ML20073M311

Forwards Response to Generic Ltr 82-33 Re Suppl 1 to NUREG-0737, Requirements for Emergency Response Capability. W/One Oversize Encl.Aperture Card Is Available in PDR

ML20073M311
Person / Time
Site:	Farley
Issue date:	04/15/1983
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, NUDOCS 8304210470
Download: ML20073M311 (50)

Text

Malling Address Alabimi Power Compiny 600 North 18th Str;et Post Office Box 2641 Birmingham, Alabar,a 35291 Telephone 205 783-6081 b

F. L Clayton, Jr.

Oflon'OZ*"'

AlabamaPower the Southern E4Ctrc systLm April 15, 1983 Docket Nos. 50-348 50-364 Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C.

20555 Attention:

Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units'1 and 2 NRC Generic Letter 82-33, " Supplement 1 to NUREG-0737 -

Requirements for Emergency Response Capability", Dated December 17, 1982 Gentlemen:

On December 30, 1982, Alabama Power Company received NRC Generic Letter 82-33, " Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability", dated December 17, 1982. This Generic Letter transmitted NUREG-0737, Supplement 1 which provided additional clarification regarding Safety Parameter Display Systems, Detailed Control Room Design Reviews, Regulatory Guide 1.97 (Revision 2), Upgrade of Emergency Operating Procedures and Emergency Response Facilities.

Additionally, Generic Letter 82-33 requested that Alabama Power Company provide a proposed schedule for completing each of the basic provisions of Supplement 1 to NUREG-0737 as well as plans for their phased implementation and integration. Alabama Power Company has evaluated the basic provisions and clarifications of Generic Letter 82-33 and has 3

developed the Preliminary Farley ERC Integrated Implementation Plan and 30 Schedule discussed herein.

Background

Y,fc.u!50'/

In Alabama Power Company's letter dated t'ovember 16, 1981 f

( Attachment 1), the impact of the overlapping provisions of existing NUREGs, Regulatory Guides and additional NRC guidance (some of which was in draft form) was discussed. Alabama Power Company's position was that the finalization of all NRC guidance was necessary in order to implement an integrated system to enhance the present emergency response capa-bilities at the Farley Nuclear Plant. The implementation of an integrated system prior to finalization of the additional draft NRC guidance could have resulted in expenditures for unnecessary future modifications.

It was intended that the integrated system address previous Alabama Power Company commitments as well as the additional NRC guidance that was anticipated. Consequently, Alabama Power Company committed to provide the NRC with an implementation plan and schedule 8304210470 830415 PDR ADOCK 05000348 F

PDR b.

Mr. S. A. Varga April 15,1983 U. S. Nuclear Regulatory Commission Page 2 for the installation of an integrated system upon the finclization of the NRC criteria for emergency response capabilities. This matter was discussed by Mr. R. P. Mcdonald of Alabama Power Company and Messrs. V.

Stello, H. R. Denton and D. G. Eisenhut of the NRC Staff prior to the issuance of the November 16, 1981 letter.

Since the issuance of this letter, finalized NRC criteria associ-ated with emergency response capabilities has been provided in Supplement 1 to NUREG-0737. Alabama Power Company believes that an integrated system to enhance the present emergency response capabilities at Farley Nuclear Plant can now be developed.

Preliminary Integrated Implementation Plan and Schedule To obtain the information necessary to develop the Preliminary Farley ERC Integrated Plan and Schedule, Alabama Power Company is actively participating in the Nuclear Utility Task Action Committees (NUTAC's) and the Westinghouse Owners Group. The Nuclear Utility Task Action Committee on Emergency Response Capabilities (ERC NUTAC) is an industry group formed by more than 40 utilities to specifically address the basic provisions of Supplement 1, to NUREG-0737. The ERC NUTAC has developed a draft ideal integration plan which is scheduled to be published by June 1983. This draft ERC NUTAC integration plan, l

described in Attachment 2, provides for total integration of the basic l

NUREG-0737, Supplement 1 provisions; however, it is ideal since it does l

not consider previously completed work or other commitments made by i

Alabama Power Company. The ability to integrate plant-specific work and previous connitments is within the f ramework of the draft ERC NUTAC integration plan. Taking into account previously completed work and commitments made by Alabama Power Company, the concepts of the draft ERC NUTAC integration plan were used in developing the Preliminary Farley ERC Integrated Implementation Plan and Schedule.

In addition, industry-originated guidance has been utilized in developing the Preliminary Farley ERC Integrated Implementation Plan and Schedule. A summary of the applicable industry-originated guidance is included as.

The Preliminary Farley ERC Integration Implementation Plan and Schedule is described in Attachment 4.

It includes a schedule which graphically displays the timetable for completing actions associated with each of the basic NUREG-0737 Supplement 1 provisions as well as thei r integration and interface. For activities dependent on past completed work and for which sufficient planning and evaluation has been performed, calendar dates are provided. Typically, dates have been given for key activities scheduled during 1983. For activities beyond 1983 for which sufficient final information is not available, durations were estimated based on certain assumptions. These assumptions include 18-month mfueling cycles, 6-week mfueling outages, current mfueling outage schedules, and completion of previously committed activities.

The identified 1983 milestones and submittals are considered firm while i

Mr. S. A. Varga April 15,1983.

U. S. Nuclear Regulatory Commission Page 3 the remainder of the schedule is preliminary and is provided only to illustrate the current planning. The Preliminary Farley ERC Integrated Implementation Plan and Schedule discusses the status of completed activities associated with the basic provisions of NUREG-0737, Sup-plement 1.

In addition, the adequacy of the existing emergency response capabilities at the Farley Nuclear Plant during the interval to imple-ment the modifications for the enhancement of these existing capabil-ities is also discussed. As shown in the schedule, SPDS implementation is the primary activity with which other initiatives must integrate.

The complete installation of the ERC integrated system is scheduled for no later than the 8th refueling outage (October 1988) on Unit 1 and no later than the 5th refueling outage (June 1988) on Unit 2.

Alabama Power Company recognizes the value of the enhancements to be provided by the ERC integrated system and desires to expedite the implementation schedule; therefore, a goal to complete implementation in approximately three and one-half years has been set.

Alabama Power Company developed the Preliminary Farley ERC Inte-grated Implementaion Plan and Schedule considering those known activ-ities whose performance may contribute to a fully integrated, cost-effective and safely implemented ERC integrated system. These schedules and durations are based on the installation of certain physical modifi-cations during the cold shutdown mode of refueling outages. During the implementation of this project, it will be determined how the overall schedule can be si ortened.

It is anticipated that schedule advancements may be obtained by reducing the duration to complete some activities, deleting or altering the scope of the identified activites or manip-ulating the sequence in which these activities would be performed. Al a-bama Power Company is anxious to advance the installation and opera-tional dates shown therein and will make every reasonable effort to do so.

It should be noted that a significant portion of these activities will affect safety-related equipment, including equipment necessary to obtain and maintain a cold shutdown condition. To ensure that no ERC modification degrades the present emergency response capabilities at Farley Nuclear Plant, Alabama Power Company will take all steps neces-sary to provide for safe implementation of the ERC integrated system.

As discussed, the completion of a final integrated plan and schedule is not possible at this time. Such a final plan and schedule requires the determination of the scope, duration, coordination and identity of the necessary activities to comply with NUREG-0737, Sup-plement 1 provisions. This determination requires:

selection of vendors determination of vendor and utility responsibilities determination of bills of material

Mr. S. A. Varga-April 15,1983 U. S. Nuclear Regulatory Commission Page 4

. establishment of equipment and procurement lead-times determination of the duration of vendor engineering and services estimations of the duration of NRC review and approval of Alabama Power Company submittals issuance of the aforementioned pending industry guidance documents determination of the scheduling impact of all licensing commitments and other plant initiatives determination of plant-specific design that may only be obtained during outages of sufficient duration (i.e., walkdown) determination of the impact of the NUREG-0737, Supplement 1 activities on each other (e.g., CRDR impact on SPDS)

The information regarding these activities can not be obtained at this time and, in many instances, the required interfaces with organizations, such as vendors and the NRC Staff, are beyond the reasonable control of Alabama Power Company.

Conclusion Alabama Power Company will provide an update to the Preliminary Farley ERC Integrated Implementation Plan and Schedule by December 15, 1983 based on completion of scheduled activities, further planning, completion of conceptual design, and schedule advancements made as a result of our goal to implement the ERC integrated system in approximately three and one-half years. Alabama Power Company desi res to work with the NRC Farley Nuclear Plant Project Manager, Mr. E. A.

Reeves, and other members of the NRC Staff to discuss the Preliminary Farley ERC Integrated Implementation Plan and Schedule in order to assure implementation of emergency response activities within a reasonable timef rame and to assure the optimization of the resources of both organizations.

The provisions of NUREG-0737, Supplement 1 are to enhance the present emergency response capabilities and are not intended to provide the sole safety function. As described in Attachment 4, the present emergency -response capabilities at Farley Nuclear Plant are adequate during the implementation of modifications to enhance these capabil-ities. These present capabilities consist of fully operational Emergency Response Facilities; upgraded emergency operating procedures that. incorporate post-TMI recommendations; a plant computer and main control board instrumentation to monitor critical safety functions and plant parameters; and a control room that has been modified for human

'Mr. S. A. Varga April 15,1983 3

O. S.- Nuclear Regulatory Commission Page 5 engineering discrepancies identified during a Control Room Human Factors and Operations Review. Consequently, the safe operation of Farley Nuclear Plant - Units 1 and 2 will not be jeopardized during the interval required to develop and implement an integrated system for the enhancement of the present emergency response capabilities.

Alabama Power Company believes that the undertaking of the initiatives described in this letter is a demonstration of a good-faith effort to meet or exceed the NRC guidance now provided in Supplement 1 to NUREG-0737.

If there are any questions regarding this matter, please advise.

Yours very truly, h

F. L. Clayton, { r.

FLCJ r/ MAL:lsh-D18 SWORN TO AND SUBSCRIBED BEFORE ME cc:

Mr. R. A. Thomas

~

DAY OF//n /,1983 Attachments THIS / sed

/

Mr. G. F. Trowbridge Mr. J. P. O' Reilly

[,

/A/[N4,/

Mr. E. A. Reeves

~ NOTARY PUBLIC Mr. W. H. Bradford My Commission Expires: /o /k ya $ 6'

/ -

ATTACHMENT 1 Memng Addr..

)'

Qtg,a Power ompany

~

,n Post Office Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6081 L

u cia, ion. u.

Alabama Power S*Q'CZ7"'

une saanern ewre sw November 16, 1981 Docket Hos. 50-348 50-364 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Washington, D. C.

20555 Attention: Mr. S. A. Varga Gentlemen:

Alabama Power Company Comitments Relating to R. G. 1.97 Rev. 2. NUREG-0696 and NUREG-0700 As a part of the Unit 2 licensing process Alabama Power Company These requirements in-comitted to address several new requirements.

cluded NUREG-0696 " Functional Criteria For Emergency Response Facilities";

Regulatory Guide (R.G.) 1.97," Instrumentation For Light Water Cooled Nuclear Power Plants to Access Plant and Environs Conditions During and Following An Accident"; and NUREG-0700," Guidelines For Control Room Design Reviews".

The NRC Safety Evaluation Report for Farley Nuclear Plant (FNP) dated March 19,1981 required Alabama Power Company to address compliance with To address the requirements of NUREG-0696, NUREG-0696 af ter its issuance.

A review of applicable a Task Force was established upon NUREG issuance.

vendors was conducted to determine available systems complying with the These A specification was submitted to qualified vendors.

requirements.

By vendors submitted proposals that have been reviewed by the Task Force.

letter dated May 19, 1981 Alabama Power Company comitted to develop a system which addresses these criteria but took exception to the required in-service date of October,1982. Alabama Power Company comitted to provide the NRC with a completion schedule upon award of contract.

The FNP-2 Full Power License Item 2.c.(20), requires th't a schedule be submitted to the NRC, prior to April 30, 1981, for bringing the facility On March 30, 1981 Alabama into compliance with Revision 2 of R.G. 1.97.

Power Company comitted to make every effort to complete this program by June,1983 with potential reasons for slippage of this date being equipment The March 30, 1981 delivery and/or time for installation and checkout.

submittal included a schedule for completing each phase of the project.

This schedule provided for submittal of Alabama Power Company's detail implementation plan by October,1981. During the R.G. 1.97 review of FNP instrumentation, Alabama Power Company developed a licensing basis and recomended hardware configuration.

/

t

Director of Nuclear Reactor Regulation November 16, 1981 U. S. Nuclear Regulatory Comission Page 2 Attention: Mr. S. A. Varga By letter of January 14,1981 Alabama Power Company comitted to address the detailed control room design review after issuance of NUREG-0700 was issued in September, 1981 and Alabama Power NUREG-0700.

Company is in process of reviewing this NUREG and developing an im-

.p emen at tion plan.

l Due to the overlapping requirements of R.G. 1.97 and NUREG 0696, implementation of an integrated system to meet both requirements was planned. A contract for this integrated system was scheduled for execution in November,1981. In the last few weeks, Alabama Power Company has become aware of additional draft NUREGs which affect design, These implementation and display of the proposed integrated system.

draft NUREGs include NUREG-0801, " Evaluation Criteria For Detailed Control Room Design Review"; NUREG-0799," Draft Criteria For Preparation of Emergency Operating Procedures"; NUREG-0814," Methodology For Evaluation of Emergency Response Facilities"; and NUREG-0835," Human Factors Acceptance Criteria For the Safety Parameter Display System". These NUREGs are currently in draft fonn and have been issued for coments.

To enable Alabama Power Company to implement an integrated system whichaddressesexistingcommitments(NUREG-0696,R.G.1.97andNUREG-0700) in a manner that will be consistent with criteria currently in review (draft NUREGs), such new criteria must be finalized by the NRC nd included in the design basis of the Farley system to preclude unnecessary future modifications.

Mr. R. P. Mcdonald contacted Messrs. Victor Stello, H. R. Denton, and D. G. Eisenhut of the NRC staff to discuss the potential impact of the draft NUREGs on the planned integrated system for Farley. From these discussions it was determined that Alabama Power Company should not expend significant funds until the regulatory requirements were finalized and that Alabama Power Company should document concerns due to lack of finalized criteria and their impact on system design and implementation.

In order that an integrated system be developedwhich addresses all oftheaboveNRCCriteria,$labama_ Rower _ Company _proposesthat_adesign Upon finalization of be_ finalized after the_dra.ft_NUREGs_are_. finalized.

these criteria, Alabama Power Company will provide an implementation plan and schedule, agreeable to the NRC, for design and implementation of this Accordingly. Alabama Power Company respectfully requests integrated system.

that appropriate licensing requirements and associated letters of commitment be revised to reflect this approach.

4

-. -. ~

November 16, 1981 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Comission Page 3 Attention: Mr. S. A. Varga Alabama Pcwer Company is prepared to meet with the NRC Staff to discuss this proposal.

Yours truly, f

n F.L.Clayton/Jir.

i FLCJr/RLG:awm cc: Mr. M. R. Denton Mr. Victor Stello Mr. D. G. Eisenhut Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. O'Reilly Mr. E. A. Reeves Mr. W. H. Bradford

ATTACHMENT 2 l

SUMMARY

OF THE DRAFT ERC NUTAC GUIDELINES FOR AN INTEGR ATED IMPLEMENTATION PLAN l

I

INTRODUCTION A subcommittee of the NUTAC on emergency response capabilities was formed to provide industry guidance to utilities for the development of an integrated implementation plan that addresses the provisions of NUREG-0737, Supplement 1.

The method developed to integrate these provisions is shown in Figure 1.

Recognizing the dif ferent stages of compliance to the individual ERC requirements, the method shown in Figure 1 assumes no work has been accomplished.

Howeve r, after deter-mining individual plant status, each utility can apply the method to prepare the plant-specific implementation plans required by the NRC.

Figure 1 is divided into basic steps that should be considered in development of an integrated, plant-specific implementation plan.

Each step and its relation to previous and succeeding steps is discussed in the following plan descriptions.

E0P PLAN The E0P plan consists of those tasks that will provide a documented method for developing, utilizing, revising and controlling emergency operating procedures.

This plan will include defining source documents, determining man-power requirements, establishing a schedule and specifying a method of document control.

This plan will also define the interfaces with other ERC elements to ensure complete integration.

Plant-specific E0Ps are developed by utilities for the purpose of mitigating the consequences of a broad range of init;ating events and subsequent multiple failures or operator errors, without the need to diagnose a specific event.

These procedures are function-oriented and written with human factors consideration given to asperts to improve human reliability.

These E0Ps are 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, under-standability, technical correctness, usability and compatability with the control room.

A walkthrough of the E0Ps provides a method of evaluating these criteria.

A utility may choose to perform an E0P walkthrough in the control room, in a simulator, in a mockup of their control room or any combination of the three.

Although Figure 1 indicates only one E0P walkthrough, this process should be repeated following any major modification to the E0Ps.

Plant-specific E0Ps should be incorporated in an iterative process with the resolution of control room HEDs, specific utility application of R.G.1.97 recommendations, SPDS design bases and emergency response facility criteria.

This iteration process should be used to determine modifications that can be made easily to the E0Ps to accomodate defic-iencies in other areas without imnacting the ef fectiveness of the E0Ps.

For this iterative process to be most ef fective, all of the elements

ATTACHMENT 2 Summary of the Draf t ERC NUTAC Guidelines Page 2 that impact E0Ps should be available at the same time.

However, due to economics, manpower limitations or vendor restrictions, this may not be possible.

To accommodate this situation and to ensure ef fective E0Ps, a utility should consider performing the iteration between E0Ps and the other impacting elements as soon as each one has been developed.

CRDR PLAN The CRDR program plan is the first step toward performing a CRDR and provides a method for performing the entire review.

The operating experience review is performed to identify any operational problems resulting from design discrepancies or to identify any improvements to the control room that would enhance the ability of an operator to respond to an emergency condition.

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 emergency, as well as normal, conditions.

The control room survey should utilize results from the E0P wa l kt h ro ug h.

This survey should include, among other things, an l

assessment of control room layout, the control room envi ronment, the usefulness of audible and visual alarms, the readability of displays, the adequacy of instrumentation, and information recording and recall capabilities.

The operators tasks and informational requirements are validated by the E0P walkthrough and provide input criteria to the control room survey process.

Control room additions associated with parameter display (e.g.,

SPDS) and incorporation of selected R.G.1.97 recommendations should be considered during the CRDR.

The control room improvements should be coordinated with changes resulting f rom the E0P, R.G. 1.97, SPDS and ERF programs.

R.G. 1.97 ELEMENT The R.G.1.97 plan provides administrative guidance required to assess and document all aspects of R.G.1.97 consideration.

A complete set of design criteria is developed f rom the plan to form a basis for plant-specific instrument selection.

Utilizing this design criteria, as well as the post-accident instrumentation requirements identified f rom the CRDR task analysis, a plant-specific list of accident-monitoring instrumentation, qualification criteria and locations is developed.

The plant-specific list also provides feedback to the control room survey

ATTACHMENT 2 Summary of the Draf t ERC NUTAC Guidelines i

Page 3 and SPDS design basis.

ERF design criteria provides additional input to the plant list.

Once the list is finalized in design, an iterative process occurs to consider changes associated with E0Ps, control room improvements, SPDS design and ERF design.

SPDS PLAN The SPDS plan describes the tasks for developing, revising, assessing and implementing the safety parameter display system design bases and a method for documenting these ef forts on a plant-specific basis.

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 display configuration.

Interf aces with other NUREG-0737, Supplement 1 elements should be clearly defined to ensure complete integration.

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.

j 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 room survey.

The E0Ps, as a result of the ef forts performed by the NSSS owners groups and 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.

i 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-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.e., the SPDS design bases may be used as input in the ERF design criteria; however, the ERF design should have no direct ef fect on the SPDS.

I

ATTACHMENT 2 Summary of the Draf t ERC NUTAC Guidelines Page 4 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 NUREG-0737, Supplement 1 elements.

A great deal of consideration is essential to determine modifications to the SPDS ef fectively without creating additional discrepancies.

To ensure an ef fective SPDS, the design bases should specify hardware, inputs 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 serves only to aid in monitoring the critical safety functions, others may elect to incorporate additional f unctions into the i

system.

In all cases, the SPDS design should consider operator usability and compatability with plant-specific E0Ps.

Once the SPDS design bases have been determined, the adequacy of 1

the design should be evaluated; however, it is preferable to peform the CRDR first, so that it may be factored into the SPDS design bases.

The E0P/SPDS design basis interface is classified as one-way; i.e.,

structure of the E0Ps will af fect the SPDS design but the SPDS design does not determine what must be included in the E0Ps.

_ERF PLAN The ERF plan consists of those tasks that describe a method for designing, implementing and utilizing the emergency response facilities.

The plan should be plant-specific.

The following items should be considered in the development of an ERF plan:

purpose of the TSC, E0F and OSC description of tasks source document availability project personnel requirements and materials needed manpower requirements and restrictions l

description of the design documentation required desired date of completion and milestones schedule controlling factors interfaces with other NUREG-0737, Supplement 1 activities

. ~. _ _ _ _

..=-_

i ATTACHMENT 2 Summary of the Draf t ERC NUTAC Guidelines Page 5 4

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) needs to be determined.

The bases for these criteria should include utility emergency plans and guidance provided by nuclear industry organizations.

Plant-specific criteria should include, but not be limited to, the following info rmati on :

j purpose location required instrumentation (not required for OSC) habitability (not required for OSC) l communications needs structural considerations (not required for OSC) size I

human factors consideratons (not required for OSC) staffing needs l

Guidance provided by the ERC NUTAC should provide assistance in the development of this criteria.

A set of criteria that provides a basis for identifying non-utility or utility of f-site interactions that have an impact on the emergency

]

response facilities should be developed to provide the following:

4 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 f acili ties non-utility personnel located in the ERF during emergency conditions A set of criteria that provides a basis for ensuring the integration of the TSC, OSC, EOF and of f-site f acilities and

.onsideration of the initial SPDS design bases should be developed.

ATTACHMENT 2 Summa ry of the Draf t ERC NUTAC Guidelines Page 6 The ERF criteria should be included in an iterative process with other activities of NUREG-0737, Supplement 1.

These include control room improvements, plant-specific E0Ps, speci fic R.G.1.97 application and SPDS design.

This iterative process should continue until all of the activities associated with ERF criteria have been completed.

A final set of criteria used to build or upgrade emergency response f acilities should be developed, based on the preceeding considerations.

2 I

_m_.

-~

4 C4uti to ' D 11 !

AN[.[.ea miatt S

,111 e si yl

-I g

g g

snessaract4

-y v__

_t het E4 8 N

$ 8'81 I 6*f g g pg Ag PleM PtAM pesso ruvs 1

I 4

I-t J

(

3

'g 1

q T

,io.4;r-ifs.gg site i

_._ L_

E iq 4

<,,,, x,,c 1c ctffh,4 ur,5;A Nvitof were u <,em *

, mt.

- l.n,fas. set

$,{,g,,

cy,g, jnj y

con de4 cg,y,

g8 8'*8 T e.ue h4 ei. eses...g s wa ys, s g

, 5 I

1-

",j- -

I l

L.

l ll L.

4 t

w t.nr <cnina w,v,; ro,;i

.u.s s ' ',, -

r

,.m. o.,,,c c.,a,x

'#'#O n

t AN N

• ]

E'" veal L p ourseO

' iOA 6 Ate tss't) util K r*8Jewh 81 2T/MY I

r i

E vatu Arson LFO h

s, b

J T E P.i een.w e r Aun

1. ^ I ##

l'a

+

JTE s' 4

,,,,, g,g,,og/'

~ ~~~"

"~

IN il l,9tU roN n ns noesten e

e

..U V 5 S

h e

ionost tenerecon v enu ro..n ce f*sA ed th r

• OV~

ter/cci.vW se'b1 t ors M**F% *E*MS rusrtw'enn rme ceniset A veneno nte a

DE U E lu't11t M T

-r

.lii e* to c g,emt u r g

Vlfe h :1te'*\\

geprn<oeteone

. r,.<,-

.))[g' 'l l j't Wt Q

- - -. - + - - - - - -.

M V'E N

,g,\\

e 1

sie.~ e seva ssat astavesp i '

s,nettenf ore 1rroM L

l v.s,, n,

.w.~

.s a, >

^

VotaboreoAl lot 1tht TlG0 fl&US l coWd M MMEOl

" GMOPt a TE &

$it p gQ :

l 1

w-Y ATTACHMENT 3

' DESCRIPTION OF GUIDELINES AND INPUT CRITERIA DEVELOPED BY INDUSTRY GROUPS I

I L

INDEX OF GUIDELINES AND INPUT CRITERIA

1. Emergency Operating Procedures Plan a.

General Guidelines i.

Emergency Operating Procedures Implementation Guidelines (INPO 82-016), published June 1982 ii.

Emergency Operating Procedure Writing Guideline (INP0 82-017), published July 1982 iii.

Emergency Operating Procedures Verification Guidelines, scheduled to be published April 1983

~

iv.

Emergency Operating Procedures Validation Guidelines, scheduled to be published June 1983 J

l v.

Westinghouse Owners Group " Emergency Procedure Guidelines, Rev.

0,"

issued 08-14-81, 08-27-81, 12-02-81, 01-04-83, 01-13-83.

The Rev.1 upgrade of this document is scheduled to be issued in August 1983.

vi.

Emergency Operating Procedures Generation Package Guidelines (INPO 83-007), published February 1983.

b.

Input Criteria i.

Writers guide i

ii.

Generic technical guidelines iii.

Task analysis

2. Control Room Design Review Program Plan a.

General Guidelines i.

NUTAC Guidance on Control Room Design Review Implementation,- scheduled to be issued in June 1983 J

ii.

NUTAC Guidance on Control Room Design Review Survey, scheduled to be issued in June 1983 b.

Input Criteria i.

Operating experience review ii.

Control room survey iii.

Human f actors engineering i

r-*

-2

--g.

.-,-,,.e,

,.e

-s-

.y

-++-.--,y,e.

+vm--.-

m-7m--nm-,----m.

y-ww

- _.. - -. =

l INDEX OF GUIDELINES AND INPUT CRITERIA

3. Regulatory Guide 1.97 a.

General Guidelines i.

Westinghouse Design Basis to Respond to R.G. 1.97, Rev. 2 ii.

NUTAC Guidelines for Accident Monitoring Instrumentation, scheduled to be issued in June 1983 b.

Input Criteria i.

Regulatory Guide 1.97, Rev. 2 ii.

Alabama Power Company R.G.1.97 Design Basis, Rev. O iii.

Alabama Power Company R.G.1.97 Conceptual Design Display System

4. Safety Parameter Display System Plan a.

General Guidelines

i. 'NUTAC Guidelines for an Effective SPDS Implementation Program (INP0 83-003 NUTAC), published January 1983.

~

b.

Input Criteria i.

Critical safety functions i i.- Alabama Power Company SPDS Specification and Conceptual

System Design

5. Emergency Response Facilities Plan a.

General Gt!idelines i.

NUTAC Guidelines on Emergency Response Facilities,

scheduled to be issued in June 1983 b.

Input Criteria i.

TSC criteria ii.

OSC criteria iii.

E0F criteria iv.

Non-utility response criteria ii

,m

_. _,,,.. ~,...... _..,

DESCRIPTION OF GUIDELINES AND INPUT CRITERIA

1. E0P Plan a.

General Guidelines i.

E0P Implementation Guideline This guideline presents the basic elements of an implementation plan for E0Ps, starting with the receipt of the emergency operating procedure guidelines (EPGs) to provide guidance to utilities for use in plant-specific E0P implementations.

The following elements are presented and discussed:

organization of implementation elements crew and shif t policy characteristics procedure system and network technical guideline use writers guide for E0Ps E0P verification E0P validation training 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 (E0 PIA) Review Group in accordance with the Activity Network described in the E0 PIA Program Description (INP0 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 and use.

By review of each element present, it is felt that a cohesive and ef ficient implementation plan for E0Ps can be developed by each utility.

This document is offered as guidance only.

-w ATTACHMENT 3 Description of Guidelines Page 2 ii.

E0P 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 f actors principles applicable to E0Ps.

The principles, if applied in developing or improving a writers guide for E0Ps, will help ensure readable and understandable procedures for emergency conditions.

This guideline document is organized to present informatin on human factors aspects and how to address them in writing E0Ps by applying principles.

For each priniciple, an explanation is provided with guidance and examples of application.

In addition, a writers guide outline, example writers guide, and example emergency operating procedures are provided to show how the principles can be tied together in writing E0Ps.

As structured, the guideline can be reviewed, starting with either the general principles or the specific example E0P.

iii.

E0P Verification Guidelines The purpose of this guideline is to provide information that can be used by a utiltiy in developing its E0P verification program.

This document provides guidance in three major areas of an E0P verification program.

These are the program objectives, program evaluation criteria, and program process.

The program objective is to ensure that consistency has been maintained between the E0Ps and the E0P 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 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 c ri te ri a.

Sample evaluation criteria are provided for each verification principle.

i l

i l

,A u-

ATTACHMENT 3 Description of Guidelines Page 3 The. program process supports the actual comparative evaluation.

i This document divides the process by phases:

preparation, verification, resolution and documentation.

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

This document is presented for guidance only.

Its program is not intended to duplicate ef forts in existing E0P review and i

approval processes..EOP verification as presented in this document is a comparative evaluation that addresses. whether the E0Ps are written correctly and are techt'Lally accurate.

The i

evaluation of whether the E0P informat'on is. usable and operationally correct is addressed during tne E0P validation.

i iv.

E0P Validation Guidelines The purpose of this guideline is to provide information that can j

be used by a utility in developed its emergency operating procedures (E0Ps) validation program.

This document provides guidance in three major areas :of E0P validation program.

These areas are the program objective, program evaluation criteria, f

and program process.

The program objective is to determine if the trained operating l

shift can manage emergency conditions with E0Ps.

This.

l determination is made by validation principles for operational correctness and usability.

Operational correctness ensures that -

L E0Ps r.rs ~ compatible with plant responses, plant hardware, and i

the operating shift.

Usability ensures that the E0Ps provide suffient 'and understandable operator information..

l.

The program evaluation criteria are used to determine if the

~

~

validation principles are satisified.

This. document provides guidance for the development of ' plant-specific evaluation c ri teri a.

Sample evaluation criteria are provided for each validation principle.

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.

1 This document is presented as guidance only.

Its program is not intended to duplicate efforts in existing E0P review and

~

a pproval ' proces ses.

E0P validation as presented in this document is a performance evaluation that addresses whether the L

.EOPs are operationally correct and usable.

Tne evaluation of l

ATTACHMENT 3 Description of Guidelines Page 4 whetner or not the E0P information is written correctly and techn1. ally accurate is made during E0P verification.

v.

Westinghouse Owners Group Emergency Procedures Guidel ir.es This document was submitted to the NRC, so a summary is not provided here.

The Rev. 1 Upgrade of this document is scheduled to be issued in August 1983 following acceptance by the Westinghouse Owners Group.

vi.

Emergency Operating Procedures Generation Package Guideline.

This document contains guidance for use in the development of the procedures generationpackage (PGP).

It identifies for presentation or description in the PGP:

technical guidelines writers guide for E0Ps E0P verification i

E0P validation training This document also presents a sample PGP.

b.

Input Criteria i.- Writers Guide for E0Ps A writers guide for E0Ps is a plant-specific document that provides instructions on writing E0Ps, emphasizing the incorporation of human factors aspects.

It can be either a separate document devoted specifically to E0Ps or a broader document with a specific section devoted to E0Ps.

The writers guide can be improved continually, 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 E0P writers.

It should cover the following topics:

E0P format E0P organization

.r--

e w

ATTACHMENT 3 Description of Guidelines Page 5 E0P level of detail role of the E0P within the procedure system and network E0P content mechanics of style ii.

Generic Technical Guidelines Generic technical guidelines are documents that identify the equipment or system 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 E0Ps.

Alabama Power Company will use the generic technical guidelines prepared by the Westinghouse Owners Group.

When addressing this element in the formulation of an E0P imple-mentation 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 E0Ps documentation requirements use of the background information supplied with the technical guideline licensing commitments The Westinghouse Owners Group has developed Rev. O of the generic technical guidelines.

Rev.1 of these guidelines is scheduled to be issued in August 1983 upon the approval of the

~

Westinghouse Owners Group.

l iii._ Task Analysis It is useful to the outcome of the CRDR that adequate attention be given to task analysis since it can integrate the opera-tional, dynamic aspects of plant operation with the results of the survey and the operating experience review.

r l

The task analysis is used to dalineate the specific actions (automatic and. manual) that must take place to accomplish system

.n, w

-e, ews.-nv, n- - - -

,,.,,,.,-.,..me-a,

men,

.v--

--e r

nm.,,--e~n

- em

-a-e n-m rd.

e e -- -r y ----

no

-ge-,-g ne-y +-;

werw-e>,--s

--e-

.y

ATTACHMENT 3 Description of Guidelines Page 6 functions.

For the CRDR task analysis, the emergency procedure 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 formation of a CRDR implementation plan, the following major items should be 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 i.

Summary of NTUAC Guidance on CRDR Implementation The Control Room Design Review Implementation Guideline provides guidance to utilities for use in developing their implementation plans for control room design review (CRDR).

The basic. elements of an implementation plan for CRDR are described.

The following elements are presented and discussed for each phase of the CRDR:

Planning Phase organization focus and extent of the review review team composition review team orientation use of EPGs and E0Ps

,e r-r--.

o

ATTACHMENT 3 Description of Guidelines Page 7 Execution Phase survey operating experience review

' task analysis (system review)

Assessment Phase human engineering review principles assessment of HEDs ef fect of operator aids effect of current modifications prioritization of HEDs Correction Phase 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

t

. ATTACHMENT 3 Description of Guidelines Page 8

. the utility for1 individual. applicability. =The appendix of the NUTAC document includes an example of a CRDR implementation plan that illustrates how the elements described in the body of this guideline might be incorporated into a plant-specific document.

- This guideline-document is of fered as guidance only.

t

- 11.

Control Room Design Review Survey Guideline

-This guide provides survey development guidance to utilities.

It describes a method for generating checklists and i

. questionnaires.

These will be used -in the CRDR human f actors t

~ s u rvey. - The document contains an introduction, a section on definitions used,.and a section on method.

Appendixes contain i.

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 term are used in the document.

j l

The survey development section describes the methodology 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.

l 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 that 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 that are predominately procurement specifications from MIL-STD-1472.

Appendix E contains those _NUREG-0700 criteria that might degrade performance and an. explanation.

l

- b.

Input Criteria i, Operating Experience Review 1

i This element is an activity within the CRDR meant to review the experience _ gained through actual plant operation.

This activity I

1 Y

T--

we f =

---,+v 7,*wt<

+e ww=m,--

pr-ew ge.-yr--#.,.re,er y-y-

%~p.,,.#-,-wa

-r

-g vi ne

.p,-e n eeswe-e.-,i--r-,,-+,me-ew---.*eN-a,6*tv-**.tvw---

+-e..+=--'e--e---

--- ewwe v e

-e-

-++r

ATTACHMENT 3 Description of Guidelines Page 9 is to determine what problems have occurred (and recurred) during actual plant operation by questioning operating personnel and reviewing operational documents.

This element of the CRDR is very ef fective in providing details concerning normal and abnormal operating modes.

An operating experience review may consist of operator interviews, a review of plant trip logs, and, possibly, a review of Licensee Event Reports (LERs), INP0 Significant Event reports (SERs), and Significant Operating Experience Reports (SOERs).

The best use of LERs is as a means of confirming problems uncovered during the operating experience review.

When addressing this element in the formation of a CRDR implementation plan, the following major items should be considered:

I availability of experienced operators type of interview technique to be used availability of skilled interviewers availability of reactor trip reports or plant significant event reports ii.

Control Room Survey The control room survey is an explicit, well-defined control 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.

The major items to be considered when addressing this element in the formation 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 this NUTAC).

Whatever criteria are chosen, 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

ATTACHMENT 3 Description of Guidelines Page 10 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 iii.

Human Factors Engineering During any design process, certain principles are used to define the specific characteristics of the item being designed.

Due to the trade-offs made during the design process, the finished product may not comply with some desirable design criteria.

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 keepin mind the human factors principles on which detailed survey guidelines are based (see " Human Engineering Review Principles," also being developed by this 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 measurements and values contained in detailed guidelines are not to be interpreted as absolute, inflexible numbers.

When addressing this element in the CRDR implementation plan, the following major points should be considered:

the level of detail of the principles the applicability of particular principles to the control room cross-reference of principles to the detailed survey guidelines

j ATTACHMENT 3 Description of Guidelines Page 11

• ' th'e behavioral. criteria used to judge that principle has been

~

met the population to which the principle is to be applied the experience of review team members in interpreting human i

factors principles the completeness of the set of principles used

3. Regulatory Guide 1.97 Plan a.

General Guidelines i.

Westinghouse Design Basis to Respond to R.G.1.97, Rev. 2 This design basis establishes criteria for determining the key and preferred backup variables to be monitored by the L

control room operating staff following.the initiation of an accident.

Criteria for determining the requirements for the instruments used to monitor these variables are also included to aid the system designer.

t ii.

NUTAC Guidelines for Accident Monitoring Instrumentation The objective of this guidance is to assist utilities in their implementation of accident monitoring instrumentation, particularly~ in the relation of such instrumentation to R.G.

1.97.

To meet this objective, the document contains guidance on the following:

j l-

. 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/E0F monitoring example-formats for.R.G. 1.97 response summary of available industry positions of R.G 1.97 and related guidance documents This document is scheduled to be issued in June 1983.

,~,.

ATTACHMENT 3 Description of Guidelines Page 12 b.

Input Criteria 1.

Regul atory Guide 1.97, Rev. 2 This guide provides the variables to be monitored by the control room operating personnel during and following an accident.

The guide also provides three categories of design criteria to aid the system designer in selecting and designing the instrumentation to monitor the variables.

ii.

Al abama Power Company R.G.1.97 - Design Ba sis, Rev. O This design basis was prepared to address R.G.1.97 prior to the issuance of NUREG-0737, Supplement 1.

The design basis identifies the variables to be monitored by control room personnel during and following an accident as well as the instrumentation design criteria.

iii.

Previous Alabama Power Company R.G.1.97 Conceptual Design of Display System This design basis was prepared to audress R.G.1.97 prior to the issuance of NUREG-0737, Supplement 1.

The design basis identifies the variable to be displayed and the conceptual design and design criteria for the display system.

4. SPDS Plan a.

General i.

Guidelines for an Effective SPDS Implementation Program t

This document provides guidance for use in plant-specific SPDS impl ementation 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

ATTACHMENT 3 Description of Guidelines Page 13 integra: ion hardware maintenance V & V of SPDS hardware and software The document's appendixes 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 By review of each topic addressed in these guidelines, a cohesive and ef ficient implementation program for the SPDS can be developed by each utility.

This document is of fered as guidance only-b.

Input Criteria i.

Critical Safety Functions The critical safety functions cre identified in the Westinghouse Owners Group Emergency Response Guidelines.

11.

Alabama Power Company SPDS Specification and System Conceptual Design The SPDS specification and system conceptual design were prepared prior to the issuance of NUREG-0737, Supplement 1.

The specification included the system design requirements and was sufficiently detailed to obtain vendor bids.

The conceptual design outlined the interface of the specified SPDS with other plant systems and identified the design modifications within Alabama Power Company's scope of responsibility.

ATTACHMENT 3 Description of Guidelines Page 14

5. Emergency Response Facilities Plan a.

General Guidelines i.

NUTAC Guidelines for ERF Plan These guidelines would serve as " input criteria" for an integrated plan of action to be developed by a separate subcommittee of the NUTAC on emergency response capability.

As such, the ERF subcommittee's objective is to provide additional guidance to selected regulatory requirements related to the TSC, OSC, and the E0F, which would be of benefit to utilities.

The objective is not to address the integration of these facilities with other emergency response initiatives in this document.

To meet the stated objective, the ERF subcommittee focused on the following:

guidance to utilities on how to interpret NRC regulatory documents as they related to ERFs guidance for satisfying the intent of NRC regulatory requirements on ERFs as identified in 10 CRF 50.47 and Supplement 1 to NUREG-0737 examples of alternatives for meeting the intent of NRC regulatory documents The purpose of these guidelines is to provide general guidance for evaluating existing emergency response facilities capabilities and for planning and implementing capability not yet in place in light of Supplement 1 to NUREG-0737.

The guidance contained in this document attempts to take into account the progress made by utilities in upgrading their emergency response facilities.

In that many of the requirements related to the emergency response facilities af fect one or more of the facilities (i.e.,

TSC, OSC, and EOF), the subcommittee's guidance address specific regulatory requirements, while identifying unique considerations related to any of these facilities for that particular requirement.

General guidance will be given for each regulatory requirement identified in Supplement 1 to NUREG-0737.

The NUTAC guidance is scheduled to be issued in June 1983.

ATTACHMENT.3 Description of Guidelines Page 15 b.

Input Criteria i.

Technical Support Center The TSC is fully operational.

The operational characteristics of the TSC will be considered in the development of any additional data systems for the ERFs.

ii.

Operations Support Center The OCS is fully operational.

The operational characteristics of the OSC will be considered in the development of any additional data systems for the ERFs.

iii.

Emergency Operation Facility The EOF is fully operational.

The operational characteristics of the EOF will be considered in the development of any additional data systems for the ERFs.

iv.

Non-Utility Response Capability The capability and needs of federal, state and local non-utility organizations will be considered in the development of any additional data systems for the ERFs.

v.

ERF Design The Alabama Power Company ERF design will be the basis to determine the compliance of the existing ERFs with the provisions of NUREG-0737, Supplement 1.

ATTACHMENT 4 Preliminary Farley ERC Integrated Implementation Plan and Schedule s

a

I.

. Safety Parameter Display System (SPDS) a.

Status of Past and Current Activities Subsequent to the issuance of NUREG-0696, Alabama Power Company formed a Task Force charged with the responsibility for the development of a conceptual design that addressses the control room, TSC and EOF data system provisions of NUREG-0696.

This Task Force developed a specification,_ reviewed available vendors systems, determined procurement lead-times and impl ementation schedules, established.a design basis, developed a list of plant parameters to be monitored, and assessed the impact of installation on existing plant systems..

Additionally, Alabama Power Company was a participating member of the Nuclear Utility Task Action Committee.(NUTAC) for SPDS.

This SPDS NUTAC has been disbanded since the publishing of the NUTAC guidelines entitled "Ef fective SPDS _ Implementation Program" in January 1983.

Subsequent to the issuance of Generic Letter 82-33, Alabama Power Company formed an Acquisition Development Team to develop a conceptual design, purchase specification and schedules for an SPDS.

The develop-ment of these specifications will consider guidance from the SPDS NUTAC, provisions of the upgraded Westinghouse Owners Group Generic Guidelines (i.e., critical safety functions) and the previously developed SPDS specification.

b.

Preliminary Schedule The preliminary SPDS schedule is shown in the Preliminary Farley ERC Integrated Implementation Schedule which is included in this attach-ment.- In April 1983, Alabama Power Company began the review of the NUTAC guidance and the preparation of an SPDS action plan.

This action plan will outline the scope of the known activities, assign responsi-bilities to APCo organizations and architect-engineers, and identify activities that may require vendor support.

The SPDS action plan is essential to control and direct-the SPDS activities.

The R.G. 1.97 design-basis is scheduled to be finalized.by August 1983 and will be used to complete the SPDS design basis.

The SPDS design basis will be based on the-R.G.1.97 design basis and may identify additional plant parameters to be displayed.

The. finalized SPDS design basis and SPDS design concept will be used as input to finalize the CRDR program plan.

Following vendor presentations and the establishment of vendor /

l utility responsibilities, the SPDS specification will be finalized and i

issued for vendor bid.

The finalization of this specification will require-the identity. of potential R.G.1.97. modifications and alterna-tives. for displaying the -R.G.1.97, Category 1 variables.

All bids will g

j be-evaluatedf and ' recommendations prepared for review.

i:

L Alabama Power Compan'y will review the SPDS vendor designs and bids L

considering the accompanying APCo scope of work, conceptual design, I

estimated costs and installation schedules.

This review will also I

I

ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 2 consider the R.G.1.97 design basis and display configuration, proposed resolution of human engineering discrepancies identified during the control room design review and additional data systems for the Emergency Response Facilities.

This review will be iterative and may require the reordering of priorities, re-evaluation of various proposed alternatives, schedule changes, etc.

Following this review, Alabama Power Company will award the SPDS contract and develop an SPDS Implementation Plan and written Safety Analysis Report.

Both the Implementation Plan and Safety Analysis Report are tentatively scheduled to be submitteu to the NRC for post-implementation review.

It is anticipated that the Implementation Plan will take 2 months and the Safety Analysis Report will take 3 months to complete.

The design of the SPDS will require a walkdown of each unit by the vendor and Alabama Power Company design organizations.

The Unit 1 sixth refueling outage (September 1985) and Unit 2 third refueling outage (May 1985) have been scheduled for these walkdowns.

The installation of the SPDS is scheduled to be completed over two ref ueling outages for each unit.

Prior to operational acceptance, the emergency operating procedures will be modified as appropriate and all licensed operators will be trained in their use.

The completion of the SPDS program is tentatively scheduled for the end of the eighth ref ueling outage (October 1988) for Unit 1 and the end of the fifth ref ueling outage (May 1988) for Unit 2.

Every effort is being made to expedite this ef fort in a manner which will assure the quickest, practical SPDS installation and

use, c.

1983 Milestones and Submittals Due to the dependence of one activity completion upon another, the delay in any activity may significantly af fect this preliminary schedul e.

These tentative completion dates are based on 18-month refueling cycles, 6-week ref ueling outages and installation time of two refueling outages.

The following significant activities have been planned:

DATE OR DURATION ACTIVITY OF COMPLETION Finalize and issue SPDS November 1983 specification for bids Preparation of written An estimated 3-month SPDS safety analysis du ra ti o n.

Completion date to be submitted with updated schedul e.

i ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 3 Preparation of specific An estimated 2-month SPDS implementation plan duration.

Completion date to be submitted with updated schedule.

4 d.

Adequacy of Current Display Capability During Interval Needed to Complete Enhancements Currently, the Farley~ plant computer and main control board instrumentation are being utilized to monitor parameters required during normal and emergency conditions.

In May 1980 an Alabama Power Company Control Room Human Factors and Operations Review Team verified that display capability was suitable for selected emergency operating procedures.

NRC staf f personnel witnessed this walkthrough and assessed the control and display panel' layout.

The acceptance of the NRC review is documented in Supplement 4 of the Farley Unit 2 Safety Evaluation Report, dated September 1980.

4 a

I

-.-__,,,_---m..

ATTACHMENT 4-Preliminary Integrated Implementation Plan Page 4 f

II.

Regulatory Guide '1.97 (R.G.1.97 )

I a.

Status off Past and Current Activities Subsequent-to the issuance of. R.G. l.97, Revision 2, Alabama Power

- Company established and implemented a program to address the -provisions o f R.G. _1.97.

This program consisted of the following four tasks:

1)

Identify licensing criteria.

1 2)

Evaluate instrumentation compliance with licensing criteria.

(

3)

Develop action plans to satisfy provisions of R.G.1.97.

4)

Implement action plans.

A schedule for implementation of this program was transmitted to the NRC r

in Alabama Power Company letter dated March 30, 1981.

- During the implementation of this program, Alabama Power Company developed, in conjunction with Westinghouse, a R.G.1.97 design basis for Farley Nuclear Plant.

The Type' A variables were determined from revi ews of 'the eme rgency operating: procedures.

A prelimina ry review of i

Farley Nuclear Plant instrumentation for the Type A variables and each parameter identified in R.G.1.97, Table 2 was completed and documented via evaluation sheets.

Potential modifications were identified as well as-exceptions to R.G.1.97 taking into account the original Farley Nuclear Plant design and licensing bases.

One of the design objectives l

was to integrate the implementation of R.G.1.97 with the SPDS.

A con-ceptual display system design was developed for the SPDS and R.G.1.97 parameters.

Alabama Power Company is _ also an active participant in the ERC NUTAC whose subcommittee is developing industry guidelines for ad-dressin g R.G.1.97.

These guidelines are scheduled to be published in June 1983.

APCo intends to. utilize these guidelines in developing.its final R.G. 1.97 program.

4

- b.

Preliminary Schedule t

The preliminary R.G.1.97 schedule is shown in the Preliminary Farley ERC Integrated Implementation Schedule, which is included in this attachment.

Alabama Power Company is scheduled for May 1983 to initiate

- the development 1of the methodology and cost estimates for the seismic qualification of the main control board.

Alabama Power Company will review the NUTAC guidance and the previously developed Alabama Power Company / Westinghouse R.G.1.97 design ' basis and will prepare a final R.G. 1.97 action plan.- This action -plan will outline the scope of the

- known activities, assign responsibilities to APCo organizations and architect-engineers, and identify _ activities that may require vendor support.

The R.G.1.97 action plan is essential to control and direct the R.G.1.97 activi ties.

t 4

.r y

-, -, - +

v,..-

--e

,,,,,-.wa.nr.,-

.~

-.~~,-...,..,,,e a

sm,.,,mm nv,,,-w-e.,e.,

s,-

n e....,.-s,-.

..w-~

ATTACHMENT 4-Preliminary Integrated Implementation Plan Page-5

-The R.G.1.97 design basis is ' tentatively scheduled to be finalized by August 1983 and used to complete the SPDS design basis. -The R.G.

1.97 design will identify the plant parameters, their type and category, and basis. for selection.

The R.G.1.97 design basis will be discussed with vendors and vendor / utility responsibilities established.

In parallel with the SPDS specification and bid efforts, a conceptual design and accompanying cost and schedule. estimates will be developed for those activities that 'are the responsibiilty of Alabama Power' Company (e.g., installation of electrical-isolation devices and the separation of redundant i nst ruments ).

Alabama Power Company will review the conceptual designs and estimated costs and installation schedules for R.G.1.97 for acceptability and feasibility.

This' review will also consider the SPDS design basis, vendor bids and ' display configurations, proposed resolution of human engineering discrepancies identified during the control room design review, and additional data systems for the ERF's.

Such a review will be iterative and may require proposed alternatives,

. schedule' changes, reorderi ng of p riorities, etc.

Following this review, Alabama Power. Company will develop the R.G.

~1.97 Implementation Plan and Compliance Report.

The R.G.1.97 Compli-ance Report will document the design basis of the Type A, B, C, D and E variables at Farley Nuclear Plant with supporting justifications.

It is anticipated that the Implementation Plan will take 2 months and the Compliance Report will take 3 months to complete.

The design of the R.G.1.97 will require a walkdown of each unit by t

the vendor and APCo design organizations.

The Unit 1 sixth refueling outage (September 1985) and Unit 2 third refueling outage (May 1985) have been tentatively scheduled for these walkdowns.

The installation l

of the R.G.1.97 modifications is scheduled to be completed over two l

' refueling outages for each unit in conjunction with the SPDS implementation. ' Prior to operational acceptance, the emergency j

operating ~ procedures will be modified as appropriate and all licensed operators will be trained in the use of the instrumentation.

The j-completion of the R.G.1.97 program is' tentatively scheduled for the end of the eighth refueling outage (October 1988) for Unit 1 and the end of

~

the fifth refueling outage (May 1988) for Unit 2.

i c.-

1983 Milestones-and Submittals Due to the-dependence of one activity completion upon another, the delay in certain activities may significantly affect this preliminary schedule.

These tentative completion dates are based on 18-month refueling cycles and 6-week refueling outages.

The prelimi na ry R.G.

1.97 integrated schedule does not consider any modifications associated with instrumentation for a tactor vessel -level system and core-exit

(

t~

l L

ATTACHMENT 4 Preliminary Integrated Implementation Plan -

Page 6 t he rmocou pl e s.

Such activities, as stated in letter dated -March 10, 1983, will be addressed after an inadequate core cooling system has been operationally proven and the completion of a post-implementation review and approval for operation by the NRC.

The following significant activities associated with R.G.1.97 have been planned:

DATE OR DURATION ACTIVITY OF COMPLETION

• Finalize R.G.1.97 design August 1983 basis Establish plan for Category 1 October 1983 display Preparation of R.G. 1.97 An estimated 2-months implementation plan duration.

Completion date to be submitted with updated schedule.

• Preparation of R.G. 1.97 An estimated 3-months compliance report with du rati o n.

Completion date' justifications to be submitted with updated schedule.

d.

Adequacy of Current Instrumentation During Interval Needed to Complete Enhancements Currently, the Farley plant computer and main control board are being utilized to monitor parameters required during normal and emergency condi tions.

As discussed, the Task Force formed subsequent to the issuance of R.G.1.97 reviewed the original design of the Farley instrumentation.

Based on this review, Alabama Power Company believes that the original instrumentation design provides an adequate emergency response capability during the implementation of modifications to enhance these capabilities.

ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 7 III. Control Room Design Review (CRDR) a.

Status of Past and Current Activities During May 1980, Alabama Power Company conducted a Control Room Human Factors and Operations Review at the Farley Nuclear Plant - Unit 2.

The basis of the review was NUREG CR-1270 (i.e., the Essex Report) and Mil-Std.147 28.

The review of the control room design for human factors and operations centered on the following:

a)

Labeling of control devices, meters and annunciators b)

Control functions c)

Dis pl ay s d)

Communications e)

Emergency procedure walk-throughs including use of emergency air breathing devices f)

Noise, lighting and traf fic control In general, the control room was found to promote effective operator actions; however, the review identified some human engineering improvements, which were categorized for either short or long term implementation.

The NRC Staff followed up the Alabama Power Company Control Room Human Factors and Operations Review with a live-day onsite control room audit as documented in NRC letter dated September 24, 1980.

The NRC Audit included an assessment of control and display panel layout, l

annunciator design, labeling of panel components, and the usability and completeness of selected emergency procedures.

The NRC audit was performed by means of detailed inspections of the control panel s,

l interviews with operators, and observation and videotaping of operators as they walked through selected emergency procedures.

The Safety Evaluation Report for J. M. Farley Nuclear Plant dated September 1980, discussed the NRC audit and concluded that "in general we [the NRC Staf f] found the control room [at Farley Nuclear Plant] was designed to promote ef fective and ef ficient operator actions."

The Safety Evaluation Report did identify some human factors deficiencies and resolutions, which Alabama Power Company has implemented.

Alabama Power Company is also participating in the NUTAC for l

Control Room Design Review (CRDR).

The CRDR NUTAC is scheduled to issue this industry guidance by the end of June 1983.

Alabama Power Company intends to utilize this industry guidance in the development of its CRDR program.

l

ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 8 b.

Preliminary Schedule The prelimina ry CRDR schedule is 'shown in the Preliminary Farley ERC Integrated Implementation Schedule, which is included in this attachment.- The previous Farley Control Room. Human Factors and Operations Review will be compared to the CRDR NUTAC guidance and a Program Plan will be developed -to determine if any additional CRDR efforts are necessary.

The finalized SPDS design basis, which considers the R.G.1.97 design basis, and SPDS design concept will be considered in the CRDR Program Plan.

Subsequent to finalization of the CRDR Program Plan, a human factors vendor will be selected to assist Alabama Power Company in the finalization and implementation of the CRDR.

The finalized CRDR program will be submitted to the NRC.

Alabama Power Company will assess the previous CRDR efforts and will determine the scope of additional control room design reviews that are necessary.

Following NRC approval of the Alabama Power Company program, any additional CRDR efforts will be performed.

Any human engineering discrepancies (HEDs) identified as a result of the additional CRDR efforts will be evaluated and resolved.

The SPDS/R.G.

1.97 displays, emergency operating procedures, etc. will be considered as potential alternatives in the resolution of identified HEDs.

For HEDs requiring plant modifications, Alabama Power Company will initiate conceptual designs and cost estimates and identify installation schedules.

A Summary Report will be prepared and submitted to the NRC af ter the resolution of all HEDs has been determined.

Alabama Power Company will implement any required plant modifications during the subsequent two refueling outages scheduled for the end of the seventh ref ueling outage (April 1987) for Unit 1 and the end of the fourth refueling outage (December 1986) for Unit 2.

c.

1983 Milestones and Submittal Dates These preliminary dates are based on receipt of industry guidance in May 1983, consideration of other Alabama Power Company licensing commitments, 18-month refueling cycles, 6-week refueling outages, and installation of any modifications during one refueling outage per unit. The following significant activities have been planned:

DATE OR DURATION ACTIVITY OF COMPLETION

• Finalize CRDR program and October 1983 submit to the NRC l

i i

l l

ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 9

• Perform additional CRDR Dependent upon assessment activities of previous activities Preparation of Summary Report An estimated 3-month du ratio n.

Completion dates to be submitted with updated schedule.

d.

Adequacy of the Current Control Room Design During the Interval Needed to Complete Enhancements The Farley Nuclear Plant has been operating since 1977 and during this period no major human engineering discrepancy has been identified.

A Controi Room Human Factors and Operations Review has beer. conducted by Alabama Power Company. The NRC Staff performed a five-day onsite control room review and as stated in Supplement No. 4 to the Fa rley Safety Evaluation Report, the control room was generally found to promote ef fective and ef ficient operator actions.

Some human engineering improvements were identified and subsequently implemented.

Based on the previous reviews, implemented improvements, and the past ef fectiveness of the main control room, Alabama Power Company believes that the existing control room design is adequate during the implementation of any modifications to enhance these capabilities.

,. _ ~

ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 10 IV. Emergency Response Facilitiy (ERFs) a.

A Status of Past and Current Activities In letter dated April 6,1981, Alabama Power Company stated that an operational Technical Support Center (TSC) was established in the Farley Nuclear Plant Auxiliary Building, immediately north of the Unit 2 control room.

The TSC has the capability to display and transmit plant status to those individuals knowledgeable of and responsible for engineering and management support of reactor operations in the event of an emergency condition.

The TSC is habitable to the same degree as the control room for postulated emergency conditions.

The Farley Nuclear Plant Emergency Plan has been revised to incorporate the role and location of the TSC.

The TSC contains a set of P&ID's for each unit and technical manuals on selected major equipment.

Other technical data are readily available from the document control facility in the plant Service Building which may be reached by intraplant phone from the TSC.

' Also available in the TSC are the Emergency Plan, Emergency Plan Implementing Procedures, Abnormal Operating Procedures, Emergency Operating Procedures and Unit Operating Procedures along with other general reference material.

Alabama Power Company has also established an Operational Support Center (OSC) functionally separate from the control room and other emergency response facilities.

Communications have been provided from the OSC to the TSC, EOF and control room.

The permanent EOF was declared operational in October 1982 and complies with habitability provisions (structure, protection factor and ventilation protection) provided in Table 2 of NUREG-0696.

E0F design and installation criteria were developed and used to verify acceptance of the EOF prior to its operational approval.

Radiation and meteoro-logical parameters have been provided in the E0F.

The operational use and capabilities of the ERFs (OSC, TSC and E0F) were demonstrated during the 1983 Farley Nuclear Plant Emergency Exercise.

Alabama Power Company is also an active participant of the ERC NUTAC whose subcommittee is developing industry guidance in addressing the ERFs.

This guidance is scheduled to be published in June 1983.

Although certain radiation and meteorological parameters have been pro-vided in the ERFs, additional data system criteria will be determined upon review of the ERC NUTAC guidance and in conjunction with parameter selection for R.G. 1.97 and the SPDS.

b.

Preliminary Schedule The preliminary ERF schedule is shown in the Preliminary Farley ERC Integrated Implementation Schedule, which is included in this attach-ment.

Following the issuance of the ERC NUTAC guidance scheduled for k

ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 11 June 1983, Alabama Power Company will review this industry guidance and prepare a ERF action plan.

This action plan will outline the scope of the known activities, assign res3onsibilities to Alabama Power Company organizations and architect-engineers, and identify activities that may require vendor support to enhance ERF instrumentation.

The ERF action plan is essential to control and direct the ERF activities and provide additional data systems.

The R.G.1.97 design basis is scheduled to be finalized by August 1983 and will be used to complete the ERF instrumentation design basis.

The ERF instrumentation design basis will identify the instrumentation design criteria and the plant parameters to be displayed that are essential to the performance of the ERF.

In parallel with the SPDS specification and bid efforts, a conceptual design and accompanying cost and schedule estimates will be developed for those activities that are the responsibility of Alabama Power Company.

The conceptual design estimated costs and installation schedules for ERF instrumentation will be reviewed by Alabama Power Company for acceptability and feasibility.

This review will also consider the SPDS' design basis and display configurations and the R.G.

1.97 design basis.

Such a review will be iterative and may require proposed alternatives, schedule changes, reordering of priorities, etc.

Following this review, Alabama Power Company will develop the ERF Implementaion Plan, which is scheduled to be completed in a 2-month duration.

The installation of the ERF instrumentation is tentatively scheduled to be performed during the implementation of the SPDS and R.G.1.97 modi fications.

Prior to operational acceptance, the ERF procedures will be modified as appropriate and all pertinent personnel will be trained in its use.

The completion of the ERF program is anticipated to be the end of the eighth refueling outage (October 1988) for Unit 1 and the end of the fifth refueling outage for Unit 2 (May 1988).

c.

1983 Milestones and Submittals l

Due to the dependence of one activity completion on another, the delay in any activity may significantly af fect this preliminary schedule.

These tentative completion dates are based on 18-raonth refueling cycles and 6-week refueling outages.

The foll owing significant activities have been planned:

ACTIVITY OF COMPLETION

• Operational ERF's October 1982

• Develop ERF additional September 1983 instrumentation design criteria

ATTACHMENT 4 Preliminary Integrated ' Implementation Plan Page 12

• Prepare ERF data implementation An estimated 2-month

_ plan duration.

Completion dates to be submitted with updated'

- schedul e.

d.-

Adequacy of Current ERF's During the Interval Needed to Complete Enhancements As previously discussed, the ERF's are fully operational and the operational use and capabilities were demonstrated during the 1983 Farley Nuclear Plant Emergency Exercises.

Alabama Power Company believes that the current design of the ERF's -provide adequate emergency reponse capabilities during the implementaion of modifications to enhance these capabilities.

ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 13 V.

Emergency Operating Procedures a.

Status of Past and Current Activities The Farley Nuclear Plant Emergency Operating Procedures have been revised to incorporate the post-TMI recommendations identified in IE Bulletins 79-05,- 79-05A, 79-06,79-06A and 79-06A, Revision 1.

These recommendations included guidance for accidents involving a loss of coolant through a stuck open pressurizer relief or safety valve that subsequently resets or is isolated, and directing the operator to consider thirteen parameters (rather than one or two) as the basis for operator action.

Selected emergency procedures were reviewed by Westinghouse Electric Corporation and the NRC Staf f as described in Section 22.2, Item I.C.1 of the Farley S6fety Evaluation Report, Supplement 4, dated September 1980.

It was concluded that the selected procedures were generally consistent with the generic guidelines for Westinghouse plants; however, minor review to the procedures were incorporated by Alabama Power Company based on the NRC reviews.

Alabama Power Company met with the NRC Staf f at the Zion simulator in Zion, Illinois to walk-through the loss of coolant, steam generator tube rupture, and safety injection emergency procedures during simulated accidents.

The procedures were further revised based on the resu:cs of the simulations and the Westinghouse comments that had.been received.

Subsequent to the himulator walk-throughs, the NRC Staff observed Alabama Power Company operators as they walked through the small-break loss-of-coolant accident procedure in the Fdriey control room.

As a result of the walk-through and final review, a few minor changes were suggested by the NRC; These changes wer.e incorporated into the

~'

procedures by 41abama Power Company.

Alabama Power / Company is represented on the Westinghouse Owners Group Procedures Subcommittee which is involved in the development of a generic emergency procedure program, generic procedure review and resolution of NRC questions regarding emergency procedures.

Through the subcommittee's efforts, the Westinghouse Owners Group has submitted Revison 0~cf the Emergency Response Guidelines (ERGS) to the NRC.

Revision 1 of the ERG's is scheduled for transmittal in August 1983 upon

-Westinghouse l7wners Group 'approva,1.

ll

)]

Additionally', Alabama'Qower (ompany has reviewed the Emergency Operating, Procedures ImplemGqtation Assistance (E0 PIA) guidelines developed,by the E0PI A indgstry working ' group.

A draf t plant-specific writer's >9uide has been develWWed for the Farley Nuclear Plant from this

/

de ',

review.

s f.,

./

)

d,

f e

6 gAW f

• 'f s

g a

+

s

[

t l*

?,.

it.

l f

ATTACHMENT 4 Preliminary Integrated Implementation Plan 1

Page 14 s

b.

Preliminary Schedule From a review of draft industry documents and previous experience with writing plant-specific emergency procedures, the preliminary E0P schedule is shown in the Preliminary Farley ERC Integrated The E0P Implementation Schedule, which is included in this attachment.

action plan and the procedure generation package (PGP) are tentatively scheduled to be completed in June 1983.

This plan will outline the scope of the known activities, assign responsibilities and identify activities that may requi re vendor support.

The PGP will include the writer's guide, a description of the program for validation of the E0Ps, and a brief description of the program for training operators on emergency operating procedures.

Following finalization of the PGP and E0P action plan, the PGP will be submitted to the NRC for review.

Alabama Power Company will develop i

the plant-specific procedures based on generic guidelines and subsequently conduct E0P validation.

The validated emergency operating o

procedures will be implemented for use following training of all licensed operators.

The emergency operating procedures will be revised as appropriate prior to operational acceptance of any modification that addresses R.G. 1.97, SPDS and CROR.

c.

1983 Milestones and Submittals From a review of draft industry documents and previous experience with writing plant-specific emergency procedures, the following significant activities have been planned:

DATE OR DURATION ACTIVITY OF COMPLETION

• Submittal of Procedure July 1983 Generation Package

• Submittal of Rev.1 Generic August 1983 (predicated upon Technical Guidelines WOG approval)

• Preparation of upgraded E0Ps 1st Quarter 1984

• Training for upgraded E0Ps 2nd Quarter 1984

ATTACHMENT 4 Preliminary Integrated Implementation Plan Page 15 d.

Adequacy of Current E0Ps During Interval Needed to Complete Enhancements The Farley Emergency Operating Procedures have been revised to incorporate the post-TMI recommendations.

In addition, selected emergency operating procedures have been revised to incorporate Westinghouse and NRC comments.

The NRC. has observea the Farley operators walk-through selected emergency operating procedures at the Zion simulator and Farley control room.

The NRC's acceptance of these procedures is documented in the Farley Safety Evaluation Report, Supplement 5, dated March 1981, and provides further evidence of the adequacy of the Farley Emergency Operating Procedures during the implementation of modifications to enhance these capabilities.

h I

e DOCUVIENT

.:o' PAGE PU_ LED

~

I ANO.m -

l NO. OF PAGES _

REASON O PAGE ILLEGIBLE.

O HARD COPt FILED AT.

PDR CF OTHER -

D BE;TER COP (REQUESTED ON -

3 hP

$A E100 LARGE10,lLM.

. Dcor<,uo

,oR ib OTHER

@Dl FILMED ON APERTURE CARD NO T

~ "* iTT " : - "'-

-