ML18092A905
| ML18092A905 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 11/18/1985 |
| From: | Corbin McNeil Public Service Enterprise Group |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8511250235 | |
| Download: ML18092A905 (4) | |
Text
-,*
Public Service Electric and Gas Company Corbin A. McNeill, Jr.
Vice President -
Public Service Electric and Gas Company P.O. Box236, Han cocks Bridge, NJ 08038 609 339-4800 Nuclear November 18, 1985 U. S. Nuclear Regulatory Commission Off ice of Nuclear Reactor Regulation 7920 Norfolk Avenue Bethesda, MD 20014 Attention:
Mr. Steven A. Varga, Chief Operating Reactors Branch #1 Gentlemen:
RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION, OPEN ITEMS FROM PROCEDURES GENERATION PACKAGES AUDIT SALEM GENERATING STATION UNIT NOS. 1 AND 2 DOCKET NOS. 50-272 AND 50-311 Public Service Electric and Gas hereby forwards its response to your letter requesting additional information concerning our Emergency Operating Procedures (EOPs) and Procedure Generation Package (PGP) dated October 30, 1985, and received November 6, 1985.
We initiated a three-phase program following your audit and our meeting with you in Bethesda on October 10, 1985.
This Program is structured to address the concerns discussed in our meeting and enumerated in your October 30, 1985 letter.
Phase I of this program is now complete and addressed the technical concerns of your enclosure 1.
The details of our Phase I actions are provided in Attachment 1.
Phase II is underway and is designed to address the General Human Factor concerns associated with our EOP Format and Writers Guide.
A summary of the Phase II program and schedule is provided later in this response.
Phase III will begin following NRC review and approval of our Writers Guide revision (to be developed during Phase II).
The EOP's will be upgraded during this final phase to incorporate the revisions necessary to comply with the revised guidance of the Writers Guide and to reflect a comprehensive editing by technical editors.
The completion of Phase III activities is tentatively scheduled to coincide with the completion of our scheduled two year review of these procedures.
--(i5i 1250235 851118 PDR ADOCK 05000272 F
Mr. Steven 11/18/85 Phase II of our program is designed to address the Human Factor concerns regarding the format, organization and content of our EOP's and Writers Guide.
As we have pointed out previously, these procedures were developed, and validated through extensive use of the Salem simulator with the involvement of Salem Operating personnel.
The resulting procedures have proven to be effective during simulator exercises and requalification training.
This method of development, while identified as unconventional in your letter, appears to us to be an effective and logical application of a resource designed and implemented for just such a purpose.
It also seems reasonable that the resulting Salem specific product is much more likely to be successful, if and when it is required, than the generic product which was shown to be unsuccessful during the early stages of our EOP development.
We appreciate the recognition by the NRC that the extensive EOP training conducted by PSE&G provides the necessary confidence in our EOP's to allow time for a planned and systematic reevaluation of our EOP's and associated products.
To accomplish this reevaluation, we have engaged the service of a third party organization with significant human factors engineering background.
Our planned reevaluation and those actions associated with Phase II are to be completed by March 31, 1986.
The following are the major elements of this Phase of the program:
A.
A Human Factor evaluation of the Salem EOP organization and format.
This will include a performance evaluation and revalidation of sample EOP's using NRC and INPO validation criteria while executing them on the Salem simulator.
B.
A review and revision of our Procedure Writers Guide incorporating the findings of the Human Factors review of the EOPs and the Writers Guide.
C.
The resubmittal of our Writers Guide and a description of our planned changes to our EOP's.
Should you have any questions concerning this information, please feel free to contact us.
Attachment C
Mr. Donald c. Fischer Licensing Project Manager Mr. Thomas J. Kenny Senior Resident Inspector Sincerely,
./
ATTACHMENT 1 RESPONSE TO NRC'S REQUEST FOR ADDITIONAL INFORMATION, OPEN ITEMS FROM PROCEDURE GENERATION PACKAGE AUDIT RESPONSE TO ENCLOSURE 1 The following responses are listed in the order as they appear on of the NRC's request for information dated 10/30/85.
- 86.
3.31.1 EOP-FRSM-1
- 4.
3.1. 3
- 15.
3.5 EOP-TRIP-1
- 2.
- 1. 2
- 4.
2.0 Step 3.31.1 has been changed to "Start one RCP by performing the following:"
This change informs the Operator to start the RCP in accordance with the subsequent steps and will eliminate the possibility of the Operator attempting to start the RCP before step 3.31.lc.
- a.
Valves CV40 and CV41 (VCT Outlet) have been added to the list in step 3.1.3.
- b.
This comment associated with "periods" will be addressed in the on-going review once the Author's Guide concerns are resolved.
- a.
We are in compliance with the ERG's, Revision 1.
This specific comment was addressed in the ERG basic procedures but was deleted in the ERG Rev.
1 procedures.
Without having all the WOG background data that deleted this step in Rev. 1, we have decided not to change our procedure.
However, we have identified this item to the WOG procedure subcommittee and will discuss this at the next subcommittee meeting, scheduled for November 20, 1985.
Based on the outcome of this discussion, we will determine if the EOP-TRIP-1 procedure will be changed.
- b.
This comment associated with "Action Verbs" will be addressed in the on-going review once the Author's Guide concerns are resolved.
- c.
This cormnent associated with "acceptable abbreviations" will be addressed in the on-going review once the Author's Guide concerns are resolved.
This step has been expanded to address symptoms that require SI.
The ERG fold out page and the basis for the fold out page for E-0 ERG's has been reviewed and the following changes have been made:
- 18.
2.6a RESPONSE TO ENCLOSURE 1
- a.
SI actuation criteria has been added to the CAS phase for EOP-TRIP-1.
The intent of the guideline, based on communications with Westinghouse, is to actuate SI under these criteria once the E-0 (EOP-TRIP-1) procedure is exited and no SI has been actuated by the Auto SI Signals.
We have requested the WOG to clarify the use of the items on the Fold Out Pages and also identify to which procedures they apply to.
- b.
Status Tree Red Path summary items have been added to the CAS phases of the Salem EOP-TRIP-1 procedure.
- c.
AFW supply switchover criteria have been added to the CAS Phase of EOP-TRIP-1.
RIGHT COLUMN:
This step has been expanded to address the conditions that require SI initiation.
Also, SI actuation criteria were alled to the CAS as indicated in the response to 4a of EOP-TRIP-1 above.
"DETERMINE" has been changed to "CHECK" which is on the action verb list and specifically calls out the action the Operator is to take.
- 75.
3.24.3 a.
Step 3.24.3 isolates all four main steam lines.
aj2 6 This step is in compliance with the ERG (Revision 1)
E-2 step 1.
The guideline checks the isolation of affected SG(s).
A review of the ERG's and the basis for step 1 of the ERG identified that, for the Salem design plant, all SGs are the affected Stearn Generators.
The basis states, "since the guideline is entered after a faulted SG has been identified, valves should have previously received a 'Closed' signal."
If not, or if the valves failed to close, the operator is instructed to rnanuallyclose the valves.
On the plants with individual loop low steam pressure isolation capability, the term "Affected SG(s)" refers to the loop(s) for which a steam line isolation signal is present.
On the reference plant, all steamlines receive the isolation signal and, therefore all SG(s) are considered to be "Affected SG(s)".
The MSIVs are checked closed in this step in an attempt to isolate the break and to isolate the SGs from each other.
Because of the above basis, the Salem procedures will not be changed.
The procedure is in compliance with the guidelines.
- b.
This comment associated with action verbs will be addressed during the on-going review once the Author's Guide concerns are resolved.