ML20073K044

Forwards Plans & Schedules for Emergency Response Capabilities Per Generic Ltr 82-33 Re Suppl 1 to NUREG-0737, Requirements for Emergency Response Capability. Meeting to Discuss Plan in Detail Planned Shortly

ML20073K044
Person / Time
Site:	Brunswick
Issue date:	04/15/1983
From:	Utley E CAROLINA POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8304190509
Download: ML20073K044 (29)

Text

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C9&L Carolina Power & Light Company April 15, 1983 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 NRC GENERIC LETTER 82-33 REQUIREMENTS FOR EMERGENCY RESPONSE CAPABILITY i

Dear Mr. Denton:

On December 30, 1982, Carolina Power & Light Company (CP&L) received

, Generic Letter 82-33, Supplement 1 to NUREG-0737, Requirements for Emergency Response Capability. As a participating member of the Nuclear Utility Task Action Committee on Emergency Response Capabilities (ERC NUTAC), which ir.cludes over forty utilities and is administratively supported by INPO, CP&L

.is' developing an integrated implementation program which responds to the requirements of Generic Letter 82-33 as follows:

PROGRAM PLAN Carolina Power & Light Company is using the ERC NUTAC's Draft Guidelines for an Integrated Implementation Plan, which is summarized in Attachment 1, as an input for plant-specific integration planning.

Attachment 1, Figure 1, shows the ERC NUTAC's method for ideal integration of emergency operating procedures (EOPs), control room design review (CRDR),

Regulatory Guide 1.97 (RG-1.97), safety parameter display systems (SPDS), and emergency response facilities (ERFs). Carolina Power & Light Company's progress in integrating the Brunswick Plant emergency response activities with other outstanding commitments is being taken into consideration in the development of CP&L's plant-specific input and integration criteria (Step 1 of Figure 1).

In developing the Brunswick Plant integration criteria, guidelines prepared by the NUTAC's, and the BWR Owners' Group will be evaluated. The

. industry guidelines CP&L will consider in developing final plant-specific plans are described in Attachment 2, and are listed below:

O 8304190509 830415 PDR ADOCK 05000324 F PDR 411 Fayetteville Street

• P. O. Box 1551

• Raleigh, N. C. 27602

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Mr. Denton April 15, 1983

1. Emergency Operating Procedures

a. . General Guidelines

i. Emergency Operation Procedures Implementation Guideline

11. " Emergency Operating Procedure Writing Guideline",

(INPO 82-017), published July, 1982 iii. E0P Verification Guidelines iv. E0P Validation Guidelines

v. BWR Owners Group Emergency Procedure Guidelines, dated December, 1982 vi. Emergency Operating Procedures Generation Package Guideline (INPO 83-007), published February 1983

b. Input Criteria

i. Writer's Guide

11. Emergency Procedures Guidelines (NEDO-24934, Rev. 2, June 1982) iii. Task Analysis

2. Control Room Design Review Program

a. General Guidelines

1. NUTAC Guidance on CRDR, issued in March, 1983

b. Input Criteria

1. Control Room Survey

11. Human Factors Engineering Principles 3 Regulatory Guide 1.97'

a. General Guidelines I

i. BWR Owners Group RG-1.97 Guidance Program, issued in July, 1982 ii. NUTAC Guidelines for Accident Monitoring Instrumentation, scheduled to be issued in May, 1983

b. Input Criteria

1. RG-1.97 Design Guidance

4. Safety Parameter Display System

a. General Guidelines

1. NUTAC " Guidelines for an Effective SPDS Implementation Program"

! (INPO 83-003 NUTAC), published January, 1983 i-I

, - ,7 Mr. Denton April 15, 1983

b. Input Criteria

1. Critical Safety Functions

5. Emergency Response Facilities

a. General Guidelines

1. NUTAC Guidelines on ERFa, scheduled to be issued in May, 1983

b. Input Criteria

1. TSC Criteria

11. OSC Criteria iii. EOF Criteria

6. Verification and Validation

a. General

i. Summary of the NUTAC Component Verification and System Validation Guidelines

11. Verificiation and Validation for Safety Parameter Display Systems NSAC/39, December 1981

b. Input Criteria 1.- V&V Input Criteria PRCPOSED SCHEDULES In parallel with the work described above and prior to the issuance

( of Generic Letter 82-33, we carefully reviewed numerous draft NRC and industry guidelines. Carolina Power & Light Company determined that the probability of further revisions to NRC requirements in some of these areas was significant, l posing substantial risk in committing resources to follow the guidance of these documents prior to full Commission approval. With Commission approval of Supplement 1 to NUREG-0737, we have now developed preliminary schedules for completion of those activities that CP&L believes can be planned at this time.

! Attachment 3 provides plans and schedules for each activity, I integrated with our current plant commitments and projected outage l

schedules. Some long-term milestones will require confirmation as near-term milestones are actually completed, and these milestones are described in

, Attachment 3.

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4 Mr. Denton April 15, 1983 As proposed by Generic Letter 82-33, we will meet with our NRC Project Manager to explain in more detail, our integrated implementation plan as described in Attachment 3 Yours very truly, E. E. Utley ]

Executive Vice President Power Supply and Engineering & Construction EEU/SRZ/lr (014ASRZb)

E. E. Utley, having been first duly sworn, did depose and say that the information contained herein is true and correct to his own personal knowledge or based upon information and belief.

G -

Notary (Seal My Commission Expires: 8/ff[13 cc: Mr. D. O. Myers (NRC-BSEP)

Mr. J. P. O'Reilly (NRC-RII)

Mr. S. D. MacKay (NRC) l i

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e ATTACHMENT 1 CLASSICAL INTEGRATION SCHEME 1-1

INTRODUCTION A subcommittee of the NUTAC on Emergency Response Capabilities was formed to provide industry guidance to individual utilities for the development of an integrated implementation plan that addresses the provisions of NUREG-0737, Supplement 1. The method developed to integrate the provisions of NUREG-0737, Supplement.1, is shown in Figure 1. Recognizing the different stages of compliance to the individual requirements in NUREG-0737, the method shown in Figure 1 assumes no work has been accomplished. However, after determining individual plant status, each utility can apply the method to prepare the plant specific implementation plans required by NRC.

Figure 1 is divided into basic steps that should be considered in the development of an integrated plant-specific implementation plan. The relation of previous to succeeding steps is discussed in the following plan descriptions.

E0P PLAN The E0P Plan consists of those tasks which will provide a documented method for developing, utilizing, revising, and controlling Emergency Operating Procedures.

This plan will include defining source documents, determining manpower requirements, establishing a schedule, and specifying method of document control. This plan also will define the interfaces with other NUREG-0737, Supplement 1 elements to ensure complete integration.

Initial plant-specific E0Ps are developed by utilities for the purpose of mitigating the consequences of a broad range of initiating events, and subsequent multiple failures or operator errors, without the need to diagnose a specific event. These procedures are symptom-oriented and written with human factors considerations to improve human reliability. These initial E0Ps are developed based upon a writer's guide, NSSS generic technical guidelines and a plant-specific task analysis.

Determination of procedure adequacy is dependent upon the trained operator's needs. E0Ps should be checked for completeness, understandability, technical correctness, usaoility, and compatability with the control room. In order for operators to have confidence in the E0Ps, all of these criteria must be met.

A walk-through of the initial E0Ps provides a method of evaluating these

criteria. A utility may choose to perform an E0P walk-through in the control room, in a simulator, using a mock-up of their control room, or any combination of the three. Prior to making this decision, a utility must determine resource availability and advantages versus disadvantages of each environment. Although Figure 1 indicates only one E0P walk-though, this process should be repeated following any major modifications to the E0Ps.

Plant-specific E0Ps must be incorporated in an iterative process with control

, room HEDs, specific utility application of RG-1.97 recommendations, SPDS l

design bases, and Emergency Response Facility criteria. This interactive

! process should be used to determine what changes can easily be made to the E0Ps to accommodate discrepancies in other areas without impacting the effectiveness of the E0Ps. In order for this iterative process to be most 1-2

-effective, all of the elements that impact EOPs should be available at the same time. However, due to economics, manpower limitation, or vendor restrictions, this may not be possible. To accommodate this situation and to ensure effective EOPs, a utility should consider performing the iteration

-between EOPs and the other impacting elements as soon as each one has been

. developed.

CRDR PLAN The Program Plan is the first step towards performing a CRDR and provides a method for performing the entire review.

The Control Room Inventory Portion of the CRDR (identification and documentation of equipment) can be done independently of the other tasks associated with the CRDR.

In performing the CRDR, accepted human factors guidelines should be used.

Good human engineering practices should be incorporated in any control room design since the operator must interface with this equipment under stressful, as well as normal conditions.

The complete Control Room Design Review should utilize results from the EOP walk-through and control room inventory, as well as human engineering criteria, to uncover any control room design problems. .This review should include, among other things, an assessment of control room layout, the control room environment, the usefulness of audible and visual alarms, the readability of-displays, the adequacy of instrumentation, and the information recording and recall capabilities.

The instrumentation and controls requirements output of task analysis should be compared with the control room inventory to determine if any required displays or controls are missing. .

The operators tasks and informational requirements are validated by the E0P walk-through and provide input criteria to the control room design review.

. Control Room additions associated with the safety parameter display (SPDS) and incorporation of selected RG-1.97 recommendatios should be considered during the CRDR.

The control room improvements should be coordinated with changes resulting

- from other programs such as EOP, RG-1.97, SPDS, and ERF.

RG-1.97 ELEMENT A detailed plan is presented which provides administrative guidance required to assess, and document all aspects of RG-1 97 consideration. A complete set of design criteria is developed from the plan to form a basis for plant-specific instrument selection. Utilizing the design criteria, as well as the post accident instrumentation requirements identified from the CRDR task analysis, a plant-specific list of accident monitoring instrumentation, qualification criteria and locations is developed. The plant list also provides feedback to the control room design review and SPDS design basis.

ERF design criteria provides additional input to the plant list. Once the 1-3

. list is finnlized in draign, En itsrativa procsco oesura to considsr shing2s cssociated with E0Pa, centrol room imprcvements, SPDS dssign, and ERP design.

SPDS PLAN The SPDS plan describes the tasks which will provide a method for developing, revising, and implementing the safety parameter display system design bases, and a method for documenting these efforts. This plan is plant-specific, though it is developed with cognizance of current NRC and other guidelines.

The plan should provide a description of each task involved and administrative guidance required to perform the tasks, including defining source documents, determining manpower requirements, specifying vendor involvement, establishing a schedule, and specifying a method of configuration control. Interfaces with other Supplement 1 to NUREG-0737 elements should be clearly defined to ensure complete integration. '

SPDS usability is essential to the effectiveness of the system. The document provided by the SPDS NUTAC entitled, Guidelines For An Effective Safety Parameter Display System Implementation Program provides human factors guidance criteria for an SPDS, as well as guidance for other factors that influence usability.

1 A plant-specific list of human factors criteria pertaining to the SPDS should be developed as a basis for developing and assessing plant-specific SPDS designs. This list of criteria may be developed in conjunction with the human factors criteria required as input for the performance of a control roon

, . design review.

The EOPs, as a result of the efforts performed by the NSSS Owners Groups and i- plant-specific considerations, specify the critical safety functions for a

. plant. The SPDS design bases should incorporate this information to allow the operator to use the SPDS,-if available, in conjunction with his E0Ps.

The CRDR/SPDS design basis interface may be classified as one-way or two-way, depending upon the intended use of the SPDS, i.e. the interface becomes two-j way if a utility intends to resolve control board HEDs by taking credit for

! the information displayed by the SPDS or incorporating additional information on the SPDS.

.The ERF Criteria /SPDS Design Bases Interface is classified as one-way, i 1.e., the SPDS design bases may be used as input in the ERP design criteria, however,.the ERP design should have no direct effect on the SPDS.

i The iteration interface is an ongoing process as long as HEDs exist or design changes that could impact the SPDS are made to any of the other basic Supplement 1 to NUREG-0737 elements. A great deal of coordination is

- essential to effectively determine modifications to the SPDS without creating i

additional discrepancies.

, To ensure an effective SPDS, the design bases must specify hardware, inputs, i and software in the case of a computer based system and identify SPDS user (s),

specify location, and define availability. Design bases may vary

! considerably. Whereas some plants may elect to design an SPDS that nerves l

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only to aid in monitoring the critical safety functions, others may elect to incorporate additional' functions into the system. In all cases, the SPDS design must consider operator usability and compatibility with plant-specific EOPs.

The E0P/SPDS design basis interface is classified as one-way, i.e., structure of the E0Ps will affect the SPDS design, but the SPDS design does not determine what must be included in the EOPr ERF PLAN The ERP plan consists of those tasks which describe a method for designing, implementing, and utilizing the emergency response facilities. The plan should be plant-specific, and developed in cognizance of current NRC guidelines. The following items should be considered in the development of an ERF plan:

- Purpose of the TSC, EOF, and OSC

- Description of tasks

- Source document availability

- Project personnel requirements and materials needed

- Manpower requirements and restrictions

- Description of the design documentation required

- Desired date of completion and milestones

- Schedule controlling factors

- Interfaces with other Supplement 1 to NUREG-0737 elements A set of criteria that provides a basis for the design or upgrade of the Technical Support Center (TSC), Emergency Operating Facility (EOF) and Operational Support Center (OSC) need to be determined. The bases for this criteria should include 10CFR50.47, 10CFR50, Appendix E, NUREG-0696, Utlity i

Emergency Plans, and guidance provided by nuclear industry organizations.'

! Plant-specific criteria should include, but not be limited to, the following information:

- Purpose

- Location

- Required instrumentation (not required for OSC)

- Habitability (not required for OSC)

- Communications needs

- Structural considerations (not required for OSC)

- Size

- Human Factors considerations (not required for OSC)

- Staffing needs Guidance produced by the ERC NUTAC will provide assistance in the development of this criteria.

A set of criteria that provides a basis for identifying non-utility or utility off-site interactions that have an impact on the emergency response facilities should be developed to provide:

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- ' Interactions with state and local government,

- Communications required between plant and utility headquarters

- Resources required from utility headquarters,

- Emergency capabilities supported by NSSS vendors, A/Es, and medical facilities

- 'Non-utility personnel located in the ERP during emergency conditions

. A set of criteria that provides a basis for ensuring the integration of the TSC, OSC, EOF, and off-site facilities should be developed.

The ERF criteria should be included in an iterative process with other elements of Supplement 1 to NUREG-0737. These include control room improvements, plant-specific EOPs, specific RG-1.97 application and SPDS design. This iterative process should continue until all of the elements associated with ERP criteria used to build or upgrade emergency response facilities are developed based on the above considerations.

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e ATTACHMENT 2 DESCRIPTION OF GUIDELINES AND INPUT CRITERIA DEVELOPED BY INDUSTRY GROUPS I

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1. EOP PLAN

a. General Guidelines i

1. - The Emergency Operation Procedures Implementation Guideline presents the basic elements of an implementation plan for EOPs, starting with the receipt of the emergency-operating procedure guidelines (EPGs). The following elements are presented and

! discussed:

! - Organization of Implementation Elements

! - Crew and Shift Policy Characteristics l

- Procedure System and Network

- Technical Guideline Use 1 - Writers Guide for E0Ps

- E0P Verification

- E0P Validation

. - Training j' - Revision, Review, and Approval Process

- E0P Control

- Supporting Documentation Control

- Experience Feedback

The elements were identified and evaluated by the Emergency Operating Procedures Implementation Assistance (EOPIA) Review Group in accordance with the Activity Network described in the E0 PIA Program Description (INPO 82-013). The elements presented are not to be construed as an exhaustive list and are considered to be generic to most plants and organizations. The elements should be reviewed by the utility for individual applicability i

and use. By review of each element presented, it is felt that a cohesive and efficient implementation plan for EOPs can be developed by each utility.

i i

.This document is offered as guidance only.

ii. EOP Writing Guideline The purpose of this guideline is to provide information that can be used by a utility in writing or improving a plant-specific writers guide for emergency operating procedures (EOPs). The Emergency Operating Procedures Writing Guideline presents human factors principles applicable to EOPs. These principles, if applied in developing or improving a writers guide for EOPs, will help ensure readable and understandable procedures for emergency conditions.

This guideline document is organized to present information on i human factors aspects and how to address them in writing EOPs by applying prirciples. For each principle, an explanation is provided with guidance and examples of application. In addition, a writers guide outline, example writers guide, and emergency operating procedures are provided to show how the ,

principles can be tied together in writing E0Ps. As structured,  ;

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the guideline can be reviewed starting with either the general t- principles or the specific example E0P.

l iii. E0P Verification Guidelines The purpose of this guideline is to provide information that can be used by a utility in developing its Emergency Operating l Procedure (EOP) Verification Program. This document provides i guidance in three major areas of an EOP Verification Program.

These are the program objective, program evaluation, criteria, i and program process.

The program objective is to ensure that consistency has been maintained between the EOPs and the EOP Source Documents.

Consistency is determined by Verification Principles for written

! correctness and technical accuracy. Written correctness ensures

, information is incorporated as specified by administrative

! guidance. Technical accuracy ensures proper incorporation of i generic and plant-specific technical information.

Program evaluation criteria are used to determine if the verification principles are satisfied. This document provides guidance for the development of plant-specific evaluation criteria. Sample evaluation criteria are provided for each i verification principle for a typical plant.

1 The program process supports the actual comparative evaluation. This document divides the process by phases:

preparation, verification, resolution and documentation.

Guidance is provided for each of these process phases along with I a sample verification procedure.

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This document is presented for guidance only.. Its program is

j. not intended to duplicate efforts in existing E0P review and approval processes. E0P verification as presented in this i document is a comparative evaluation which addresses whether the

! E0Ps are written correctly and are technically' accurate. The evaluation of whether the E0P information is usable and operationally correct is addressed during the EOP validation.

i iv. E0P Validation Guidelines l

The purpose of this guideline is to provide information that can l be used by a utility in developing its Emergency Operating Procedures (EOPs) Validation Program. This document provides l

guidance in three major areas of E0P Validation Program. These

! areas are the program objective, program evaluation criteria and

. program process.

The program objective is to determine if the trained operating i shift can manage emergency conditions with EOPs. This determination is made by validation principles for operational

correctness and usability. Operational correctness ensures that E0Ps are compatible with plant responses, plant hardware, and l

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the operating shift. Usability ensures that the EOPs provide

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sufficient and understandable operator information.

The program evaluation criteria are used to determine if the validation principles are satisfied. This document provides guidance for the development of plant-specific evaluation criteria. Sample evaluation criteria are provided for each validation principle for a typical plant.

This program process supports the actual performance evaluation. .This document divides the process by phases:

preparation, validation resolution, and documentation. Guidance is provided for each of these phases along with sample procedure for each validation method.

This document is presented for guidance only. Its program is not intended to duplicate efforts in existing EOP review and approval processes. EOP validation as presented in this document is a pe.aformance evaluation which addresses whether the i BOPS are operationally correct and usable. The evaluation of whether or not the EOP information is written correctly and technically accurate is made during E0P verification.

v. BWR Owners' Group E0P Guidelines The purpose of this guideline is to provide generic symptomatic

emergency procedure guidelines (FPG's). These EPGs are generic to GE BWR-1 through 6 designs, in that they address the major systems which may be used to respond to an emergency. The guidelines are written for plants as they are currently

configured, no attempt has been made to propose system modifications. Because no plant has the same system

configuration, the EPGs are applied to individual plants by

! deleting statements which are not applicable or by substituting

equivalent systems where appropriate.

l The program objective is to produce procedures that are more comprehensive, less voluminous and symptomatic in their treatment of emergency situations. The entry conditions, therefore, are symptomatic of both emergencies and events which may degrade into emergencies. Entry into such a procedure set is not conclusive that an emergency has or will occur.

l l vi. Emergency Operatina Procedures Generation Package  ;

l Guideline (INPO 83-007), Published February, 1983 This i document contains guidance for use in the development of the Procedures Generation Package (PGP). It identifies for presentation or description in the PGP:

- Technical Guidelines Writers Guide for E0Ps

- EOP Verification

- EOP Validation

- Training t 2-4

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-_,,_-,-.--c_,., _ _ _ . _ - _ _ - _ _ - , - . . . _ _ - _ - . . _ _ _ - _ _

-- a - # s -. :f This document also presents a sample PGP.

, b. Input Criteria 1.' Writers Guide for EOPs A writers guide for E0Ps is a plant-specific document that provides instruction on writing EOPs, emphasizing the incorporation of human factors principles. It can be either a separate document devoted specifically to E0P's or a broader

! document with a section devoted to EOP's.

The writers guide can be continually improved, based on feedback from operator training and experience. In addition to establishing sound writing principles, a well-developed writers

guide helps to promote consistency among all E0Ps independent of the number of. EOP writers. It should cover the following j topics

) - E0P format

- EOP organization

- EOP level of detail

- role of the EOP within the procedure system and network

- EOP content

- mechanics of style ii. Emergency Operating Procedures Mr. Eisenhut's letter of February 8,1983 approved NEDO-24934 Rev. 2, June 1982. These generic guidelines identify the 1

equipment or systems to be operated and list the steps necessary to mitigate the consequences of transients and accidents. They provide sound engineering bases for the development of EOPs. A 3

given plant will use at least one of the two types of technical guidelines: generic or plant-specific.

- Generic Technical Guidelines - Technical guidelines prepared by a group of plants or owners groups for plants with a similar design.

- Plant-Specific Technical Guidelines - Technical guidelines prepared for plants using a generic technical guideline and/or plant-specific guidelines developed specifically for the particular plant.

When addressing this element in the formulation of an E0P l implementation plan, consideration of the following major items should be included:

- mechanics of conversion

- - location of the plant-specific technical information

- - how the plant-specific technical information was used

- the use of old ROPs l

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- documentation requirements

- use of the background information supplied with the technical guideline

- licensing commitments

iii. Task Analysis The use of the term " task analysis" in the CRDR has caused some confusion. Of all implementation elements, the task analysis is probably the least understood and, hence, may require more time and effort to be integrated properly with other CRDR activities.- It is vital to the outcome of the CRDR that adequate attention be given to task analysis, since it can integrate the operational, dynamic aspects of plant operation with the results of the CRDR.

The task analysis is used to delineate the specific actions (automatic and manual) that must take place to accomplish system functions. Fce the CRDR task analysis, the emergency precedure guidelines (EPGs) can be the technical bases for emergency operation.

The level of detail and types of information collected during task analysis is dependent on the focus of the CRDR. When addressing this element in the formulation of a CRDR implementation plan, the following major items should be I

considered:

- focus and desired output of the overall CRDR

- availability of personnel to conduct task analysis

- definition of how the implementation plan can make use of industry and owners group task analysis

- extent of training required by review personnel in the use of task analysis

- documentation necessary to use data from the task analysis in potential control room deficiencies.

2. CONTROL ROOM DESIGN REVIEW PROGRAM PLAN

a. General Guidelines

1. NUTAC Guidance on CRDR (a) CRDR Implementation Guidelines This document provides guidance to utilities for use in developing their implementation plans for control room design' review (CRDR). The basic elements of an ir.plementation plan for CRDR are described. The following elements are presented and discussed for each phase of the CRDR:

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Planning Phase

- Organization

- Focus and Extent of the Review

- Review Team Composition

- Review Team Orientation

- Use of EPGs and EOPs Execution Phase

- Survey

- Task Analysis (Syster Review)

Assessment Phase

- Human Engineering Review Principles

- Assessment of HEDs

- Effect of Operator Aids

. Effect of Current Modifications

- Prioritization of HEDs Correction Phcse

- Enhancements and Modifications

- Procedure Changes

- Operator Training Effectiveness Phase

- Validation

- Reporting

- Feedback

- Upkeep Documentation Phase

- Document Control

- Working Documents

- Summary Report These elements were identified by the Nuclear Utility Task Action Committee (NUTAC on CRDR). The elements presented are not to be construed as an exhaustive list, but are considered to be generic to most plants. The elements should be reviewed by the utility for individual applicability. In an appendix of this document is an example of a CRDR implementation plan that illustrates how the elements described in the body of the guideline might be incorporated into a plant-specific document.

(b) CRDR Survey Development Guideline The Control Room Design Review Survey Development Guideline provides survey development guidance to utilities. It 2-7

describes a method for generating checklists and questionnaires. These will be used in the CRDR human factors survey. The document contains an introduction, a section on definitions used and a section on method.-

. Appendices contain examples of checklists and questions on NUREG-0700 guideline critiques. The definitions section provide definitions of those terms associated with the control room survey as those terms are used in the document.

i The survey development section describes the methodology

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used when screening guidelines for inclusion in a control room survey checklist. Each element of the methodology is associated with at least one appendix that delineates those specific NUREG-0700 Section 6 Guidelines to which the screening criteria applies.

Appendix A contains example questions, checklists and surveys. They represent a partial conversion of NUREG-0700, Section 6 Guidelines into a set of achievable tasks.

Appendix B contains NUREG-0700, Section 6 criteria which are vague or unquantifiable. The criteria have been annotated with objective criteria.

Appendix C contains NUREG-0700, Section 6 criteria called

, " preferred designs". The criteria should be considered under the " Selection Improvement" phase of CRDR.

Appendix D contains those NUREG-0700 criteria which are predominately procurement specifications from MIL-STD-1472.

Appendix E contains those NUREG-0700 criteria which might degrade performance and an explanation.

j. b. Input Criteria

. 1. Control Room Surrey l The control room survey is an explicit, well-defined control i room design verification activity within the CRDR. The survey consists of comparing the characteristics of the existing

! control' room with commonly accepted human engineering design

! criteria.

i The major items to be considered when addressing this element in the formulation of a CRDR implementation plan are the human engineering criteria to be used in the review and the extent of the survey. Default criteria are contained in Section 6, NUREG-0700, " Guidelines for Control Room Design Reviews." Other applicable human engineering criteria may also be used to support the desired focus (see " Control Room Design Review Survey Development Guideline", also being developed by the i

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NUTAC). Though the survey can be applied to any operational area of the plant, for the CRDR the survey should be focused to the operating panels and environment inside the control room.

Whatever criteria are chosen for use, they should be referenced explicitly in the implementation plan. The following aspects of the survey should be considered:

- completeness of the survey criteria

- applicability of survey criteria to the focus of the CRDR

- training of the survey team (s) in the use of the selected criteria

- availability of equipment to measure the parameters necessary to meet the selected criteria

- auditability of the technique (s) used to apply the survey criteria

- documentation of survey results

- description of the specific operating areas to be surveyed ii. Human Factors Engineering During the survey phase of the CRDR, the existing control room is reviewed for compliance with commonly accepted human engineering design criteria. These criteria can be found in many source documents, such as NUREG-0700, MIL-STD-1472C, etc.

Aspects of the control room that do not conform to design guidelines are classified as HEDs. The next implementation element (3 3 2) deals with the assessment of HEDs to determine the potential seriousness of errors that might result from such discrepancies.

It can be useful during the assessment phase of the CRDR to keep in mind the human factors principles on which detailed survey guidelines are based (see ' Human Engineering Review Principles,"

also being developed by the NUTAC). During the control room survey, it is easy to lose sight of where the detailed survey criteria originated and why they were developed. The inclusion

[

of basic human engineering principles in the development of the CRDR implementation plan serves as a reminder that the i

measurements and values contained in detailed guidelines are not l to be interpreted as absolute, inflexible numbers.

! When addressing this element in the CRDR implementation plan,

( the following major points should be considered:

l l - the leva

• detail of the principles

- the appiAcacility of particular principles to the control room

- cross-reference of principles to the detailed survey guidelines

- the bahavioral criteria used to judge that principle has been met

- the population to which the principle is to be applied l

l 2-9 l

-- the experience of review team members in interpreting human factors principles

- The completeness of the set of principles used 3.. REGULATORY GUIDE 1.97 PLAN

a. General Guidelines

i. BWR Owners' Group RG-1.97 Guidelines The objective of the BWR Owners Group RG-1.97 is to provide the BWR Utilities with an evaluation of the safety effects and the feasibility of implementing the proposed regulatory positions, particularly those defined in Table 1 of RG-1.97. The Owners Group has provided, as a result of their efforts, the following information:

- A Summary Position Statement

- A Detailed Position on a variable-by-variable basis

- Abstracts of supporting analysis and studies

11. NUTAC Guidelines for Accident Monitoring Instrumentation The objective of the RG-1.97 NUTAC subcommittee is to assist utilities in their implementation of accident monitoring instrumentation, particularly in the relation of such instruuentation to RG-1.97. To meet this objective the subcommittee will provide a document that contains the following:

- selection of plant-specific qualification criteria, ensuring that sufficient flexibility exists to accommodate plant-specific needs

- selection of plant-specific instrumentation for control room, in-plant and TSC/ EOF monitoring

- example formats for RG-1.97 response

- summary of available industry positions of RG-1.97 and related guidance documents.

This decument is scheduled to be issued in May 1983 l b. Input Criteria

1. RG-1.97 Design Criteria (See 3.a.i.i above) 2-10

4. SPDS PLAN i

a. General Guidelines

i. NUTAC Guidelines for an Effective SPDS Implementation Program (INPO 83-003)

Provides guidance for use inplant-specific SPDS implementation programs. The document provides guidance for each of the following considerations:

- Implementation Planning

- Formulation of Design Bases

- System Design

- Preparation of Purchase Specifications

- Installation and Testing

- Training

- Documentation

- Integration

- Hardware Maintenance l - V&V of SPDS Hardware and Software J

The document's appendices provide the following additional information:

- Appendix A clarifies the definition of the SPDS in terms of its operational attributes

-- Appendix B summarizes human factors considerations applicable to the SPDS.

- Appendix C describes the relation of the SPDS to plant-specific critical safety functions (of the E0Ps).

- Appendix D describes the evaluation of the SPDS in a control room environment, and serves as a brief introduction to the Component Verification and System Validation guidance of the ERC NUTAC.

By review of each topic addressed in these guidelines, a cohesive and efficient implementation program for the SPDS can be developed by each utility. This document is offered as

[

guidance only.

b. Input Criteria

1. Critical' Safety Functions Guidance is provided with the NUTAC Technical Guidelines.

5. ERF PLAN

a. General Guidelines i

1. NUTAC Guidelines for ERF Plan This document provides additional guidance to selected regulatory requirements related to the TSC, OSC, and the EOF 2-11 l

. - .= . .- .= .- -

which in the opinion of the NUTAC on Emergency Response i

Capability, would be of benefit to utilities.

It provides: .

- Guidance to utilities on how to interpret NRC regulatory documents as they relate to ERFs.

- - Guidance for satisfying the intent of NRC regulatory requirements on ERFs as identified in 10 CFR 50.47 and Supplement 1 to NUREG-0737.

- Examples of alternatives for meeting the intent of NRC regulatory documents

! It is recognized that most utilities have already addressed the

{ role and function of these facilities on an interim basis, and have developed conceptual designs based on previously defined requirements. For operating license and near-term operating license plants, parts or all of these conceptual designs may have been implemented. As such, the guidance contained in this document takes into account the progress made by utilities in '

upgrading their emergency response facilities.

The following format was used:

- Issue

! - Regulatory Requirement

- Applicability (ERF to which requirement applies)

- NUTAC position (guidance on implementing the requirement)

< - Justification for the position

- Example l b. Input Criteria

1. TSC - See description of Item 5.a.1) above ii. OSC - See description of Item 5.a.1) above iii. EOF - See description of Item 5.a.1) above

6. Verification and Validation

a. General

1. Summary of the NUTAC Component Verification and System Validation Guidelines l

The purpose of this document is to provide guidance in developing a Component Verification and System Validation (V&V)

Program. This documentation presents Component Verification as a comparative evaluation conducted to determine that there is consistency between appropriate source documents and the f operator, plant, procedure and training components of a model l system (Systes). Validation is presented as an evaluation t conducted to determine that the System functions to accomplish 2-12

i

'the desired results. For ERC evaluation the desired results are to mitigate the consequences of emergency conditions. Guidance is provided for three major areas: program objectives, program evaluation criteria, and program process.

The verification process supports the actual comparative evaluation of the individual components, while the validation process supports the actual overall system evaluation. Both use evaluation criteria developed from either Component Verification or System Validation Principles. Each process is divided by four phases: preparation, verification or validation, resolution, and documentation. Guidance is provided for each ,

phase.

This document is presented for guidance only to assist utilities in responding to the provisions of NUREG-0737, Supplement 1.

b. Input Criteria

i. V&V Input Criteria V&V PLAN  ;

The V&V Plan addresses component verification and system t validation. The system of concern consists of four major

! components: operator, procedures, plant, and training.

I Component verification is a comparative between appropriate source documents and a component. EOPs are an example component and the technical guidelines are sample source documents.

System validation is an evaluation conducted to determine that l the system components function together to accomplish the desired results.

'Further guidance can be found in the following documents being

developed:

i - Guidelines for Component Verification and System Validation

- Emergency Operating Procedures Verification Guideline

- Emergency Operating Procedure Validation Guideline

- - Guideline for an Effective SPDS Implementation Program i

EOP VERIFICATION

(

E0P verification is the evaluation performed to confirm the I written correctness of the procedure to ensure that the generic l and plant-specific technical aspects have been properly incorporated. The evaluation should also check that the human factors aspects presented in the writers guide for EOPs have been applied.

1 2-13

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4 When addressing this input in the formulation of an integration plan, consideration of the following major items should be included:

- how EOP verification will be performed

- documentation of the verification process

- the process used in resolving discrepanies Further guidance can be found in the document Emergency Operating Procedures Guideline, which is being developed by the E0 PIA Review Group.

EOP VALIDATION Validation of E0Ps is the evaluation perfermed to determine the actions specified in the procedure can be performed by the operator to manage the emergency coaditions. Methodology for E0P validation should be developed to utilize present, available, state-of-the-art methods while recognizing and allowing for future improvements. Validation should evaluate the operators' ability to manage emergency conditions. It need only validate that part of the EOP not covered by any validation of generic technical guidelines.

When addressing this input in the formulation of an integration plan, consideration of the following major items should be included:

- how EOP validTtion will be performed

- use of a simulator, plant walk-throughs, or desk-top checks

- operator and training experience

- evaluation criteria and method for resolving disciepancies

- documentation of the validation process Further guidance can be found in the document Emergency Operating Procedures Validation Guideline, which is being developed by the E0 PIA Review Group.

(014ASRZ2b) 2-14

I O

ATTACHMENT 3 PLANS AND SCHEDULES FOR EMERGENCY RESPONSE CAPABILITIES 3-1

i L

SAFETY PARAMETER DISPLAY SYSTEF (SPDS); ,

l The computer-assisted. approach tor.SPDS, selected by CP&L as best meeting the intent ~ of NRC requirements, requires a major capital investment. Expenditures of this magnitude could not be jrstified prior to Commission' approval of requirements ~in this area. This is particularly true for SPDS owing to the considerable debate-and. subsequent changes.in guidance which impacted specific design-related and cost-sensitive areas such as seismic-qualifications,

. Class 1E qualifications and availability. The development of detailed-hardware, software and installation bid specifications could not be completed until these requirements were approved by the Commission.

Only after detailed negotiations with a vendor is it possible to establish this design and procurement schedule including'the schedule impact of other orders received by the vendor. An installation schedule cannot be completed

+

-until final design of the system is completed by the SPDS vendor and delivery is scheduled. Finally, the CRDR and E0P upgrades and RG-1.97 implementation-9

' must be integrated with the overall SPDS logic. This integration logic is shown on Figure 1, Attachment 1.

, Carolina Power &' Light Company has written a functional specification for the SPDS, which is adaptable to all three CP&L' nuclear plant sites.

On February 25, 1983, CP&L received bids - from firms to provide preliminary engineering, construction cost,-and schedule estimates and to conduct on-site evaluations to identify and recommend solutions for space, HVAC and power .

supply problems.- A firm was selected and has conducted a preliminary l

assessment. Carolina Power.& Light Company's best estimate of a schedule for development of.the procurement specifications and award of contract-for

. production of the.SPDS is as follows:

Award Contract: ' May 1984 Submit Safety Analysis: July 1985 SPDS Operable: 3 months after startup from Refueling n Outage #6 (Unit 2) (Spring 1986)

SPDS Training Complete: -3 months after startup from Refueling Outage #5 (Unit 1) (Summer 1986)

Following negotiation with a vendor, and award of contract for_the SPDS, CP&L t will;be in a position to commit to a firm delivery schedule for the SPDS. As requested'by Generic Letter 82-33, CP&L does not desire an NRC pre-implementation review.

3 DETAILED CONTROL ROOM DESIGN REVIEW (DCRDR)

The Essex Corporation has completed a DCRDR for the current- configuration of

the BSEP control room'and has identified some human engineering discrepancies (HED's). Carolina Power & Light Company has reviewed these HED's and is establishing a schedule'for resolution of the remaining applicable HED's.

Resolutions for applicable HED's will be determined by July, 1984 and,

' depending on the total scope, it is anticipated that a schedule for completion can be' completed.by December, 1984.

i' 3-2 1

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After SPDS and RG-1.97 implementation plans and E0P upgrades are complete, a design-improvement verification and validation will be performed. Our best estimate is that, once the scope is fully analyzed, correction of any additional HED's can be completed for Unit 1 by three months after Refueling #5 (currently scheduled for Summer 1986) and for Unit 2 by three months after Refueling #6 (currently scheduled for Spring 1986). After these HED's are completed, CP&L will submit a DCRDR summary report and a description of HED's corrections in summary form.

REGULATORY GUIDE 1.97 Carolina Power & Light Company will evaluate the BWR Owners Group and NUTAC guidance documents on RG-1.97 as described in Attachment 2 in preparing an integrated plan for RG-1.97 compliance. A recommendation for an implementation plan will be developed by Hay, 1983 These recommendations must be integrated with SPDS plans and EOP upgrades before finally deciding which modifications to instrumentation are required. However, we anticipate the following milestones can be achieved:

Submit-Preliminary Report to NLo 9/33 Complete Implementation: (after SPDS installation)

Unit 1 3 months after Refueling #5 (currently scheduled for Summer, 1986)

Unit 2 3 months after Recasling #6 (currently scheduled for Spring 1986)

We will be able to commit to 3; '* mentation dates after completion of our preliminary report in September 1983 UPGRADE EMERGENCY OPERATING PROCEDURES (EOPs_)_

Carolina _ Power & Light Company has drafted upgraded E0Ps using the BWR Owner's Groups technical guidelines and INPO's E0P Writing Guideline, as described in Attachment 2 and NUREG-0899. In accordance with Supplement 1 to NUREG-0737, we will submit a procedures generation package, including plant-specific technical guidelines, and plant-specific writers guide, and description of our program for verification and validation by July 1983 Training on this version of the E0P's will be completed by December, 1983 As the SPDS, RG-1.97 requirements and CRDR results are implemented, additional minor-revisions to the E0Ps may be required. Assuming milestones for SPDS, RG-1.97 and CRDR activities are achieved on our proposed schedule, we anticipate completion of operator training within six months after Refueling Outage #5 for Unit 1, currently scheduled for Summer,1986, and Refueling Outage #6 for Unit 2, currently scheduled for Spring, 1986. We will be able to commit to this schedule after additional future milestones for these activities are actually achieved.

3-3

EMERGENCY RESPONSE FACILITIES With respect to emergency response facilities, CP&L is currently using interim facilities, which have functioned effectively during emergency drills conducted in August 1981 and April 1982. Carolina Power & Light Company commenced construction of. permanent EOF /TSC. facilities in October 1982, at a location' approved by NRC letter dated May 19, 1982. Construction of the building is 40% complete, with completion of the building scheduled for December, 1983 We anticipate that communications, except for Emergency Response Facility Information System (ERFIS), security modifications, and training on these facilities will be completed by July 1984. In addition, when the ERFIS is implemented in the EOF /TSC along with the SPDS in the Control Room, we anticipate training using these systems can be completed for Unit 1 by three months after Refueling #5 (currently scheduled for Summer 1986) and for Unit 2 by three months after Refueling #6 (currently scheduled for Spring 1986). We will be able to commit to these proposed schedules after additional milestones on communications, security modifications and ERFIS are actually achieved.

We anticipate being able to meet NRC requirements listed in Supplement 1 to NUREG-0737 for Emergency Response Facilities with the exception of one item shown on Table 1. Our EOF is located adjacent to the plant and will meet the radiation protection criteria as the TSC and control room. No occupant of the EOF will receive more than 5 REM (or equivalent) during the design basis accident. In addition, the state and local agencies will not be using our EOF for their State Energency Response Team Headquarters, but have elected to use the North Carolina Army National Guard Headquarters in Wilmington, N.C.

Should utility, local, federal or state personnel wishing to travel to the EOF elect not to do so because of radiological protection reasons, an alternate facility is available at the Bolivia County Office Complex, 11 miles from the plant, for their use in communicating with the TSC and EOF. As described in the draft NUTAC Guideline on ERFs, we believe that an exception to the Commission's requirement for a backup EOF is justified because:

(1) There are no situations whereby evacuation of the primary EOF would be required.

(2) State and local agencies will not use the primary EOF but will establish reliable communications from their Emergency Center at the North Carolina Army National Guard Headquarters.

(3) Emergency response will be enhanced by remaining in the primary EOF and not by retreating to a backup EOF with less reliable communications, facilities and training.

(4) An alternate communication facility exists at the Bolivia County Office Complex, 11 miles from the plant.

As provided in Paragraph 3 7 of Supplement 1 to NUREG-0737, NRC will make allowances for work already done by licensees in good-faith to meet previous NRC guidance. We feel that planning and training to remain in the primary EOF is a more reliable and enhanced emergency response position, and is consistent with the positions of many other licensees that are in a similar situation of 3-4

F having~ proceeded to construct these facilities in good faith. Carolina Power & Light Company, therefore, requests written confirmation from the Commission that our reasoning is sound and a backup EOF would not enhance our emergency response capability nor those of the federal, state, or local agencies.

SUBMITTALS TO NRC.

In summary, CP&L expects to submit the information requested in Supplement 1 to NUREG-0737 for NRC review in accordance with the following schedule:

NUREG-0737 Supplement 1 Submittal Reference Schedule

1. SPDS Safety Analysis 4.2a 7/85

2. DCRDR Summary Report 5.2b 3 months after:

Unit 1 Refueling #5 &

Unit 2 Refueling #6 3 RG-1.97 Report 6.2 9/83

4. E0P Technical Guide- 7.2a Complete (February 8, 1983) lines (Generic)

5. E0P Procedures Gen- 7.2b 7/83 eration Package (014ASRZ3b-Ir) 3-5