ML20033F346

Forwards Safety Evaluation Addressing Items That Must Be Satisfactorily Reviewed Before 860731 Procedures Generation Package Can Be Acceptable

ML20033F346
Person / Time
Site:	Fermi
Issue date:	03/13/1990
From:	Eng P Office of Nuclear Reactor Regulation
To:	Sylvia B DETROIT EDISON CO.
References
TAC-59019, TAC-59621, TAC-72048, NUDOCS 9003200086
Download: ML20033F346 (12)

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UNITED STATES p

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NUCLEAR REGULATORY COMMISSION p

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<g WASHINoTON. D. C. 20666 k...o p' March 13,1990 Docket flo. 50c341 Mr. B. Ralph Sylvia Senior Vice President - Nuclear Operations Detroit Edison Company 6400 North Dixie Highway Newport, Michigan 48166

SUBJECT:

SAFETY EVALUATION OF THE FERMI-2 PROCEDURES GENERATION PACKAGE (TAC 59019), El!ERGENCY OPERATING PROCEDURES FOLLOW UP REVIEWS (TAC 59621), AND UPGRADED PROCEDURES GENERATION PACKAGE (TAC NO. 72048)

References:

1.

Letter from F.E. Agosti to E.G. Adensam dated July 31, 1986 2.

Letter from B.R. Sylvia to the USNRC dated December 12, 1988(NRC-88-02S9) 3.

Letter from A.C. Thadani to D. Grace dated September 12, IS88 4.

FIRC Inspection Report 341/88200 dated September 8, 1988 Py tre letters specified es references 1 and 2 above, you rubmitted your initial procedures generation package (PGPs) and your upgraded PGPs as revised to the requirements of Revision 4 of the Boiling Water Reactor Owners' Group cer+ric Er.tergency Procedure Guidelines, respectively.

Enclosed is the staff's safety evaluation (SE) of your July 31, 1986, submittal.

The SE finds that the PGPs for Fermi-2 as originally submitted contain several iters that nust be satisfactorily addressed before the PGP is acceptable.

D(trcit Edison Company (DEcc) should review these items against the current PGP cnd correct these items for which the SE comments are still valid, or provide justificution for why further revision is not necessary.

Please note that new POP revisions need not be submitted; however, they should be retained for subsequent review t'y the NRC staff. Transmittal of the SE closes out our TAC No. 59019, and the staff's review of the issue.

.By reference 2, you submitted your upgraded procedures generation package for our review. As noted in the enclosed SE, submittals of your revised program are not required, consequently, a detailed review of your submittal will not be conducted at this time; however, documentation of resolution of these items identified in the SE should be retained for future review by the NRC staff. This letter concludes our efforts regarding TAC 72048.

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During the summer of 1988, an inspection of the Fermi-2 emergency operating During the course of the procedures (EOPs) was conducted by)the !!RC staff. reviewed the E0P development process, (2)pection,theinspectionteam(1 compared the emergency procedure guidelines to the E0 ins documentation, (3) validated E0Ps using the site specific simulator and plant walkdowns, (4) independently verified selected E0Ps and appendices for conformance with the PGP and (5) reviewed operator requalification training on the E0Ps.

Findings identified during the inspection were summarized in reference 4.

At tne time of the inspection Fermi-2 was in the final stages of implementing Revision 4 to the Boiling W)ater Reactor Owners' Group (BWROG) Emergency ProcedureGuidelines(EPGs. Revision 4 of the BWROG EPGs was reviewed and approved by the flRC on September 12, 1988.

Althcugh several deficiencies with individual E0P requirements were identified during the inspection, the inspection team noted that the E0Ps in place during the inspection would allow operators to adequately control emergency operating conditions. The team also concluded that the overall quality, legibility and readability of t!e E0Ps was very good, and that both the E0Ps and the plant specific technical guidelines were prepared in accordance with Revision 4 of the BWROGs.

Resolution of the deficiencies identified in 1988 was investigated during a follow up inspection of your E0Ps in mid 1989. The-follow up inspection revealed that the vast majority of deficiencies identified during the 1988 inspection had been resolved and that the remainder of the deficiencies would be completed during your first refueling outage. Deficiencies for which resolution was not complete were designated as open items and referred to the resident inspector office for final resolution.

None of the remaining deficiencies were related to improper procedures or to invalid E0Ps. The inspection also reve61ed that Deco had implemented emergency operating procedures based on the PGP ano that the Fermi-2 operating staff had been trained on the E0Ps. This completes our actions on TAC 59621.

The NRC amended the Fermi-2 license to include License Condition 17 which requires that:

a.

Prior to July 31, 1986, DECO shall provide for NRC staff review and approval, a Procedures Generation Package (PGP) to meet the requirements of Section 7 to Supplement I to NUREG 0737 b.

Prior to startup following the first refueling outage, Deco shall complete training on, and have implemented, emergency operating procedures based on the PGP.

' As stated above, you have fulfilled parts a and b of license condition 2.C.17.3.

A proposed amendment to the facility technical specifications will be necessary to remove the condition from the license.

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This 16tter completes the staff's efforts regarding TAC Hos. 59019, 59621, and 72048.

Please note that TAC Nos 59019 and 59621 are associated with Fermi-t License Condition 2.C.17.3.

If you htye any questions, please contact myself or John Stang.

Since

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Patricia L. Eng, Proje t Manager Project Directorete 111-1 Divisien of Reactor Projects - III IV, V and Special Projects Office of Nuclear Reactor P.cgulation cc: Enclosure See next page

Mr. B. Ralph-Sylvia' Fermi-2 Facility Detroit Edison Company' cc:

John Flynn, Esq.

Senior Attorney Detroit Edison Company 2000 Second Avenue 4

Detroit, Michigan 48226 Nuclear Facilities and Environmental

-Konitoring Section Office Division of Radiological Health P..O. Box 30195-Lansing, Michigan 48909 Mr.. Walt Rogers U.S. Nuclear: Regulatory Comission Resident Inspector's Office 6450 W. Dixie Highway q

flewport, Michigan 48166 tionroe County Office of Civil Preparedness 963 South'Raisinville i

tionroe, Michigan 48161 l

Regior.a1 Administrator, Region III

. U.S. t!uclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137 Ms. Lynne Goodman Supervisor - Licensing 1

-Detroit Edison Company Fermi Unit 2

.6400 t!or.th Dixie Highway fiewport, Michigan 48166

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sg ..3- \\ .This'1etter completes the staff's. efforts regarding TAC Nos. 59019.-59621, tand 72048. - Please note that TAC Nos 59019~and 59621 are associated with' . Fermi-2 License Condition 2.C.17.3.. p If.you have any questions, please contact myself or.-John Stang, h Sincerely, Original signed by. h* Patricia L.' Eng, Project Manager f' Project Directorate III-1 Division of Reactor Projects - III IV, V and Special~ Projects Office-of Nuclear Reactor. Regulation. cc: Enclosure. 'See next page. DISTRIBUTION = DocketJUste NRC-& Local PDRs-

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. This letter completes the staff's efforts regarding TAC N0s. 59019, 59621, and 72048. Please note that-TAC Nos 59019 and 59621 are associated with fermi-2 License Condition 2.C.17.3. If you have any questions, please contact rayself or John Stang. Sincerely, Patricia L. Eng, Project Manager Project Directorate 111-1 Division of Reactor Projects - III IV, V and Special Projects Office of Nuclear Reactor Regulation ec: See next page . DISTRIBUTION Docket File NRC & Local PDRs PD31 Reading JZwolinski-MRShuttleworth PEng OGC EJordan-ACRS(10) 0 1;. RSP LHF (A)D/PD31:D(SP '1i/0[G LA/PD31:DRSP PM/PD3 : RSP dSTA

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+ Enclosure S/JETY EVALUAT10tl REGARDING THE PROCEDURES GENERAT10tl PACKAGE FOR FEPJ41-2 1. . lliTFCDUCT101! Ic11cwingtheThreetiileIsland(TMI) accident,theOfficeofNuclear PeactorR(sulationdevelopedthe"TM1ActionPlan(NUREG-0660and i:L' REG-0737) which required licensees of operating reactors to reanalyze tiensients and accidents and to upgrade emergency operating procedures (EOPs)(ItemI.C.1). The plan also required the NRC staff to develop a 1cng-term plan thet intcgrated and expanded efforts in the writing, rcviewing, and monitoring of plan procedure (Item I.C.9). NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures," represents the f:RC staff's long-term program for upgrading E0Ps, and describes the use of a " Procedures Generation Package" (PCP) to prepare E0Ps. Submittel of the PGP was made a requirement by Generic Letter 02-33, "Supplcment I to NUREG-0737 - Requirements for Emergency Response Capability." The Generic Letter requires each licensee to submit to the !!RC 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 E0Ps (iv) A description of the training program for the upgraded E0Ps. This report describes the review cf the Detroit Edison response to the Gencric Letter related to develoment and implenientation of E0Ps (Section 7 cf Generic Letter 82-33) for tie Fermi-2 plant. Our review was conducted to determine the adequacy of the Detroit Edison progran for preparing and irplementing upgraded FOPS for fermi-2. This revi m was based on flVREG-0800 (formerly NUREG-75/087), Subsection 13.5.?, Standard Revicw Plan for the Review of Safety /,nelysis Reports fer f:uclear Power Plants. Section 2 of this report briefly discusses the Detroit Edison submittal, the NRC staff review, and the acceptability of the submittal. Section 3 contains the conclusions of this review. As indicated in the following sections, our review determined that the procedure generation progran for fermi-? has several items that should be addressed before the PGP is acceptable. Detroit Edison nay resolve these items in a revision to the PGP, or provide justificetion for why such revision is not necessary. This revision and/or justification need

i not be submitted, but t ould be retained for subsequent review by h ? the I;RC staff. The revision of the PGP, and subsequently of the c E0Ps, should not impact the schedule for the use of the E0Ps. The revision should be made in accordance with the Fermi-2 administrative pt ocedures and 10 CFR 50.59. 2. EVALUATION AND FlilDINGS In a letter dated July 31, 1986 from Frank E.- Agosti (Detroit Edison) to Elinor_G.Adensam(NRC).DetroitEdisonsubmitteditsPGPforFermi-2. The PGP contained the following sections: o Plant-Specific Technical Guidelines o Writer's Guide for E0Ps o E0P Verification Program o E0P Validetion Program o E0P Training Progran. The flRC staff review of the Fermi-2 PGP is documented in the following subsections: A. Plant-Specific Technical Guidelines (P-STG) Eecause staff cvaluation of Revision 4 of the generic technical guidelines is new complete, the P-STG program description should be revised to conform with Revision 4 of the General Electric Boiling Water Reactor Owner's Group (BWROG) Emergency Procedure Guidelines (EPGs). Safety significant deviations from the BWROG Emergency 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 t.ethods for accorplishing the objectives stated in !WREG-0899. The writer's guide provides detailed instructions for the preperation and revision of E0Ps using effective writing principles and addresses aspects of writing procedures from a hun.an factors standpoint. Compliance with the writer's guide should ensure that all ECPs are concise, complete, accurate, unan.biguous, and that they are uniform in format, organization, level of detail and style. Our review of the Fermi-2 writer's guide identified the following concerns:

1. E0Ps are generally ccmposed of various types of action steps the operatcr is to perform. These steps include simple action steps, verification steps, continuous or periodic steps, and alterr.ative or equally acceptable steps. The content and format of each type of action step needs to be described in the writer's guide to provide adequate instructions to the procedure writers. Although the writer's guide addresses 2

4 9 simple action steps and concurrent steps, the writer's guide should also address the other steps in the above list. See NUREG-0899, Subsections 5.7.2-5.7.8, for additional information. 2. Section 5.4(1) should require that each page of the E0P include the number of pages in the format of "Page 3 of 30." 3. Conditional and logic-statement are commonly used in E0Ps. It is important that writers understand the meaning of logic terms, and how they are used and combined to make logic statements. Section 4.7 should be expanded to include or reference more examples of acceptable and unacceptable a combinations. See NUREG-0899, Appendix B, fo" additional information. 4. Section 5.5(1) states that referencing other steps within the procedure being used should be minimized and that these steps should be repeated rather than referenced. The writer's guide should also. state that where possible referencing steps in other procedures should also be minimizea, and that these steps should be repeated rather than referenced. The writer's guide 4 should provide decision criteria to determine when to repeat steps of other procedures, and when to reference them. See NUREG-0899, Section 5.2.2, for additional information. 5. Section 3.2. states that location information for components or parts that might otherwise be difficult to find should be provided. Section 6.7 contains some guidance but should be expanded to include how this location information should be provided and in what format. 6. To minimize confusion, delay, and errors in the execution of E0P steps, the following concerns should be adoressed in the writer's guide: L a. Action steps should be structured so that they can be executed by the minimum shift staffing required by the facility Technical Specifications. b. Action steps should be structured to be consistent with the roles and responsibilities of the operators. c. Action steps should be structured so as to minimize movement of personnel in the control room (where technical guidelines permit). d. Action steps should be structured to avoid unintentional duplication of tasks. p e. Action steps should be structured te enable the control l room supervisor to follow staff actions and monitor plant status. 3

I y,, t. ~ See NUREG-0899, Section 5.8, for additional information. With adequate resolution of the above items, the Fermi 2 writer's guide should accomplish the objectives stated in NUREG-0899 and should provide adequate guidance for translating the technical guidelines into E0Ps that will be usable, accurate, complete, readable, convenient to use, and acceptable to control room operators. C. Verification and Validation Programs L' 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 descriptions consist of a set of relevant definitions, source documents, and the verification and validation process. Our review of the Fermi 2 i verification and validation program descriptions identified the following concerns: i 1. The PGP should describe all of the types of people to be included in these progroms (i.e., operators, subject matter i experts, procedure writers and human factors professionals) and further should specify their roles and responsibilities. 2. To assure complete verification and validation of the E0Ps, the program description should include an indication that the full complement of E0Ps will be reviewed and exercised to their fullest extent. 3. The validation program should be expanded to include a description of the criteria that will be used to select the scenarios to be run during the validation process. The criteria should be developed on the basis of what is needed to validate the procedures and should ensure that single, sequential, and concurrent failures are included. A review of the capabilities and the limitations to the simulator will then identify what can be validated on the simulator. For the parts of the E0Ps that cannot be validated on the simulator, the l criteria for selecting any additional validation that may be needeo and the methods to be used, such as a control room walk-through should be described. 4 Particular attention should be paid to deviations from and additions to the generic technical guidelines that are of safety significance during the validation program. The PGP should discuss how the deviations from and additions to the E0Ps are to be validated. 5. The E0Ps will require a certain number of operators to carry out 'i. the various activities and steps specified in the E0Ps. The validation program should indicate that the E0Ps will be exercised, during the simulator exercises and during control 4

+ room walk-throughs, with the minimum staffing required by the f acility Technical Specifications. r 6. The verification and validation programs should include the criteria or methods that will be used for determining the need ~to reverify and revalidate any changes in the E0Ps resulting from subsequent E0P revisions. With adequate resolution of the above items, the Fermi 2 verification and validation programs 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 conditions. D. Training Program The description of the operator training program on the Fermi 2 upgraded E0Ps was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899. The training program as described in the PGP consists of classroom instruction, control room walk-throughs and simulator exercises. Our' review of the Fermi 2 training program description for E0Ps identified the following concerns: 1. It is crucial that all operators be trained on all aspects of each E0P so that all operators are prepared to execute each E0P to its fullest extent. The training program should include a commitment to train all operators on all E0Ps. L 2. The PGP states that the Fermi 2 simulator will be used for I training. The training program description should indicate the l use of a wide variety of scenarios, including multiple the extent possible)quential) failures, to fully exercise (to (simultaneous and se l the E0Ps on the simulator and thus expose E the operators to a wide variety of E0P uses. 3. The training program description should be expanded to include a discussion of the method to be used to train operators in areas where the simulator does not react like the plant and in parts i. of the E0Ps that cannot be run on the simulator. 4. The training program description states that training on major E0P revisions will be conducted by use of classroom instruction. Classroom training alone is not a sufficient mechanism for training on E0P revisions. The training program description should be expanded to include simulator training or control room walkthroughs, as appropriate, to enhance training on major E0P revisions. 5

liith adequate resolution of the above items, the Fermi-2 training pro 5ran should accomplish the objectives stated in NUREG-0899 and should result in appropriate training of the Fermi-2 operators on the upgraded E0Ps. 3. CONCLUSIONS The staff concludes that, the PGP submitted by Detroit Edison for Fermi-2 it. t letter from Frank E. Agosti (DE) to Elinor G. Adensam (NRC), dated July 31,1986, should be revised to address the iters described in Section 2 of this report. This revision need not be submitted to the URC. For items in Section 2 that the licensee deems inappropriate, no longer applicable or unnecessary for inclusion in its PGP, it should develop and maintain documented justification. All revisions to the PGP should be reflected in plant E0Ps within a reasonable period of time and rade in accordance with 10 CFR 50.59. 6 .---- _ _ _ __ _____ _ -_____ _ __ _ _J}}