room staffing required by the DCPP Technical Specifications.
3.
To assure verification/validation of all the
- EOPs, the program description should include an indication that the full complement of EOPs will be exercised, including multiple (simultaneous and sequential) failures..
4.'he validation program should include a description of the criteria that will be used to select the scenarios to be run during the validation process.
The criteria should be developed on the basis of what is needed to validate the procedures.
The criteria should ensure that single, sequential, and concurrent fai lures are included.
For the parts of the EOPs that cannot be validated on the simulator, the criteria for selecting any additional validation that may be needed and the methods to be used, such as a control room or a mock-up walk-through, should be described.
5.
The verification/validation program uses a generic simulator for the validation of the EOPs.
Since the plant-specific simulator is operational, the verification/validation program should specify that the EOPs will be revalidated on the-plant-specific simulator.
Resolution of the above items should result in a verification/validation program that meets the objectives and guidance of NUREG-0899 and should provide assurance that the EOPs adequately incorporate the guidance of the writer's guide and the generic technical guidelines.
D.
EOP Training Program The licensee's description of its plan for training operators on the EOPs for DCPP was reviewed against the objectives of NUREG-0899.
The training program presented in the PGP consist of two phases.
Phase I, initial training, consists of classroom training and control room walk-throughs.
Phase II, simulator training, involves both classroom briefings and actual simulator sessions on the plant-specific simulator.
The training program also provides for long-term training during annual simulator training or when the EOPs are modified.
Our review of the DCPP training program for EOPs identified the following concerns:
1.
The PGP should state the training objectives and describe how these objectives will be accomplished by the training program.
2.
The description of the training program indicates that when a
problem is noted with a procedure, feedback is provided to the verification/validation process.
If major changes are made in the EOPs as a result of the training feedback, the program should describe how the needed retraining will be controlled and performed.
3.
The training program description should be revised to include the use of a wide range of scenarios, incorporating multiple and sequential failures, for both the control room walk-through and the simulator exer cises.
e I
4.
The training program should be revised to describe the methods used for evaluating operators following the training program and for determining appropriate followup training for deficient areas.
5.
The description of the training program states that all operator s will be trained on all the plant-specific EOPs, but it is not clear from the description if all operators will be trained on all EOPs during the simulator portion of'he program.
The training program should be revised to clarify the extent of operator training on the
. EOPs at the simulator.
Inclusion of the above items should result in a training program that meets the requirements of Supplement 1 to NUREG-0737 and the guidance of NUREG-0899 and should provide assurance that the, operators are adequately trained on the EOPs prior to implementation.
CONCLUSION The staff concludes that, the PGP submitted by Pacific Gas
& Electric Company for Diablo Canyon Units 1 and 2 in a letter from J.
O. Schuyler to the
- NRC, dated July 1, 1983, should be reviewed to address the programmatic improvements outlined in Section 2 of this report.
A PGP revision should not be submitted to the NRC.
For items the licensee deems inappropriate or no longer applicable for inclusion in its PGP, it should develop and maintain documented justification in an auditable form.
All revisions to the PGP should be reflected in plant EOPs within a reasonable period of time, e.g.
the next planned revision of the EOPs.
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