ML20006E479
| ML20006E479 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 02/15/1990 |
| From: | Mcdonald D Office of Nuclear Reactor Regulation |
| To: | Creel G BALTIMORE GAS & ELECTRIC CO. |
| References | |
| TAC-44289, NUDOCS 9002230310 | |
| Download: ML20006E479 (8) | |
Text
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S-4 L
FEB 151990
. Docket Hos. 50-317 Distribution:
and 50-318 CNG NRC/ Local PDR PDI-1 Rdg EJordan SVarga-ACRS(10)
BBoger-Plant File Mr. G. C. Creel RCapra
'JLinville Vice President Nuclear Energy DMcDonald OGC Baltimore Gas & Electric Company CVogan W. Regan
-Calvert Cliffs Nuclear Power Plant G. Galletti MD Rts 2 & 4 P. O. Box 1535.
Lusby, Maryland 20667
Dear Mr. Creel:
SUBJECT:
PROCEDURES GENERATION PACKAGE - SAFETY EVALUATION CALVERT CLIFFS UNITS 1 (TAC NO. 44289) AND 2 (TAC HO. 44290)
By letter dated March 14, 1984, youprovidedtheProceduresGenerationPackage(PGP)-
for Ca': vert Cliffs, Units 1 and 2.
Your initial submittal was supplemented on October 25,_1985, and July 25, 1988. The staff has completed its review of the PGP. The enclosed safety evaluation discusses programmatic improvements which
- will enhance your ability to develop)and maintain consistently high quality Emergency Operating. Procedures (EOPs. The majority of the-tindings are related to the writer's guide. The staff concludes that your PGP needs to be.
reviewed to address these programmatic improvements.. For items you deem inappropriate or no longer applicable for inclusion in your PGP, you should develop and maintain documented justification in an auditable form.
An audit of your Integrated Plant Emergency Operating Procedures (IPEOP) was
- performed during the period of May 15-25, 1988. The staff recommends that both the enclosed discussion and ce results of the E0P inspection documented in Inspection Report number 50-311/80 and 50-318/80 dated August 2, 1989, be considered and utilized as appropriate in the next major revision of your PGP and E0Ps.
.The staff recognizes that your PGPs may have been revised since the submittals, and requests that you maintain records-of all revisions to your PGP and E0Ps in an auditable form. No further submittals are required. This completes the staff's action in relation to the above referenced TAC numbers.
Sincerely, ORIGINAL SIGNED BY
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Daniel G. Mcdonald, Senior Project Manager 9002230310 900215 Project Directorate I-1 PDR ADOCK 03000317 Division of Reactor Projects - 1/11 P
PDL.
Office of Nuclear Reactor Regulation cc: See next page
Enclosure:
As stated f
LA:PDI-1 1-1 D:PDI-1 CVog/90 2/gq/90 an Mcdonald 2//fRCap/90 l\\\\
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A1 Mr..G.' C. Creel Baltimore Gas & Electric Company Calvert Cliffs Nuclear Power Plant cc:
Mr. William T. Bowen, President Mr. Joseph H. Walter Calvert_ County Board of Engineering Division Connissioners Public Service Commission of Maryland Prince Frederick, Maryland 20678 American Building 231 E. Baltimore Street.
Baltimore, Maryland 21202-3486 D. A.: Brune Esq.
General Counsel Baltimore Gas and Electric Company Ms. Kirsten A. Burger, Esq.
P. O. Box 147F Maryland People's Counsei Baltimore, Maryland ?!?03 American Building, 9th Floor i
s.
231 E. Baltimore Street Mr. Jay E. Silberg, Esq.
Baltimore, Maryland 21202 i
Shaw, Pittman, Potts and Trowbridge 2300 N Street, NW Ms. Patricia Birnie
. Washingtor., DC ?0037 Co-Director Maryland Safe Energy Coalition Mr. W. J. Lippold, General Supervisor P. O. Box 902 Technical Services Engineering Columbia, Maryland 21044 Calvert Cliffs Nuclear Power Plant MD Rts 2 f 4 P. O. Box 1535 Lusby, Maryland 20657 I
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Resident Inspector c/o l'.S. Nuclear Regulatory Commission P. O. Box 437 Lusby, Maryland 20657 Mr. Thomas Magette Administrator - Nuclear Evaluations
~ Department of Natural Resources 580 Taylor Avenue Tawes State Office Building PPER 83.
i Annapolis, Maryland 21401 i
Regional Administrator, Region I U.S. Muclear Regulatory Commission 475 Allendale Road i
King of Prussia, Pennsylvania 19406 l
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, E[.Qlto UNITED STATES NUCLEAR REGULATORY COMMISSION w
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f SAFETY EVALUATION REGARDING TliE F
PROCEDURES GENERATION P ACKAGE FOR H
CALVERT CLIFFS NUCLEAR PLANT UNITS 1 AND 2 1.
INTRODUCTION.
The "TMI Action Plan" (NUREG-0660 and NUREG-0737) required licensees of.
operating reactors to reanalyze transients and accidents and to upgrade emergency operating precedures (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 the Preparation of Emergency Operating Procedures," describes the use of a " Procedures Generation Package" (PGP) to prepare E0Ps.
A PGP is required by Generic Letter 82-33, Supplement I to NUREG-0737, " Requirements for Emergency Response Capability." The generic letter requires each licensee to submit a PGP, which includes:
(1)
Plant-specific technical guidelines (ii)
A writer's guide (iii) A description of the program to be used for the validation of E0Ps (iv)
A description of the training program for the upgraded L
E0Ps.
This report is the review of the Baltimore Gas and Electric Company (BG&E) submittal describing the development and implenentation of E0Ps for Calvert Cliffs Nuclear Power Plant, Units 1 and 2. (CCNP).
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The review was conducted to determine the adequacy of the BG&E program for preparing, iniplementing, and maintaining upgraded E0Ps for CCNP. 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 BG&E submittal, the NRC staff review, and the acceptability of the submittal.
Section 3 contains the ~ staff's conclusions.
The staff determined that the procedures generation program for CCNP has several items that must be satisfactorily addressed before the PGP is acceptable.
BG&E should address these items in a revision tc the PGP cr
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document justification for why such revisions are not necessary.
This
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revision and/or justification need not be submitted, but should be D
retained for subsequent review by the NRC staff.
The revision of the PGP, l-and subsequently of the E0Ps, should not impact the schedule for the use L
of the E0Ps.
The revision should be made in accordence with the CCNP administrative procedures and 10 CFR 50.59.
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2.
EVALUATION AND FINDINGS
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In'a-letter dated March 14, 1984, from A. E. Lundvall (BG&E) to the i
Director of Nuclear Reactor Regulation, BG&E submitted its PGP of CCNP.
j The staff conducted a review of the CCNP PGP, and identified its findings
.in a Request for Additional Information (RAI) which was forwarded to BG&E in a letter dated August 7.1985.
BG&E provided responses to the RAI items in a letter dated October 23, 1985 f mm A. E. Lundvall to A. C.
Thadani (NRC).
In a letter dated July 25, 1988, from J. A. Tiernan (BG&E) to the U.S. Nuclear Regulatory Commission, BG&E submitted a revised
. Procedures Writer's Guide.
The Ju ly 25, 1988 letter also contained the-procedure verification / validation plan and the E0P training program.
The 1
PGP contained the following sections:
Plant-Specific Technical Guidelines Emergency Operating Procedure Writer's Guide Description of Verification /Velidation Program E0P Training' Program Description i
Sample E0P The staff review of the CCHP PGP is documented in the following subsections:
A.
Plant-Specific Technical Guidelines (P-STG)
The P-STG program description was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899.
The P-STG includes a discussion of the process of how the licensee plans to develop the E0Ps from the generic technical guidelines (CEN-153).
The licensee described a process where the source material listed in the writer's guide will be used to establish plant-specific entry conditions, precautions, innediate actions, recovery actions, and exit conditions (where appropriate) for each procedure.
This plant-specific information is to be i
compared with the generic guidelines and any deviations are to be formally documented.
Engineering analysis will be done as required. When a deviation is substantiated, it will be incorporated into the plant-specific procedure.
BG&E identified the following source documents for use in generating E0Ps for CCNP:
j Final Safety Analysis Report Technical Specifications Architect / Engineer Technical Documentation Human Factors considerations Operating experience Technical manual y
POEAC recommendations PGSRC recomandations 4
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, Proce&ral-Development request forms CCOM Change Reports 7'
Current and past revisions of Ols, ops, AOPs, and.EOPs Coeustion Engineering generic emergency procedure guidelines
( CD1-152)
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The staff review of the CCNP P-STG identified no concerns.
1 The. CCNP plant-specific technical guidelines program should accomplish the objectives stated in NUREG-0899 and should provide adequate guidance for translating the Conbustion Engineering Generic Emergency Procedure Guidelines into the CCNP E0Ps.
i As a result of our review of the revised PGP, the staff has the j
following additional comment.
This consnent is provided with the 3
recommendation that BG&E consider incorporating the resolution to
[
this conenent in the next revision of the CCNP PGP.
E In the October 23, 1985 letter item A.3 states that BG&E will translate generic infornation and control characteristic document into a plant-specific docunent as a part of the contml room design myiew project.
In order to nake the PGP complete, this control characteristic document should be referenced in the PGP.
B.
Writer's Guide The writer's guide was reviewed to determine if it described j
acceptable methods for accomplishing the objectives stated in-NUREG-0899. The CCNP writer's guide provides guidelines to be 1
employed in the preparation of E0Ps.
These guidelines have been established to insure consisteny in the organization, format, style, and content of CCNP E0Ps.
The staff identified the following j
concerns:
1.
Information should be presented in procedures so that interrup-tions in the procedure's flow are minimal.
To achieve this, each procedure should be written so that an action step is L
completed on the page where it began.
The only valid reason j
i for breaking an action step is when the step is too long to fit entirely on one page.
In that event, the action step should probably be re-written, if possible, in order to shorten it.
The limitations of wordprocessing tools are insufficient l.
justification for breaking action steps between pages.
c 2.
Major functions the operator must accomplish during an event are placed in boxes. The writer's guide shews exanples of major functions bordered by horizontal lines but not boxes.
This inconsisteny should be corrected.
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With adequate resolution of the. above items,- the CCNP writer's guide should acconplish the objectives stated.in NUREC-0899 and shculd J
provide adequate guidance for translating the technical guidelines into E0Ps that will be usable, accurate, complete, readable, convenient.to use and acceptable to contml room operators.
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' As a result of our review of the revised writer's guide, the staff s-has the following additional comments.
These consnents are provided with the recommendation that BG&E consider incorporating resolutions d
to these comments in the next revision of the CCNP writer's guide.
3.
The discussion in the writer's guide of cautions and notes l
should be revised with regard to the following:
a.
The section in the writer's guide on cautions and notes
.should be expanded to describe a method of formatting notes.
So that notes are'not confused with' cautions, this format should be clearly different than the fornet used for cautions.
b.
.The writer's guide should state that notes will be conplete on one page, i.e., a note will not be broken between pages. An exanple of a properly formatted note should be included, c.
The writer's guide should contain an exanple of a properly formatted caution.
.d.
The writer's guide should further state that only cne topic will be included in a caution or note.
When a caution or note contains more than one topic, the importance of any one topic is obscured.
4.
The discussion in the writer's guide of logic terms should be revised with -regard to the following a.
The writer's guide implies that OR may be c%d in both the l
inclusive and the exclusive sense. Te exclusive OR should be presented in a different manner than the-inclusive OR.
The writer's guide should provide instructioiis for formatting logic statenents that use OR
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used in either sense.
b.
The writer's guide should discuss the logic term IF NOT.
c.
Using the logic term THEN at the end of an action to instruct the operator to perform another action within the
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same step runs actions together.
Actions that are embedded in this way create several problems:
enbedded actions may be overlooked and not performed, or they may be confused with logic statements.
The writer's guide should state that THEN will not be used to run action steps together.
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The writer's guide should discuss the use of AND and OR
. within the same step.
An example should be provided.
5.
The writer's guide shcgid be expanded to include exagles of referencing and branching formats that are consistent with the text.
6.
Section VII.C.2.b page 17, states, " Brackets will normally not be used." There is neither a statenent as to when brackets are permissable nor an exanple of the proper use of brackets.
The
- writer's guide should be anended to specify when brackets may be u sed.
7.
Section VII.C.3.b, page 18, instructs procedure writers to use words that are concrete rather than vague, specific rather than general, familiar rather than fornal, precise rather than blanket.- 'It should also state that key words with more than one meaning will be avoided in E0Ps.
Such terms should be included in a list of words to avoid.
If anbiguous key words must be used in E0Ps, they should be defined every time they are used.
8.
The writer's guide should include instructions for writing the various types of action steps that an operator may take to cope with different plant situations.
a.
The writer's guide should address the definition and fornet of the following types of action steps and should provide examples:
nonsequential steps, equally acceptable steps, concurrent steps, and diagnostic steps.
See NUREG-0899, Section 5.7, for further information, b.
The writer's guide should include a means by which operators will be reminded to perform recurrent steps, as well as a means of letting operators know when it is no longer necessary to perform a recurrent step.
c.
The writer's guide should discuss the location of E0Ps in the control room and the techniques that will be used to differentiate E0Ps from other plant procedures.
C.
Verification and Validation Program The description of the verificatbn and validation program was reviewed to determine if it desm.:d acceptable methods for accomplishing the objectives stated in NUREG-0899.
The verification program plan describes methods for confirming the technical accuracy i
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and written correctness of the procedures.
The validation program plan describes methods for confirming the usability and operational correctness of the procedures.
The staff identified the following concerns:
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1.
The. verification and validai.6 programs describe the verification and validation that was performeo on existing E0Ps but do not specify that. the programs will be fo110we.1 in the future. The validation and verification programs should describe BG&E's plan for verifying and validating current E0Ps as well as E0Ps that receive major revisions.
2.
.The verification and validation program should specify the criteria for selection of team members, and the role and re-sponsibilities of each individual involved in all phases of verification and validation program.
With adequate resolution of the above items, the CCNP verification and validation program should accomplish the objectives stated in
).
NUREG-0899 and should provide assurance that the E0Ps adequately incorporate the~ guidance of the writer's guide and the technical guidelines and will guide the operator in mitigating emergency 4
P conditions.
D.
-Training Program The description of the operator training program on the CCNP upgraded E0Ps was reviewed to determine if it described acceptable methods i
for accomplishing the objectives stated in NUREG-0899. The training program will be established to support implementation of the E0Ps.
The staff identified the following concern:
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The training program and CCNP training policy guidelines should state that all operators will be trained in the latest revisions of all E0Ps before assuming responsibility for their assigned duty station.
With adequate resolution of the above item, the CCNP training l
program should accomplish the objectives stated in NUREG-0899 and should result in appropriate training for the CCNP operators on the L
upgraded E0Ps.
3.
CONCLUSIONS L
The staff concludes that, the PGP submitted by Baltimore Gas and Electric Company for Calvert Cliffs Nuclear Plant Units 1 and 2 in letters to the NRC, dated March 14, 1984, October 23, 1985, and July 25, 1988, 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 l
items the licensee deems inappropriate or no longer applicable for L
inclusion in its PGP, it should develop and maintain documented t
justification in an auditable form. All revisions to the PGP should be L
reflected in plant E0Ps within a reasonable period of time, e.g., the next planned revision of the E0Ps.
Dated:
Principal Contributors:
G. Lapinsky G. Galletti 6
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