ML20042D077
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t SEP 121986 i
Donald Grace, Chairman BWR Owners Group GPU Nuclear 1 Upper Pond Rd Evilding E Parsippany, tki 07054
Dear Mr. Grace:
SUBJECT:
SAFETY EVALUATION OF "BWR OWNERS' GROUP - EMERGENCY PROCEDURE GUIDELINES, REVISION 4,"
NED0-31331, MARCH 1987 The NRC staff has reviewed the General Electric Topical Report NED0-31331,
" Emergency Procedure Guidelines, Revision 4," March 1987 and has found the Emergency Procedure Guidelines to he generally acceptable for implementation.
We believe that the BUR Emergency Procedure Guidelines (EPG) provide a basis for a significant improvement in current emergency operating procedures.
The new hydrogen control guidelines for Mark I and Mark 11 plants and the detailed Guidance for determining the Primary Containment Pressure Limit (PCPL) are the major improvements.
[ Mark III Containment Hydrogen Control Guidelines are addressed separately under the Hydrogen Control Owners Group (HC0G) program.)
The Safety Evaluation Report recommends a few changes to Appendix B of the guidelines.
The recommended changes in Appendix B ar6 described in the summary of the SER.
EPG-Rev 4 provides improved guidance on venting, but you should remain fully aware that the Commission is continuing to assess means for further minimizirt the potential downside of venting. The Commission is currently considering a MARK 1 containment improvement program which could result in additional hardware changes.
The purpose of these modifications would be to realize the full benefits of ventinc in reducing public risk.
Those changes will be an integral part of the MAE, I program.
As discussed in the Safety Evaluation Report (Enclosure 2), we find the actions specified in the Emergency Procedure Guidelines-to be generally correct and appropriate and within the operators' capability. The combination of all emergency actions into four. guidelines and six contingencies and the reductions in caution statements to seven greatly simplifies the emergency instructions.
The continued use of symptoms, rather than events as bases for actions, should serve to minimize errors resulting from incorrect diagnosis of events and addresses the possibility of multiple failures and operator. errors. We therefore find the guidelines acceptable for implementation.
We are sending a copy of this letter to the BWR licensees and applicants.that I
will provide them with the Safety Evaluation Report.
For those licensees who are now following Revision 1, Revision 2 or Revision 3 of the EPG and wish to revise their Emergency Operating Procedures to Revision 4 of the EPG, a suggested implementation program is given in Enclosure 1.
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Donald Grace.
The SER closes all the open items carried from the previous revisions of the EPG.
We consider the BWR EPG review as complete.
Hgwever,gach BWR-licensee who wishs -to_ use the: Revision-4 of the EPG should assure that th_e EPGT WtM not impact its licensing bases.
For example, if the hydrogen control guidelines are implemented as written, the containment atmosphere dilution (CAD) system may not be adequately addressed.
That is, BWR plants that employ the CAD system as part of a hydrogen mitigation scheme would need to implement additional plant specific procedures consistent with its safety analysis or provide the staff with additional information to justify such deviations.
We expect that the BWR Owners will continue to improve the EPGs.
Since the guidelines do not provide comprehensive severe accident mitigation strategies, we expect the Owners to upgrade the EPGs in parallel with resolution of severe accident issues.
The principal contact for this activity is George Thomas, Reactor Systems Branch, at 301-492-0892.
Sincerely, 5
Ashok C. Thadani, Assistant Director for Systens Division of Engineering & Systems Technology Office of Nuclear Reactor Regulation
Enclosures:
1.
Implementation Progran 2.
SER on Emergency Procedure Guidelines, Rev-4 cc w/ enclosures:
R. Goranson, Northern States Power P. Snith, GPU Nuclear L. S. Gifford, GE BWR Licensees DISTRIBUTION Central Files SRXB R/F A. Thadani M. W. Hodges R. Jones L. Gifford (GE)
G. Thomas G. Thomas R/F N
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This report applies to the following plants:
Boston Edison Co.
Pilgrim 1 1
Carolina Pcwer and Light Brunswick 1 & 2 Cleveland Electric Illuminating Co.
Perry Ccmmonwealth Edison Company LaSalle 1 & 2, Dresden 2-3, Quad Cities 1 & 2 Detroit Edison Fermi-2 Georgia Power and Light Hatch I & 2 GPU-Nuclear Oyster Creek 1 Gulf States Utilities River Bend, 1 Illinois Power Co.
Clinton Iowa Electric Light and Power Duane Arnold Lono Island Lighting Shoreham Nebraska Public Power District Cooper New York Power Authority Fitzpatrick Niagara flohawk Power Nine Mile Point 1 & 2 Northeast Utilities Millstone 1 Northern States Power Monticello Pennsylvania Power and Light Susquehanna 1 & 2 Philadelphia Electris Company Peach Bottom 2 & 3, Limerick 1 & 2
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Public Service Electric and Gas Hope Creek System Energy Resources, Inc.
Grand Gulf 1 Tennessee Valley Authority Browns Ferry 1-3 Vermont Yankee Vermont Yankee Washington Public Power Supply Company WNP-2 (Hanford 2) 4
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ENCLOSURE 1 IliPLEMENTATION PROGRAM Licensees who are now following Revision 1, Revision 2 or Revision 3 of the EPG should revise their E0Ps tc reflect the. guidance in Revision 4 of the EPG as early as practical.
The staff suggests that implementation of the guidelines proceed in two steps;-
as follows:
(1) Preparation of Plant Specific Technical Guidelines (PSTG) that conform to the Emergency Procedure Guidelines referenced above and implementation of these guidelines as outlined in the following documents:
Supplement 1 to NUREG-0737, transmitted by Generic Letter No. 82-33, dated December 17, 1987, NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures" August 1982; and HUREG/CR-3632, " Methods for Implementino Revisions for Emergency Operating Procedures," May 1984.
(2) Preparation of supplements to the Plant-Specific Technical Guidelines which cover changes, new eouipment, or new knowledge and incorporation of these supplements into plant-specific procedures.
Step (1) refers to the guidelines referenced above; Step (2) refers to guideline updates which will be ger,erated as a matter of routine after the plant-specific-procedures have been put in place.
The staff notes that the guidelines are written for the procedure writers, not for control room operators. Therefore, preparation'and implementation of plant specific procedures will require " human factors" input to assure that the procedures are logical, readable, easy to use, and consistent with plant conventions, labels and equipment. All emergency operatino procedures and
- revisions should be developed in conformance with an acceptable plant-specific writer's guide, should be validated by appropriate methods, and should be included in' plant training programs.
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The steff is concerned about the continuing failure of licensees to properly implement the EPGs.
Results from the NRC staff review of numerous plant PGPs and recent audits and inspections of the E0Ps have identified a number of problems.
Even though URC Information Notice 86-64, Supplement I dated April 20, 1987 and 86-84 dated August 14, 1986 informed licensees of deficiencies uncovered by the staff in the licensee's implementation program, the deficiencies identified in the information nctices continue to be identified.
The staff review of numerous plant procedure g?neration packages (PGP), recent audits and inspections of the E0Ps have resulted in the following findings:
1.
The EOFs for the most part accurately incorporated the generic guidelines and were technically correct.
1 2.
Simulator exercise of the E0Ps have shown that the operators were able to shutdnwn the plant safely.
3.
Many plants had good labeling and component identification for the equipment used in the E0Ps.
4.
In many plants equipment (tools, jumper cables, etc.) were readily available and the operations personnel were familiar with the equipment location and use.
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I However, the staff is concerned about the continuing-failure of licensees to properly implement the EPGs.
i specifically:
1.
Inadequate evaluation and documentation of deviations from the NRC approved generic technical guidelinee,; and, in some cases, significant deviations without any evaluation.
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Inadequate implementatier. nf licensee specific E0P writer's guide.
3.
Inadequate verification and validatation of plant specific E0Ps.
4 Inadequate training and evaluatation of the operating staff in the use of the upgraded E0Ps.
5.
Failure to apply operational quality assurance controls to the E0P upgrade process to ensure meeting licensing commitments, f While the above findings do not necessarily represent the situation at any single plant, the frequency of their discovery across the plants visited i
rai'ses concerns that the overall quality of E0Ps may not meet the requirements of NUREG-0737, Supplement-1, and should be improved. To address these safety significant deficiencies, a high level of management oversight and effective management control should be provided to assure proper implementation of the EPGs.
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