ML17157A084
| ML17157A084 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 03/16/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17157A083 | List: |
| References | |
| NUDOCS 9003260452 | |
| Download: ML17157A084 (13) | |
Text
l UNITED STATES NUCLEAR REGULATORY COMMISSION EVALUATION OF PROCEDURES GENERATION PACKAGE PENNSYLVANIA POMER 5 LIGHT COMPANY SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1
AND 2 DOCKET NOS. 50-387 AND 50-388
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WASHINGTON, O. C. 20SSS ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
1.0 INTRODUCTION
Following the Three Mile Island (TMI) accident, the Office of Nuclear Reactor Regulation developed the "TMI Action Plan" (NUREG-0660) which required licensees of operating reactors to reanalyze transients and accidents and to upgrade emergency operating procedures (EOPs)
(Item I.C.l).
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,"
describes the use of a "Procedures Generation Package" (PGP) to prepare EOPs.
Submittal of the PGP was made a requirement by Generic Letter 82-33, "Supplement 1 to NUREG-0737, Requirements for Emergency
Response
Capability."
The generic letter requires each licensee to submit a
PGP, which includes:
(i)
Plant-specific technical guidelines (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 evaluation summarizes the review of the Pennsylvania Power 5 Light Company (PPLL) response to the generic letter related to development and implementation of EOPs (Section 7 of Generic Letter 82-33) for Susquehanna Steam Electric Station (SSES) Units 1 and 2.
Our review was conducted to determine the adequacy of the PP&L program for preparing, implementing, and maintaining upgraded EOPs for SSES.
This review was based on NUREG-0800, Subsection 13.5.2, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants."
Section 2 of this report briefly discusses the PPAL submittal, the NRC staff review, and the acceptability of the submittal.
Section 3 contains the conclusions of this review.
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90032C~0452 900316 PDR ADOCK 05000387 P
As indicated in the following sections, our review determined that the procedure generation program for PP&L has several items that must be satisfactorily addressed before the PGP is acceptable.
PP&L should address these items in a revision to the PGP, or document why such revi-sions are not necessary.
This revision and/or justification should not be submitted to NRC, but should be retained for subsequent review by the NRC inspectors.
The revision of the
- PGP, and subsequently of the
The revision should be made in accordance with the SSES administrative procedures and 10 CFR 50.59.
2.0 EVALUATION AND FINDINGS In a letter dated May 13, 1985 from N.W. Curtis (PP&L) to W.R. Butler (NRC),
PP&L submitted its PGP for SSES.
The PGP contained an introduction and the following sections:
Plant-Specific Technical Guidelines Writer's Guide Verification Program Validation Program EOP Training Program.
The NRC staff review of the SSES PGP follows.
A.
Plant-Specific Technical Guidelines (P-STG)
Because staff evaluation of Revision 4 of the generic technical guidelines is now complete, the P-STG prooram description should be revised to conform with Revision 4 of the General Electric Boiling Hater Reactor Owner 's Group (BWROG) Emergency Procedure Guidelines (EPGs).
Safety significant deviations from the BWROG Emeroency Procedures Guidelines should be documented, justified, and archived for future reference.
B.
Writer's Guide The writer's guide was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899.
The writers'uide is intended to illustrate specific areas of EOP flow chart preparation from the EPGs, including procedure interrelationships, step preparation, vocabulary, and format.
Our review of the SSES writer's guide identified the following concerns:
1.
Section 6.4.5.b states that cautions and notes should be located in an area on the flow chart entitled CAUTIONS AND NOTES.
It would appear that cautions and notes are located in one area and from the examples in the writer's guide they appear to be listed and mixed in this area, not segregated.
The following items should be addressed:
a.
The writer's guide should be expanded to indicate that notes and cautions will be placed directly before the step or procedure to which they apply.
b.
Cautions are defined differently than notes.
The writer' guide does not appear to provide a way of differentiating between the two.
The writer's guide should provide a
method by which cautions are easily distinguished from notes.
2.
Conditional and logic statements are very important and widely used in EOPs.
It is very important that writers understand the meaning of logic terms and how they are used and combined to make logic statements.
Section 6.5.4 should be modified to address the following:
a.
Section 6.5.4.b states that the use of time dependent actions should be avoided "whenever possible."
The writer's guide should be expanded to identify the means provided to assist the operator in performing the steps within the required time frame when time dependent steps are necessary.
b.
The examples shown in Section 6.5.4 are not consistent with the guidance provided and not consistent with each other.
For example, the example in Section 6.5.4.f contains an underlined IF and THEN, but in Section 6.5.4.g and 6.5.4.i IF is not underlined and the THEN is not used.
Also, the guidelines do not require a
comma to separate. the IF part from the THEN part.
In Section 6.5.4.h, and 6.5.4.j the logic terms are capitalized, but in Sections 6.5.4.a through 6.5.4.d they are in lower case.
The writer's guide should provide guidance regarding underlining, punctuation, and capitalization of logic terms and the examples provided should be consistent with the guidance given.
c.
Section 6.5.4.c should be revised to state that "then" is always used with "when."
d.
Section 6.5.4.j should be revised to discuss the format for combinations of "AND" and "OR" with "IF" and "THEN" as occasions may arise when such use is necessary.
e.
Section 6.5.4 in the writer's guide should be expanded to include more examples of acceptable and unacceptable combinations.
See NUREG-0899, Appendix 8, for additional information.
3.
Flow charts can be valuable means of presenting information,
'owever, to ensure their consistent use the writer's guide should address the following concerns:
Section 6.5.2 states that only capitalized letters should be used in flow charts.
If all words are capitalized, then capitalization cannot be used for emphasis..
Furthermore, text written in all capitals is more difficult to read than mixed case.
The writer's guide should be revised to indicate that capitalization in flow charts will conform to the rules established for written procedures.
b.
Section 6.6.7.a begins with the phrase, "When cautions contain actions..."
Cautions (as well as notes) should not contain operator actions.
The writer's guide should define cautions and notes and state that they are not to contain operator action statements.
Further, Section 6.6.7.a should state whether the caution goes above or below the division line.
c.
Section 6.?.10 states that entry symbols should point to the right and not come in from the left.
Yet the example shows the entry symbol coming in from the left and pointing to the right.
The text should be revised to coincide with the example.
Additional information regarding flowchart design may be found in NUREG/CR-5228, Vol.
1 and 2, Techniques for Preparing Flowchart Format Emergency Operating Procedures.
4.
EOPs are primarily composed of various types of action steps the operator is to perform.
These steps include simple action steps, verification steps, continuous or periodic steps, alter-native and equally acceptable
- steps, and steps which refer the operator to another subsection of the procedure.
The definition,
- content, and format of each type of action step needs to be described in the writer's guide to ensure that the procedure writers can write them consistently and correctly. 't is partic-ularly important for the symbols used in the flow chart to be distinct for each type of step.
The guidance for both the wording of the step and the symbolology to use in the flow chart should be provided in the writer's guide.
See NUREG-0899, Subsections 5.7.2 - 5.7.8, for additional information.
5.
Section 6.4.10 discusses referencing other procedures within a procedure and states that the content and format of the
'reference is presented in'Section 6.7.2.
However, this section does not include information on reference content or format.
The writer's guide should provide a discussion of the content and format of a reference statement.
- Further, the writer' guide should describe the criteria used to determine when the steps of a referenced procedure are to be included in the EOP rather than referenced.
6.
Sometimes components, equipment, control panels, etc.,
referenced in EOPs are seldom used, remotely located, or difficult to locate.
The writer's guide should provide criteria for the writer to determine when to include location information and the format for the location information.
7.
To minimize confusion, delays and errors in execution of EOP
- steps, the following concerns should be addressed in the writer' guide:
a.
EOPs should be structured so that they can be executed by the minimum shift staffing and minimum control room staffing required by the Technical Specifications.
b.
Instructions for structuring EOPs should be consistent with the roles and responsibilities of the operators.
c.
Action steps should be structured so as to minimize movement of personnel around the control room while carrying out procedural steps (where the technical guidelines permit).
d.
Action steps should be structured to avoid unintentional duplication of tasks.
e.
EOPs should be structured so that the control room supervisor will be able to keep up with staff actions and plant status.
See NUREG-0899, Section 5.8, for additional information.
8.
Because of the stressful conditions under which EOPs are used, a high possibility of error exists when any calculations or conversions of numerical data are required of operators.
- Thus, it is critical that limits, tolerances, and acceptance values are presented in a manner easily and immediately understood by the operator.
The example calculation, Figure 6.4.9.c, does not provide the parameter name or sufficient other information to instruct the operator as to what value is to be used in the sixth line of the calculation.
This figure should be revised accordingly.
Additionally, Section 6.4.9.c.5 (page
- 13) should be revised to state such information should be provided.
- 9.
Color coding and line pattern coding are helpful techniques for improving the usability of flow charts.
>lith regard to this the writer's guide should be revised as follows:
a.
Section 6.4.9.a.4, defines color coding and labeling to be used with flow chart graphs.
However, the referenced
- example, Figure 6.4.9.a illustrates the use of line pattern coding and labeling.
Figure 6.4.9.a or Section 6.4.9.a.4 should be revised so that they are consistent.
If line pat-tern coding is to be used for the writer's guide example, then "[RED]" and
"[YELLOW]" should be noted in the appropriate areas of the graph.
b.
Section 7.0, Color Conventions, should be revised to incorporate the use of colors discussed in Section 6.4.9.a.4.
c.
Section 8.0, Producing and Revising Procedures, should describe how color coded flow chart graphs will be produced and reproduced to maintain the color coding.
10.
Yocabulary and syntax used in EOPs should be readily understood by all operators.
So that EOPs can be clearly understood, the writer's guide should be revised as follows:
a.
Attachment B should be expanded to include all acceptable verbs for use in the EOPs.
Attachment F of the verification procedure, Item 11, refers to "open," "turn," and "shut,"
which are not included in the verb list.
Section 6.5.3.a.2 should be revised to state that Attachment 8 is an inclusive list.
b.
Paragraph 6.5.3.b.2 (page
- 16) defines the use of the modifier "can be."
The accompanying example does not use the modifier, "can be."
This section and the example should be revised to correct this inconsistency.
c.
Section 6.5.4.i should be revised to clarify the use and format of the exclusive "OR" as occasions may arise when its use is necessary.
d.
Section 6.5.5 states that statements which present options may be constructed as sentences or lists, and if a qualifying conjunction is missing, "or" will be assumed.
The writer's guide should state how the writer should format and word an option's statement and provide examples so that it can be recognized and a missing conjunction can be correctly and safely assumed to be an "or."
11.
EOPs must be current to be usable.
Section 8.2 should be expanded to include a description of a system for ensuring that the EOPs are updated in a timely fashion when changes occur in plant design, Technical Specifications, technical guidelines, the writer's guide, the control room, or other plant procedures that interface with the EOPs.
See NUREG-0899, Subsection 6.2.4, for additional information.
With adequate resolution of the above items, the SSES writer' guide should accomplish the objectives stated in 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.
Verification and Validation Program The descriptions of the verification and validation programs were reviewed to determine if they described acceptable methods for accomplishing the objectives stated in NUREG-0899.
The SSES verifi-cation and validation descriptions consist of a set of relevant def-initions, personnel types and responsibilities, the verification and validation process, and a set of rather comprehensive checklists and forms.
The PGP gives as objectives for the verification and validation process:
That the EOPs are written correctly; they incorporate information from the SSES writer's guide and other appropriate administrative policies.
That the EOPs are technically accurate; they incorporate generic and/or plant-specific technical information from EOP source documents.
That the EOPs are usable; they can be understood and followed by trained operators without errors, delays, confusion, etc.
That there is a correspondence between the procedures and the control room/plant hardware.
That the language and level of information presented in the EOPs are compatible with the minimum number, qualifications,
- training, and experience of the operating staff.
That there is a high level of assurance that the procedures will work.
Our review of the SSES verification and validation program description identified the following concerns:
1.
Section 5.1 of the verification program descr iption states that verifiers may be selected from various plant groups and disciplines.
The use of variety of verifiers helps to ensure that all aspects of EOPs are completely and accurately verified.
The verification program should state that a variety of verifiers will be selected from relevant plant groups and disciplines.
The verification program should also specify those individuals'oles and responsibilities.
2.
Section 7.2 of the validation program description states that scenarios will be selected so that the simulator EOP validation will exercise as many steps of each EOP as practical.
Section 6.3.1 of the validation program states that if a scenario is beyond the capability of the simulator, a table-top review may be used for validation.
The validation program should state that walk-throughs are to be used if the simulator is not capable of carrying out parts of the
- EOPs, and that a table-top review should only be used to supplement simulator or walk-through validation.
3.
The verification and validation process needs to be carried out for both units to the extent there are differences between the two units in terms of instrumentation,
- controls, equipment or any other'aspect which may affect plant safety.
The verification and validation program descriptions need to address how the two units wi 11 be accounted for in the verification and validation process.
With adequate resolution of the above items, the SSES verification and validation programs should accomplish the objectives stated in NUREG-0899 and should provide assurance that the EOPs adequately incorporate the guidance of the writer's guide and the technical guidelines and will guide the operator in mitigating emergency conditions.
0.
Training Program I
The description of the operator training program on the SSES EOPs was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899.
The EOP training program will consist of classroom instruction, simulator demonstrations, and simulator performance.
The four broad objectives of the training program are:
Trainees must understand the technical bases of the EOPs.
Trainees must have a working knowledge of the technical contents of the EOPs.
Trainees must understand the philosophy of the guidelines.
Trainees must be capable of executing the EOPs under realistic operational conditions.
Our review of the SSES training program description for EOPs identified the following concerns:
1.
It is crucial that all operators be trained on all aspects of each EOP so that operators are prepared to execute the operator action in each EOP to their fullest extent.
The EOP Training program description should make this requirement clear.
2.
The PGP states that the plant-specific Susquehanna simulator will be used for training.
The EOP training program description should address the following:
a.
Indicate the use of the simulator for team training using minimum staffing and for previously planned operator roles.
b.
Indicate the use of a wide variety of scenarios, including multiple (simultaneous and sequential) failures, to fully exercise (to the extent possible) the EOPs on the simulator and thus expose the operators to a wide variety of EOP uses.
3.
The training program description should be expanded to include a discussion of the methods to be used to train operators in areas where the simulator does not react like the plant and in parts of the EOPs that cannot be run on the simulator.
These areas would include differences between the simulator and the control room as well as differences between the two units.
4.
The training program should include a statement of commitment to train all operators on all EOPs, including revised
With adequate resolution of the above items, the SSES training program should accomplish the objectives stated in HUREG-0899 and should result in appropriate training for the SSES operators on the new EOPs.
- 10,-
3.0 CONCLUSION
S The staff concludes that, the PGP submitted by Pennsylvania Power
& Light Company for Susquehanna Steam Electric Station in a letter from N.
W.
Curtis to the NRC, dated May 13, 1985, should be reviewed to address the programmatic improvements outlined in Section 2 of this report.
A PGP re-vision should not be submitted to the NRC.
For items the licensee deems inappropriate, no longer applicable, or unnecessary 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.
Dated:
March 16, 1990
O 1i I
Mr. Harold M. Keiser Pennsylvania Power 5 Light Company Susquehanna Steam Electric Station Units 1
5 2
CC:
Jay Silberg, Esq.
Shaw, Pittman, Potts 5 Trowbridge 2300 N Street N.M.
Mashington, D.C.
20037 Bryan A. Snapp, Esq.
Assistant Corporate Counsel Pennsylvania Power 5 Light Company 2 North Ninth Street Al 1 entown, Pennsy1 vani a 18101 Mr. J.
M. Kenny Licensing Group Supervisor Pennsylvania Power 5 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Mr. Scott Barber Senior Resident Inspector U. S. Nuclear Regulatory Commission P.O.
Box 35 Berwick, Pennsylvania 18603-0035 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Resources Commonwealth of Pennsylvania P. 0.
Box 2063 Harri sburg, Pennsylvania 17120 Mr. Jesse C. Tilton, III Allegheny Elec. Cooperative, Inc.
212 Locust Street P.O.
Box 1266 Harrisburg, Pennsy 1 vani a 17108-1266 Mr. S.
B. Ungerer Joint Generation Projects Department Atlantic Electric P.O.
Box 1500 1199 Black Horse Pike Pleasantville, New Jersey 08232 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, Pennsylvania 19406 Mr. Harold G. Stanley Superintendent of Plant Susquehanna Steam Electric Station Pennsylvania Power and Light Company 2 North Ninth Street Al1 entown, Pennsy1 vani a 18101 Mr. Herbert D. Woodeshick Special Office of the President Pennsylvania Power and Light Company 1009 Fowles Avenue Berwick, Pennsy'lvania 18603 Mr. Robert G. Byram Vice President-Nuclear Operations Pennsylvania Power 'and Light Company 2 North Ninth Street Allentown, Pennsylvania 18101
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