ML20077J100

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Forwards Response to Questions 422.11-15 Re Procedures Generation Package (Pgp).Pgp Will Be Revised as Indicated. FSAR Will Be Amended in Near Future Providing Ref to Matl Contained in
ML20077J100
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 08/10/1983
From: Schmidt H
TEXAS UTILITIES SERVICES, INC.
To: Youngblood B
Office of Nuclear Reactor Regulation
References
TX-4022, NUDOCS 8308150193
Download: ML20077J100 (28)


Text

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d TEXAS UTII.lTIES SEINICES INC. Log # TXX-4022 2 u nin w n n u n n m . w in u w ,2.,n. n. File # 10010 Aug"st 10, 1983 Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION CONCERNING THE CPSES PROCEDURES CENERATION PACKAGE (NRC Q422.11 thru Q422.15)

Dear Mr. Youngblood:

Attached is the response to NRC Questions 422.11 thru 422.15 concerning the CPSES Proceduras Generation Package (PGP). The CPSES PGP will be revised as indicatu in this attachment. Futhermore, the CPSES Final Safety Analysis Report will be amended in the near future providing reference to this letter.

If you have any comments, please contact this office.

Sincerely, k/ f/

H. C. Schmidt RWH: tis Attachment cc: S. B. Burwell J. W. Clifford

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B308150193 030810 PDR ADOCK 05000445 A PDR

Item 422.11 The following steps will be added to CPSES PGP, ODA-204:

3.8 Validation - The demonstration that tasks specified in the tech-nical guidelines are sufficient to accomplish the objective of the guideline.

3.9 Verification - The assurance that plant specific technical data is correctly transcribed into the WOG generic guidelines to pro-vide accurate and usable CPSES Emergency Response Guidelines.

422.12 a) CPSES PGP, ODA-204, will be changed as follows:

4.2.2 Development of Plant Specific Data Each CPSES plant specific technical guideline is based on the l Westinghouse Owners Group generic guidelines. The WOG generic guideline shall be reviewed to determine which data must be made plant specific. This review shall be the basis for the development of a " Comanche Peak Data Package" for each guide-line. Attachment 1 indicates the format for the Data Package.

422.12 b) CPSES PGP, ODA-204, will be changed as follows:

4.2.3 Validation of the technical guidelines 4.2.3.1 The generic technical guidelines have been validated by the Westinghouse Owner's Group. This validation applies also to the Comanche Peak Technical Guide-lines since only plant specific data has been inserted and no substantial changes have been made to the basic guideline.

4.2.3.2 In order to ensure that the validation process is not compromised, the person responsible for inserting plant specific data shall determine the effect, if any, on the validation as follows:

4.2.3.2.1 An engineering evaluation of the generic plant design compared to CPSES plant specific design will be made of each generic guideline. The evaluation will consider the CPSES FSAR, Technical Speci-fications, System Technical Descriptions, Elementary Wiring Diagrams, Flow Diagrams, 422.12 c) and Instrument and Control Diagrams. Any design discrepancies identified during this process are to be evalua'ted and technical justification documented on page two of Attachment 1. Each discrepancy will be evaluated with respect to the generic guideline basis background document to ascertain if it compromises the safety of the plant and/or function of the guideline.

The technical justification will provide the basis for the plant-specific approach which will ensure the safety and/or function of the generic guideline has not been com-promised.

422.12 d) Due to TUGCo implementing NUREG-0700 requirements for a Detailed Control Room Design Review prior to the issuance of the Westinghouse Owner's Group generic guidelines and subsequent preparation of plant specific ERG's, it is not TUGCo's intention to perform a separate detailed task analysis. However, the following summary is the method TUGCo has applied to plant specific procedure preparation in accordance with NUREG-0899. On May 21, 1981 TUGCo received an audit report of our prelicensing control room design review from Robert L. Tedesco, Assistant Director for Licensing, Division of Licensing, NRC. This report stated that "If the schedule permits, your staff may respond to these open issues and deficiencies in the Detailed Control Room Design Review (DCRDR) to be performed in response to Item I.D.2 of NUREG-0737". TUGCo elected to perform the DCRDR and correct Human Factors Engineering deficiencies identified in the preliminary control room design review in accordance with NUREG-0700 prior to fuel load. The DCRDR was completed and submitted to the NRC on December 15, 1982. As part of the HFE evaluation, event oriented procedures werc utilized for video taping and walk-throughs prior to issuance of WOG generic guidelines. Following implementation of HFE deficiencies backfits, the CPSES plant specific ERG procedures were walked through the main control board by personnel previously licensed as Senior Reactor Operator. This process consisted of a step-by-step verification of all ERG's to ensure the information and control system indication needs of the operator were accurately displayed in the control room in order to accomplish the objective of the guideline. The CPSES Results Engineering Section conducted a review of all indications referenced in the ERG's to determine if FSAR Table 7.5-7 adequately addressed all of the display instrumenta-tion an operator would need to respond to and recover from an accident condition. FSAR Table 7.5-7 outlines how CPSES has addressed Reg.

Guide 1.97 Rev. 2. An evaluation of each instrument was made to determine the reliability or safety classification of the instrument and, if found unreliable, what would be the alternative to the indication. The review determined that the instrumentation listed in the ERG's but not in Table 7.5-7 was either Class 1E, and therefore very reliable, an alternative indication was available, or the indication was not required for the safe shutdown of CPSES following the accident condition. Therefore, the display instrumentation at CPSES provides the necessary displays required to effectively execute the ERG's and to fulfill the objec-tive of each procedure.

By way of integration of the DCRDR, ERG development, the Safety Parameter Display System (SPDS), and Licensed Operator Training,

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TUCCo has developed a unified approach to cope with an accident or upset condition.

422.13 a) CPSES PGP, ODA-204, will be changed as follows:

422.13 b) 4.4 Verification of Emergency Response Guidelines Each procedure shall be verified to ensure the procedure is accurate and usable. The verification process will include, as applicable, the following and will be documented on Attach- )

ment 3 when completed. An Attachment 3 check list for eacia procedure will be filed with the Comanche Peak Data Package.

4.4.1 Simulator Exercising - If simulator time is available prior to the initial operation of CPSES, the simulator exercising box on Attachment 3 should be checked to verify the procedure utilized accomplished the objective of the ERG. When the CPSES plant specific simulator becomes available, each revision of the ERG procedures will be verified on the simulator to ensure it accom-plishes the objective of the ERG and maintains the plant in a safe and stable condition.

4.4.2 Control Room Walkthrough - Each ERG will be walked through the control room and/or plant specific simulator. The walkthrough is to ensure nomenclature on handswitches, annunciators, monitor light boxes, and/or any verbage used in the main control room is identical to that of the ERG procedure. The Control Room Walkthrough box should be checked on Attachment 3 when completed.

4.4.3 Desk Top Review - The desk top review box should be checked to denote the data package for each procedure 5

has been completed and filed with the procedure.

4.5 Verification Criteria 4.5.1 Attachment 3, No. 1 - The reviewer is to sign and date confirming the ERG has been written in accordance with the generic procedure and procedure data package.

This verification is a step-by-step review of the generic WOG guideline background basis document versus the plant specific ERG procedure to ensure the intent of the step was not compromised when made plant specific.

4.5.2 Attachment 3, No. 2 - The reviewer is to sign and date confirming the plant specific ERG has been written as depicted in the ERG Writers Guide, Attachment 2 of this

! procedure. This review is to ensure all ERG's are written consistently, with good human factors principles.

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4.5.3 Attachment 3, No. 3 - The reviewer is to sign and date confirming the plant specific procedure has been walked through the control room verifying that the procedure can be followed by a newly licensed operator without confusion, delays or errors. This verification should be completed by a licensed Reactor Operator or a certi- l' fied Senior Reactor Operator.

4.5.4 Attachment 3, No. 4 - The reviewer is to sign and date confirming the plant specific design has been verified that it is not dif ferent from that which was used in the generic plant design. The plant specific design will be compared to the generic plant design delineated in the WOG data package. Any differences will be recorded in the comments section and evaluated to insure that the differences do not compromise the intent of the procedure.

4.5.5 Attachment 3, No. 5 - The reviewer is to sign and date confirming the ERG is sufficient to allow the least qualified (newly licensed) operator to use it effectively.

This verification should be completed by a licensed Reactor Operator or a certified Senior Reactor Operator and is based upon the reviewer's past experience.

4.5.6 Attachment 3, No. 6 - The reviewer is to sign and date confirming the plant specific procedure has been verified by a control room walkthrough and/or simulator exercise and that the minimum shift crew complement, as delineated in ODA-102 Attachment 1, can successfully complete all steps within the plant specific ERG.

4.5.7 Attachment 3, No. 7 - The reviewer is to sign and date confirming the plant specific procedure has been verified against the ERG transition flow chart provided by the WOG. This process is to verify that transition from one procedure to another can be done accurately and in a timely manner.

422.14 The following is a summary of the CPSES Training Department Emergency Operating Procedure Training. This CPSES Training summary is not intended to become part of the CPSES Operations Procedures Generation Package.

1 EOP TRAINING DEVELOPMENT a

This description provides a summary of the present CPSES approach to developing criteria for Emergency Operating Procedure (EOP) training.

' There are seven " phases" to the training development. The training development process begins with an analysis of the need for a specific training development project and ends with an evaluation of the training effectiveness.

t' The development is based on the principles of systems development l technology (analyze, develop, Laplement, evaluate) as applied to instruction.

Although these principles are in no way uniques to CPSES, this development l represents a tailoring of the general principles to the requirements of CPSES.

This document briefly describes each phase in two ways:

. The major activities of the phase, and

. The major outputs of the phase.

The shortage of industry man-power, regulating schedules, overall operation schedules and good business practice requires this process to be accom-plished as efficiently as possible.

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Phase 1 Preproject Study A request for training may originate from several different sources.

In some cases, training is requested by a department, in others by an extra-regulatory agency, in still others by rule or regulation.

In the academic sense, it is appropriate to determine whether there is a need for training or whether there is a more appropriate approach. The purpose of the Preproject Study is to make this determination.

Data collection and analysis is the heart of the Preproject Study. This is to:

1. Collect data from the person or organization requesting the training.
2. Collect data from the producer and user of the outputs or services that prompted the training request.

This first phase of training development usually ends with recommendations for further action. Th'ese recommendations are of two general types:

training and non-training.

In the practical sense, a requesting organization in the nuclear industry is often one with regulatory or editorial powers. These forces practically vitiate a non-training recommendation.

When training is recommended, the effort moves on to other phases of development.

Major Output Recommendation for further action

. Phrse 1 (Cont.)

. Requesting Orgcnization(s) Contact / Interfaces Title References Requiremen-Operations Ops. Supt. NUREG-0899 Guideline Engr., Ops. }[ WOG , ERG , Commitment Vol 1-3, CPSES Oper. Trg.

Training Trg. Supv. CPSES/FSAR Commitment Trg. Supv.

CPSES Mtg w/NRC Trg. Spec.

concerning EOPs.

Trg. Spec. }[ WOG Seminars NUREG/CR-1989, Analysis of Severe Core Damage Accidents for the Zion pwr; Haskin, et al, 10/82.

Quadrox Mgr. Projects INFO-82-017, OP Writing Project Mgr.

Guideline NUREG-0737, Item I.C.1 NRC NRC/LQB NRC Letters, 12/17/80 (Hanauer to Newton),

5/28/81 (Eisenhut to Jurgensen), 7/6/81 (Internal Memo)

NRC Draft Letter, Procedures Generation Package (PGP); Clari-fication and Review Criteria l Memorandum 10/25/82 (Cifford to Ziemann),

l Summary of Meeting with l TUGC0 on Comanche Peak Procedures Generation Package, 9/13/82.

NRC Letter, 5/12/82, B. J. Youngblood to R. J. Gary Liccusing (TUSI) Lic. Supv. NUREG-0578, Item 2.1.9.c Engr., Lic. NUREG-0660, Item I.C.1 RECOMMENDATION: Training

Phase 2 Job Study For training to be on target, the instructional content must match the on-the-job performance requirements. To the extent that there is a mismatch, the training may not prepare the student for the job.

The findings produced during the Job Study becomes the basis for all further development work.

For the Job Study to serve as an adequate basis for training development, it is necessary to collect and analyze data leading to a complete description of job performances under study. There are four major sources of such data: documentation that provides information about how the job functions are to be carried out; designers of the system, hardware, software, organization or service; developers of methods for carrying out the job functions; and persons actually carrying out the job activities or supervising those activities.

Maior Products Procedures for Tasks Skills and Knowledge Required to Perform Entry-level (Prerequisite) Skills and Knowledge Recommendations for Further Actions: Training or Other Alternates

__ _ _ _ _____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ ____ ..-----J

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Phase 2 (Cont.)

P cumentation Sources:

1. Design function
a. NSSS, Systems Descriptions
b. CPSES Nuclear Training (Systems)
c. W Zion Systems Training
2. EOP Design
a. WOG
3. Developer
a. Quadrex
b. TUGC0 Operations
c. TUGC0 Training
4. Utilization
a. TUGC0 Operations
b. TUGC0 Training
c. WNTC Procedures for Tasks:

Procedures for the Tasks are contained within the ERG program itself.

Five Elements involved in overall program:

1. Optional Recovery Guidelines
2. Critical Safety Function Status Trees
3. Function Restoration Guidelines
4. Example Guideline Format
5. Probabilistic Risk Assessment-based Procedures Evaluation Procedures for Program Preparation:
1. NOT-101, " Training Program Administration".
2. NOT-103, " Preparation and Control of Lesson Material and Visual Aids".
3. NOT-104, " Training Records".
4. NOT-105, " Preparation and Control of Exams and Keys".
5. NOT-107, " Training Reference Material".
6. NOT-108, " Lesson Material Revision".
7. NOT-110. " Evaluating the Effectiveness of Training".

Emergency Response Guidelines

Phase 2 (Cont-)

T=eks ERG CSF FRG Example Format Procedure Evaluation Subtasks EOP-Series Suberiticality FRS-Series Non-training Non-training EOS-Series RCS Integrity FRP-Series ECA-Series Core Cooling FRC-Series RCS Inventory FRI-Series Core lleat Sink FRil-Series Containment Integrity FRZ-Series

Pha e 2 (Cont.)

ERG EOP-Series (Nominal Emergency / Upset Response)

E0P-0.0 Reactor Trip or Safety Injection EOS-0.1 Reactor Trip Recovery EOS-0.2 Natural Circulation Cooldown EOS-0.3 SI Termination Following Spurious Safety Injection

-f EOS-0.4 Natural Circulation Cooldown with Steam Void in Vessel Upper Head E0P-1.0 Loss of Reactor Coolant (LOCA)

EOS-1.1 SI Termination Following Loss of Reactor Coolant i EOS-1.2 Post-LOCA Cooldown and Depressurization g EOS-1.3 Transfer to Cold Leg Recirculation Following Loss of Reactor Coolant I EOS-1.4 Transfer to Hot Leg Recirculation E0P-2.0 Loss of Secondary Coolant (LOSC)

EOS-2.1 SI Termination Following Loss of Secondary Coolant EOS-2.2 Transfer to Cold Leg Recirculation Following Loss of Secondary Coolant E0P-3.0 Steam Generator Tube Rupture (SGTR)

EOS-3.1 SI Termination Following Steam Generator Tube Rupture EOS-3.2 SGTR Alternate Cooldown by Backfilling RCS EOS-3.3 SCTR with Secondary Depressurization

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Phace 2 (Cont.)

FRG FRS-0.1 Response to Nuclear Power Generation FRS-0.2 Response to Loss of Core Shutdown FRP-0.1 Response to Imminent Pressurized Thermal Shock Conditions FRP-0.2 Response to Anticipated Pressurized Thermal Shock Conditions FRC-0.1 Response to Inadequate Core Cooling FRC-0.2 Response to Degraded Core Cooling FRC-0.3 Response to Potential Loss of Core Cooling FRC-0.4 Response to Saturated Core Cooling Conditions FRI-0.1 Response to Pressurizer Flooding d.

w FRI-0.2 Response to Low System Inventory '

FRI-0.3 Response to Voids in Reactor Vessel FRH-0.1 Response to Loss of Secondary Heat Sink FRH-0.2 Response to Low Steam Generator Overpressure FRH-0.3 Response to Steam Generator High Level FRH-0.4 Response to Steam Generator Low Level FRH-0.5 Response to Loss of Steam Generator PORVs and Condenser Dump Valves FRZ-0.1 Response to Containment High Pressure FRZ-0.2 Response to High Containment Sump Level FRZ-0.3 Response to High Containment Radiation Level FRZ-0.4 Response to High Hydrogen Concentration in Containment FRZ-0.5 Response to Containment Flooding

. Phare 2 (Cont.)

Suberiticality

1. Nuclear criticality
2. Nuclear cycle
3. Inherent reactivity affects
4. Nuclear poisons
5. Core characteristics
6. Core construction
7. Borated water systeas
8. Reactor shutdown system ,
9. Nuclear Instrumentation
10. RCS Temperature RCS Integrity
1. RCS Description
2. RCS Water Chemistry
3. RCS Temperature and Pressure Limits
4. RCS Sources of Water
5. Radiation Monitoring
6. RCS Pressure
7. Containment / Containment Systems Core Cooling
1. HTFF/ Thermodynamics
2. Core Cooling Mechanisms
3. RCS Water Sources
4. RCS Description
5. S/G Water Sources
6. RCS Temperature
7. RCS Pressure C. RCS Level l

RCS Inventory

1. RCS Temperature Affects
2. RCS Water Inventory Sources l

Ph ast 2 (Cont.)

Core Heat Sink

1. HTFF/ Thermodynamics
2. S/G
3. RCS 1
4. AFW
5. MFW
6. SW
7. CCW Containment Integrity
1. Containment Systems l
2. Containment Integrity Requirements Systems
1. RCS
2. ECCS
3. Rod Control
4. Rod Position Indication
5. S/G
6. AFW
7. SW
8. RHR
9. SI
10. Charging
11. Accumulator
12. AC Power l 13. DC Power l

14 Pressurizer and Relief Systems l

15. Steam Dump
16. Radiation Monitoring
17. Hydrogen Control
18. RCS Temperature

! 19. RCS Pressure Level

20. CS

Phesa 2 (Cont.)

Systems (cont'd)

21. CVCS
22. CCW
23. Rad Waste
24. HVAC
25. Meteorology System
26. Accident Sampling Skills and Knowledges Knowledges
1. CPSES Basic Nuclear Training (or equivalent)
a. Phase I
2. CPSES Plant Systems
a. CPSES Nuclear Training
b. CPSES Systems Walkdowns Skills
1. CPSES Systems Operations
2. CPSES Control Room Operations Pre-requisite Skills and Knowledge CPSES Nuclear Training CPSES Systems Walkdown

Phase 3 Training Design The Training Design produced in Phase 3 is closely limited to the insrJuctional content established in the Job Study Phase. Using the results of the Job Study, a design is built to provide the best means for students to learn the required content.

The Training Design is similar to a blueprint for building a house. Once that design has been produced, the training will be developed using the design as a specification.

Phase 3 has been constructed so that it may be applied to existing training that is being revised, or to training that is being built from-the-ground-up, or to some combination of these.

Limitations on training development are identified early in the design process so that they may be dealt with appropriately. Then end-of-course objectives are written to serve as a focus for all further design work.

This is followed by the development of one or more tests to judge the effectiveness of training.

The design is focused from the point of view of how the training will be presented. Lessons, modules and sequence are developed into the form in which the materials will later be presented to the students.

Major Products

. Training Objectives Job Performance Test

. Design Document, Including Specification on How the Training Will Bo Carried Out

l Phcze 3 (Cont.)

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Training Objectives Terminal Objectives:

1. The Operator should use procedures to maintain Critical Safety Functions.
2. The Operator should use procedures to restore Critical Safety Functions.
3. The Operator should use procedures to mitigate the consequences of core damage.

Enabling Objectives:

1. The Operator should describe the background of the procedure development (technical basis for ERGS).
2. The Operator should describe the structure, organization, relationships and interrelationships of the Emergency Response Guidelines.
3. The Operator should use indication (instrumentation, alarms, and computation) with procedures.
4. The Operator should select and follow the correct procedure.
5. The Operator should demonstrate the ability to utiliza procedures for error correction.

! 6. The operator should demonstrate the knowledge of immediate actions required.

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Phrza 3 (Cont.)

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Design Plan for Training , C?SES Chapter A. CPSES Nuclear Training - .

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1. Station Operating Procedures (Overview) (3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />); ;, XII-2
2. Emergency Response Guidelines (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) XII-3
3. Transient and Accident Analysis - XII-1 thru 15
a. Optimal Recovery Guidelines - Day 5,6 (10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />) XII-13
b. Emergency Contingency Action - Day 6 (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />) XII-14 -
c. Functional Restoration Guidelines - Day 7 (5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />) XII-15
4. Mitigating the Consequences of Core Damage XII-16 thru 19 B. CPSES Systems Walkdown Block 15(13)
1. Control Room Instrumentation
2. Instrumentation and Control
3. Procedure Walkdown C. Simulator Training
1. WOptionIII(14 days,PrelicenseRefresher)usingCPSES ERGS on Zion plant simulator.

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Performance Test Test Method

1. Students demonstrate knowledge TAA/MCD exam (2 exams) .

requirements

2. Students are successful in main- '

' walkdown/ simulator evaluations taining CSF (

3. Students are successful in using walkdown/ simulator evaluations ERG Student evaluations are accomplished by observation check sheets when using the Zion simulator. \

Knowledges of written material are evaluated by. written exams.

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Walkdowns are evaluated by oral / observation dictamen'te. tion sheets.

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CRITICAL SKILL OR BEHAVIORAL INSTRUCTIONAL EVALUATION ENABIING OBJECTIVE KNOWLEDGE PROCESS SETTINC METHOD REMARKS f

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  • The Operator should describe No Cognitive Classroom Written exam the background of the pro- Walkthrough Oral / Observation cedure development (tech- Simulator nicci basis for ERCS).
  • The Operator should describe No Perceptual Classroom Written exam the otructure, organization, Cognitive Walkthrough Oral / Observation relctionships and inter- Simulator relationships of ERCS.
  • The Operator should use Yes Perceptual Walkthrough Oral / Observation Walkthrough in plant i indicstion (instrumentation, Cognitive Simulator must be used to alarms and computation) with Communication augmentZionsimulatorh' procedures. Motor training. 8 i
  • The Operator should select Yes Perceptual Walkthrough Oral / Observation Zion simulator training and follow the correct Cognitive Simulator may be used with actual prccedure. Communication plant procedures to

, Motor provide complete training.

The operator should demon- Yes Perceptual Walkthrough Oral / Observation Zion simulator training ctrete the ability to Cognitive Simulator may be used with actual ,

utilize procedures for Communication plant procedures to errcr correction. Motor covide complete training.
  • The Operator should demon- Yes Perceptual Classroom Written exam A written exam may be atrate the knowledge of Cognitive Walkthrough Oral / Observation used to verify knowledge immediate actions required. Communication Simulator of immediate actions.

Phase 4 Materials Development The purpose of Phase 4 is to develop training materials using the Training Design produced in Phase 3.

By depending on a design, the course development concentrates on development itself. Attention is given to readability, appropriate visuals, etc.

Once the training materials are drafted, they are reviewed and/or tried out (developmentally tested).

c Major Products Trainee Materials Trainee Tests Trainer Materials Developmental Review (Test) Results

Phase 5 Field Test A Field Test is carried out to evaluate all aspects of the just-developed training under realistic conditions. During the Field Test, conditions will be as close as possible to those that will be encountered after the

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training is in general use.

l Planning for the Field Test includes attention to the tryouts required, the tryout sample (who the students will be and what their backgrounds are), how many students are required, etc.

Training materials for the student are evaluated as well as lesson plans for the instructor, visual materials, demonstration equipment, and so on.

Criterion or job performance tests are administered during the Field Test of training.

Field Testing is used to refine the training for general use.

Major Products Field Test Results Modified Training Materials

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l Phase 5(Contd The Field Test for simulator training was selected to be the first group of Option III participants. The Zion simulator was evaluated for use with EOPs. A label change list package was generated for the Zion simulator control board.

The Field Test for CPSES control room walkdowns was selected to employ instructors in the Test.

The Field Test for Transient / Accident Analysis and Mitigating Core Damage lectures was waived. The first implementations were treated as field trials.

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Phase 6 Training Introduccion Two groups of people have significant roles in the introduction of j training: the organization that developed the training and any l organization that receives the training in preparation for teaching it.

l Among the early Phase 6 activities, the developing organization announces the availability of training and prepares to receive training evaluations.

These evaluations may be used in evaluating the effectiveness of training, as well as maintaining and revising the training.

An organization receiving the training conducts a variety of activities.

It must see that the instructors are prepared, training location is ready, ordered materials are received, students are scheduled, etc. The receiving organization may review the criterion test to determine whether or not the training matches its requirements. If not, training is adjusted to match the needs while preserving its integrity.

Phase 6 may be optionally treated in the first Laplementations of training as field trials. -

Major Products-Final Form of Materials Availability Announcement l . Adaptations

Phase 7 Follow-Up Evaluation l

l A Follow-up Evaluation is carried out after the introduction of training.

All training - even training that has been carefully developed and

, tried out - has the potential, af ter a time, to become mismatched with job requirements. Sometimes this happens because those requirements change.

The Follow-up Evaluations address whether or not the needs turned up by the Preproject study have been met and the training content matches the current job. Of ten, a judgment is also made about the value of continuing the training without change, revising it, or dropping it.

Some evaluations address other issues as well. For example, sometimes it is important to determine whether non-training recommendations from the Preproject or Job Study have been carried out effectively. Other evaluations are concerned with whether or not the right students are attending the training, the training is being administered as intended, etc.

Depending on the outcomes of the evaluation, no further action may be necessary, or recommendations may be made to correct deficiencies or develop major segments of training.

Major Products

+ Findings on How Well the Training Prepares Its Students Recommendations for Further Action

Phase 7 (Cont.)

EOP Revisions will be incorporated into requalification training programs.

Review of revisions may be done in accordance with ODA-106 " Review of Documents". I Incorporation of revisions into operator training programs is accomplished in accordance with Nuclear Operations Training Procedure NOT-108 " Lesson Material Revision".

Requalification training, described by CPSES Training Procedure TRA-204,

" Licensed Operator Requalification Training Program", provides a mechanism for training on major and minor revisions to the ERGS. This is accomplished in the following ways: annual review and sign-off of Abnormal Conditions Procedures and Emergency Response Guidelines, a review conducted as a regular part of the scheduled lecture series and annual examination, as part of performance evaluations as on-shift walkthroughs conducted by Shift Supervisors or Assistant Shift Supervisors and by use on a simulator.

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422.15 a) TUGCo will review the Emergency Response Guidelines Structure schematic when Westinghouse Owners Group releases Rev. 1 of the WOG ERG's and will make changes as applicable.

422.15 b) CPSES PGP, ODA-204, Step 4.1.3 will be changed as follows:

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"...In the unlikely event that SAS is inoperative during an accident, a manual back-up system shall be provided." The backup system will l consist of a solid backboard structure to allow flipping through each critical safety function status tree in priority of use. After .

the status of each individual safety function has been determined, the tear-off tablet status sheet (see example below) attached to the botton of the solid backboard will be so marked and given to the operator implementing the ERG's.

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'lQ' saz as 3,55l,,o rei o.i es, DNVINTo#v i81 o satis 8stD In reference to the additional item following Item 422.15, the evaluation does not assume that a compromise of the generic technical basis for the guideline is not possible. However, as written, before the data is entered into CPSES ERG data package, it must be made plant specific. The sign off sheet of Attachment 1, page 2 of 3 is a verification that CPSES design does not compromise the generic technical basis as provided in the WOG background docu-mentation. If a discrepancy is noted, the reviewer will not sign until the discrepancy has been resolved. The ERG procedure will not be issued for use until the data package is signed.

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