ML18040B007

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Forwards Response to Generic Ltr 82-33,Suppl 1 to NUREG-0737, Requirements for Emergency Response Capability. W/One Oversize Encl.Aperture Card Is Available in PDR
ML18040B007
Person / Time
Site: Susquehanna  Talen Energy icon.png
Issue date: 04/15/1983
From: Curtis N
PENNSYLVANIA POWER & LIGHT CO.
To: Schwencer A
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, PLA-1621, NUDOCS 8304220569
Download: ML18040B007 (40)


Text

REGULATORY "iFORMATION I

DISTRIBUTION SY. EM (RIDS)

'ACCESSION NBR; 8304220569 OC DATEi 83/00/15 NOTARIZ: NO DOCKET Electr ic Stationi Uni;t li Pennsyl va

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FACIL:.50 387 Susquehanna Steam 50-388 'Susquehanna Steam Electr ic Stationi Unit 2i Pennsylva 0 AUTH+NAME AUTHOR AFFILIATION CURTIS<N,W, lPennsyl vania Power 8 Light ~Co ~

'RECIP,NAME RECIPIENT AFFILIATlON

'SCHNENCERi'A, Li censing Br anch "2

SUBJECT:

Forwards response to Generic Ltr,82 33'-Suppl. 1, to NUREG 0737'"Requirements for Emergency Response Capabilitty," 8/one oversize, encl,Aperture card is available DISTRIBUTiON ~CODE: A003S ICOPIES >RECEIVED:LTR ..ENCL g SIZE>>,

TITLE: OR/Licensing Submittal: Suppl 1 to NUREG 0737(Generic Ltr 82-33)'OTE 8: icy NMSS/FCAF/PM, 05000387 1cy NMSS/FCAF/PM, 05000388 RECIPIENT IES RECIPIENT COPIES ID CODE/NAME LTTR ENCI ID iCODE/NAME LTTR ENCL NRR LB2 BC 7 7 INTERNALS IE/DEPER/EPB NRR/DHFS/HFEB 1 1 NRR/DHFS/PSRB 1 1 NRR/DL/ORAB 1 1 NRA/DL/ORBS 5 '.5 NRR/DS I/CPB 1 NRA/DSI/ICSB 1 1 NRR/DS I/METB 1 1 NOTES'COP

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TOTAL NUMBER OF COPIES REQUIRED: LTTR Q ENCL

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0 Pennsylvania Power & Light Company Two North Ninth Street ~ Allentown, PA 18101 ~ 215/770.5151 Norman W. Curtis Vice President-Engineering & Construction-Nuclear-215/ 770-5381 April 15, 1983 Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555 SUSQUEHANNA STEAM ELECTRIC STATION Docket No. 50-387 RESPONSE TO GENERIC LETTER 82-33 50-388 ER-100450 FILE 896 PLA- 1621

Dear Mr. Schwencer:

On December 30, 1982, Pennsylvania Power 5 Light Company received NRC Generic Letter 82-33, Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability. PP5L is a participating member of the Nuclear Utility Task Action Committee on Emergency Response Capabilities (ERC NUTAC), which includes over forty uti'lities and is administratively supported by INPO. Their guidance has been useful in developing our integrated approach described in this letter.

Current Status PPttL addressed the TMI Emergency Response capability requirements in Chapter 18.0 of the FSAR. These proposals have been reviewed and approved by the NRC and are addressed in the Safety Evaluation Report. With the issuance of Generic Letter 82-33, several NRC requirements have been changed or clarified.

Consequently, we have re-examined our plans for emergency facilities and have concluded that several changes are necessary and appropriate.

Before discussing any changes, however, we should review the current status of the major items addressed in Generic Letter 82-33:

(a) The Safety Parameter Display System (SPDS) for SSES will be provided by a consortium of Levy Systems and Simmonds Precision. The system design is QOY presently completed and software development and hardware procurement are in progress. The system was described in detail in PLA-704 to 0/Sbf/,,

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- Apr'il 15, 1983 SSES PLA-1621 ER-100450 File 896 Mr. A. Schwencer B. J. Youngblood from N. W. Curtis dated April 2, 1981. Details of the SPDS are also presented in Chapter. 7.0 of the SSES Emergency Plan.

(b) An initial Control Room Design Review was conducted by PP&L with assis-tance from experienced human factors personnel from General Physics Corporation prior to licensing of SSES Unit 1. The NRC evaluation of that review is contained in Section 22 and Appendix F to the SSES SER.

Since the initial review effort, PPSL has established a program for a Detailed Control Room Design Review. This program was submitted to the NRC in PLA-1079 dated June 3, 1982. PP8L has completed the Control Room survey','unction and ta'sk analysis, Control Room inventory and has assessed the Control Room for Human Engineering Deficiencies (HEDs).

(c) Post-accident monitoring instrumentation was addressed in PLA-965 to Mr. A. Schwencer from Mr. N. W. Curtis dated November 13, 1981. The NRC evaluation of our position is contained in Sections 7, 22 and Appendix D of the SSES SER.

(d) Emergency Operating Procedures based on an early version of the BWR Owners Group Emergency Procedure Guidelines have been reviewed by the NRC. The final version of these procedures, which incorporated NRC comments, was submitted to the NRC in PLA-791 to B. J. Youngblood from N. W. Curtis dated May 15, 1981. The NRC evaluation of those procedures is contained in Section 22.2 (1.C.l) of the SSES SER.

(e) The Emergency Response Facilities (ERF), which include the Technical Support Center (TSC), Operations Support Center (OSC), and the Emergency Operations Facility (EOF), are complete and operational. Descriptions of these facilities are provided in Chapter 7.0 of the SSES Emergency Plan.

The TSC and EOF are capable of acquisition, collection, evaluation and display of information on conditions in containment, radiological releases and meteorology necessary to determine protective measures. The TSC and EOF are provided with all documents required for their functions. They provide sufficient working area for PPSL, federal, state, and local personnel. Successful emergency drills have been completed and observed by the NRC in March of 1982 and March of 1983. NRC evaluation of these facilities is contained in Section 22.2 (III.A.1.2) and Appendix D to the SSES SER.

I The emergency plan and emergency facilities implemented by PPSL provide the capability for timely and adequate response to an emergency.

Chan es to the Plan As a result of the changed requirements in Generic Letter 82-33 and the experience gained in the emergency exercises performed at Susquehanna, we have concluded that several changes in our approach to emergency planning are appropriate. These are identified and discussed in Attachment I.

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April 15, 1983 SSES PLA-1621 ER-100450 File 896 Mr. A. Schwencer Schedule In response to Generic Letter 82-33, we have developed an integrated implemen-tation schedule using appropriate portions of the ERC NUTAC's draft Guideline for an Inte rated Im lementation Plan as input. This draft guideline is the ERC NUTAC's method of ideal integration of Emergency Operating Procedures (EOP), Control Room Design Review (CRDR), Regulatory Guide 1.97 (RG-1.97),

Safety Parameter Display System (SPDS) and Emergency Response Facilities (ERF). Although much of this emergency response capability has already been completed by PP8L, the NUTAC guidance was taken into consideration in the development of our plant-specific input and process criteria for the remaining work. Attachment III contains our proposed integrated schedule for the remaining work.

Inte ration Plan Attachment II to this letter is the detailed plan for integration of emergency response capabilities which includes a verification and validation plan.

~Summar This letter provides the necessary details of our existing emergency response program, a description of proposed enhancements and changes and a schedule and plan for integrated implementation. This information is provided in response to Generic Letter 82-33 and forms the basis for your evaluation based on currently established regulatory requirements. We are available to discuss this response with your staff. We are prepared to finalize this plan as soon as possible.

Very truly yours, Norman W. Curtis BW:cvc HB-5 Attachments

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ATTACHMENT I PROPOSED CHANGES TO PREVIOUS COMMITMENTS Prior to Generic Letter 82-33, PP8L made various commitments with respect to emergency planning. These commitments were made based on interpreta-tions of the then existing regulatory guidance. The publication of Supplement 1 to NUREG-0737 along with experience gained through drills exercising our emergency response capability has indicated that certain changes to the existing program would be appropriate. The proposed changes and reasons for them are listed below:

SPDS The SPDS for SSES will be provided by a consortium of Levy Systems and Simmonds Precision. The system design is presently completed. The system description as presented in PLA-704, dated April 2, 1981, and Chapter 7.0 of the SSES Emergency Plan remains unchanged. Installation of a func-tional system is scheduled for completion by September 30, 1983. However, operator training must be conducted prior to considering the system operational. Additionally, we feel validation of the system must also be conducted prior to the system being considered operational. User training and validation of the system are presently scheduled for completion by December 30, 1983. However, our current license condition requires SPDS be completed by September 30, 1983. A request for change in licence condition will be submitted to reflect the additional time needed for training and validation.

Mannin of the EOF PP&L committed to having the emergency operations facility functional, including the stationing of a senior manager at the EOF, within approxi-mately one hour of declaration of a site or general emergency. This commitment, although it appeared to be beneficial, has been demonstrated during drills to have the potential for negatively affecting the manage-ment of an emergency. In order to accommodate the requirements imposed by this commitment, multiple transfers of authority have occurred at times critical to the successful management of the emergency. The multiple transfers are necessitated by the combination of the obligation to staff within one hour and the Company's desire to apply its best management resources to the emergency. Any transfers of authority should take place at times which more naturally fit the developing management of the emer-gency and not at artificially predetermined times established to meet an arbitrary requirement. Additionally, the number of transfers of authority should be minimized to avoid loss of continuity. Our experience during drills indicates that TSC personnel can effectively attend to plant safety and manage the off-site protection function until a logical transition to the Recovery Manager's staff can occur. Because of the unique features of off-site radiological monitoring and assessment activities, we have seen the benefit of applying additional dedicated resources to this function as quickly as possible in the EOF. A future revision to Section 6.0 of the

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SSES Emergency Plan will be submitted to reflect the following. First, manning of the EOF by radiological monitoring and assessment personnel shall occur within one hour of the declaration of a site or general emergency. This manning will include a senior manager capable of making radiological assessments and protective action recommendations. Secondly, manning of the EOF by the Recovery Manager and his staff should occur on a timely basis, preferably within three hours of the declaration of a site or general emergency.

Emer enc Res onse Com uter S stem The Emergency Response Computer System, as it was envisioned prior to Generic Letter 82-33, is described in detail in Section 7.0 of the SSES Emergency Plan. The original purpose of ERCS was to provide a seismically qualified, single failure proof, safety grade type system with remote interrogation capability for the acquisition, preparation, and display of Unit 1, Unit 2, and common plant data for the ERF. The overall design was directed toward providing both a dedicated system for the operation of a SPDS, and an integrated system which would tie together the operations of the various ERF. The previously envisioned system went far beyond the requirements of Supplement 1 to NUREG 0737.

Currently, we have installed plant process computer access terminals in the TSC and EOF. Data displays on these terminals were utilized to support emergency management activities during our last NRC observed emergency drills. Prior to our next NRC observed emergency drill, we plan to have a functionally independent SPDS utilizing its own data acquisition, preparation, and display systems. The SPDS is comprised of two subsystems, one providing display to the TSC and control room and the other providing display to the EOF. Based on our successful utilization of the existing System and the status of present requirements, we feel that these systems will satisfy all data requirement in the TSC and EOF. We no longer find it necessary to install a dedicated, independent emergency data acquisi-tion system. A future revision to Section 7.0 of the SSES Emergency Plan will be submitted to reflect this change.

Location of the Backu EOF PP&L's current emergency planning philosophy includes maintenance of a backup EOF located in Hazleton, Pennsylvania. Although this facility is adequate in every respect, recent experience indicates that the technical support function would be better served by the Allentown General Office.

Even though this facility is approximately 50 miles from the site, there are obvious advantages to utilizing it in a technical support roll in the event the primary EOF is evacuated. During the course of any emergency the General Office serves as an extension of our technical support capabil-ity and would, therefore, be manned throughout the course of an emergency.

All necessary communication facilities are in place and fully functional.

Normally, during an emergency there is an established data flow to the

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General Office thereby eliminating the potential for losing continuity which could occur should the primary EOF be evacuated under the present scheme. We propose that the backup facility in Hazleton be utilized to maintain PP&L presence in the area near the site in the event of primary EOF evacuation. Functions maintained in this facility would include overall emergency management, radiological assessment, and liaison with off-site agencies. Technical support for the facility would be provided by a combined technical support group located in Allentown. We believe evacuation of the primary EOF has a very low probability of occurring since the facility has a protection factor of at least five, is capable of isolating ventilation, and is equipped with HEPA filters. A future revision to Section 7.0 of the SSES Emergency Plan will be submitted to reflect this change.

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ATTACHMENT II Pro osed Inte ration Plan PP&L has developed the following plan for integration of Emergency Response Capabilities. The plan assures that efforts toward completing enhanced emergency response capabilities are well coordinated and consolidated.

The plan is also responsive to the requirements of Supplement 1 to NUREG-0737.

The plan addresses the following individual Emergency Response capability enhancements:

o Revised Emergency Operating Procedures (EOPs) o Safety Parameter Display System (SPDS) o RG 1.97 Instrumentation o Emergency Response Facilities o Detailed Control Room Design Review (DCRDR) o Training on the above capabilities For the purpose of integration, these individual capabilities were grouped into two distinct systems. System 1 (depicted in Figure 1) can be called the "Accident Mitigation and Prevention System." This system revolves around the control room "operator" and involves the integration of the operating shift, the Control Room (including all enhancements), the emergency operating procedures and operator training.

System 2 (depicted in Figure 2) can be called the "Emergency Plan Response System." This system revolves around the "emergency personnel" and involves the integration of emergency personnel (as per the emergency plan), emergency response facilities (including all enhancements), the Emergency Plan Implementing Procedures (EP-IPs), and emergency plan training. Integration of capabilities within each of these systems is vital and the plan is directed toward validating the effective integration of capabilities within each of these systems. Integrated schedules have been developed separately for each sys'em. Also, separate validation tests will be performed on each system. Validation testing on System 2 will be performed during the yearly full-scale, NRC observed, emergency plan exercises. Validation of System 1 will be performed on the Susquehanna simulator to the maximum extent possible. It is recognized that there is some interplay between the two systems; however, the influence is a second-order effect and can be introduced into the individual system validations without the necessity of,testing both systems concurrently.

The integration plan is described in two documents. The first is an integrated schedule of critical activities for System 1 and System 2

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(Attachment III to this letter). The salient features represented in this schedule are as follows:

o SPDS will be made "functional" on a schedule independent from and in advance of the schedule for the remainder of System 1.

o SPDS will be declared "operational" following a successful validation of System 1 with the addition of SPDS.

o System 2 will be validated during each yearly full scale exercise.

Capabilities exercised for the first time in a given exercise will be considered "operational" if successfully validated during that exercise. (See Table 1 for a proposed timetable for System 2 capa-bility validation.)

o System 1 will be validated in the simulator prior to the first refueling outage on Unit l.

o All System 1 enhancements will be in place in each unit prior to startup from the first refueling outage for that unit.

o Completion of all activities supports licensing of Unit 2.

The second document is an integrated verification and validation (V@V) plan. There will be three distinct VIV plans for the emergency response capability enchancements. One for the early SPDS implementation, one for the final System 1 configuration, and one for the staged implementation of System 2. Proposals for all three V8V plans are attached (Attachment A).

The integration plan is intended to achieve an optimum integration of emergency response capability and validate that the resultant integrated systems produce the desired increase in ability to mitigate and respond to emergencies at Susquehanna SES.

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Table 1 Pro osed S stem 2 Validation Timetable Full Scale Exercise New* Elements Validated March, 1983 Facilities EOF, Process Computer Terminals, Van Sciver Bldg.

Procedures Revised EP-IPs Personnel Inexperienced personnel

~Trainln Training performed by Nuclear Training for first time April, 1984 Facilities SPDS (in Control Room, TSC & EOF), OSC Procedures Revised EP-IPs Personnel Inexperienced personnel

~Trainfn - Revised training April, 1985 Facilities Final RG 1.97 Functions Procedures Revised EP-IPs, Revised EOPs Personnel Inexperienced personnel

~Trainin - Revised training

  • New is defined as changes since the last full-scale exercise.

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Figure 1 System 1 Accident Mitigation and Prevention INCLUDING:t Detailed Control Room Design Review Modifications CONTROL Reg. Guide 1.97 Parameters ROOM Safety Parameter Display System "OPERATOR" EMERGENCY TRAINING OPERATING PROCEDURES System Validation: Simulator Test

Figure 2 System 2

.:. Emergency Plan Response,.....,

INCLUDING:

Reg Guide 1 97 Parameters'perations Support Center Technical Suppoit. Center Operations Facility 'mergency EMERGENCY RESPONSE, FACILITIES "EMERGENCY PERSONNEL" EMERGENCY PLA'N TRAINING IMPLEMENTING PROCEDURES System Validation: Full Scale Emergency Plan Drill

ATTACHMENT A INTEGRATED V&V PLAN FOR EMERGENCY RESPONSE CAPABILITY Overview PP&L has developed an integration plan to address emergency response ca-pabilities.'his plan divides emergency response capabilities into two systems. The integration in System 1 is directed toward improving the control room operator's ability under emergency conditions to accomplish the actions needed to mitigate the consequences of the emergency. The inte-gration in System 2 is directed toward improving the ability of emergency plan personnel under emergency conditions to respond to the emergency. An evaluation of the capabilities of these systems is needed to determine fact the changes to the systems have improved the response and not degraded if in emergency response capability. This evaluation is system validation.

Prior to system validation, verification of changes to system components should be completed. Component verification ensures consistency between the system components and appropriate source documents. Source documents are the fundamental documents or records upon which the system components are based. Appropriate source documents are determined by the interfaces of the system components. Each system component should have a source document that describes the component itself and each of its interfaces with the other system components. The objective of verification is to determine maintained if consis-tency has been between system components and the appropriate "

source documents.

System validation addresses the workability of the components within the system as they exist at the time of validation. Its objective is to deter-mine if the components are compatible as they interface when the system performs its desired function (i.e., accident mitigation or emergency plan response). Determination of this compatibility implies a dynamic, performance-based evaluation involving all the system components. This evaluation is different than the static, comparative-based evaluation in component verification. However, the combination of the two in a Verifica-tion and Validation (V&V) Program provides confirmation that the changes to system components are technically accurate and that the total system is operationally correct.

PP&L V&V Plan Verification and validation are inherent in the normal course of business in PP&L. Though not labeled as such document reviews, gA audits, simulator training and many other routine functions are pieces of an ongoing V&V Program. For this reason it is not necessary to create a specific stand-alone V&V Program for Emergency Response Capability. Instead a plan has been developed to assure that all elements of an integrated V&V Program are identified, completed and documented.

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The plan is actually three distinct plans. One plan addresses verifica-tion and validation of System 1 immediately following installation of SPDS. Since SPDS is being implemented prior to implementation of many of the other System 1 enhancements, this plan only addresses changes in components associated with the addition of SPDS to an existing System 1.

The existing System 1 underwent extensive verification and validation during the recently completed preoperational test program, startup test program and operator licensing program.

A second plan addresses verification and validation of System 1 with all components in their final configuration (i.e., all enhancements complete).

The integration plan was based on making the validation phase of this plan possible prior to the completed System 1 being "operational." The following strategy was employed to make this possible:

o As many changes as possible to System 1 components will be implemented in the Susquehanna simulator prior to the first refueling outage on Unit 1.

o The System 1 validation will be performed on the Susquehanna simulator prior to the first refueling outage on Unit 1. (Note:

this validation is applicable to both Unit 1 and Unit 2.)

o All changes to System 1 components will be implemented in Unit 1 prior to or during the first refueling outage on Unit 1 and in Unit 2 prior to or during the first outage on Unit 2.

o The validated System 1 with all enhancements will be "operational" in both units prior to startup from the first refueling outage on the respective unit.

The third plan addresses verification and validation of System 2. System 2 validation occurs with every Full-scale Emergency Plan Exercise. As compo-nent enhancements are complete, this ongoing V@V program will address them.

The specific plans are described in the attached tables. Each plan addresses the following:

For Verification The element (component or interface) being addresssed.

The source document on which that element is based.

The methodology for verification of that element.

The method of documenting the verification process and resolution of findings resulting from the verification.

References describing applicable verification guidance.

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o The general objective of verification of the element.

For Validation o The element (interface or system) being addressed.

o The methodology for validation of that element.

o The method of documenting the validation process and resolution of findings resulting from the validation.

o References describing applicable validation guidance.

o The general objective of validation of the element.

The plans assume the following general principles will be followed in each of individual segments of the V&V plan:

Objectives of the verification/validation will be established consistent with the plan.

Specific evaluation criteria will be developed to determine if the objective has been satisfied.

Adequate preparation will be made prior to performance of the verification/validation to assure adequate resources and specific guidance is available.

The verification/validation will be conducted using qualified personnel and acceptable practices.

All findings from the verification/validation will be resolved properly.

Documentation will be such that there is a clear paper trail for the entire process.

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SYSTEM 1 VIV FOR INTRODUCTION OF SPDS VERIFICATION PLAN (Verification Does Element Match its Source Document)

Source Documentation SPDS Design Spec. Design Review Levy Reports Levy Reports Ref. 1 (below)

(Objective Hardware & software reflect design guidance)

SPDS- Design Doc. HFE Review Levy Reports Levy Reports Ref. 1 (below)

OPERATOR (Objective HFE considerations for ability of operators to use SPDS)

SPDS- Design Doc. Design Review Levy Reports Levy Reports Ref. 1 (below)

EOPs (Objective Technical content of EOPs correlate with SPDS)

SPDS- Design Doc. Review of Doc. Review Doc. Review Ref. 1 (below)

TRAINING Lesson Plans (Objective Training program accurately reflects SPDS)

VALIDATION PLAN (Validation Does Element Perform Intended Function)

Documentation Element Methodolo of Validation of Resolution Reference SPDS Factory Acceptance Test Levy Report Levy Report Ref. 1 (below)

(Objective Hardware 5 software work as expected)

SPDS- SPDS Demonstration NT Records NT Records Ref.,l (below)

OPERATOR (Objective - SPDS can be used effectively by the operators)

SPDS- (Validated during System 1 validation) Ref. 1 (below)

TRAINING (Objective Training program adequately trains the operator to use SPDS)

SPDS- (Validated during System 1 validation) Ref. 1 (below)

EOP s (Objective - SPDS is an aid in performing EOPs)

SYSTEM 1 To be determined Special Report Special Report Ref. 1 (below)

(Objective SPDS in the Control Room can be used effectively by operators to aid in response to emergencies)

References (1) Guidelines for an Effective SPDS Implementation Program January, 1983 (INPO 83-003 (NUTAC)).

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SYSTEM 1 V&V FOR COMPLETED SYSTEM VERIFICATION PLAN Source Documentation Element Document ~Hethodolo of Verification of Resolution Reference EOPs EPGs Document Review Doc. Review Doc. Review Ref. 1 (below)

Forms Forms (Objective " EOPs reflect guidance in EPGs)

EOP's-OPERATOR Writer's Guide Document Review Doc. Review Doc. Review Ref. 1 (below)

Forms Forms (Objective - EOPs reflect HFE considerations in writer' guide)

EOP's-CONTROL ROOM Design Document Document Review Doc. Review Doc. Review Ref. 1 (below)

(or Control Room (or walkthru) Forms Forms itself)

(Objective - EOPs accurately reflect plant design)

EOP's"TRAINING EOPs Document Review Doc. Review Doc. Review Ref. 1 (below)

Forms Forms (Objective - Lesson plans & test accurately reflect EOPs)

CONTROL ROOM Design Document Post Installation Work Packages Work Packages Checkout (Objective - Control Room enhancements reflect design documents)

CONTROL ROOM- HFE Standards HFE Reviews DCRDR & HFE DCRDR & HFE Ref. 2 & 3 OPERATOR Reviews of Changes Review of Changes (below)

(Objective - The Control Room reflects human eng. guidance)

CONTROL ROOM- Design Document Document Review Document Review Document Review TRAINING Forms Forms (Objective - Lesson plans & tests reflect the as-built plant)

TRAINING NTIs QA Audits Audits Reports Audit Closeouts (or internal review) 4 (Objective - Training is performed in accordance with established STDs)

TRAINING-OPERATORS Training Reqmts. QA Audits Audit Reports Audit Closeouts (or internal review)

(Objective - Operat'or training fulfills the established requirements)

OPERATORS Operating Philosophy QA Audits Audit Reports Audit Closeouts (or internal review)

(Objective - Operator qualifications/staffing meet established criteria)

References (1) Emergency Operating Procedures Verification Guideline, December, 1982 (Preliminary).

(2) Control Room Design Review Survey Development Guideline (INPO 83-004) Draft (INPO).

(3) Human Factors Principles For Control Room Design Review (Draft) (INPO).

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SYSTEM 1 V&V FOR COMPLETED SYSTEM VALIDATION PLAN Documentation Element ~hothodolo of Validation of Resolution Reference CONTROL ROOM Post Installation Work Package Work Package Testing (Objective - Control Room enhancements function as designed)

EOP'S-OPERATOR (Validated during System 1 validation) Ref. 1 & 2 below (Objective - Operator can effectively use the EOPs)

EOP's-CONTROL ROOM (Validated during System 1 validation) Ref. 1 & 2 below (Objective "'OPs accurately reflect plant performance)

EOP '-TRAINING (Validated during System 1 validation) Ref. 1 & 2 below (Objective - Training on EOPs is adequate for performance)

CONTROL ROOM- (Validated during System 1 validation) Ref. 1 & 2 below OPERATOR (Objective - All Control Room equipment can be used effectively by the operator)

CONTROL ROOM- (Validated during System 1 validation) Ref. 1 & 2 below TRAINING (Objective - Training on Control Room is adequate for performance)

TRAINING-OPERATORS (Validated during System 1 validation) Ref. 1 & 2 below (Objective - Operator training is sufficient to perform functions)

SYSTEM 1 Dynamic Simulation Special Report Special Report Ref. 1 & 2 below (Objective - System 1 emergency response capability enhances the capability of the operator to mitigate or prevent emergencies)

References (1) Component Verification and System Validation Guideline, February, 1983 (Draft) (INPO NUTAC).

(2) Emergency Operating Procedures Validation Guidelines, November, 1982 (Draft) (INPO NUTAC).

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SYSTEM 2 V&V VERIFICATION PLAN SOURCE DOCUMENTATION ELEMENT DOCUMENT METHODOLOGY OF VERIFICATION OF RESOLUTION EP-IP's Emergency Document Review Doc. Review Doc. Review Plan Forms Forms (OBJECTIVE - EP-IP's reflect commitments in Emergency Plan)

EP IP~s Emerg. Writer Document Review Doc. Review Doc. Review Personnel Guide Forms Forms (OBJECTIVE - EP-IP's reflect HFE considerations in Writer's Guide)

EP-IP's ERF's As Built Document Review Doc. Review Doc. Review Facilities Forms Forms (OBJECTIVE EP-IP's accurately reflect emergency facilities)

EP-IP's Training EP-IP's Document Review Doc. Review Doc. Review Forms Forms (OBJECTIVE Lesson Plans 5 Tests accurately reflects EP-IP's)

ERF's Design Facility Evaluation Punch Lists Documents Reviews Report (OBJECTIVE ERF's reflect design documents)

ERF's Emerg. HFE Standards HFE Review Report HED's Personnel O (OBJECTIVE ERF's reflect Human Engr. guidance)

ERF's Training As Built Document Doc. Review Doc. Review Facilities Reviews Forms Forms (OBJECTIVE Lesson Plans 5 Tests reflect the as built facilities)

Emergency Plan NTI's QA Audit Audit Reports Audit C loseouts Training (or internal review)

(OBJECTIVE Training is performed in accordance with established standards)

Training Emerg. Training QA Audit Audit Reports Audit Closeout Personnel Matrix (or internal review)

(OBJECTIVE EP Training accomplished established requirements)

Emerg. Personnel Emergency QA Audit Audit Reports Audit Closeout Plan (or internal review)

(OBJECTIVE Emergency personnel qualifications/staffing meet established criteria)

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SYSTEM 2 V8V VALIDATION PLAN DOCUMENTATION ELEMENT METHODOLOGY OF VALIDATION OF RESOLUTION EP-IP's Emerg. (Validated during System 2 validation)

Personnel (OBJECTIVE Emergency personnel can effectively use the EP-IP's)

EP-IP's - ERF's (Validated during System 2 validation)

(OBJECTIVE EP-IP's are consistent with the flow in the ERF's)

EP-IP's Training (Validated during System 2 validation)

(OBJECTIVE - Training on EP-IP's is adequate for performance)

ERF's Emerg. (Validated during System 2 validation)

Personnel (OBJECTIVE ERF's are used effectively by emergency personnel)

ERF's Training (Validated during System 2 validation)

(OBJECTIVE Training on ERF's is adequate for performance)

Emerg. Personnel (Validated during System 2 validation)

Training (OBJECTIVE EP training is sufficient for emergency personnel to perform assigned functions)

Full Scale Exercise Critique Exercise Records Records (OBJECTIVE System 2 emergency response capability enhances the ability of emergency personnel to respond to emergencies)

A rt ATTACHMENT 3 SCHEDULE 29JANB2 17DEC82 22MRR83 15APR83 IAUG83 19SEP83 29SEP83 30SEP83 31BCT83 7DEC83 290EC83 300EC83 9JANB't 29FEBBV 28ttRRBV 30APRB'I 19JUNBV 25JULBV 26JULB'I 31AUGBV 31DECB't 12FEBBS 28FEBBS 29MRRBS 30RPRBS IMAYI35 LVMRYBS ZBNE 0 NRC/NUTRC SCHEDULE 1000 1001 1002 1003 170EC82 0 22lfAR83 0 15APR63 0 IRU663 3'I N U N NU N SN I C TER 82- SP E TS NR RC I E 1005 100't FINALIZE PLAN 8 SUBtllT FINAL PL R )h)R EjCj JHFS N TS NRC ZBNE I SYSTEII I 11'tV I JltHBV 13V HN 5 jh UN[V 2 CR I NS RL E I 12'I 1125 305E 83 27JANB'I 10 1110 IOJUNBV 1119 h 8'I GJUN 1 11 25JUL 'I FCB'I E 3 8 9 N L H N 1. U 1 N BGR 8 SIIBHIT RE HR IIR 1122 1123 1127 1101 1120 1128 1102 1112 1103 1139 0 I 0 'I INHVBZ GSEP83 I I JUN81 tl Jahet i e L 'I I 2384 81 19JUNB'I JUL 110CCBV 2 RCRP V PL PG N DV 1 5 I NAL OE R 1.

3 HBN-Slh TR41NI UN 4 RC PG 6 619Slh 5 ~N UN CetlPLET SN IG .

li TRAINING SN Sl UN N S Ilf UNIT UN I CR N

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1107 1129 1121 1109 I 126 1115 1116 J H IP 'I ONBV62 0 9 E 11 305 3 H 1 I u 61 U 1 11 5, 1 I s: -lha CehPLETE (HP TRajNING PRB Ih Val /[TISH Srj I R)V)EV Rjs epos L

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