ML18141A043

Forwards Procedures Generation Package for Emergency Operating Procedures in Response to NUREG-0737,Suppl 1 (Generic Ltr 82-33)

ML18141A043
Person / Time
Site:	Surry, North Anna, 05000000
Issue date:	07/01/1983
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Eisenhut D Office of Nuclear Reactor Regulation
Shared Package
ML18141A044	List: ML18141A043 ML18141A045
References
RTR-NUREG-0737, RTR-NUREG-737 006A, 6A, GL-82-33, NUDOCS 8307120386
Download: ML18141A043 (16)

Text

e e VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND? VIRGINIA 23261 W. L. STEWART VICE PRESIDENT NUCLEAR OPERATIONS July 1, 1983 Mr. Harold R. Denton, Director Serial No. 006A Office of Nuclear Reactor Regulation NO/JHL:acm Attn: Mr. D. G. Eisenhut, Director Docket Nos. 50-280 Division of Licensing 50-281 U. S. Nuclear Regulatory Commission 50-338 Washington, D. C. 20555 50-339 License Nos. DPR-32 DPR-37 NPF-4 Gentlemen: NPF-7 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT NOS. 1 AND 2 NORTH ANNA POWER STATION UNIT NOS. 1 AND 2 PROCEDURES GENERATION PACKAGE SUBMITTAL Per our Response to Supplement 1 to NUREG-0737 (Generic Letter No. 82-33),

dated April 15, 1983 (Serial No. 006), attached is the Procedures Generation Package for the Emergency Operating Procedures for the Surry and North Anna Power Stations.

Ve~

W. L. Stewart  ;.("

Attachment cc: Mr. James P. O'Reilly Regional Administrator Region II Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing Mr. D. J. Burke NRC Resident Inspector Surry Power Station Mr. M. B. Shymlock NRC Resident Inspector North Anna Power Station 8307120386 830701 PDR ADOCK 05000280 F PDR

50-280/281 .. SURRY ... VEPCO EMERGENCY PROCEDURE GENERATION PACKAGE w/ltr,* 7/l /83 ... 8307120386 THE ATTACHED FILES ARE OFFICIAL REC'JRDS OF THE DIVISION OF DOCUMENT CONTROL. Th!: 'i' HAVi:: SEEN CHARGED TO YOU FOR A LIMITED Tin';,~ c;ERlOD AND MUST BE RETURNED TO THE REC(h'_'D'.:. F ;~.C!UTY BRANCH 016. PLEASE DO NOT SEN::1 _DOCUPicENTS CHARGED OUT THROUGH THE MAIL. RE.'k:JV.D.L Gt ANV PAGE(S) FROM DOCUMENT FOR REPRO,J'...iCTiOf'-; MUST BE REFERRED TO FILE PERSONNEL.

DEADLINE RETURN DATE ----*------------

RECORDS FACIU,Y BRANCH

VIRGINIA ELECTRIC AND POWER COMPANY EMERGENCY PROCEDURE GENERATION PACKAGE A. INTRODUCTION This procedure generation package was developed in accordance with Item 7.2.b of Supplement 1 to NUREG-0737 and describes the method that will be used to develop and implement the initial set of improved, human factored, function and event oriented, emergency response procedures for Virginia Electric and Power Company's. Surry Power Station and North Anna Power Station.

This procedure generation package consists of the following six parts:

A. Introduction B. Procedure Development Program

c. Writers Guide D. Procedure Verification Program E. Procedure Validation Program F. Procedure Training Program The program described in this package will be implemented by the issuance of station Administrative Procedures, or other similar documents, approved by the Station Nuclear Safety and Operating Committee (SNSOC).

In response to Item I.C.l of NUREG-0737, and because it was felt prudent to provide the operator* with improved methods for mitigating emergency events as soon as these methods became available, Vepco has been engaged in the development and implementation of improved emergency procedures for some time now. The method presently being used to develop and implement these procedures is in basic compliance with the method described in this package. However, the initial set of improved emergency procedures may not have available all the supporting documentation described in this pack~ge. Since a major revision of these procedures is: anticipated following the issuance and approval. of Revision 1 to the Westinghouse Emergency Response Guidelines, it is intended to apply the methods described in this package to these revisions.

Page 2 It is also our intent to apply the methods described in this package in the generation of future emergency procedures and in the revision of existing emergency procedures. However, changes may be made to these methods in the future by revising the Administrative Procedures: or other documents, in accordance with the applicable Technical Specification and 10CFR 50.59 requirements for revising procedures .

Page 3

B. PROCEDURE

DEVELOPMENT PROGRAM

1. General The procedure development program will develop plant specific emergency procedures from generic Westinghouse Emergency Response Guidelines (ERGs). The initial set of improved plant specific emergency procedures will be developed using the Basic Revision of the Westinghouse ERGs, dated September 1, 1981. Once the pending Revision 1 of the Westinghouse ERGs is issued and receives NRC approval, it will be incorporated into later revisions of the emergency procedures.

2. Writing Team A procedure writing team will be designated by the Superintendent Operations to develop the plant specific emergency procedures. This writing team will consist of one or more individuals knowledgeable in station operations. The leader of the team shall possess a current Reactor Operator or Senior Reactor Operator license.

3. Reference Material The writing team will have available and use the following reference material in developing the plant specific emergency procedures:

0 Westinghouse ERGs, 0 writers guide, 0 FSAR, 0 Technical Specifications, 0 existing plant procedures (Emergency Procedures, Abnormal Procedures, Operating Procedures, etc.),

o plant drawings, o setpoint documents, and q manufacturers technical manuals

• Page 4

4. Procedure Development

• The.writing team will follow the ERGs step by step when writing the plant specific procedures.

where required, They will change step content ana sequence based on the differences between the Westinghouse reference plant and the plant for which the procedures are being developed. They will add .,. footnoted information where designated in the ERGs. They will use the reference material as appropriate to ensure the correctness of each step.

5. Documentation During the writing of each procedure, each step will be documented.

This documentation will:

o justify any significant deviation between the ERG step and the procedure step, o justify the sequence of the ,step,

• 0 0

justify any setpoint used, and list any reference material used.

The completed documentation will provide a basis for each procedure step and will* assist in the procedure verification, review, and approval process. It will also be available for reference when making later revisions to the procedure.

Page 5 C. WRITERS GUIDE

1. Gen~ral The writers guide used to develop plant specific emergency procedures was initially developed to assist in the development of improved Emergency Plan Implemen~ing Procedures in 1982 and was modified to allow its use in developing other emergency response procedures.

The writers guide covers the following major topics:

.o procedure designation and numbering, o procedure format, o writing of instructional steps, and o mechanics of style.

Th.e writers guide provides guidance for writing procedures in the dual column format and gives numerous examples to illustrate the various rules. A copy of the writers guide for Surry Power Station is provided as Attachment 1. The North Anna *Power Station writers guide is identical except for certain administrative details such as power station name and referenced procedure numbers

• Page 6

D. PROCEDURE

VERIFICATION PROGRAM

1. Gen~ral Procedure verification is the process performed to confirm the written correctness of the plant specific procedure and to ensure that the applicable generic and piant specific technical information has been properly incorporated.

The* procedure verification program was developed using the industry document, Emergency Operating Procedures Verification Guideline (INPO 83-004), as guidance. This document was developed by the Emergency Operating Procedures Implementation Assistance (EOPIA)

Review Group, in which Vepco was a participant, and published by INPO.

2. Verification Method Procedure verification will be done using one, or both, of two different methods. These methods are:

o in-plant review method, where a verification team reviews the plant specific procedures, or o reference method, where reference is made to verification of a similar procedure at a similar plant or to verification of a generic ERG.

The method(s) used to verify a specific procedure will be determined by the Superintendent Operations based on the attributes of the procedure and the resources available at the time of verification.

3. Verification Team Procedure verification will be performed by one or more knowledgeable individuals (normally members of the Safety Engineering Staff)

• designated by the Superintendent Technical Services.

individuals designated to perform verification of a procedures shall Those

Page 7 not be the same individuals who wrote or revised the procedure being verified. The selection of individuals to perform verification will tak~ into consideration their:

o plant experience, o understanding of plant equipment, o understanding of ERGs~ and o familiarity with the writers guide.

4. Written Correctness Criteria The verification of written correctness will confirm that the information in the plant specific procedures is presented in accordance with the instructions in the writers guide. To do this, the assessment will use evaluation criteria which address the following areas:

0 legibility, 0 format consistency, o identification information, o information presentation, and o procedure referencing and branching.

5. Technical Accuracy Criteria The verification of technical accuracy will ensure that the technical information contained in the plant specific procedure is consistent with and adequately incorporates the technical information contained in the procedure source documents. To do this, the assessment will use evaluation criteria which address the following areas:

o entry condition (symptom) information; o instruction step, caution, and note information; o quantitative information; and o plant equipment information

• Page 8

6. Assessment Wri~ten correctness and technical accuracy will be verified by comparing each step of the plant specific procedure against the writers guide and other appropriate source documents, using the evaluation criteria. In addition, the procedure step justification documentation developed during the writing of the procedure will be used as reference material. Any discrepancies which are not addressed by the justifying documentation will be identified and documented.

7. Resolution Once discrepancies have been identified and documented, they will be given to the procedure writer for resolution. The writer may resolve the discrepancy by providing additional justification or by revising the step. The proposed resolution will then be returned to the verifier for acceptance. Any discrepancies which cannot be resolved between the writer and the verifier will be forwarded to the Superintendent Operations, or his designee, for final resolution.

8. Documentation Documentation will record the major activities performed during the verification process to facilitate future verification activities.

The documentation will include the following:

o verification method used, o discrepancies identified, o resolution of discrepancy, 0 bases for resolution, o certification of verification of written correctness, and o certification of verification of technical accuracy

• Page 9

E. PROCEDURE

VALIDATION PROGRAM

1. Gen~ral Procedure validation is the process performed to confirm that control room operators can manage emergency situations using the procedures by ensuring the usability an,d operational correctness of the procedures.

The procedure validation program was developed using guidance provided by the EOPIA Review Group, in which Vepco was a participant.

2. Validation Method Procedure validation will be done using any one, or a combination, of four different methods. These methods are:

o simµlator method, where control room operators perform procedure steps on a simulator using a scenario; o walk-thru method, where control room operators conduct a step-by-step enactment of their actions on the control board during a scenario without performing actual control manipulations; o table-top method, where personnel explain and discuss procedure steps in response to a scenario; o reference method, where reference is made to validation of a similar procedure at a similar plant or validation of a generic ERG.

The extent to

• which a given procedure must be validated and the method (s) to be used in validating it will be determined by the Superintendent Operations based on.., the attributes of the procedure and the resources available at the time of validation.

3. Operator Team The Superintendent Operations will designate an operator team to

• perform the procedure steps during validation. The composition of

Page 10 this team will be consistent with the expected numbers and level of training for a normal operating shift.

4. Review Team The Superintendent Operations will designate a review team to develop required scenar:i:os, observe operator responses, and identify performance deviations during procedure assessment. In selecting members of the review team, consideration will be given to their knowledge of plant operations and procedures.

5. Usability Criteria The validation of usability will confirm that the procedures provide sufficient and understandable information to allow the operator to manage emergency situations. To* do this, the assessment will use evaluation criteria which address:

• 6.

0 o

level of detail and understandability Operational Correctness Criteria The validation of operational . correctness will confirm that the procedures are compatible with the expected operator responses, plant equipment, and shift manning. To do this, the assessment will use evaluation criteria which address:

o plant equipment compatibility and 0 operator compatibility

7. Scenario

• A scenario, or written description, of a transient wil1 be used to exercise* the procedure during assessment. The scenario will be

• developed by the review team and approved *by the Superintendent

Page 11 Operations or his designee. The scenario will be designed to guide the operator team through the anticipated evaluation path so the evc!luation criteria can be addressed. The detail contained in the scenario will vary depending on the validation method used. For example, the scenario for a walk-thru method will be more detailed than one used for the simulator method. The scenario will, at a

'1.*.

minimum, contain:

o prerequisite conditions and o expected sequence of plant symptoms and operator responses

8. Assessment Procedure usability and operational correctness will be validated using one or more of the four validation methods to exercise the procedure during the transient condition described in the scenario.

During this exercise, the review team will observe operator responses. Based on these observations and using the evaluation

• criteria, deviations.

the review team If appropriate, will detect a debriefing with following the exercise may also be held.

and record the performance operator team

9. Resolution Deviations identified during assessment will be evaluated by . the review team to determine if resolution is required. For those deviations where resolution is required, the review team will recommend a course of action, such as training, design change, or procedure revision. The Superintendent Operations, or his designee, will review the recgmmendations and determine the resolution action to be taken.

10. Documentation Documentation will record the major activities performed during the validation process to facilitate future validation activities. The documentation will include:

Page 12 o participants, o validation method(s) used, o scenario(s) used, o deviations identified, o resolution of deviations, o certification of validation for usability, and o certification of va].i.dation for operational correctness

• Page 13

F. PROCEDURE

TRAINING PROGRAM

1. General An emergency pro*cedure training program will be established to support the transition from the present emergency procedures to the improved procedures. Tb.e objectives of this training program are to provide the operators with:

o an understanding of the procedure structure, o an understanding of the technical bases of the procedure, o an understanding of the content of the procedure, and o the ability to use the procedure under operational conditions.

This training will be given to all licensed operators, licensed operations supervisors, and Shift Technical Advisors.

2. Initial Training Training on the initial set of improved procedures will be conducted prior to implementing the procedures. The training will consist of classroom instruction and simulator exercises. The classroom instruction will cover:

o general format and structure of procedures, o guidelines for use of procedures, o technical bases of each procedure, and o content of each procedure.

Simulator exercises using scenarigs will be conducted on selected procedures. During this training, the participants will perform their normal control room functions

• Page 14 3* Continuing Training Th~ existing training programs in place at both stations already contain emergency procedure training as part of operator license training and retraining programs. No changes are required in these training programs due to the introduction of the new procedures, other than to substituta,.the new procedures for the old ones.

4. Training on Revisions When revisions are made to the improved procedures, the Superintendent Operations will evaluate the extent of the revision and determine the training required. If the revision is judged to be minor in nature, training on the revision will be conducted through required reading (self-taught), shift briefings, or classroom instruction as part of the retraining program. Training on major revisions will be conducted by using classroom instruction and, if appropriate, simulator exercises *

• 5. Documentation Documentation of training on emergency procedures will be in accordance with the existing station requirements for documenting training.