ML20055G527

Safety Evaluation Re Facility Procedures Generation Package. Util Needs to Revise Package to Address Programmatic Improvements Identified

ML20055G527
Person / Time
Site:	Grand Gulf
Issue date:	07/18/1990
From:	Office of Nuclear Reactor Regulation
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ML20055G523	List: ML20055G522 ML20055G527
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NUDOCS 9007230282
Download: ML20055G527 (8)

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5 - 6: W A 6HING T ON, D. C. 20666 ENCLOSURE SAFETY EVALUATION BY THE OFFICE Of NUCLEAR REACTOR REGULATION OF THE PROCEDURES GENERATION PACKAGE FOR GRAND GULF NUCLEAR STATION. UNIT 1  !

1.0 INTRODUCT10W The "TM1 Action Plan" (NUREG-0660 and NUREG-0737) required licensees of operating reactors to reanalyze transients and accidents and to upgrade energency cperating procedures (EOPs). The plan also required the NRC -

staff to develop a long-term plan that integrated and expanded efforts in i the writin , reviewing, and monitoring of plant procedures (Item I.C.9). >

NUREG4899 " Guidelines for the Preparation of Emergency Operating Procedures,"describestheuseofaProceduresGenerationPackage(PGP) to prepare E0Ps. A PGP is required by Generic Letter 82-33, "Supslement 1 to NUREG-0737-Requirements for Emergency Response Capability." Tae generic letter requires each licensee to submit a PGP, which includes:

Plant-specific technical guidelines 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.

i ThenameofthelicenseeforGrandGulfNuclearStation, Unit 1(GGNS-1) has changed twice since the operating license was issued on November 1, 1984. Prior to December 20, 1986, Mississippi Power & Light Company was the licensee. From that date until June 6,1990, System Entergy ,

Resources, Inc., was the licensee. On June 6, 1990, the licensee became '

Entergy Operations, Inc. In this safety evaluation the date is used to designate the applicable licensee when necessary;, for example, for submittals to the NRC. ,

This safety evaluation describes the review of the licensee's submittals regarding the development and implementation of E0Ps for GGNS-1. An NRC ,

team audited GGNS-1 emergency procedures during the period April 11-18, 1988 (NRC Inspection Report No. 50-416/88-06, datedJune7,1988)and made comments and observations regarding the PGP. By letter dt.ted July 8, 1988, the Itcensee committed to address the concerns identified in this E0P inspection report.

This review was conducted to determine the adequacy of the licensee's program for preparing, implementing, and maintaining upgraded E0Ps for GGNS-1. 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 licensee's sub-mittals, the NRC staf f review, and the acceptability of the submittals.

Section 3 gives the staff's conclusions.

9007230292 900718 FDR ADOCK 05000416 P PDC

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2 The staff deterwined that the procedure generation program for GGNS-1 has several items that must be satisfactorily addressed before the PGP is acceptabic. The licensee should address these items in a revision to the PGP. This revision and any justification should not be submitted, but should be retained for subsequent audit by the NRC staff. The revision of the PGP, and subsequently of the E0Ps, should not impact the use of the E0Ps. The revisions should be made in accordance with the GGNS-1 admini-strative pror ,' and 10 CFR 50.59.

2.0 EVALUATION In a letter c t s April 11, 1985, the licensee submitted its PGP for GGNS-1.

The PGP contained the fo11cwing sections:

Introduction PlantSpecificTechnicalGuidelines(PSTG)PreparationGuide i

• Emergency Procedures (EP)* Writer's Guide Yerification and Validation Plan EP Training Program Description ,

The staff reviewed the PGP submittal and requested additional information -

by letter dated, May 27, 1986. The liceensee's response dated July 15, 4 1986, included a revised PGP. On March 2, 1987, the licensee submitted a number of revised pages which contained some minor changes to the July 1986 PGP. These changes were incorporated as a result of NRC staff coments on the July 1986 submittal. Additional information was submitted by the licensee on September 4, 1987 and September 12, 1988.

Based on its review of the GGNS-1 PGP the staff has the following s recommendations for programatic improvements.

A. Plant Specific Technical Guidelines j Because the NRC staff's saf ty evaluation of Revision 4 of the

, Boiling Water Reactor Owners Group (BWROG) Emergency Precedure Guidelines (EPGs) is now issued,** the PSTG program d2scription should be revised to confonn with Revision 4 of the EPGs with due consideration of the staff's safety evaluation and subsequent BWROG revisions. Deviations from the CWROG EPGs should be documented, justified, and retained for future reference.

• The Heensee uses the term " emergency procedures" in lieu of the term

" emergency operating proedures" used in staff documents.

• September 12. 1988 letter from A. Thadani, NRC, to D. Grace. BWROG, transmitting the Safety Evaluation of "8WR OWNERS' GROUP - EMEPGENCY PROCEDURE GUIDLEINES, REVISION 4, NEDO-31331, March 1987." ,

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B. Writer's Guide  ;

i The writer's guide was reviewed to determine if it described  !

acceptable methods for accomplishing the objectives stated in l NUREG 0899. The writer's guide " establishes format an. content  !

standards for (GGNS 1) Emergency Procedures and gives bidance to i the EP writer for the creation and revision of all EF-." ,

1. Section 3.4.10, page 3-9, indicates that notes may be referenced  :

by a number that appears in a circle. So that the correct note i is observed only a single note referencing number should be placedwithInthecirclesymbolusedtoindicatenotes. Errors  !

such as mistaking references to notes 1 and 2 for a reference to ,

note 12 can be made if multiple numbers are placed within the same circle, i

2. The discussion in the writer's guide of logic terms should be revised with regard to the following:

a. Section 3.5.5.a. page 3-15, states that the use of AND and OR within the same action should be avoided. TFere are occasions when it is necessary to use AND and LR in the same sentence. Section 3.5.5 should pI~ ovide guTdance and anexampleofacceptableusagesof[NDandQ,Rtogether, R

b. Section 3.5.5.d. page 3-16, should be expanded t. address the inclusive and exclusive use of OR. R

c. Section 3.5.5, pages 3-15, 3-15a, and 3-16, incorrectly define BEFORE as a logic term. Section 3.5.5, should be .

revised to exclude the term BEFORE.

d. In the example in Section 3.5.7.c.2, pages 3-19 NOT is used as a logic term but it has not been under1Ine C This example should be corrected,

e. Section 3.5.5.b, page 3-15, states that a list format should be used when AND is used to join two or more conditions in a step I A list format is not used in the example in Section 3.5.7.c.2, page 3 19, where AND is used to join two conditions in a step. Thewriter'sTu'ide should be revised to remove this inconsistency.

f. In examples in the writer's guide, instructions to perform actions precede statements about the conditions under which those actions should be performed (e.g., Section 3.5.5.b.1,page3-15A,"ManuallySCRAM[unlessexecuting RC/Q])." To ensure that operators are aware of the conditions under which actions should be performed before they perform the actions, conditional information should always be presented before instructions to perform actions contingent upon those conditions.

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3. The discussion in the writer's guide of referencing and ,

branching should be revised to adcress the following: 1

a. The writer's guide should be revised to indicate that the following information will be included in a reference or branch: the step number, the procedure title, and the -

procedure nuiser.

b. The writer's guide describes various formats for branches and references. Section 3.5.7 states that branches can be i indicated with "words such as 'GO TO' or ' EXIT HERE'."  ;

The following formats are described for references:

(1)Section3.4.3,page3-5,indicatestheconcurrent performance of steps should be indicated with an " execute ,

, concurrently" flowchart symbol; (2) Section 3.5.4.f. page 3-15, states that concurrent performance of steps should be indicated by using words such as " simultaneously." "at the same time," or " concurrently"; and (3) Section 3.5.7 pages 3-18 through 3-19, states that a reference can be '

indicated with *words such as ' REFER T0' or '...USING PROCEDURE E-5' or using the concurrent step symbol." A single format for branches and a single format for i references should be defined in the writer's guide. If l multiple formats are necessary, the conditions under which ,

each format should be used should be stated. Examples l should be provided. '

l 4. The instructions relating to the graphics of-flowcharts should be revised as follows:  :

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a. The writer's guide should either state that each flowchart L will be presented entirely on a single page or provide j detailed guidance on the placing of page breaks in flowcharts.

b. The writer's guide should state that the principal directions of movement in flowcharts will be from top to L bottom and from left to right.

5. Section 3.5.11, page 3-20, describes acceptable uses of under-lining, and states that underlining iray also be used when special emphasis is required. The overuse of underlining will detract from emphasis throughout the EPs. Section 3.5.11 should state specifically all situations in which underlining should be used.

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I e 6. syntax, and The discussion punctuation shouldin bethe writer's-guide revised to address the of follow vocabulary,ing: '

a. instructs writers to use Section 3.5.10.c.

" action verbs such as page those3-19, listed in AppendixThe 30."

writer's guide should present an inclusive list of acceptable verbs, and instruct writers to use only those verbs in EPs.

b. Section 3.5.10f, page 3-20, instructs procedure writers to define key words that may be understood in more than one way. Section 3.5.10 should state that key words with more than one meaning will not be used in Eps. Such terms )

should be included 1D the list of words to avoid. If '

ambiguous key words must be used in EPs, they should be l defined every time they are used.

c. Section 3.6.3 page 3-21, states that dividing a word at theendofalineshouldbeavoidedinflowcharts.

Section 3.6.3 should be revised to state that words will not be broken between lines.

d. Examples in the writer's guide use two formats for presenting lists. In the examp?e in Section 3.5.3.f. page 3-13, a bullet precedes each item in a list and in examples in Section 3.5.5, pages 3-15 and 3-18, a hyphen precedes each item in a list. The writer's guide should .

state when bullets and when hyphens should be used before  :

each item in a list. ,

7. Section 3.5.2, pages 3-12 through 3-23, should specify that I action steps should be sequenced according to technical priority, timing, the physical layout of the control room, minimizing of >ersonnel movement in the control room, being l consistent witi operators' roles and responsibilities, and .

l enabling supervisors to follow staff actiont and monitor plant status. .

8. The writer's guide should be revised to address the following ,

concerns regarding step numbering

l a. Section 3.4.12, page 3-10, should be revised to state L where step numbers should be positioned relative to .

flowchart symbols. ,

b. A step number should be provided in Figure 3C-1, page 3C-2, for the step composed of the LP-25 exit arrow. .

[ 9. The writer's guide should include instructions for writing the various types of action steps that an operator may take to cope with different situations.

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4. Because retainment steps place a burden on an operator's  !

memory, it is hecessary to remind operators about '

retainment steps in subsequent portions of the flowchart. >

If space precludes placing reminders in the flowpaths, alternative techniques should be considered. For example, a strong visual emphasis of the retainment ste  !

dark or large step sym6ol) may draw operators'ps (e.g., a attention j to the steps and thus help remind operators to observe the 4

steps.  ;

b. In the example in Section 3.5.5.e, page 3-15, a note is incorrectly formatted and embedded inside of a step. This note should be eliminated by re-wordin' the IF clause of  :

the step (i.e., J,F WHILE EXECUTING STE; $ LP L-35).  ;

c. The writer's guide describes two methods of presenting decision steps: (1) using flowchart decision symbols and  !

(2)usinglogicstatements. So that writers know which of these two formats to use in all situations, the writer's  ;

guide should be revised to discuss when each format should be used,

e. Section 3.5.4.e page 3-14, addresses steps that may be i performed in alternative ways. Because space is limited in flowcharts, Section 3.5.4.e should state that presenting multiple alternatives will be avoided in EPs  !

and discuss conditions when multiple alternatives should be presented. Examples should be provided.

10. Section 3.5.9.b, page 3-19, should describe the format to be .

used in presenting location information and should provide an '

example.

11. Section 3.2, page 3-1, indicates that the unit designation is ,

included in EP procedure numbers. However, the unit designation "

l 1s not included in the EP procedure number in Figure 3C-1 >

3C-2,noristheunitdesignationshowninthetitleblockpage in s

! Figure 3C-1. This discrepancy should be resolved, and the  ;

guidance in Section 3.5.9, page 3-19, should ensure that the  ;

unit designation is included in the title blocks of EPs.

12. The placekeeping symbol omitted from Section 3.4.13, page 3-10, should be restored.

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13. Appendix 3F, pages 3F-1 to 3F-2, should be revised to include the abbreviation *SUPP," which is used in examples in the writer's guide.

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C. Verification and Validation Program Thedescription.oftheverificationandvalidationprogram(V8V)was reviewed to determine if it described acceptable methods for I accomplishing the objectives stated in NUREG-0899. The focus of the l verification process will be to evaluate the written correctness and  !

the technical accuracy of the GGNS-1 PSTGs and EPs. The validation process will detemine whether the actions specified in the EPs can 1 be performed by trained operators to manage emergency conditions successfully. The staff identified the following concerns:

1 The validation and verification plans should be expanded to 1.

address the following concerns:

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, a. The validation program should indicate that the EPs will  ;

be exercised, during simulator exercises and control room

, walk-throughs, with the minimum control room staff required by the Technical Specifications.

b. The V4Y program should specify the criteria for selection '

of V&V team members.

, D. Training Program i lhe description of the operator training program on the GGNS-1 upgraded EPs was reviewed to determine if it described acceptable siethods for accomplishing the objectives stated in NUREG-0899. The -

L training program description states that EP training will be a vital element in the overall operator training program at GGNS-1, Unified effort on the part of the training department and the EP writers ,

will result in operators who are knowledgeable in both the intent and use of these procedures. The. staff identified the following concerns:

1. Section 5.4.2 page 5-2, refers to Figure 5-1 but this figure hasnotbeenIncludedinthePGP. The PGP should be revised to -

include Figure 5-1.- .

2. Section 5.4 normalstaffpage5-2,shouldberevisedtostatethatboththe complement and Technical Specification minimum staffing will be used in simulator exercises and control room walk-throughs.

3. The training program description should be expanded to indicate that all o w ators vill exercise all EPs on the simulator or, for tn6se areas not conducive to simulator -

training, in control room walk-throughs.  ;

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. 4. The training program should state that the operators' knowledge and performance on the use of the EPs will be evaluated during and after training and that appropriate follow-up training will be conducted, if necessary. Operators should also be tested '

after retraining.

3.0 CONCLUSION

ThestaffconcludesthattheGGNS-1ProceduresGenerationPackage(PGP) should be modified to address the programmatic improvements identified in Section 2.0 of this safety evaluation. The licensee has committed to i address the additional concerns in the NRC inspection Report dated  :*

June 7,1988, identified in Section 1.0 of this safety evaluation. With adequate resolution of these items, the GGNS-1 PGP will accomplish the objectives stated in NUREG-0899 and, therefore, will be acceptable. A PGP revision should not be submitted to the NRC. For items the licensee deems inappropriate or no longer applicable for inclusion in its PGP, it should develop and maintain documented justification in an auditable form. All rev3sions to the PGP should be reflected in plant E0Ps within a reasonable period of time, e.g., the next planned revision of the E0Ps.

Principal Contributor: G. Galletti Dated: July 18, 1990 ,

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