ML20085N657
| ML20085N657 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 11/04/1983 |
| From: | Kuncl L NEBRASKA PUBLIC POWER DISTRICT |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-83-28, NUDOCS 8311110147 | |
| Download: ML20085N657 (124) | |
Text
_ _ _ _ - _ _ _ _ _ _ _ _ . _ _ _ . _
f GENERAL OFHCE P.o Box 499. COLUMBUS. NEBRASKA 68601-0499 L Nebraska Public Power Distn.t t _ _ _ _ _ . _ _ _ . _ _ _ _ _ _ - -
TcLee o~t <<o2>564-asei
- - . - - - - - - - - = =
November 4,1983 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Washington, DC 20555 Attention: D. G. Eisenhut, Director
Subject:
Response to Generic Letter 83-28, " Required Actions Based on Generic Implications of Salem ATWS Events."
NRC Docket No. 50-298, DPR-46 Re<grence: (1) Letter, D. G. Eisenhut to All Licensees of Operating Reactors et al., " Required Actions y Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)", dated July 8,1983.
(2) NPPD letter, L. G. Kunct to D. G.
Eisenhut , " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)", dated September 6, 1983.
(3) BWR Owners' Group letter, T. J. Dente to D. G. Eisenhut, " Schedule for Submittals in Response to NRC Generic Letter 83-28",
dated September 6,1983.
(4) Nuclear Utility Task Action Committee (NUTAC) letter, E. P. Griffing to D. G. Eisenhut, " Generic Letter 83-28, Section 2.2.2", dated September 15, 1983.
Dear Mr. Eisenhut:
This letter and the attached report provide Nebraska Public Power District's response to the NRC Generic Letter 83-28, Reference (1). In our earlier submittal, Reference (2), we indicated the actions that were being taken by the District to i, assess the current conformance of Cooper Nuclear Station with /
regard to the NRC positions contained in Reference (1).
detailed description of these actions is provided in Section 2 of A
'g.
g the attached report which includes our participation in the nuclear industry programs, References (3) and (4), to address hy the requirements that have a generic application to all BWR plants.
g\
8311110147 831104 PDR ADOCK 05000298 p PDR I
/ ,
D. G. Eisenhut Page 2 November 4,1983 Section 3 of the enclosed report provides a detailed response to '
the seven action items in Reference (1) that are applicable to BWR plants. For each action item, the District has described its current conformance to the requirements including ongoing >
activities that are applicable to these actions. In addition, we have provided a proposed program that will improve the District's conformance with these positions. A number of these ongoing activities and proposed programs involve participation in the BWR Owners' Group programs and the Nuclear Utility Task Action Committee (NUTAC) programs that address the generic issues for BWR plants.
In Section 4, we have provided a summary of the District's current complianac with the actions required in Reference (1).
Also, a schedulu 1:as been provided for proposed future actions.
In many cases, there is sufficient uncertainty in the District's implementation plan, such that we are only able at this time to provide an estimate of the dates for each of the action items.
As noted in our report, the issues raised in Reference (1) reflect upon a number of ongoing activities at the Cooper Nuclear Station. Of particular importance are the District's "
actions being taken in response to NUREG-0737, Supplement 1, and to a recent appraisal of the District's nuclear management by an independent consultant. These responses have been enclosed as appendices to the report.
The District will continue to keep you informed of the status of our proposed programs intended to improve our conformance with the positions of Generic Letter 83-28 Sinceyely, q M
L. G. Kunct Assistant General Manager - Nuclear LGK/ gat:rt2/7(QAC4)
Enclosures cc: B. Siegel D. Dubois J. Collins I
O
D. G. Eis nhut Page 3 November 4,1983 O
STATE OF NEBRASKA)
- )ss
- PLATTE COUNTY )
l L. G. Kuncl, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this information on behalf of Nebraska Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.
I /
L. p. Kuncl N Subscribed in my presence and sworn to before me this 4l day of M eu ,, . A d , 1983.
O
<5hur...< rl > WWJ NOTARY PUBLIC hCEN(R4Nongy,gg e~i ILORENCEM K __st@My comm_ ryg /.n.OLMpy 1 l
_ - - = .- . . _ _ _ . . . _ . - _ . - _ . . - _ - . . - - - -
. i 4
4 l t ) November 4, 1983' !O i I i i 1 i l i i I f i 1 i COOPER NUCLEAR STATION . i _ i ', i . l l RESPONSE TO REQUIRED ACTIONS BASED ON 4 GENERIC IMPLICATIONS OF SALEM ATWS EVENTS l (Generic Letter 83-28) i NRC Docket No. 50-298, DPR-46 , !' i
}
s i i
. O :
I g . - l l Nebraska Public Power District l i s. A b l x i r f i l OL _ f
; / , ,
.u. .:5
%t e, '
%g et, - m wrew + w *v.w-w e se, r-ewrwe-,..--wwe.em-,-w-o-e-reemmew-e*+,av.w.-.*,. es. ,=-+.c e -- ww.mer e eW m. -_.~--*.----*-.=ce------,--++,e.
~ l Table of Contents O SECTION PAGE
- 1. BACKGROUND 1-1 1.1 Introduction 1.2 Scope of Response l 2. ANALYSIS OF CENERIC LETTER 83-28 ISSUES 2-1 2.1 Overview 2.2 Independent Evaluation 2.3 BWR Owners' Group (BWROG) 2.4 Nuclear Utility Task Action Committee (NUTAC)
- 3. DETAILED RESPONSE TO GENERIC LETTER 83-28 (See Note Below) 3-1 3.1 Action 1.1 Post-Trip Review (Program Description and Procedure) 3.2 Action 1.2 Post-Trip Review - Data and Information Capability 3.3 Action 2.1 Equipment Classification and Vendor Interface (Reactor Trip System Components) 3.4 Action 2.2 Equipment Classification and Vendor Interface (Programs for all Safety-Related Components) 3.5 Action 3.1 Post-Maintenance Tenting (Reactor Trip System Components) 3.6 Action 3.2 Post-Maintenance Testing (All Other Safety-Related Components) 3.7 Action 4.5 Reactor Trip Systaa Reliability (System Functional Testing)
- 4.
SUMMARY
4-1 APPENDICES A. Response to NUREG-0737, Supplement I with revision. B. Response to the management appraisal report. C. NPPD Letter, L. G. Kuncl to D. G. Eisenhut, " Required Actions Based on Generic Implications of SALEM ATWS Events (Ceneric Letter 83-28)", dated September 6, 1983. f (p) Note: Action Items 4.1, 4.2, 4.3, _ and 4.4 of the Generic Letter were not i applicable to BWR's, thus they are not addressed in this response. L
- 1. BACKCROUND f}
(_/ 1.1 Introduction This report provides the 120-day response of the Nebraska Public Power District (District) to the Nuclear Regulatory Commission (NRC) Generic Letter 83-28 of July 8, 1983, Generic Implications of Salem ATWS Events. Presented in this report is the current compliance of Cooper Nuclear Station (CNS) to the action items in Generic Letter 83-28. The report describes the District's participation in the additional programs being conducted by the industry through the BWR Owners' Group (BWROG) and the Nuclear Utility Task Action Committee (NUTAC) to address the generic issues raised by the Salem ATUS event. Also, the District has identified proposed programs and schedules for completing activities that will resolve issues raised in Generic Letter 83-28. , 1.2 Scope of Response In developing this response, the District recognized the need to address both the management issues and the equipment issues, especially reactor trip system reliability. Prior to the issuance of Generic Letter 83-28, a detailed independent audit was conducted of its entire nuclear organization. As a result of this review, a number of new programs were initiated in the nuclear organization to improve the overall performance of CNS. A number of the programs initiated as a reselt of the audit
/si address Generic Letter 83-28 issues. \
The review process for Generic Letter 83-28 issues involved a number of specific actions. In addition to the review conducted by District personnel, an independent consultant was retained to assess the conformance of CNS with respect to the NRC's proposed actions. Also, the District has been an active participant in the BWROG and NUTAC groups which are addressing the generic issues raised by the NRC. A detailed description of these activities is presented in Section 2 of this report. Section 3 provides a detailed response to the seven action items requested of BWR licensees. The current status and ongoing programs that relate to Generic Letter 83-28 action items are provided in each section. In addition, a number of future District actions are proposed to improve performance with respect to the issues raised by the Salem ATWS events. Section 4 summarizes the proposed program of prospective actions and schedules for conformance to the requirements of Generic Letter 83-28. Finally, the appendices to this report contain copies of documentation previously submitted to the NRC that are relevant to the issues addressed in this report. s , s l l 1-1
t
- 2. ANALYSIS OF GENERIC LETTER 83-28 ISSUES O
b 2.1 Overview Recognizing the importance of the is; ues raised by the Salem ATWS event and by the subsequent issuance of NUREG-1000 and Generic Letter 83-28, a program was developed to provide the District's response to these issues. The goals of this program included: (1) Evaluation of existing programs that addressed issues raised in Generic Letter 83-28; (2) Review of existing documentation governing post-trip review, maintenance, surveillance testing, spare parts replacement, system and component classification (Q list); (3) Determination if program modifications currently being implemented should be modified or placed on an accelerated schedule; (4) Participation in industry groups (BWROG and NUTAC) addressing these issues; and (5) Development of an implsaentation schedule for future actions. To supplement the District personnel involved in this review process, an independent consultant was contracted to review the District's current programs and to make recommendations for improvements. ?D
~
2.2 Independent Evaluation The consultant working with District personnel conducted a detailed review of the CNS processes, procedures, programs, and components to determine the current status with reference to these issues. Specifically, the corsultant performed the following tasks: (1) Conducted interviews with C6d and General Office personnel; (2) Reviewed existing plant procedures, technical specification, etc., with respect to the issues raised in Generic Letter 83-28; (3) Verified that plant personnel were performing their functions in accordance with plant procedures and other documentation; (4) Evaluated existing and proposed equipment utilized in providing post-trip information; (5) Reviewed existing classification of components in the reactor protective (RPS) and control rod drive (CRD) systems; (6) Reviewed a sampling of past reactor scram reports and maintenance work orders; 1 () (7) Determined status of existing equipment classification program; and v (8) Reviewed a sample of post-maintenance testing of RPS and CRD system l components. ' 1 2-1
i I I The results of these tasks were used in the preparation of this report and also for the development of the follow-on program. 2.3 BWR Owners' Group (BWROG) The District has been an active participant in the BWROG program to address the generic issues that affect all BWRs. An ad-hoc committee of the BWROG first met on August 18, 1983, to develop a program with General Electric. As a result of this meeting and subsequent committee meetings, the BWROC together with General Electric is proceeding to develop guidelines in the following areas:
- a. Develop gereric criteria for reactor restart following a reactor trip,
- b. Discussion of methods / criteria for event comparison in evaluating reactor trip events.
- c. Description of General Electric vendor information programs.
- d. Adequacy of current reactor trip svstem functional testing.
- c. Procedure for safety-related component identification.
- f. Personnel qualifications and training for post-trip review.
In addition, a separate committee of the BWROG is proposing to conduct a () review of existing intervals for on-line functional testing required by Technical Specifications to determine if the intervals are consistent with achieving system availability. The efforts of the BWROG's activities have been included in the response to the individual action items (Section 3). Also, the proposed BWROG program for future actions is incorporated in our summary of future actions (Section 4). 2.4 Nuclear Utility Task Action Committee (NUTAC) In addition to its participation in the BWROG efforts, the District has also participated in the NUTAC. This NUTAC group was organized on ' September 1, 1983, to develop a guidance program for use by nuclear utilities to address the vendor interface requirements of Generic Letter 83-28, Section 2.2.2. Since its initial meeting, the group has selected a number of options for consideration in the development of a practical approach to this issue. The NUTAC has established a goal of February 1, 1984, to complete this effort. The results of the Committee's work will be incorporated into our future actions. s I r ! 2-2 l w- m w >w r
- - ~
+W q == -g %g
- 3. DETAILED RESPONSE TO GENERIC LETTER 83-28 n_- s 3.1 Action 1.1, Post-Trfp Review (Program Description and Procedure) 3.1.1 Post-Trip Review Upon a reactor trip, and in accordance with CNS General Operating Procedure 2.1.5, Emergency Shutdown From Power, a Scram Report (Exhibit 3.1-1) is completed. As part of this procedure, the Division Manager of Nuclear Operations (formerly the Station Superintendent), Operations Manager, and Reactor Engineering Supervisor are notified of the reactor trip. Also, in accordance with CNS Administrative Procedure 1.27, Shift Communicator Responsibility, a Notice of Significant Events Checklist (Exhibit 3.1-2) is completed with notification of the Division Manager of Nuclear Operations and the NRC.
CNS has always conducted a review of both scheduled and unscheduled reactor shutdowns. Figure 3.1-1 shows the process currently being employed by CNS personnel to analyze reactor trips. The Reactor Engineering Supervisor and reactor engineering staff are responsible for collecting the information on the plant trip. A detailed description of the available information is provided in Section 3.2. The reactor engineering staff also discuss the scram events with the operating personnel on duty at the time of the scram and also () '~ review performance of the system with respect to the plant Technical Specifications. The Operations Manager also conducts a review of the reactor trip, verifies each trip signal, and then attempts to determine the cause and potential methods for correcting the problem. In addition, the Operations Manager requests the Plant Engineering Department to conduct an independent review of the trip to determine the cause. The Plant Engineering Department will utilize personnel on the staff who are most familiar with the systems involved in the reactor trip. At CNS, members of the engineering staff are assigned responsibility for specific plant systems. These engineers are knowledgeable in the system design, operation, Technical Specification requirements, and other peeformance specifications for the specific plant systems. Within a few hours of the reactor trip, a group meeting is convened to discuss the trip. This group is composed of members of the Station Operating Review Committee (SORC) plus other personnel needed to provide the necessary technical expertise. The meeting is either led by the Nuclear Operations Division Manager or his designee. A detailed description of j the responsibilities, authorities, qualifications, and training of meeting personnel is presented in Section 3.1.2. t \/~;h 3-1
The group reviews the sequence of events leading up to the (~) trip, and collectively confirms the cause of the trip. They
\/ also verify that no other abnormalities were observed in the analysis of the trip to ensure that the cause of the event has been accurately determined. At the meeting, the group confirms what actions need to be taken to correct the cause of the trip.
The group approach employed at CNS provides for technical input and review by personnel knowledgeable in all facets of station operation. When the group is satisfied that the cause of the trip has been determined and corrected and safe operation of the plant can resume, the Nuclear Operations Division Manager authorizes that the reactor should be restarted upon completion of the required maintenance, testing, and verification. Since the reorgar tzation of the CNS operations group in July, 1983, the post-trip review meetings are of ficial meetings of the SORC. Results of the meeting are documented in the SORC meeting minutes which are retained for the life of the plant. Prior to that time, the post-trip review meetings were not considered as official SORC meetings. However, the scram reports with associated documentation of the plant trip were maintained in accordance with the plant quality assurance procedures. 3.1.2 Personnel Involved in Post-Trip Review Personnel typically involved in the review of a reactor trip O v include the following: Nuclear Operations Division Manager - Responsible for all operations of CNS. The current manager is a member of SORC and possesses a Senior Reactor Operator (SRO) license at the Cooper Station. He has over 30 years of experience, almost all in the nuclear field, including 14 years at the CNS. Technical Staff Mat.ager - In addition to managing staff functions, he assists the Nuclear Operations Division Manager. He is currently in training for an SRO license and is a member of SORC. He has 12 years of experience, a B.S. degree, and has been at CNS for three years. Operations Mar;ager - Responsible for the overall operations function including maintenance, instrumentation and control, i and nuclear planc operations. He holds an SRO license, a B.S. l degree, and is a member of SORC. He has 20 years of experience l in the nuclear Navy, and he has been at CNS for two years. l Maintenance Supervisor - Responsible for electrical and mechanical maintenance at CNS. He'nas 30 years of experience, including 13 years at CNS and is a member of SORC. ' O) L, 3-2
Instrument and Control Supervisor - Responsible for all surveillance and I&C maintenance at CNS. He has over 27 years of experience, including 23 in the nuclear field, and has been at CNS for 11 years. He is a member of SORC. Operations Supervisor - Responsible for plant operations. He is an SRO and has 23 years of experience, including 20 in the nuclear field, and has been at CNS for 14 years. He is a member of SORC. Technical Manager - Responsible for chemistry and health physics, computer applications, plaat engineering, and reactor engineering. He is a member of SORC and is currently in training for an SRO license. He has 14 years of experience, all in the nuclear field, a B.S. degree, and is a registered [ Professional Engineer. He has been familiar with CNS operations for 5 years and has been employed at CNS for 1 year. Plant Engineering Supervisor - Responsible for the management of plant engineering functions including electrical, j mechanical, performance, and radiation protection. He is a member of SORC, is completing training as a Shif t Technical l Advisor (STA) and holds a B.S. degree. He has 12 years of I experience, including 2 years at CNS. Reactor Engineering Supervisor - Responsible for reactor engineering analysis. He has completed degraded core training, ATWS training, and is . currently completing STA training. He has a B.S. degree with 10 years of experience and has been at CNS for 7 years. He is a member of SORC. Quality Assurance Manager - Responsible for all quality assurance at CNS and is a non-voting member of SORC. He has over 24 years of experience in the nuclear field and has been at CNS for 14 years. In addition to the above personnel other members of the engineering, operations, and maintenance staff contribute to the evaluation of rear. tor trips as required. l 3.1.3 Review Process As diccussed in Section 3.1.1, the SORC is involved in the review of all reactor trips. Only when the SORC is satisfied that the trip's causes have been identified and remedied will the reactor be restored. In addition, the Safety Review and Audit Board (SRAB) reviews the minutes of meetings of the SORC and all events which are required by Technical Specifications to be reported to the NRC in writing within 24 hours. 3.1.4 Proposed Actions Although the current post-trip review process provides adequate assurance that the plant can be' restarted safely, the District' 3-3
will develop an administrative procedure to formalize and enhance this process. It is anticipated that a procedure will O be completed, reviewed, approved, and plant personnel trained in the new procedure by July 1, 1984. As indicated in Section 2.3, the District is participating in-the BWR Owners' Croup program addressing the generic issues with respect to Generic Letter 83-28. The Owners' Croup has contracted with General Electric (CE) to develop generic post-trip restart criteria and restart procedure guidelines. Their activities are scheduled to be completed by CE in February, 1984. The District will incorporate the results of the CE studies as appropriate into this new procedure. l l lO O 3-4
. = ~ . - . . . . . _
. . . . - _ . . . . - . . . - - - . .~. . . . . _ _ . - - . . _ . .. .
i. i Figure 3.1-1 i Reactor Trip Analysis Process i 1 Reactor Trip 1f
- Notification of
, Plant Management i 0 , Collection and
- Review of Trip Data U
Independent
- Review of Cause i U Group Review l and Discussion i
I U 1 i Maintenance, Testing, and Verification i 4 p
- Restart O
3-5 I
.1 o
_ _ _ __.____ _ - _ , _ _ . . . _ . , . _ . . . , _ . _ _ . . - , _ - - - _ . _ , , . . , _ - . . . , , , - , . . _ . . . . . . . . , . . _ _ . . . . . . . - - . . . ~ _ . ~ , . . , , ,
C00PEm NUCNEAR STATION OPElmI@h1 1;&WAL MTACHMENT "A" GENERAL OPERATING PROCEDURE 2.1.5 EMERGFNCY SHUTDOWN FROM POWER EXHIBIT 3.1-1 fs V, SCRAM REPORT
/
Number: Date: Time: l l l MODE SWITCH POSITION REACTOR STATUS FLOW CONTROL STATUS CAUSE (PRIOR TO SCRAM) (PRIOR TO SCRAM) (PRIOR TO SCRAM) O Operator error O Run O critical too9 Manual C Testing Error Startup MWT Master Manual Equipment Failure Refuel O Subcritica1 Master Automatic Other STATION STATUS SCRAM TIMES STATION (,0NDITIONS (PRIOR TO SCRAM) (FOR MONITORED CRDs) (PRIOR TO SCRAM) Starting-Up C None Available Core Flow: Lb/Hr Shutting-Down Average: Sec Reactor Pressure: psig O Changing Power Fastest Rod: Steam Flow: Lb/Hr Steady State Time: Sec Vessel Level: Inches Surveillance Testing Slowest Rod: Feedwater Flow: Lb/Hr Other: Time: Sec Off Gas Activity Level: Mr/Hr Stack Gas Activity Level: cps Building Vent Activity Level: Mr/Hr Generator Output: (gross) C Off Brief Description Of Scram: Corrective Action Taken: Plant Superintendent Notified: Procedstre 1.27, Attachment "A" (Shif t Communicator Time Responsibility) Initiated: Operations Supervisor Notified: Time Time Reactor Engineer Notified: EPIP 5.7.1 (Emergency Procedure) And EPIP 5.7.6 Time (Notifit:ation) Implemented: Yes No N/A Shift Supervisor: Time: m (,jcwedBy: Date: rocidure Number 2.1.5 Date N/I 4 Revision 5 Page 1 of 1 Page:
l COOPER NUCLEAR STATION OPERATIONS MANUAL , l ATTACHMENT "A" ADMINISTRATIVE PROCEDURE 1.27 SHIFT COMMUNICATOR RESPONSIBILITY l EXHIBIT 3.1-2 Page 1 rN NOTIFICATION OF SIGNIFICANT EVENTS CHECKLIST (_) (PER 10CFR50.72)
- 1. TIME OF REPORT: DATE GF REPORT:
- 2. ORGANIZATION: Cooper Nuclear Station, Brownville, NE
- 3. CALLER'S NAME:
- 4. EVENT CLASSIFICATION (CIRCLE APPROPRIATE ITEM NUMBER AND EMERGENCY CLASS. IF ITEM 1 APPLIES):
Item 1 - Emergency Plan Event; Unusal Event, Alert, Site Area Emergency, General Emergency Item 2 - Exceeded Technical Specifications Safety Limit Item 3 - Power Plant Not In Controlled Or Expected Condition Item 4 - Safety, Security or Sabotage Item 5 - Shutdown Due To Technical Specifications LCO Item 6 - Personnel Error Relating To Safety Systems Item 7 - Manual Or Automatic Scram (3
'\ 51 tem 8 - Serious Injury Requiring Off-Site Medical eItem 9 - Serious Personnel Contamination Item 10 - See Page 2 And 3 Of Procedure, Steps K.l.a.1) Through K.I.a.4)
Item 11 - Strike (See Page 4, Step L.) cCombination Of Items 8 And 9 May Be An Unusual Event (EPIP 5.7.1, Item 6.5)
- 5. EVENT DESCRIPTION:
- 6. EVENT TIME: 7. EVENT CAUSE:
- 8. REACTOR POWER PRIOR TO EVENT: __
- 9. POWER NOW:
- 10. HPC1/ ADS /LPCI OPERATED: Yes/No 11. COOLING MODE:
- 12. CONTAMINATION: Yes/No 13. RELEASES: Yes/No l14. CONTAINMENT INTACT: Yes/No 15. OTHER PROBLEMS:
l l16 , PLANS: 17. OTHER AGENCIES NOTIFIED: Yes/No 7 ( 187') FILL OUT PAGE 2 IF EMERGENCY ACTION PLAN INITIATED. remcmanrem hmfeere 1.27 lnsan !/-$-EY 9wnsnm 3 psca 1 er 2 p w, g
LOOPER WULLLad 3 A At iUN UPhRal10.sh ItAhLAL ATTACHMENT "A" ADMINISTRATIVE PROCEDURE 1.27 SHIFT COMMUNICATOR RESPONSIBILITY EXHIBIT 3.1-2 Page 2 7 NOTIFICATION OF SIGNIFICANT EVENTS CHECKLIST (, (PER 10CFR50.72) FACILITY NAME: Cooper Nuclear Station, Brownville, NE EMERGENCY CLASSIFICATION: ; DATE: _ ; TIME: EQUIPMENT STATUS REACTOR STATUS DRYWELL STATUS SUPPRESSION CHAMBER Water Level: Water Level: Water Level: Teptreture: Temperature: Temperature: Pres ure: Pressure: Torus Spray: Rod Positions: Drywell Spray: Power (%): Drywell Coolers: , , , Rrcirc Flow Loop A: Rtcirc Flow Loop B: A Ei_) SYSTEMS: HPCI: ; RCIC: ; LPCI (RHR): ; Core Spray: ; ADS: ; SGT: ; SLC: ; SW: ; RBCCW: ALTERNATE RPV WATER INJECTION SYSTEMS: CRD Hydraulic: ; SW Water System: ; Ferdwater/ Condensate Systems: REACTOR C00LDOWN MODES: Steam Dump To Condenser; RHR Steam Condensing Mode; RHR Shutdown Cooling Modn; Feed And Bleed Method; RWCU System CONTAINMENT SYSTEMS: Primary Containment Isolation; Secondary Containment Isolation; SGT System Actuation; MSIV Isolation: Inboard, Outboard; Safety /SRV Actuation: Open, Closed WATER TANK LEVELS: Condensate Storage Tank: ; Emergency Condensate Storage Tank: VITAL ELECTRICAL SYSTEMS: Off-Site Power Availability: ; DGs: ; On-Site AC High Volt: ; Medium Volt: ; Low Volt: ; DC Volt: ON-SITE RADIOLOGICAL / CONTAMINATION PROBLEMS: CORE / FUEL DECRADATION: INOPERABLE EQUIPMENT:
/~
PL.j NNEL INJURY: ; NATURAL DISASTER: ; EECURITY THREATS: i l roceduru Number 1.27 _ Date #)7" R2 Vision _ 3 page 2 or ,2 Pages
3.2 Action 1.2, Post-Trip Review - Data and Information Capability (')/
- s. 3.2.1 Equipment and Parameters Monitored The Reactor Protective System (RPS) initiates plant trips following abnormal operational transients. Figure 3.2-1 shows a block diagram of the scram functions at the Cooper Nuclear Station (CNS). A detailed description of the RPS is provided in Section VII-2, Reactor Protection Systems, of the CNS Updated Safety Analysis Report.
In the event of a trip, plant personnel have access to the information provided by the following set of equipment: (a) Plant chart recorders; (b) Annunciator system; (c) Reactor Protection System relays; and (d) Plant process computer. The plant chart recorders provide a continuous basis for monitoring key reactor system parameters for diagnosing unscheduled reactor trips. The parameters monitored on chart recorders which can be used to review the cause of reactor trips are listed in Table 3.2-1. These strip chart recorders () provide an indication of the changes in major plant process variables that cither initiate a trip or change due to a trip. Whenever an- RPS sensor trips, it lights a printed red annunciator window, common to all the channels for that variable, on the reactor control panel in the Control Room to indicate the out-of-limit variable. Each trip system lights a red window indicating the trip system which has tripped. The actuation of an annunciator also sounds a buzzer or a horn to alert the operator. The annunciator window lights latch in until manually reset; reset is not possible until the condition causing the trip has been cleared. In addition to information provided by the annunciator, the operators may, prior to a scram reset, identify the physical positions of RPS relays. This will identify the individual sensor that tripped in a group of sensors monitoring the same variable. l To supplement the information provided by these plant systems, a General Electric Model 4020 plant process computer provides a , monitoring function in the event of a reactor trip. A detailed description of the plant process computer is provided in Section VII-16, Plant Process Computer, of the CNS . Updated l Safety Analysis Report. ((~)S _ The computer provided with Cooper has-a sequence annunciation program which will indicate the sequence in which events such 3-9
l as scram, APRM trip initiation, pressure scram initiation, (~} i s/ etc., occur. This program also indicates when the scram setpoint is cleared. This will provide information on how long a scram condition exists and thus provide some measure of the energy added during a transient. Thus, computer information normally will be available for analyzing scrams; however, if the computer information should not be available foi any scram analysis, Technical Specification 1.1.C will be relied on to determine if a Safety Limit has been violated. When a reactor trip occurs, the system monitors 114 Sequence Of Event (SOE) points at 1/60 of a second interval. Table 3.2-2 provides a list of the parameter monitoring messages for the SOE points. The table also provides the data point ID number, normal print message, and alarm print message. Events are recorded in chronological order except that events occurring within two milliseconds of each other are treated as having occurred simultaneously. SOE logging is initiated at the time the trip occurs and continues until the event is reset or the event log is filled. In addition to the SOE data, the process computer system provides pre- and post-trip data for 53 analog process variables. The 13 parameters listed in Table 3.2-3 are monitored at five-second intervals and readings are available for five minutes before the trip to 30 minutes after the trip. ()'~ The remaining 40 analog process variables listed in Table 3.2-4 are monitored at 30-second intervals and are available for five minutes before the trip to two hours after the trip. All of the equipment used in the post-trip review are supplied by both off-site and on-site power sources via a non-interruptible, no break supply utilizing the CNS battery system. 3.2.2 Data Format Output and Retention The chart recorder output is displayed on standard format recording paper indicating the time and the parameter values. The computer output for the sequence of event log, five-second a-d 30-second post-trip review logs are on standard computer
; >er. Exhibit 3.2-1 shows the output of the sequence of esents log for an actual reactor trip. Entries from the sequence of events are indented to distinguish them from the normal alarm printout. The data entry indicates the time of the event, the computer cycle (1-60) at that time, the data point ID number, parameter message, and the status. In the case where two different parameters change status within a single computer cycle and thus are not distinguishable by the system, an asterisk is printed before the SEQ notation.
Exhibits 3.2-2 and 3.2-3 show the five- and 30-second post-trip logs, respectively. Time is indicated in the left-hand column g) and the variables are listed under their data point ID number. (./ 3-10
a-Data records are maintained in accordance with Technical A Specifications and CNS Quality Assurance Instruction QAI-7, , U Quality Records, Retention, Storage, and Disposition which is based on ANSI N45.2.9-74. Normal plant operation charts and alarm typer output are retained for a five year period. SORC meeting minutes, scram reports, and the data used in the post-trip review are retained for the life af the plant. (See Section 3.1.) 1 3.2.3 Other Data and Information Used in Post-Trip Review In addition to the information described in Sections 3.2.1 and 3.2.2, the plant personnel have access to the information provided by direct reading indicators in the Control Room and other areas of the plant that could provide additional indications of plant parameters that may have caused the scram. The alarm typer output of digital and analog process points prior to the five-minute post-trip log data provides additional information. Also, the plant personnel have access to the information on past scrams that have occurred at the station and the CNS Updated Safety Analysis Report, Technical Specifications, and other plant documentation to allow them to identify the cause of the reactor trip. 3.2.4 Proposed Changes The District is currently in the process of upgrading.the plant process computer system as part of a Plant Management Information System (PMIS). The PMIS will incorporate the Safety Parameter Display System (SPDS) requirements of NUREG-0737, Supplement 1. In addition, the PMIS will have an improved capability for event data' collection. As identified in our letter of April 15, 1983, to Mr. D. G. Eisenhut and updates thereto (enclosed in Appendix A), the District intends to submit to the NRC the documentation necessary for a pre-implementation review of the PMIS by March 1, 1984. As part of the proposed actions discussed in Section 3.1, the District will be changing its post-trip review and reporting procedures. These actions may require modifications to our existing data retention procedures and'the content of the scram reports. Also, as part of the proposed actions discussed in Section 3.1, we will be reviewing the training raquirements for personnel involved in post-accident review. O l 3-11
)1 1 HOCmC' G. L O ELE E
V NAR I l BV US RPO UOL TTC S EE TR E VR L SU l ASU RS IS VO F % lLL BOC u ER 0 E R R NP 3 I U T BE TS I NA RG OF UA C TT S
$ I R
[ C N H s I G C LD E NNI P T M OI R AIA I R R I O IWN S U I E T L UI T M E R T0 S H DN N1 5 ENP NOA OI AI M M M EH H C ING I T LH I N MN I WU SR A0 El EN Ti 0I SA I 0 ND M I A A E G R M R R C AEH CH TG SWH AI OEL I ME MuV A tE R CV 0L W HP S LO CU EL TT $L EE I WR 5A VV I ES T l RE D OL ON TR M I CE AT EA "H RW G NN OIP R R R I D H O T ' T I UIT e ENt i NOl L M g p N H H C L T G i NI E lsU H I $F l E EE 8 R DR u R ts ON MI i E R cP L A U _ N A M H CM T IW T S O E DS H OMI N O 2 6IwN
4 -Table 3.2-1 Parameters Monitored On Chart Recorders i Reactor Pressure Main Steam Flowrate Main Feedwater Flowrate Recirculation Flowrate Reactor Water Level Reactor Water Temperature Main Feedwater Temperature Reactor Power (Average Power Range Monitor) Reactor Power (Intermediate Range Monitor)
- Reactor Power (Source Range Monitor)
O i l l () 1 h i 3-13
.,_... - . _ _ ;...-. ..a,_._..
l TABLE 3.2-2 SEQUENCE OF EVENT POINTS Normal Alarm Point ID Parameter Message Print Print D500 DISCH VOL LVL SOUTH Al RSET TRIP D501 DISCH VOL LVL SOUTH B1 RSET TRIP 1 D502 DISCH V0L LVL SOUTH A2 RSET TRIP l D503 DISCH VOL LVL SOUTH B2 RSET TRIP H D504 MAIN STEAM LINE CHNL Al NRML TRIP D505 MAIN STEAM LINE CHNL B1 NRML TRIP D506 MAIN STEAM LINE CHNL A2 NRML TRIP D507 MAIN STEAM LINE CHNL B2 NRML TRIP D508 CONTMT HIGH PRESS CH Al NRML TRIP D509 CONTMT HIGH PRESS CH B1 NRML TRIP D510 iCONTMT HIGH PRESS CH A2 NRML TRIP D511 CONTMT HIGH PRESS CH B2 NRML TRIP D512 REACTOR CHNL Al HI PRESS NRML TRIP D513 REACTOR CHNL B1 HI PRESS NRML TRIP , D514 REACTOR CHNL A2 HI PRESS NPML TRIP D515 REACTOR CHNL B2 HI PRESS NRML TRIP D516 REACTOR LO WTR LVL CH Al NRML TRIP D517 REACTOR LO WTR LVL CH B1 NRML TRIP D518 REACTOR LO WTR LVL CH A2 NRML TRIP O D519 D520 REACTOR LO WTR LVL CH B2 MSL Al HIGH RADIATION NRML RSET TRIP TRIP D521 MSL B1 HIGH RADIATION RSET TRIP D522 MSL A2 HIGH RADIATION RSET TRIP D523 MSL B2 HIGH RADIATION RSET TRIP D524 NEUT MON SYSTEM CHNL Al RSET TRIP D525 NEUT MON SYSTEM CHNL B1 RSET TRIP D526 NEUT MON SYSTEM CHNL A2 RSET TRIP D527 NEUT. MON SYSTEM CHNL B2 RSET TRIP D528 MANUAL SCRAM CHANNEL A RSET TP.IP D529 MANUAL SCRAM CHANNEL B RSET' TRIP D530 REACTOR SCRAM CHANNEL A RSET TRIP D531 REACTOR SCRAM CHANNEL B RSET TRIP D532 TSV FAST CLOSURE CHNL Al RSET TRIP D533 TSV FAST CLOSURE CHNL B1 RSET TRIP D534 .TSV FAST CLOSURE CHNL'A2 ~RSET TRIP D535 TSV FAST CLOSURE CHNL B2 RSET TRIP D536 TCV FAST CLOSURE CHNL Al RSET TRIP D537 TCV FAST CLOSURE CHNL B1 RSET 'TRIPJ D538 TCV FAST CLOSURE CHNL A2 RSET TRIP' D539 TCV FAST CLOSURE CHNL B2 RSET- TRIP-D540 APRM CHNL A~ UPSCALE LVL RSET : TRIP-D541 APRM CHNL B UPSCALE LVL RSET TRIP D542 APRM CHNL C UPSCALE LVL RSET TRIP D543 APRM CHNL D UPSCALE LVL RSET TRIP D544 APRM CHNL E UPSCALE LVL RSET TRIP-O, D545 APRM CHNL F UPSCALE LVL RSET TRIP D546 IRM CHNL A UPSCALE LVL ' RSET- TRIP 3-14
I Normal Alarm Point ID Parameter Message Print Print D547 IRM CHNL B UPSCALE LVL RSET TRIP D548 IRM CHNL C UPSCALE LVL RSET TRIP D549 IRM CHNL D UPSCALE LVL RSET TRIP ' D550 IRM CHNL E UPSCALE LVL RSET TRIP D551 IRM CHNL F UPSCALE LVL RSET TRIP D552 IRM CHNL G UPSCALE LVL RSET TRIP D553 IRM CHNL H UPSCALE LVL RSET TRIP D554 GRP 1 ISOL CHNL A RSET TRIP D555 GRP 1 ISOL CHNL B RSET TRIP D556 MN STM RELIEF VALVE 71A CLSD OPEN D557 MN STM RELIEF VALVE 71B CLSD OPEN
- D558 MN STM RELIEF VALVE 71C CLSD' OPEN D559 MN STM RELIEF VALVE 71D CLSD OPEN D560 MN STM RELIEF VALVE 71E 'CLSD OPEN D561 MN STM RELIFF VALVE 71F CLSD OPEN D562 MN STM RELIEF VALVE 71G CLSD OPEN D563 MN STM RELIEF VALVE 71H CLSD OPEN D564 DISCH VOL LVL NORTH Al RSET TRIP D565 DISCH VOL LVL NORTH B1 RSET TRIP D566 DISCH VOL LVL NORTH A2 RSET TRIP D567 DISCH VOL LVL NORTH B2 RSET TRIP D600 EXHST 1A TEMP ABOVE 250 NRML ALRM D601 EXHST 1B TEMP ABOVE 250 NRML- ALRM D602 CONDENSER VACUUM TRIP RSET TRIP D603 TURBINE BRG OIL PRESSURE RSET TRIP i D604 TG THRUST BRG PRESSURE RSET TRIP D605 TG OVER SPEED RSET TRIP.
D606 AUTO STOP TRIP SOLENOID RSET. TRIP D607 ER RESEV LEVEL LOCK 0UT NRML LKOT D608 AUTO STOP OIL LOW PRESS LRML LKOT D609 TURB GEN MOTORING NRML ALRM D610 ACB 3310 TRIPPED CONTACTS RSET TRIP i D611 GEN-345KV LINE OVRALL DF NRML TRIP-I D612 ACB 3312 TRIPPED CONTACTS RSET TRIP D613 REAC FEED PUMP VIBRATION NRML ALRM' D614 MN GEN LOSS OF FIELD NRML . TRIP D615 TRIP CIRCUIT SUPERVISION NRML ALRM j D616 TURBINE MANUAL TRIP RSET TRIP D617 RFP TURBINE 1A ~RSET TRIP D618 RFP TURBINE IB RSET TRIP D619 MN GEN OVER EXITATION DF NRML TRIP l D620 MN GEN DIFFENTIAL NRML TRIP' D621 MN GEN GROUND NRML- TRIP D622 CLASS-I SER WTR ISOLATION CLSD OPEN D623 EMERG GEN BKR EG1 RSET TRIP D624 EMERG GEN BKR ED2 RSET TRIP D625 -VACUUM RELIEF TO TORUS NRML TRIP D626 VACUUM RELIEF TO TORUS NRML TRIP D627 STRTUP XFRMR NEUT CURNT NRML TRIP p D628 MAIN GEN NEG SEQ RELAY RSET . TRIP V D629 MAIN GEN VOLTAGE REGTOR- RSET ' TRIP j D630 NORM SERV XFMR SUD GAS P NRML TRIP i 3-15
-~ . _ . _ _ _ _ - -, _
Normal Alarm Point ID Parameter Message Print Print D631 MAIN XFRMR SUDDEN GAS PR NRML TRIP D632 MAIN XFRMR NEUT CURRENT NRML TRIP D633 NORM XFMR SEG Y LO VOLT OK ALRM D635 STA SRV XFMR 1B PR HI-LO NRML ALRM D636 STA SRV XFMR 1A PR HI-LOW NRML ALRM D637 TG ROTOR VIBRATION NRML ALRM D638 STA SRV XFMR IG PR HI-LO NRML ALRM D639 4160 BUS 1F UNDERVOLTAGE OK ALRM D640 4160 BUS IG UNDERVOLTAGE OK ALRM D641 MOTOR GENERATOR SET 1A HRML LKOT D642 MOTOR GENERATOR SET 1B NRML LKOT D643 MN STM BYPASS VAINE 1A NRML OPEN D644 MN STM BYPASS VALVE IB NRML OPEN D645 MN STM BYPASS VALVE 1C NRML OPEN O O - 3-16
TABLE 3.2-3 () FIVE-SECOND POST-TRIP LOG Point ID Parameters Units i B000 APRM "A" Flux Level % Power B002 APRM "C" Flux Level % Power B012 Reactor Total Core Flow MLBH B015 Reactor FW Loop A Flow MLBH B016 Reactor FW Loop B Flow MLB11 B022 Total Steam Flow MLBH B013 Reactor Core Pressure Differential PSID B021 Reactor Water Level Inches B025 Reactor Pressure PSI B026 Reactor Recire. Loop A Flow MLBH () B028 Reactor Recire. Loop B Flow MLBH B034 Reactor Recirc. Loop A Inlet Temp. Degree F B036 Reactor Recire. Loop B Inlet Temp. Degree F
- o 3-17
TABLE 3.2-4 THIRTY-SECOND POST-TRIP LOG Point ID Parameters Units T139 MS Safety Valve "A" Temperature Degree F T140 MS Safety Valve "B" Temperature Degree F T141 MS Safety Valve "C" Temperature Degree F T142 MS Safety Valve "A" Temperature Degree F T143 MS Safety Valve "B" Temperature Degree F T144 MS Safety Valve "C" Temperature Degree F T145 MS Safety Valve "D" Temperature Degree F T146 MS Safety Valve "E" Temperature Degree F T147 MS Safety Valve "F" Temperature Degree F T148 MS Safety Valve "G" Temperature Degree F T149 MS Safety Valve "H" Temperature Degree F F000 Main Condensate Flow MLBH F007 Condensate Booster Pump Disch. Hdr. PSIG F008 Condensate Pump Disch. Hdr. PSIG F010 Condenser Hotwell Level 1A FT F011 Condenser Hotwell Level IB FT F034 RFP Discharge Temperature Degree F E005 Startup Transformer Cross () E008 E009 Emergency Transformer Load Normal Station Service Transformer MW MW MW T003 Main TG Vibration Bearing 1 MILS T004 Main TG Vibration Bearing 2 MILS T005 Main TG Vibration Bearing 3 MILS T006 Main TG Vibration Bearing 4 MILS T007 Main TG Vibration Bearing 5 MILS T008 Main TG Vibration Bearing 6 MILS C004 Main TG Vibration Bearing 7 MILS G005 Main TG Vibration Bearing 8 MILS C006 Main TG Vibration Exciter Bearing MILS T009 Condenser Vacuum 1A INHG T010 Condenser Vacuum IB INHG C038 Torus Pressure PSIG C039 Drywell Pressure PSIG T113 Drywell Zone 2A AZO _ Degree F i T114 Drywell Zone 2A AZ120 Degree F T115 Drywell Zone 2A AZ240 Degree F T020 Main IG Bearing Oil PSIG T022 Main TG EH Fluid PSIC l ~ ("')8
%, B021 Reactor Water Level Inches B025 Reactor Pressure PSI l
l 3-18 i
-* aice-35-32 EXbIBIT 3.2-1 0E2n45 f.0PM Ft27 CONDENErlF CONTC1IVil) !:nt. f dG 0iG ROD 34-23 la l' O O 00:059 HUD 2t-15 in 10 ts OF3106 (T)kg r021 FXCITrR COLD Ain TTAP FO'C al 0e3122 000 34-29 -e [0 ;0
. ;01 / L 4 r' ? / UPef fit t .! Jum .h:l l f i .i f t i.
' 0 3N Lor: c( 2 7 Fxcllth COL!; A I .h Ir.p g .7 ec
,082345 f!ORM F527 CO'lDE!!E A1E CotJDOCT IVITY llWL
(--05 Ci 23 LI C 3629 L Ai.0/L :3Ch t ' Chef.tHL h IkiP Od 2 -A J, % :.F0D62>SANU/b:n.sJ ait t.Ni f. A 11 1 ?
>0r2508 /LF 1526 APPk rm DECALE ALARJ A til Ur?aua ROD 2e.-15NO DAi/ AT LFA!T I i!01C11 Or250H /LM /' 42 000 0U1 HLOCK ON Of250d ALL M.to ROD l'RIFl ALAku ON 063511 ROD 26-15 8 TO O
(,>$251 o 6 tio 0644 A i: M M inpa!! sptvr 10 raw L 0129 t e. 16 SEO De43 kN b1M it)P At t V/LVE lA f!fi'A L
- t;f M.
08751 e. 24 Src D6 A5 1.N SIM in P 4 f t t # LV F IC 2510 LHL fl 00 APRF A FLU X LUVE!. T Prik I NCit 21 P
! OP2522 LOW F021 REACTOR WATER LEVEL l0F352) /LP Ft39 dhu EnrH IF MCC IK HKR TRIP tot 43527 LRL 6002 APRM C FLUX LEVEL % PWiv* m
'Of3528 /!.y E521 DISCH 40L ROD RLK 'l0DTit ON Oe2528 NORM Et29 480 SWGR IF MCC IK RKR RSET T M
012529 6 5E0 0567 DISCit VOL LVL I:0 RIH B2 IRIP 033529 6 SEO D567 DISCH VOL Lvl NORTit H2 RSET Da2529 7 SFO D567 DISCH VOL LVL NORTH R2 TRIP l ( 093529 7 SEO D567 DISCH VOL Lvt tiORTH B2 Hi l:T f 093529 7 SEO D567 DISCH VOL LVL I40RTH it? TRIP
.1
~ 04?529' ~ ~ T SFO'D567 ~DISCH VOL LVL NORTH b2 REFT 09?529 7 S_O F 05e7 DISCit VOL LVL t!ORTO H2 TRIP 4
!, 082529 7 5F0 053I REACTOR SCRAF CilAI'NEL F THIP
~ 083520" 9 -~SEO~ D5?O RE AC10R SCR A L CHAtilEL / IPIP
. 0:13329 11 SFO 05c6 DISCO VOL LVL t;0RI'It A2 fi< ! P
- I 062533 7 SEO D503 D!bCri VOL LVL LOU 1H B2 TRIP
~~,'~~~
0875?I' 16 Si O 'D502~ DISCH VOL 1.VL SOUTH A2 TRIP
._. _0d2535 _ 54_ pE0 D9eb DISCH VOL Lvl NokTH ril InlP Od3535 54 SEO D5c5 DISctl VOL Lil IIORTil bl RSET
^ - ' r.3 ? 5 5 5 ' ' 5 4~ 5EG D565'DISat VOL Lvl NORT!1 al TRIP O O O
ua32JO FivE seco:o P.u r ru!P Lod EXHIBIT 2-2 T I Mt: 3000 3302 3012 ILJid ualo 802.2 3u13 U j21 im >5 s e "> h.vi t ) .14 boJi O O Or$3J32 14 16 22.54 0.00 0.34 0.0a 1.3 J> +>2 3.1 1.1 425 5J4 OdJ0J1 14 16 22./9 0.00 0.38 0.04 l . .I 3D nl 3.9 J.9 723 521
- Oc3042 13 16 22.59 0.00 0 . 13 0.04 1.3 J5 951 J.4 .i . :1 9 2') 528 a OdJ04/ IJ l6 22.00 0.00 0.29 0.04 1.J J5 r>J 3.9 3.b ,26 523 033052 13 16 22.40 0.00 0.32 0.03 1.J 35 951 J.3 J.H 5J6 525 083057 13 16 22.51 0.00 0.31' O.04 1.3 35 952 3.4 3.8 526 525 0d3802 13 16 22.35 0.00 0.32 0.08 1.3 35 V51 J.4 J.a iP6 525
'00310/ 13 16 22.50 0.00 0.38 0.04 1.3 35 vi2 J.4 J.9 526 525 033112 13 16 ~22.12 0.00~ 0 .31 - 0.03 1.3 35 952 1.4 3. ts 626 525 06311/ 13 16 22.63 0.00 0.30 0.03 1.3 35 952 J.4 3. ts s2o 525 i 093122 13 16 22.62 0.00 0.29 0.04 1.J .55 962 3.4 3. t3 925 525 526 0U3121 13 ~I6 '22. 13 ~0.00 O'31~' 0.03 1.3 35 952 3.5 3.8 525' ~
i
. Or13132 13 16 22.52 0.00 O 2/ 0.03 1.3 35 962 3.5 3.8 529 525 00J13/ 13 16 22.6a 0.00 0.28 0.04 1.3 35 951 J.5 J.8 526 525
( JOS3142 13 16 ' 22 .~70 ~ 0~.00 0~.28- D.'02 1.3 35 952 3.4 3.8 526 525 S I
- 00314/ IJ 16 22.65 0.00, 0.26 0.02 .l.3 J5 952 3.5 3.6 5326 525 _
, 083152 IJ 16 22.00 0.00 0.2p 0.03 1.3 J$ 952 3.5 3.6 526 525
'003157 13 16~ 22. 7 7 ~ ^ ~0. 00 ' ~ 0'.29 ~ 0.~02 ~l.3 35 952 3.4' 3.8 527 525' i
Od3202 63 15 22.t14 0.00 0.29 0.03 1.3 J5 952 3.4 3.H 52/ 525 _ i 033201 13 IS 22./5 0.00 0.29 0.03 1.3 35 952 3.5 3.8 526 525
'083212 13 15 ~22.72 ~ 0.00 0.29 - ~ ~0. 02 I.3 35 951 3.4 3.8 526 525 ~-
t 06321/ 13 .. _15 22.66 0. 00 0.26 0.02 1.J 35 938 J.4 3.H 62/ 525 - - - - - , 1083222 13 15 22.42 0.00 0.24 0.03 1.3 35 951 3.4 3.8 52f 526 J083227 13 15" 22.59 "~~0.00 0.26 ~ "O.03 - I.3 35 951 3.4 3.8 527 526~ , t Ot13232 12 15 22.49 _ 0.00 0.26 _0.02 1.3 35 961 3.4 3.H 52/ 526 - 0d323/ 12 IS 22.56 0.00 0.26 0.02 1.3 J5 941 J.4 3.0 52/ 526 3.8
' ' ' ~ .083242 12 15 22.61- 'O.00 O'.~26 " 0.01 I.3 35 951 3.4 527 ' 52f 06J24 / 12 15 22.61 0.00 0.29 _ 0.02 1.3 35 951 3.5 3.8 621 5R6 i
063252 12 15 22.66 0.00 0.26 0.03 1.3 35 951 3.5 3.8 521 52$ 083251 12 15 ~ 22.6 3 ~ O'.00' '- 0.~28 -- 0.~01 1.3 34 951 3.4 ~ ~ 3. 9 521 526 O O e - - - - - -
l s EXHIBIT 3.2-3 u4-3/J 5 Ol e-2' 3':5537 11!!iGY .J CmD ibot TRIP ltC f e c.v e 11 hLa LLLs t~ Tr f Tils' T14G T141 Ti r.2 TIG laL4 TILL l i hr. 11t7 T18.? TIu F LL , FLc7 6 L31
^
TLL) l'a u4 tom Two6 TvG7 Tur uoLL u t6 TL U '. M' (1 1 uh T.1; Tilt lib T ;. Tv2. wii s. u 4 nu 177C uo3ML2h 1,
. .i 2 l m
l ob s '.2 luk 1L1 164 190 176 ILS 157 171 iLi 172 ;"5 1.s L 7 *. Is' 7.3 -.? LL L.C u.Ju u s.v J J/J.0 - 1.0%9uu.uuu999.uust a .ttsuu%.0 0.9 L.u m .c .'.4 2L.2 0..? 0 . c .' .t. ! . 7 '. Lb 23.1 t'. 7 4 b a toc M
- l sblu IL) ul 104 1% 17G ILL 157 171 ALA 17u m ;, o L 7:, LL 7.3 t. 7 LL u,e ,, . J s u . s . .
.aus.a A.L%99a.GWuw .0La uu.uw as.u D.L u. m m .o 2L.3 .L.3 s.vi L.o2 ILL . 7L n,L ;3.2 .613 a 4.
oc3144 lu} ALi 164 lub 1/u lb5 157 17. lui 17s JL ..a L75 13; ..s ..I L w.L . sssss.- sssas.G 1.ssauss.L;asaa.Lusaa. 0suss9.. u.o w.sssukt.. ;L., 'L.s
. ..u. ... lov .74 11. i;.L .7a4 ; _..
..:s;1; lo) 16. IL4 lub 17L 1La 157 171 lui 175 IT; ..; ' 7. 133 7.s o./ -> -L.0 -. sas...-
usu.L 1.%;9% CL9%L 39/AA.Cwns.0 L.b C .%%L J . J 25. .e 2L . f. u." w.s2 ILL l i'. 14 23.5 1912 s5 4. . 2.3i4; IL3 ILI ILt. 195 17L 1r5 157 171 101 17s IM 2.; L7r 15 7.2 .7 a o.3 o.uom. u n i .5 1.0%%t .09%% .09'tht .P%9% .C I: .0 L .f t%'JL . , 2 T . ', ?T.1 o.' 9.J2 If f l'. - 1% ?!.3 1%3 Z ., W a'a ilz 163 101 IL4 195 170 105 157 17C ILI 179 1r.5 1.9 57C 134 7.3 L./ L5 w.0 -.v.ss. .. 1.Gu9%9.r,%%L.0%%t.0S%5f. 0 7t.3 20.3 C.U2 U .L"' ILC 17 t. 150 22.9 1777 % u; 3uw9.0 0.E G.L%%9.L o _ JJ3342 103 ILI IGr. 155 176 ILG 157 171 IL1 179 1l5 3.3 5 7'. 13! 7.3 L.7 f f. -0.0 c.h nto tsfia.0 U.'#t;9% .0W9% .099S99.059599.0 0.L ,0.LW'fts.u 2f: .3 20.3 0.U? J.02 luf. 174 4% 2. 7 1%1 34 al N n .2M12 163 ILI 164 195 170 105 157 170 101 170 If.5 2.k L72 133 7 . :. L.7 E4 -L.0 . .J osa .o a 9Wau.0 1.099%S .0%WS .CWW9.0Wt % .C L.. 0.09%ub.u 2 0 . t. 2L.k 0.C2 J.L2 1L5 174 A5b 3.2 ILCL % 0. wEi442 ilk lul 164 195 176 106 157 171 101 179 ILL 2.L ',7 7 34 7.s o./ L t. -c.c o.ous..
.. sasuu.0 u.9993a9.0999su.099995.CuS999.0 u.7 0.09993).. 25.4 20.i L.L2 L.e2 ILS 47L isb 43.G 1017 s4 sLA
*1 Os12 192 4u1 lu4 1% 17b ILG ILC 171 ILI 179 105 2 . t. 575 134 7.) u7 e,4 v.0 . . J m u .o J.usJww.0t#JW.0JsJun.uawau.G u.7 u.twsw.. 25.4 20.3 0. 2 v.s2 ILS 17L Iso 13.b zus0 s4 a,a i, , _ uns).d
.E s:,42 Au3 ibt Ib4 In 1/b ibb 158 170 lui 179 IL5 L.1 M2 4;l 7.1 ../ L4 v.a u .au nu .u n assu.u u.uasus.0'#ItJu.09wua.09tnu.0 u.7 L.L9suw.u 2 0. f. 20.% u.v2 w uz 1L5 174 ILL ;3.4 ILLA .v o3 Eiu14 Auk ib1 164 195 176 lb6 15E 170 lb1 179 ILL 3.2 %3 13L 7.i L./ EL u.0 - .0sa ru . u
. nun.D u.uu/ sus.09W39.UWW9.Uvuw9.0 'u . 7 u 7Wuuu.u 20.ie 21.= u.02 u.02 ILL 474 Lb 23.4 1025 %%s sJu v33v42 Au3 lui ib4 1% 17b 1G5 15E 170 1G1 17J ISL 3.u %5 133 7.2 w.o 54 -u.1 o.Jn n s.0 a suasu.0 u.999999.0593u9.05us99.093990.0 0.7 u.739999.u 26.4 2t.4 0.62 u.02 ILG 174 ILG 22.9 1576 uutus L74 J U112 103 161 163 l';5 17f, ILG 157 171 101 179 105 2.5 %4 1!5 7.e L.b E3 L.0 v.Gru n. u i muus).G u.b99999.0L9999.0999)9.099999.0 0.7 0.799995.0 28.4 2;.4 U.c2 0.u? 100 174 156 22.9 151E Sui)u e4L cLi742 103 IL1 163 195 170 105 15E 171 101 17S 105 2.3 %1 135 7.2 L.G UI -c.C v . an a . L
- 9t/J9.b d.Su9999.099999.099999.099999.0 0.7 0.795999.0 2S.4 20.4 0.02 u.07 10C 174 157 22.9 1792 99sss Lis i
685h12 lb2 lul 163 195 176 155 158 171 101 179 105 7.C LEI lb '/ . i L.G .3 v.0 u . ;,9wn . L
. 99993.0 0.999999.099999.099999.059999.0 0.7 0.799999.b 28.4 2F.4 0.02 0.02 ILG 174 15G 23.4 1939 Suss9 LJ/ ,. uS3T.42 lb2 161 lb3 1% 17L 165 150 171 101 179 185 1.9 %1 134 7.3 L.6 b3 u.0 w.LW 43.u ,
9b999.0 b.999999.039995.099995.099999.0 L.7 L.7999ub.J 2E.5 2t.4 u.02 0.02 IGG 173 l' sb 23.0 isle bdubu ou4 O O O
_ _ _ . . . . . ~ 3.3 Action 2.1, Equipment Classification and Vendor Interface (Reactor Trip System Components) 3.3.1 Reactor Trip System Components This section should be reviewed in conjunction with Section 3.4 l which provides general information on the procedures, documents, and computerized information handling system at CNS which control maintenance and parts procurement activities.
. The activities performed and controlled under these procedures apply to all essential system and components including those in
, the " Reactor Trip System." i ' The Cooper Nuclear Station Updated Safety Analysis Report in Section VII-2, Reactor Protection Systems, and Section III-5, Control Rod Drive Mechanical Design, provides detailed
, information on the two principal systems, RPS and CRD, which ; compose the "Recctor Trip System" for CNS.
A general review of the CNS computerized Equipment Data File (EDF)* is underway to verify the correct classification (essential or non-essential) of Reactor Protection System (RPS), and Control Rod Drive System (CRD) equipment. The Equipment Spare Part Inventory (ESPI)* data for the RPS and CRD system was also reviewed to determine the consistency 2 between this file and the EDF. .In general, the classification of spare parts was consistent with the - overall component classification. In certain instances, differences in the files were noted due primarily to the non-essential nature of certain piece parts and convenience of procuring essential parts for both essential and non-essential components. Finally, a review of previous Maintenance Work Request (MWR) information listed in the computerized Equipment ' History File (EHF)* was performed for the RPS and CRD maintenance activities
- occurring during the past three years. Selected MWRs were a retrieved from document storage and were reviewed to determine j
the adequacy of the work performed.. For the MWRs reviewed, the j work performed, including work approval and performance post-maintenance functional testing, had been completed l properly. 3.3.2 Vendor Interfaces General Electric is the principal vendor for the Cooper' Nuclear Station, CRD, and RPS~ systems and components. The majority of l The computerized Equipment Data File (EDF).-Equipment History File (EHF), and Equipment Spare Parts Inventory '(ESPI) are subsystems of the CNS ( ._ computerized Plant Equipment Management (PEM) system which is described-in Section 3.-4.2.. 3-22.
-. - z-
spare parts and material procurements for these systems' equipment are purchased from General Electric. This procurement method , O assures that both NPPD and GE controls on those spare parts apply to the procurement of spare parts for these systems. A description of this vendor information program will be provided as an output of the BWROC generic program. 3.3.3 Proposed Actions . The EDF, ESPI, and other subsystems of.the plant's computerized PEM, described in Section 3.4, are used as an integral part of the procedures and activities associated with surveillance, maintenance, and procurement of replacement parts and equipment. The proposed actions described in Section 3.4.5, for a review of the PEM and component classification, may indicate that modifications or enhancements of the PEM and classification system are necessary. In addition, GE, under guidance from the BWROG, is developing additional information related to the classification of components and vendor interfaces. The District will incorporate this information, as appropriate, into future actions. 3.4 Action 2.2, Equipment Classification and Vendor Interface (Programs for All Safety-Related Components) 3.4.! Safety Classification Response i Table 3.4-1 is Table 1, Quality Assurance Program for Operation from Appendix D of the CNS- Updated Safety Analysis Report. This table is the listing of Safety-Related (Essential) Systems covered by the District's Quality Assurance Program. This system level classification is the reference QA document which is presently used to identify safety-related systems.. The j classification is further refined to a component level classification in the CNS computerized Equipment Data File (EDF). The EDF is presently used as a guide to assist station l persennel in their identification- and' performance of safety-related activities. The EDF is the responsibility of - the CNS Plant. Engineering Department. The generalized criteria used to classify components within essential systems follows the guidance -established by Quality Assurance Instruction QAI-9, Guidelines for Establishing Quality Classifications of Components and Materials. These guidelines-are restated as part of CNS Administrative Procedure 1.11, Requisitioning, Receiving, Storage of - Essential ' Parts and Components. These procedures and other data sources were used to develop the existing EDF listing maintained at-CNS. O 3 _ . . ~ . _ - _ _ . . _ . _ _ , _. _ . _ - _ __. _ __
~ -. . .= _. - -- . - . . - __.- - -
- w ;
i
's D)
To . the maximum extent practicable, system . and equipment classifications established during engineering and construction O have been retained and further refined'as necessary.within the [' EDF. Where new regulatory requirements ' or design changes impact such classifications, such changes are considered design changes and are controlled ;un' der CNS Administrative Procedure 1.13, Station Design Changes. The design changes
- performed under this' procedure assure design conformance with applicable codes, standards, and regulatory requirements. The controls identified in this procedure apply not only. to engineering considerations, but also to maintenance, repairs, l and delineation of acceptance criteria for inspection and testing. The classification of new equipment developed as part I
of these design changes are incorporated as appropriate into the EDF equipment file. '_ y 3.4.2 Plant Equipment Management System * ' j The computerized EDF is one element oI the CNS computerized Plant Equipment Management (PEM) system. The PEM system " presently resides on a Zytron data base computer located at ! CNS. Upgrading of this computer to a Prim 3 650 is currently being planned. N The PEM System is a set of computer controlled subsystems that assist plant personnel in the operation and maintenance of plant equipment and procurement of spare parts at Cooper j , Station. Presently incorporated and functioning as part of the PEM System are the following subsystems: Equipment Data File (EDF) Work Item Tracking (WIT) Equipment Spare Parts Inventory (ESPI) Purchase Order Tracking (POT) D- < i Originally conceived as part of PEM and presently under i dsvelopment is an Equipment Spare Pcrts List--(ESPL) Subsystem.
- The EDF.is designed to contaJn records'on all plant components i and is, used as the central data base , for 5 component .
I classification in the PEM system. Selected data in;the EDF
' file is accessible and is used by other subsystems of PEM. The.
i data fields which presently exist in the EDF'are identified in Table 3.4.2. The " Component ID' Code.(CIC)" field isfa' unique component zidentifier consisting of a plant : system, code, a. component . identification code, and an identifier for = the - individual equipment' item within'the. system,ie.g., RHR-MOT lA. ,.' N
- The " Description"' field provides general information on - the. >b I
component's use within the system. The " Class" field provides Y f ( an identification of. . the - essential -(safety-related) orb 1 ~ non-essential classification of the component.. Certain -' N subclassifications are used to clarify thel nature of the u essential classification. These classifications are used as a' ^ O guide _intheidentificationofmaintenanceactivities~andthed m.[
.3-24 . . .
y n;" j- ,
- . . ,, . . . . - . - - . -,. , .-.-:-., n. -..,,,-- - . , - , ~ ..
procurement of spare parts. The other fields provide O' generalized information pertinent to the particular component which assist plant personnel in the performance of maint.enance and other activities. The WIT subsystem of PEM provides the ability to schedule and track corrective and preventive maintenance. The system also provides the capability to store and retrieve selected historic information on the maintenance activities performed to date on various components.- In addition, the WIT subsystem automatically prints the forms, including the Maintenance Work Request (MWR), used to control maintenance activities at CNS.
! The EDF.and WIT subsystems are incorporated as an' integral part of the CNS Work Item Tracking (WIT) Maintenance Program. 'The WIT Maintenance Program is used to identify and control work items at the station that require repair or resolution and is the mechanism to enforce tlsir orderly accomplishment.
The WIT Maintenance Program is controlled by the following CNS t procedures: CNS Procedure 1.7.1 - Work Item Tracking - Corrective Maintenance; i CNS Procedure 1.7.2 - Work Item Tracking - Preventive Maintenance;
' O
- CNS Procedure 1.7.7 - Work Item Tracking - Equipment t_ History.
These procedures contain criteria on the methods -. used to j identify, schedule, approve, perform, test, and verify these
; repair activities. %. Two primary documents are used to control maintenance activities under these procedures:
- The Work Item Tracking (WIT) form, which. identifies the type of repair work required'to be performed.
The Maintenance Work Request- (MWR) form, which controls the scheduling, approval, performance, testing, and verification of these repair. activities.
" ~
Both of-these forms are generated by the' WIT subsystem of the computerized PEM. [ In accordance with the general operating philosophy -at CNS, i diverse' reviews and ^ approvals including both' maintenance, operations, QC, and engineering .are required - prior? to the l performance of essential maintenance. Each individual within l -this process may. review, in addition to otherLaspects of'.the MWR, - the appropriate ' classification of the work to ~ be [ performed. Reference 'is made to the. EDF ' file and other I
'3-25'
p information such as the CNS Technical Specifications as part of this review process. As part of the computerized generation of
.O the MWR, the CNS Maintenance Planner and Scheduler interrogates the CNS EDF to identify the specific component classification.
., This classification or the actual work classification is prominently identified on both the WIT and MWR forms, h '
The individuals involved in this review and approval process prior to commencement of the work include:
- ;- Originator of the maintenance report Originator's supervisor Maintenance Planner and Scheduler (is a licensed RO)
CNS engineer assigned to the System
- Operations Supervisor
- Maintenance Supervisor
- Instrument and Control Supervisor
- Q.C. Inspector Shop Supervisor Shift Supervisor
~
* (not required for non-essential MWRs) 3.4.3 Parts Procurement _
Equipment and parts for CNS are typically specified and procured to numerous industrial standards which include IEEE, ISA, ASME, ANSI, ASTM, UL, NEMA, and ANS. Many of these standards were written specifically for nuclear power plant ! applications. Others define generic equipment design and ' functional performance requirements including specific testing criteria necessary to assure manufacturer's conformance to the standard's criteria. Included in the variety of tests required are various performance tests and environmental tests. In addition, NPPD's review and acceptance of manufacturers as qualified suppliers considers not only the manufacturer's quality assurance but NPPD's and the industry's collective operative experience with the manufacturer's equipment.- The use of these standards and procurement from approved vendors assures that components provided are of high quality, reliability, and performance. Supplementing these activities are the receipt inspection, construction inspection, pre-operational and operational testing which assures that each installed safety-related component's operability is verified prior to operational acceptance. These activities combined with the periodic surveillance and performance testing and post maintenance operability testing assure continued performance of each piece of installed safety-related equipment. Incorporated into these maintenance, testing, and replacement activities are manufacturers' recommendations with respect to maintenance, refurbishment, and equipment replacement. O 3-26
These measures collectively provide reasonable assurance of p safety-related equipment performance. In those rare cases
\ where design defects or production flaws are found, NPPD internal reviews supported by manufacturer, industry, or NRC information assure generic resolution of such deficiencies.
CNS Administrative Procedure 1.11, Requisitioning, Receiving, Storage of Essential Parts and Components, controls the requisitioning, receiving, inspection, storage, warehouse issue and control, and installation of essential parts and components. The Equipment Spare Parts Inventory (ESPI) and Purchase Order Tracking (POT) subsystem of the PEM are used to enter, store, and retrieve information associated with equipment spare parts and procurements. The ESPI subsystem provides a method of maintaining equipment spare parts inventory records and provide a listing of current parts inventory status. In addition, it maintains and computes information required to issue, return, reserve, and order spare parts. Essential components and spare parts are so identified in the ESPI. The POT subsystem provides a method of processing, tracking, and retrieving purchase orders from their origin to close-out. The POT subsystem also provides for automatic updating of () records on the ESPI files when spare parts are affected, Any substitution of parts or components for essential equipment is considered a design change and are processed as design changes including securing necessary approvals of the SORC and SRAB groups. All essential parts, components, and equipment received and stored at CNS must be tagged with Essential Acceptance tags. A multi-leveled review and approval process similar to that employed for MWRs is used for the procurement of components and spare parts. It is the requisitioner's responsibility to check the ESPI and EDF files to determine the classification of replacement comynnenta. The requisitioner, department supervisor, Quality Assurance Department, Maintenance Supervisor, and appropriate managers all review and/or approve essential material and part purchase orders. In addition, CNS engineering must review all vendor documents and purchase order requirements as part of receipt inspection to assure that the materials provided meet all purchase order requirements and and will perform adequately in the intended service. CNS Quality Assurance conducts periodic reviews of MWR and purchase orders to assure that the requirements of CNS procedures have been properly implemente? and that activities affecting essential equipment have been properly performed. O 3-27
These QA audits also include a review of selected non-essential O MWRs and purchase orders to verify their appropriate classification. 3.4.4 Vendor Interface Response Vendor manuals at CNS are controlled distribution documents and are presently the responsibility of the CNS Engineering Department. CNS Administrative Procedure 1.11 requires review for acceptability of all essential purchase order documentation i by the responsible CNS engineer. This review would normally include consideration of the adequacy of vendor manual information. Existing methods and procedures also control information from vendors and others which is related to plant equipment. CNS Administrative Procedure 1.26, Routing Procedure for Operating Experience Review, identifies the formal , mess that is utilized to review material originating of. - *e which may potentially effect plant activities or procedur. . The information controlled under this procedure includes NRC Office of Inspection and Enforcement (IE) bulletins, circulars, notices, NRC letters to operating plants, off-site License Event Reports (LER), Electric Power Rascarch Institute (EPRI) studies, Institute of Nuclear Power Operations (INPO)/ Nuclear Safety Analysis Center (NSAC) Significant Event Evaluation and () Information Network (SEE-IN) Reports, INP0/NSAC Significant Operating Experience Reports (SOER) , General Electric, and their other vendor information. This material normally would be sent to the CNS Division Manager of Nuclear Operations or to either the NPPD Assistant Caneral Manager-Nuclear or the NPPD Technical Staff Manager at the General Office who routes a copy to the Division Manager of Nuclear Operations. The Division Manager of Nuclear Operations at CNS, upon receipt of material with potential applicability to CNS, will determine whether the entire SORC staff and/or only certain selected Department Managers or Supervisors shall review the material and will so designate on the front page of the material. In some cases, individual copies of the material will be routed to selected Department Managers and/or Supervisors in addition to the copy routed to SORC. The Department Manager / Supervisor (s), upon receipt of the material, will then determine which individual (s) within their department shall review the material and will solicit recommendations for action as appropriate. The Department Manager / Supervisor (s) will assure that the results of the review and the resultant actions (if any) taken by their respective department (s) are indicated upon their copy of the material and that a copy documenting that review and actions taken is filed in the appropriate subject file. 3.4.5 Proposed Actions SALP, INPO, and NPPD internal audits have all verified the adequacy of the station activities associated with essential 3-28
i systems and components. Prior to the issuance of Generic
- Letter 83-28 and in response to a management audit and a
! recognized need to further improve the existing classification . j system, the District has committed to additional activities related to system and component classifications. These , activities include the completion, verification, and formal incorporation of the EDF as the reference QA classification document for CNS. The District is also continuing an evaluation of the existing 4 internal processes and controls associated with the use of l equipment classifications. At the completion of that review, the District will identify necessary procedural and process changes which will clarify existing classification methods and enhance their incorporation and use in the performance of safety-related activities. Initial program recommendations will be reviewed and a schedule for phased implementation of these modifications is estimated to be completed by July 1, 1984. Any modifications to the procedural framework surroundir.;, safety-related activities must be accomplished in a carefully controlled manner which minimizes disruptions and assures proper training and indoctrination of all associated personnel
- ' prior to final implementation. The schedule'to be proposed will incorporate appropriate consideration of these and other elements deemed necessary prior to full implementation. In addition, preference will be given to the modification of any procedures or activities which directly affect the Reactor Trip Function.
The District has participated as a member of the INP3 NUTAC
. group formed to address the vendor interface requirement of Generic Letter 83-28. The NUTAC mission is to develop a practical approach that will contribute to the safety and reliability of nuclear plants. The NUTAC is presently considering various options to meet this goal. These options include use of INPO NPRDS and SEE-IN data bases. INPO may also-serve as a clearing house for vendor information.
The District will evaluate NUTAC recommendations for incorporation into CNS procedures which concern vendor manual control. 1 0 i 1 3-29
Tcbla 3.4-1 SAFETY-RELATED (ESSENTIAL) SYSTEMS COVERED BY THE QUALITY ASSURANCE PROGRAM I. Nuclear Steam Supply System
- a. Reactor Primary Vessel
- b. Reactor Primary Vessel Supports
- c. Control Rods and Drive System equipment necessary for Scram Operation
- d. Control Rod Drive Housing
- e. Fuel Assemblies
- f. Core Shroud II. Reactor Coolant Systems
- a. ADS - Automatic Depressurization System
- b. HPCI - High Pressure Coolant Injection System
- c. LPCI - Low Pressure Coolant Injection System
- d. CS - Core Spray System
- e. RCIC - Reactor Core Isolation Cooling III. Reactor Protection and Engineered Safeguard Systems
- a. Reactor Protection System
- b. Rod Sequence Control System
- c. Standby Liquid Control
(~) d. Standby Gas Treatment /
- c. Diesel (enerators
- f. Electrical Aux Power
- 1. Cri ical 4160 V Equipment
- 2. Critical 480 V Equipment
- g. Neutron Monitoring Systems
- 1. APRM
- 2. IRM
- 3. LPRM
- 4. RBM
- 5. SRM
- h. DC Power Supply - 125 V, 250 V plus charges
- 1. Nuclear System Leak Detection J. Containment Isolation System
- k. Nuclear Boiler and Related Instrumentation
- 1. Primary Containment IV. Nuclear Fuel Systems
- a. Refueling Interlocks for Fuel Handling and Vessel Servicing Equipment
- b. Fuel Pool Liner and Gates V. Radioactive k'aste Disposal Systems g-] a. Process Radiation Monitoring System is_j 1. Off-Gas Vent Pipe Radiation Monitoring 3-30
Tabla 3.4-1 (Cont.)
- 2. Off-cas Monitoring
- 3. Aug Off-Gas Monitoring
{s-) 4. Main Steam Line Monitoring
- 5. Reactor Building Vent Monitoring (CE)
- 6. Drywell and Suppression System Leak Rate VI. Other Essential Support Systems
- a. Reactor Equipment Cooling (Except NM-Crit.-Loop)
- b. Service Water (Except Non-Crit. Loop)
- c. Emergency Bypasa Function on Control Room Heating, Vent, and AC
- d. Reactor Recirculating (Pressure Retaining Parts Only)
VII. Structures (Seismics)
- a. Reactor Puilding
- b. Control Building
- c. Elevated Release Point
- d. Intake Structure
- c. Diesel Generator Building
- f. Radwaste Building (Below Grade)
NOTE: Even though a system is classified as ESSENTIAL, each individual component within that system may or maj not be Essential. O V G 3-31
Table 3.4-2 PLANT EQUIPMENT MANAGEMENT SYSTEM OUTLINE O Field Names in Equipment Data File Records: Component ID Code (CIC) Cross Peference Class Purchase Order or Contract Description Manufacturer Vendor Manual MPL Number Model Number Serial Number Catalog Number Location Drawing Power Supply Specification Remarks Reference Voltage Rating Frequency Rating Phase Pressure Rating Temperature Rating Power Rating Flow Rating Type Size KVA Frame Size Input Signal From . . . Output Signal To . . . Input Signal Output Signal Material Instruction Manual Instrument Loop NPRD Reportable ? Type of Enclosure Amperage Rating Pressure Drop Solenoid Catalog Number Range of Measurement Operational Setpoint Accuracy Elevation Differential () Actuation Setpoint Speed Rating Limiting Setpoint Power Factor Rating Service Factor Temperature Rise Pipe Size Design Heat Transfer Rating Heat Transfer Rating Gear Ratio Shaft Seal Information Revision Orifice Size Position for Plant Start-Up Failed Position Spare Parts List Number 3-32
3.5 Action 3.1 Post-Maintenance Testing (Reactor Trip System Components) () 3.5.1 Post-Maintenance Actions NPPD has conducted a general review of post-maintenance work requests (MWR) on the Reactor Protection and Control Rod Drive Systems at CNS. This review was conducted concurrently with the MWR reviews as described in Section 3.3. Selected MWRs were retrieved from document control to determine if appropriate post-maintenance testing requirements were identified, performed, and cocumented. In no case were MWRs found which did not require or adequately complete post-maintenance testing activities. For these and other systems associated with reactor trip actuation existing surveillance and maintenance procedure contain specific information on appropriate methods to determine equipment operability. The development and use of these procedures is consistent with the overall BWR industry approach to surveillance testing of these systems. In addition to the generalized surveillance procedures which permit on-line overlapping testing for most of the RPS and CRD system essential components, CNS Procedure 10.9, Control Rod Scram Time Evaluation, t eriodically requires the time tests of individual control rod drives. This procedure and the associated Technical Specification Sections 4.3.C.1 and 4.3.C.2 (~) require 10 percent of the operable rods to be tested at 16-week \/ intervals during power operating and testing of all operable rods during each refueling outage prior to exceeding 40 percent power. For all full scrams from power operation, the process
. computer is set up to monitor scram times for up to 20 selected control rods. This data developed is in addition to the Sequence of Events information available post-trip from the process computer and is used to verify proper timing of this selected group of rods. In Section 3.7, the District has identified the types of normal surveillance testing performed to assure RPS and CRD system operability. These overlapping on-line tests provide added assurance of function operability of these systems. The scram time testing of individual rod drives combined with the periodic overlapping surveillance testing of the electrical portions of the RPS and CRD systems, and the post-maintenance operability testing performed under MWRs assures adequate verification of reactor trip system operability.
3.5.2 Future Action Section 3.6.2 describes future actions that are applicable to RPS and CRD components. Should the results of these activities suggest changes in the generic CNS approach to pose maintenance operability testing, modifications to the proced.tres associated with hPS and CRD post-maintenance testing will be iF ven first O priority. 3-33
- ~ . . _ .- . . - - - _ -- . .- .. . -- -
3.6 Post-Maintenance Testing (All Other Safety-Related Components) ) l V 3.6.1 Post-Maintenance Actions The review to determine if appropriate post-maintenance testing is being performed at CNS consists of two elements. The ffrat l , , fnvolves assurance that the Maintenance Work -. Request (MWR) l which control all maintenance activities at CNS, identify and I require such operability testing as part of the maintenance activity. The second involves consideration of the ability of the surveillance procedures presently in place to arpropriately i verify the operability of safety-related equipment. \ j As previously discussed in Section 3.4, CNS Administrative ' Procedure 1.7.1 is the overall procedure used to control CNS l corrective maintenance activities. An integral part of the overall identification, scheduling,- and approval process ] defined by this procedure is the clear identification of the l type of testing required prior to placing essential equipment back into service. Attached to each essential MWR is a Quality Control / Testing Checklist. _The checklist, provided here as Exhibit 3.6-1, identifies for each MWR the "In Progress" and
- " Post Work" testing required as part of the maintenance l; performed, i Section 3.4 also identified the review and approval process required for all essential MWRs. The MWR review process -
7 incorporates these independent reviews to assure that all facets of essential maintenance activities, including functional testing, are performed in a way which assures the ability of safety-related equipment to function when they are returned to service. 4 In general, the post-maintenance operability testing performed. i either relies on the relevant portions ~of existing station surveillance procedures which address the applicable equipment
, items or specifically references functional- testing' ! requirements contained -in the controlling maintenance q procedure. In situations where additional testing is J
determined by the personnel involved in the preparation or
! review of the MWR to be required, such testing will be
-identified on the MWR Quality- Control / Testing Checklist and performed as part of-the MWR activities.
J Existing surveillance procedures 'at CNS were -developed i to periodically demonstrate the operability - of - safety-related equipment. The development and periodic review of these procedures incorporates consideration of equipment vendor, GE,~ other operating BWR experience and:CNS. equipment performance history. The use of relevant portions of these procedures and the additional: post-maintenance. testing requirements contained in certain maintenance- procedures 1 assure that - the . level .of operability demonstrated post-maintenanco /is at. a level consistent < with that. demonstrated 'by norral surveillance testing activities. l 3-34 l t r,,,.~-r , e- 3 g - -~ , g, g , . , , 9 , ,y,, ,sp-, ,. .j yv . ._
-.9
, 'llI '
/l?!{,f;fs\ l >$t! f l)J !1$D!a,
,]
sNSR=s _G". D; N N dm<N mWon y :c $ t w+".~ co$ sH$ eNnNZ e bo rem < y ZHMZ E c 'Zo.. T E A T D A S D mxrH3 a u*@1" (O L E E T V A E D L / S
' ) L I
I A I I T I R E R N O ". O I TU I CT EA I PN SG L NI E 1 S V E L ( g T S : I W E L
- I K S V C T E G E L R H U : N S N I
'C E O T S R C. I S TL G Q T E U N U T S I L L E
T A O S N S L R O
' ). I F
E R R
'u T
N L' O O E C R T T A Y N D T O I C L Y A T U I Q L - A ) N - U I O Q I N D I E R R I O U Q I E I R L E V E L ( T S _ E T U E I V E : 1~ , 3 4 5 1 2 3 4 5 R S E
. I s C s s C. N
' )_ e k Q A cQ r g
r o L P E o r W A R P t I C T S s I I n o N D I P I
- 2
- o { :"c.EIYA, J
. ou; / ~ > iG E)# .
l !<
? pro =
u mNc g cm -, mD3 7 ll ! l1\'l .l1t
-- ~
In general, any vendor and/or engineering information available
/'
4' is utilized in the preparation of surveillance procedures and the testing portions of maintenance procedures. In accordance with CNS Administrative Procedure 1.3, such procedures are periodically reviewed every two years to determine if changes are required. During this review process, relevant information available from vendors, District engineering and operational maintenance, INPO, and the NRC are evaluated to determine if modifications to these procedures are warranted. In Section 3.4, the District identified the existing controls placed on external information which may impact the procedural requirements. The CNS surveillance and testing procedures which provide continued assurance of equipment operability encompass more 1 than the Technical Specification requircments for such j activities. As an ongoing activity, CNS personnel continually
- identify and evaluate situations, including post-maintenance
! testing requirements, which may have an impact on plant safety.
Should situations arise where conditions resulting from or actions taken during surveillance testing or post-maintenance operability testing are found co degrade plant safety, the ageropriate notifications and requests for Technical Specifications modifications will be requested by the District. 3.6.2 Future Action () The District is continuing to review the overall process associated with mcintenanca activities and post-maintenance testing including the CNS procedural framework within which these activities are performed. Based on the results of this review, certain modifications to existing work practices and procedures may be proposed. Since the existing procedures and post-maintenance testing generally conform to the content of the NRC Generic Letter Action Item 3.2, such modifications will likely be limited to clearer definition of responsibilities ! during the preparation and use of surveillance procedures and MWRs for post-maintenance operability testing. In addition, supplemental training on the identification and use of such . post-maintenance testing may be proposed.
- 3.7 Action 4.5, Reactor Trip System Reliability (System Functional Testing) i 3.7.1 Reactor Trip System Operation
! Per NUREG-1000 and previous GE analysis,- there are no single-failure points within.the General Electric reactor trip system that can prevent a fell reactor trip. Failure to trip l the reactor due to multiple . failures within the process i instrumentation is considered unlikely due to the diversity of the sensed parameters . and the. large number of failures required. Since each control rod has its own associated scram j'%. accumulator tanks, scram valves, scram pilot valve (s) , and
%._) scram pilot valve solenoids, multiple failures in these components (resulting in the failure to scram) - are also considered unlikely.
l 3-36
There are four combinations of two selective contactor failures (~ \ which could result in only half the rods inserting. Four selective contactor failures are required to prevent all rods from inserting in response to an automatic reactor trip signal. In the Cooper Nuclear Station reactor trip design, manual capability is not lost then particular combinations of automatic contactors fail. The contacts from the manual trip switches actuate a separate set of manual contactors. Contacts from the manual trip switches are located in the power supply lines to these separate contactors. In this design, manual scram capability exists even if automatic contactors have failed. RPS and CRD components required to assure reactor scram can be tested during normal reactor operation by five separate tests. The first test is the manual trip actuator test. By depressing the manual scram button from one trip system, the manual scram logic actuators are deenergized, opening contacts in the actuator logics. After resetting the first trip system, the stcond trip system is tripped with the other manual scram button. The total test verifies the ability to deenergize all eight groups of scram pilot valve solenoids by using the manual scram push button switches. Scram group indicator lights verity that the actuator contacts have opened. This test can be pet 'ormed from the Main Control Room. In addition, all compone6 ts covered in this test are accessible either in the () Control n7am or in the CRD hydraulic module area of the reactor building. Both areas are accessible during normal plant operation. The second test is the automatic actuator test which is accomplished by operating, one at a time, the keylocked test switches for each automatic logic. The switch deenergizes the actuators for that logic, causing the associated actuator contacts to open. This test verifies the ability of each logic to deenergize the actuator logics associated with the parent trip system. The actuator and contact action can be verified by observing the physical position of these devices. This test can be performed from the Control Room. The third test includes calibration of the Neutron Monitoring System by means of simulated inputs from calibration test equipment. These simulated signals can be applied to all neutron monitoring equipment including SRMs, IRMs, LPRMs, and the LPRMs making up the APRMs and RBMs. These neutron monitoring systems are designed so that any one channel of the SRM, IRM, APRM, and RBM can be bypassed for calibration without affecting the ability of the Protection System to function properly. Calibration signals can be applied to the inputs of the SRM and IRM pre-amp units which are located on local racks in the Reactor Building, while signals for the LPRM, APRM, and r's RBM are applied to the units through input jacks on the back of (_) the neutron monitoring panels located in the Control Room. In all of the above neutron monitoring equipment, there is also 3-37
the ability to test the equipment using the internal test /~' k ;/ features of the equipment. This allows on-the-spot functional testing without the need of auxiliary test equipment. These tests provide complete testing of amplifiers and other signal conditioning equipment in addition to complete functional testing of all trip circuits associated with the neutron monitoring system. The fourth test is the single rod scram test which verifies capability of each rod to scram. It is accomplished by operation of toggle switches on the protection system operation panel which is located in the Control Room. Timing traces or computer outputs are available for each rod scrammed. This test can be performed from the Control Room and the action of the individual CRD hydraulic units can be observed in a safe area of the Reactor Building. The fifth test involves the application of a test signal to the process sensing instruments in each RPS channel in turn and observing that a logic trip results. This test also verifies the electrical independence of the channel circuitry. The test signals can be applied to the process type sensing instruments (pressure and differential pressure) through calibration taps. These calibration tapa are located on local panels located in the Reactor Building. By putting calibration signals into the various instruments, remote readings and actions can be checked in the Control Room. b \- The alarm typer provided with the process computer verifies < proper operation of many sensors during plant startups ani shutdowns. The verification provided by the alarm typer is considered in the selection of test and calibration frequenct and is not required for plant safety. 3.7.2 Surveillance Requirements Section 4.1 of the CNS Technical Specifications identifies the surveillance requirements which apply to the RPS system. In particular, Table 4.1.1, Reactor Protection System (Scram Instrumentation) Functional Tests, Minimum Function Test Frequencies for Safety Instrument and Control Circuits, and Table 4.1.2, Reactor Protection System (Scram) Instrument Calibration, Minimum Calibration Frequencies for Reactor Protection Instrument Channels, identify the surveillance and calibration frequencies which apply to specific components and modes. Section 4.3 of the CNS Technical Specifications identifies the surveillance requirements which apply to the CRD system. The RPS backup scram valves are presently not designed to permit on-line functional testing. The operation of either one of the two backup scram valves will cause the insertion of ' all control rods and initiate a reactor shutdown. (~h 'w / 3-38
1 3.7.3 Future Actions O The BWROC and CE are presently reviewing the adequacy of
, current functional tests of the backup scram valves. The results of this analysis will be available by March 1,1984. -
O l l l O i 3-39
- 4.
SUMMARY
(-s The District believes that its current programs and procedures provide an excellent basis for e.ddressing the issues raised in the seven action items (for BWR plants) requested by the NRC in Generic Letter 83-28. As indicated in Section 3, the District is currently involved in a number of changes in existing plant systems, such as a new plant process computer, that will further enhance its capabilities in the area of post-trip reviews. Ilowever, the District also recognizes the need to improve or proceduralize its current operations as a result of its analysis to date. The actions described in Section 3 fall into two general categories: industry-related generic issues and NPPD specific issues. The District is an active participant in the programs being conducted by the BWROG cnd NUTAC that will address a number of the generic issues. Also, the District has developed a program to improve its conformance to the actions requested in Generic Letter 83-28. Table 4-1 provides a summary table of the proposed actions and an estimated schedule completion date. The District will continue to inform you of our progress in implementing these programs through a dialog process similar to that discussed in Attachment 8 to our response to NUREG 0737, Supplement 1 (Appendix A). O O 4-1
.-. - . _ _ . - . . . . - . . - ~ . - .-- .. ._ - .-- - - . . . -. . - , _ __ _ - . .
TABLE 4-1 i () Implementation Schedule for Future Actions in Response to l Generic Letter 83-28 s Initiative Milestone Date Status
- Post-Trip Review Procedure Completed, reviewed, approved, and July 1, 1984 E i plant personnel trained in the nev i i procedure. BWROC restart criteria will be incorporated in this procedure as appropriate t
Post-Trip Incorporate Post-Trip Requirements March 1, 1984 C Data Capability into PMIS Parameter Selection Completion of Pre-Implementation May 31, 1984 E i Review of PMIS by NRC Equipment Class- Installation of Prime March 1, 1984 E ification/ Vendor Computer System Interface i Evaluate NUTAC program guidelines April 1, 1984 E-() for incorporation into CNS procedures regarding vendor manual control and vendor information i programs.
- Prepare schedule for phased imple- July 1, 1984 E I mentation of equipment classifi- l cation upgrade program.
Completion of Classification' July'1, 1986 E of All Plant Components-Reactor Trip BWROG Report of Functional March 1, 1984 E System Testing of RTS
* - E = estimate (subject to change) .
C = Commitment
'4-2.
4 > -<- +e. e , ~ , - - - -v- -w--- - m =,= v e -
ON "*b"" ""b" LQA8300129 April 15, 1983 Mr. Darrell G. Eisenhut. Director Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Conmission Washington, D.C. 20555
SUBJECT:
Response to NUREC 0737 Supplement 1 Emergency Response Capability Cooper Nuclear Station NRC Docket No. CO-298, DPR-46
Dear Mr. Eisenhut:
This letter and its attachments provide Nebraska Public Power District's response to generic letter 82-33 Supplement i to NUREG 0737, " Requirements O for Emergency Response Capability" for Cooper Nuclear Station, It is our objective to work with the NRC to develop and implement a schedule for cost-effective emergency response improvements that fully meets the intent of Supplement 1. Therefore, we have developed an overall strategy for the implementation of the requirements. The District's strategy for implementation of Supplement 1 to NUREG-0737 includes the following objectives:
- 1. Fully meet the intent of the 0737 Supplement I requirements.
- 2. Provide a cost effective implementation plan.
- 3. Provide for the proper integration of the various emergency response improvements from a human factor standpoint.
4 Maximize the benefits to NPPD from the efforts of the Bh'R Owners' Group which we have supported in several areas.
- 5. Establish a systematic dialog and review process with the NRC staff which will allow us to establish commitment dates based upon sound information and to estinate dates where information is not yet firm enough to establish a commitment. At the same time, we will keep the staff fully informed of our evolving plans.
Attachment I shows the relationship of the major activities involved in the emergency respcuse improvement program. Attachment 2 shows a su= mary of our proposed implementation schedule.' OsttN per, p
. i I
- Mr. Darrell G. Eisenhut Page 2 April 15, 1983 In the area of Emergency Operating Procedures (EOP's), the District intends to use the work which has been performed by the BWR Owners' Group (BWROG) to i
develop generic guidelines, consider the input from the INP0/EOPIA Review Group writers' guide, and develop a plant-unique writers' guide for CNS to i i use in converting the generic guidelines to our Cooper-specific emergency operating procedures. Our plan regarding development of the CNS Emergency Operating Procedures is described in further detail in Attachment 3. With regard to the Control Room Design Review (CRDR), the District has performed the review phase under the BWROG control room survey program. The , methodology used was as described in the BWROG 1etter 81-51 (W.J. Armstrong to V.A. Moore (NR0]) dated Aug. 25, 1981. As noted in BWROG 1etter 83-04 (Dente [BWROG) to Eisenhut (NRC]) dated March 7, 1983, the BWROG is awaiting action on the August 25, 1981 submittal. However, we understand that the program is generally considered acceptable by the NRC. Our plans regarding the control room design review are discussed in further detail in Attachment 4 With regard to Regulatory Guide (R.G.) 1.97, the District plans to complete the assessment of variables as described in Attachment 5. Any deviations or alternatives to instrumentation as discussed in R.G. 1.97 will be addressed in a report upon completion of the assessment.. The SPDS is being given high priority as requested by Supplement 1 to ' NUREG 0737. We are planning to continue to take advantage of the work that is being done by the BWROG. Specifically, we are considering the results of the control room design review as input in our SPDS design. We are also review-ing the results of the simulator evaluation of the BWROG graphics displays, which was conducted in Tulsa in May and June of 1982, f actoring the results of that work into our SPDS design. Additionally, we plan to follow the work to improve the BWR Owners' displays, which is currently being planned by the Electric Power'Research Institute under the technical guidance of the BWROG. The SPDS is discussed further in Attachment 6. The District's goal is to complete the SPDS design, Reg. Guide 1.97 assessment, and writing of plant-specific emergency operating procedures at approximately the same time so that we can perform a final validation by a detailed walk-through of the E0Ps in the plant, including any supplementary work that is required as a result of the control room design review. These activities are depicted in a flow path format in Attachment 1. Having trained the CNS operators in both the procedures and SPDS separately, we would then implement both SPDS and Emergency Operating Procedures. Having implemented the corrective action from the control room design review, with the SPDS and the energency operating procedures in place, all the emergency response improvements would then be tested. This would provide the final validation that all the pieces work together to provide the desired emergency response capability. The training plan is described in more detail in Attachment 7. t I
Mr. Darrell C. Eisenhut Page 3 O April 15, 1983 With regard to establishing a systematic dialog and review system between NPPD and the NRC, District management has made coc:mitments in this letter only for these items where we feel that we have sufficient information upon which to solidly base a commitment and these items are designated on Attachment 2 as C, indicating commitment. Other dates which are given are indicated by the letter E, meaning estimate. With many factors yet unsettled, the District does not feel it is appropriate to establish coc:mitment dates where such things as outside procurements remain to be accomplished and contractural decisions having a direct affect on schedules are unresolved. Estimates are based on standard review cycles which would be expected normally in the course of business in the nuclear industry and are subject to change. What we propose to do is to set up a system whereby our Licensing Manager meets with the NRC Project Manager on a routine basis. At each of these meetings (or during. telephone conversations), we would review the status of commitment dates, and some of the dates which had previously been in the "esticate" category would be updated to cocimitments based upon subsequent action which had taken place. Our approach on the schedule co.cmitment s / estimates and subsequent systematic dialog with the NRC is described in further detail in Attachment 8. The status of the District's Emergency Response Facilities (ERF's) is contained in Attachment 9.
~ \
We look forward to our initial meeting to review these plans with our Project Manager. This will be the start of a continuing dialog which will keep the NRC fully informed of our activities and allow us to proceed on an integrated basis to establish an overall ecergency response improvement program as required by Supplement 1 to UUREG-0737. Sincerely, A.lf ay M 11 ant [ Division Manager of Licensing & Quality Assurance JMP:sn13/4 cc: John T. Collins, Regional Administrator U.S. Nuclear Regulatory Commission Region IV bec: NRC Distribution d R. Hackney D. M. Smith K. R. Wire J. M. Meacham l D. A. Whitman
. ~
Mr. Darrell C. Eisenhut Page 4 () April 15, 1983 List of Attachments
- 1. Emergency Response Improvement Program
- 2. Implementation Schedule
- 3. Upgrade of Emergency Operating Procedures
- 4. Detailed Control Room Design Review
- 5. Regulatory Guide 1.97
- 6. Safety Parameter Display System / Plant Management Information System
- 7. Training Plan
- 8. Schedule Commitments / Estimates
- 9. Energency Response Facilities O -
~
O
O O O - ATTACIFIENT 1 Emergency Response Improvement Program
% WRITERS GUIDE PLANT EOP SPECIFIC
--> CENERIC CUIDELINES E0P'S ,
TASK ANALYSIS i
. TRAINING BWROG NHC PLAKr CRDR --e= CRS APPROVAL SPECIFIC COMPLETED OF PROGRAM BWROC CRS PLAN CRDR SUPPLEMENT
& E0P WALKTIIROUCll RC 1.97 :- ASSESSHENT/ ACTIONS SPDS I DESICN/ TRAINING U
lied ASSESSHENT & CORRECTIVE ACTION PLAN EnERGEl.CT I RESPONSE IIED CORRECTION TSC y DESIGN l EOF W l SPDS IMPl.EMENTATION In TRAINING l INTEGRATED TRAINING ON EMERCENCY RESPONSE IMPROVDIENTS 1 FINAL VALIDATION Notes E = Estimate (and subject to change) C = Comunitment i e
ATTACHMENT 2 Implementation Schedule
- IMITIATIVE MILESTONE DATE STATUS
- I I
SPDS Submittal of Safety Analysis Feb. 1, 1984 E SPDS Operable Feb. 28, 1986 E Operators trained Feb. 28, 1986 E Pre-Implementation Review by NRC (Verification & Valida-tion Review) i . Start Mar. 1, 1984 E
. Completion May 31, 1984 E
. Audit of installed system by NRC Feb. 28, 1986 E CRDR Submittal of Program Plan Sep. 30, 1983 E Submittal of Summary Report Apr. 15, 1984 E Regulatory Guide 1.97 Submittal of Assessment Report Nov. 30, 1983 C Implement Requirements June 30, 1985 E E0P Upgrade Submittal of Generic Technical Guidelines Dec. 22, 1982 C fubmittal of Procedures
. Generation Package June 30, 1984 E Implementation of E0Ps Dec. 31, 1984 E ERF Emergency Plan Exercise April 6, 1983 C verifies facilities complete at this time Exercise to verify facilities complete per Supplement 1 April, 1986 E Integrated Training Completion of Integrated Training Plan Mar. 31, 1986 E
- E = estimate (subject to change)
C = commitment
- ATTACHMENT 3 Upgrade of Emergency Operating Procedures i
{_ _ Current Status of Emergency Operating Procedure (EOP) Upgrade Develop-
- ment / Submittal Data for Generic Technical Guidelines Nebraska Public Power District is planning to develop symptomatic based E0Ps for Cooper Nuclear Station (CNS) based on the Emergency Procedure Guidelines (EPGs) developed by the BWR Owners' Group (BVROG) to satisfy the requirements of Supplement 1 to NUREG-0737 Item I.C.1. The following summarizes the generic guidelines status:
June 1, 1982 EPG, Revision 2, dated May 20, 1982 j transmitted to the NRC i Oct. 4, 1982 Errata to EPG, Revision 2, dated September 28, 1982 transmitted to NRC Feb. 4, 1983 NRC issued SER approving EPG, Revision 2 for use in development of upgraded E0Ps. l ] Dec. 22, 1982 EPG, Revision 3, dated December 8,1982 Transmitted to NRC. Nebraska Public Power District presently plans to subcontract for assistance in the development of the E0Ps and update the E0Ps when EPG, Revision .3 is approved by the NRC. EPG, Revision 3 expandM EPG, Revision 2 by adding two new guidelines: Secondary Containment Control (identified as needing completion by the NRC in the SER for EPG, Revision 2) and Radioactivity Release Control. The BWROG plans to address combustible gas control and close on the exceptions identified in the SER for EPG, Revision 2 in 1984. A schedule for incorporation cf EPG Revision 3 and future EPG Revision will be developed with the NRC as each revision is approved by the NRC. Requesi:s for proposal for assistance in the development of E0Ps for CNS are presently d planned to be transmitted to qualified subcontractors in July 1983 (estimate). Submittal Dates for Procedures Generation Package and Data for Implementing E0Ps I It is presently anticipated that development and implementation of the E0Ps , for CNS will consist of the following planned elements.
- 1. Development of a CNS Writer's Guide for E0Ps based on " Emergency Operating Procedures Writing Guideline," developed by the Emergency '
Operating Procedures Implementation Assistance (EOPIA) Review Group dated July 1, 1982 (INPO 82-017). l l 2. Collection of data and generation of plant-specific values and curves for the EOPs. ( -_ -. - - . . -~ . - . -.
Page 2 0 3. Preparation of CNS plant-specific Technical Guidelines based on the EPGs. Will be submitted as part of PGP.
- 4. Development of the E0Ps for CNS based on the plant-specific Techni-cal Guidelines and Writer's Guide.
- 5. Review of the existing CNS, EOPs, and Abnormal Operating Procedures (AOP) to delete those replaced by the upgraded E0Ps and revision of those retained to ensure they integrate with the upgraded E0Ps.
- 6. Preparation of a flow diagram for the CNS upgraded E0Ps.
- 7. Development of an E0P verification program for CNS consisting of desk top reviews and control room walk-throughs based on " Emergency Operating Procedures Verification Guideline" being developed by the E0 PIA Review Group.
- 8. Development of an E0P validation program for CNS consisting of simulation practice of the CNS upgraded E0Ps based on " Emergency Operating Procedures Validation Guideline" being developed by the E0 PIA Review Group.
- 9. Development of a CNS training program for the upgraded E0Ps.
O 10. Based, on the " Emergency Operating Procedures Generation Package Guideline" developed by the E0 PIA Review Group dated February 1983 (INPO 83-007), prepare and submit to the NRC a Procedures Gen-eration Package at least three months prior to formal CNS operator training on the upgraded E0Ps. The Procedures Generation Package will include:
. The CNS plant-specific Technical Guidelines
. The CNS Writer's Guide
. A description of the CNS validation program for the upgraded E0Ps
. A brief description of the CNS training program for the upgraded E0Ps.
- 11. Incorporate SPDS in walkthrcugh of the E0P's.
The proposed schedule for these tasks is shown on the following two pages. Major milestones are shown in Attachment 2. O
I CNS EMERCENCY OPERATING PROCEDURES UPCRADE PROCRAM , Sleet 1 of7 1983 1984 JtX. AUG SEP OCT NOV DEC JAN FEB HAR APR HAY JUN JUL AUG SEP OCT NOV DEC SELECT EOP SUbCONTRACIOR PREPARE RFP XXX OBTAIN PROPOSALS XXXXX SELECT SUBCONTRACTOR ( HU
- SUBCONTRACTOR START X
DEMP CM E0P WRITER'S CUIDE (1)* ------------------- XXXXXXX
. REVIEW & APPROVAL XXXXX PLANT SPECIFIC VALUES (N ----------------------- COLLECT DATA XXXXXXX
& CURVES CENERATE VALUES & CURVES XXXXXXXXXXX PREPARE CNS TECilNICAL ------------------------------- XXXXXXXXXXXXXXXXXXXXXX CUIDELINES DEVELOP CNS DPCRADED E0P'S --------------------------------- XXXXXXXXXXX REVIEW & APPROVAL XXXXXXXXXXXXXXXXXXXXXXXXX EXISTING EOP'S AND AOP'S I I -------------------------------- REVISE XXXXXXXXX REVILW & APPROVAL XXXXX PREPARE EOP HDW DIACRAM ----------------------------------------------------- XXXXXXXX DEVEIDP VERIFICATION PROGRAM --------------------------------------------------------+-- XXXX REVIEW & APPROVAL XXXXX DEVELOP VALIDATION PROGRAM (8) ---------------------------------------------- J----------------- XXXXX REVIEW & APPROVAL XXXXX
- These numbers refer to planned etenients in Attachment 3.
A
\ .
CNS ENERCENCY OPERATING PROCEDURES UPCRADE PROGRAM , Sheet 2 of 2 1983 1984 JUL AUG SEP OCT NOV DEC JAN FEB HAR APR MAY JUN JUL AUG SEP OCT NOV DEC DEVELOP TRAINING PROGRAM ( ------------------------------------------------------------ XXXXXXXXXXXXXX DEVELOP PCP (10) ---------------------------------------------------------------------------------- XX DELIVER TRAINING LECTURES ---------+---------------------------------------------------------------------------------- Yrrrry PROVIDE SIMULATOR --------------------------------------------------------------------------------------------------------- XXXXXXX TRAINING CONTROL ROOH TRAINING ----------------------------------------------------------------------------------------------------------- XXXXXXX E0 P IMP LEMENTAT I ON - - - - - - -- --- - -- -- - -- --- --- --- - - - - -- - - - - - - - - - - - - - - - - -- - - - -- - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- ---- -- - - - - - - -- XX XXXXX l 1 e
ATTACHMENT 4 4 Control Room Design Review (CRDR) Current Status CNS is a participant in the BWR Owners' Group (Bkl0G) Control Room Survey Program and is implementing its cetailed control room design review (DCRDR) in accordance with the methodology described in the BWROG generic program plan (letter no. BWROG 83-51, from W.J. Armstrong to V.A. Moore, dated August 25, 1981). Currently the NRC is reviewing this generic program plan. Using the BWROG program, the review phase of the CRDR was performed in February 1981 by an inter-utility survey team. The results of this effort are cur-rently being evaluated and will be incorporated into an integrated plan for control room enhancecents. l 1 Schedule for Submittal of Program Plan and Summary Report A plant-specific program plan will be submitted .per Accachment 2 with subcontractor assistance. The Summary Report will also be submitted per Attachment 2. , Integration of CRDR with Other Emergency Resoonse Improvements The overall integration plan for the DCRDR program with other energency O . response improvements will include the following activities.
- 1. Factor preliminary results into Safety Parameter Display System (SPDS) development.
- 2. Perform cask analysis and walk-throughs of plant-specific emergency operating procedures when developed.
- 3. Consider SPDS in the development of the CRDR implementation plan.
O -
ATTACHMENT 5 Regulatorv Cuide 1.97 NPPD is a participant in the BWR Owners' Group subcommittee on Regulatory Guide 1.97. Since several generic positions are being adopted through that organization and these positions will be submitted to the Staff, the CNS assassment vill probably adopt those positions. Final resolution of the modifications to be implemented at CNS is dependent on the staff's review of the BWR Owner's subnittal. We are currently assessing Post Accident Monitoring variables identified by R.C. 1.97 to determine the current degree of compliance. Each variable is being assessed as to installed range, seismic and environmental qualification, quality assurance, redundancy, power supply, and display location. It is the District's intent r. hat our initial review of the R.G. 1.97 variables will be reviewed by our NSSS vendor to verify the adequacy of our plans prior to submitting the final assessment to the Staff. The results of this review and schedule for installation of any modifications will be submitted to the NRC Project Manager as indicated in Attachment 2. O . O e O
ATTACHMENT 6 Safety Parameter Display Svstem/ Plant Manageeent Information System PMIS Overview Supplement I to NUREC 0737 providas for improved emergency response to accidents. Concurrently the Nebraska Public Power District (NPPD) is finding additional great need for:
- 1) placing numerous plant management functions on a computer,
- 2) computeri::ing engineering applications, and
- 3) replacing the GE/ PAC 4020 plant process computer which is becoming
. obsolete.
NPPD Management consequently intends to install a new integrated computer system at Cooper Nuclear Station to satisfy the District's needs as well as the requirements of the NRC. Such a system will be a total Plant Management Information System (PMIS). By integrating all functions required of a new j computer system, many safety aspects of plant operation wi?.1 be improved to a point exceeding those of the present NRC requirements alone, f}
\
NPPD is in the process of developing a PMIS for Cooper Nuclear Station using the latest computer technology. Successful implementation of the following objectives will accomplish the NRC and District requirements.
- 1) Satisfy the Nuclear Regulatory Cottmis sion requirements of Supplement I to NUREG-0737 " Requirements for Emergency Response l Capability" as it relates to the PMIS.
- 2) Replace the existing GE/ PAC 4020 plant process computer which is reaching obsolesence.
- 3) Provide computer capability to perform other balance of plant and plant management functions.
- 4) Provide a system compatible with NPPD's long-range goal of an overall computer network.
In accordance with the established objectives, Figure i shows: 1) the various functions that will be performed by the PMIS, 2) the source of the function, and 3) the requiring agency. The pie segments show approximate , proportions of the PMIS computer CPU usage for various groups of functions. t As can be seen, the overall PMIS encompasses a greater number of functions than those required by NUREG-0737 and will provide additional capability to CNS. p - d
Page " O Current Status of SPDS Design In early 1981, shcrtly after the August 1980 issuance of the final report on NUREG-0696, the Functional Criteria for Emergency Response Facilities, NPPD started preliminary planning of an integrated computer system called the Plant Management Information System (PMIS) for CNS that would satisfy the NUREG-0737 requirements for a Safety Parameter Display System (SPDS) plus additional CNS needs. There was an apparent urgency for a new meteorological system to obtain more reliable meteorological data. Since the meteorological system could easily be segmented out, it was initially decided to handle this task separately. It was planned the meteorological data would eventually be integrated into the PMIS computers to provide for predictive radiological dose assessment. The Plant Management Information System (PMIS) is to be an integrated comput-er system comprised of a modular intelligent multiplexed front end data acquisition subsystem, redundant preprocessors, and modern, high-speed, real-time, multi-user multi-tasking central processors coupled with opera-tor-interactive sof tware and colorgraphic display equipment. The PMIS is to incorporate all functions of the existing GE/ PAC 4020 Plant process computer as well as a Safety Parameter Display System (SPDS), ability to characterize and predict radiological plumes, the functions of the transient recording and analysis system, and additional plant manageme.nt systems. The PMIS will provide improvements in the ability of the plant operators and support staff Os to determine the status of the plant, avoid abnormal events, and react promptly to recover from adverse conditions. Human-factored CRT displays will assist the operator in assessing the plant status and will guide him in the respcase to plant transients. Appropriate sample rates and on-line long-term data storage and retrieval capabilities are provided to support post-transient analysis and core performance calculations. The new system will also provide memory and computing power to support plant maintenance, spare parts inventory, periodic technical specification requirements, component qualification, interchangeability data, degraded core analysis, trend analysis of plant systems, ODAM and updated Appendix I, Spectrum Analyzer report generating, Reactor Engineering Analysis programs, STRUDL pipe stress analysis program, and other plant-specific computing needs. l l O_ l l l l
PLANT MANAG EMENT INFORMATION SYSTEM O s i5
- is , i h,, 'o, 5$ 0f a
> r.
E c, Sy +'lg, ,, /s
, \
1
'~
! ,o , "~' $f7b,., \ ![ stNf) *'
g ;, ~~.,, ;;,, . % i .e , ,.a E"[;*[5sIo,,,.oR 85 wlaec S #es** a
~ .$*[*,'[
,... .y w-(("
*
- ce -
a ea ~>~-2%
"'""' 't ' ' ' " " ' ' , ,' . "' ' " ^ " " *" " "
O !' ['"'" "' '- .o gsn\Cb w 0*olog, $ peo *' h ,. #N0 L h s s'* . qg n v::,
%c, %, '-
e
+
4 o.S N *A }
!? 1, 555 * *t"s \",
,E l
6 O FIGURE I i
Page 4 Currently the District is in the process of selecting a System Integrator to design and develop a PMIS for CNS. The activities that have transpired prior to this point are as follows: O May 1981 A task force was established to determine what NPPD should do concerning the post-TMI Emergency Response Facilities and upgrading of the computer system at CNS. June 1981 The task force initiated the evaluation process for selection of a nuclear / software vendor to design a PMIS for Cooper Nuclear Station that would satisfy the guidance of NUREG-0696 and NUREG-0654. Thirteen vendors made preliminary proposals. It became apparent during the interviews that a more thorough assessment of the requirements of a PMIS was needed. August 1981 General Electric was contracted to perform a Plant Management Information System Application Assessment Report for Cooper Nuclear Station. December 1981 General Electric presented the results of the report to NPPD management along with a budgetary cost estimate for the PMIS. January 1982 A project manager was named to head up the PMIS proj-ecc. March 1982 A " Plant Management Information System Overview Report" was generated and presented to NPPD's Board of Direc-O- tors. May 1982 The Board of Directors approved proj ect funding for further evaluation of nuclear / software vendors, gen-erating implementation plans, engineering studies, and development of specifications. An architect / engineer, Burns & Rce, was also approved to assist NPPD in these tasks. June 1982 A subtask under Burns & Roe's ongoing Engineering Service Agreement with the District was established for their consulting services. July 1982 Started development of a preliminary PMIS functional specification that would make up the major portion of the Request for Information (RFI) document. This is the second phase of the system integrator evaluation process. November 1982 Transmitted Request for Information document to six system integrators. 4 O
Page 5
- O
! January 1983 Received written submittals to the RFI from the six System Integrators and initiated review.
February 1983 Received oral presentations from the six System Inte-grators. March 1983 Selected three System Integrators from the original six to participate in the last J.ase of the selection process, the Request for Proposal (RFP). March 1983 Initiated preparation of the Request for Proposal Document. With the assistance of an A/E, the District has generated a functional specification for the PMIS and is currently in the process of selecting a system integrator to design and develop such a computer system for CNS. Six firms were requested to participate in a detailed Request For Information (RFI) evaluation phase. Three firms have been selected for further consideration. These firms will be asked to submit a proposal in response to a Request For Proposal (RFP) document issued by the District. Status of Meteorological System Implementation of the Meteorological Monitoring System for Cooper Nuclear Station has involved the ef forts of several District departments as well as , the consulting services of Dames and Moore. Full implementation of the system also involves close coordination with the CNS Plant Management Information System (PMIS) . The following discussion provides an overview of the project status. NRC/ District Correspondence
References:
- 1) June 30, 198O, Letter f rom J. M. Pilant to D. G. Eisenhut, " Post TMI - Requiremen s/NUREG 0737."
- 2) July 30, 1981 Lettar from J. M. Pilant to T. A. Ippolito, Letter LQA 8100238.
- 3) June 9, 1981, Letter from J. M. Pilant to D. G. Eisenhut, "Energency Response Facilities."
- 4) June 4, 1982, Letter from J. M. Pilant to D. G. Eisenhut, " Post PMI Requirements Response (Generic Letter No. 82-10).
The District is in the process of upgrading the meteorological measuring facilities at Cooper Nuclear Station (CNS). Dames & Moore was contracted to develop the implementation plan which was submitted to the NRC in , Reference 1. The District later entered into an Engineering Service ! Agreement with Dames and Moore to develop the computer sof tware required to l neet the meteorological energency preparedness requirements of Regulatory Cuide 1.23. l
i
. . I Page 6 O I. The implementation plan served as a basis for the following activities:
- 1. Location of Primary and Backup Tower:
A map of the CNS site showing all possible locations of the towers that met the Regulatory Guide 1.23 guidelines was reviewed and tower locations selected. Lecation of the 100-meter primary tower does not fully comply with the 10 X distance rule. As a result of telephone conversations with the NRC staff concerning this matter and the NRC concurrence requested in Reference 2, the District concludes the tower locations are acceptable to the NRC.
- 2. 100 Meter Tower:
The 100-Meter guyed tower erection was completed in November, 1981, and installation of the instrument elevator was completed in December of 1981.
- 3. 10 Meter Tower:
A free standing climbable 10-meter tower with safety line and maintenance cage was erected in November 1981.
- 4. Instrument Shelters:
An instrument shelter to house the meteorological signal processing equipment as well as any future microwave equipment has been constructed at the base of each of the 100- and 10-meter towers. These shelters have temporary power and air conditioning equipment intalled and operatin,g. These shelters contain the meteorological sensor signal conditioners and the data transmission Data Acquisition System (DAS). These instruments are operating.
- 5. Meteorological Sensor Instrument: The sensor instrumentation for the meteorological monitoring system was purchased from Climetronics. The signal conditioners are installed in instrument racks in the shelters. The sensors are installed on the 100 , 60 ,
and 10-meter elevations of the primary tower and on the 10-meter backup tower. Sensor installation, with leads to the signal i conditioners in the shelter, is complete.
- 6. Data Transmission:
A Computer Products Incorporated (CPI) Data . Acquisition System (DAS) is used for transmission of meteorological data in digital form from the tower shelters to the CNS computer room where the information will be displayed on analog strip-chart recorders and in digital format. O
l
'Page 7 l
O During the interim model phase of the Meteorological / Radiological i project the meteorological data will be manually inputted from the strip-chart recorders into the PRIME computer for operation of the ! interim model during ' emergency conditions. During the initial phases of the PMIS installation, the meteorological data will be manually inputted until the final Plume Dispersion Model. becomes l operational. At this time the meteorological data will be i automatically-inputted directly into the PMIS computer system as well as the strip-chart recorders. 1 I
- 7. Power and Communications:
Temporary power has been provided to the instrument shelters from the existing construction power in the area of the tower sites. Permanent power will be provided to the shelters after completion , of the 12.5 kV bus from the switchyard to the plant which is 95 percent complete. The power cable will be energized from the off-site substation switchyard under normal conditions with the j capability of manually switching to the emergency bus from the plant if normal power has failed. The co=munications cable consisting of two (50 twisted pair) underground cables has been installed to fom a loop to provide two communication paths to the computer room. O 8. Strip Chart Recorders: At the present time the meteorological sensors, located on the Elevated Release Point (ERP) and the old 10 meter tower, feed data 4 to strip-chart recorders located in the computer room. New Esterline Angus strip-chart recorders to record the meteorological data from the new 10- and 100-meter. towers are installed in the computer room. The. six new recorders will be replacing the existing meteorological instruments. These strip-chart recorders will be maintained after operation of the PMIS to provide permanent recording in accordance with' NRC life of plant retention requirements.
- 9. Microprocessor:
i A DEC PDP 11/23 16-bit microprocessor has been installed in~che computer room to collect the meteorological data and drive the strip-chart recorders.
- 10. Software:
Operating software for acquiring the meteorological date from the j towers, error checking, averaging, performing engineering conversions, and outputting -to _the strip chart-recorders and
- m storing data on mag tape is approximutely 80% complete.
Page 8 O ' II. The scope of the Dames & Moore Engineering Service Agreement covers an interim Model; Appendix I, Calculations and Reporting; and Plume Dispersion Model. A brief description of each activity follows: Interim Model: -
"An operable dose calculction methodology (DCM) shall be in use in the
- control room and at appropriate emergency response facilities." Dames &
Moore developed an interim computer model EMERGENC". PREPAREDNESS MODEL (EPM 2) for the District to provide a neans of estimating the dispersion of radioactive material resulting from an accidental release. EEM2 computes relative concentrations, dose races, and absolute doses due r.o accidental atmospheric releases of radioactivity. Results are based on source data and weather data provided by the operator for each 15-minute time interval simulated by the program. EPM 2 has the capacity for 20 separate release scenarios. Each scenario addresses the relative abundance of t: e 13 radionuclides listed in NUREG 0654. The relative abundance of nuclides for each scenario is based on the source term, { time factor following the accident, and mode of release. The effluent j source rate of the accidental release if also input to the program. The i effluent source rate combined with the relative abundance of nuclides for a specific scenario will provide absolute doses and dose rates for given distances and directions based on weather data which is input by the operator during each 15-minute interval. The weather data is ] current infor=ation which is read directly from the meteorological strip-charts. EPM 2 computes relative concentrations at standard polar ! grid receptors and at 528 special receptor points, most of which are strategically located within a 10-mile radius of CNS. f Usage The interim model became operational in February of 1982 and was j operating during .the March 10, 1982, NRC Emergency Preparedness Test. The model is run as a standalone program on the District's PRIME , conputer in the General Office. Meteorological data fr,om strip-chart recorders and radiological data is manually input into the cor puter. The primary input terminal is located in the TSC with a slave terninal located in the EOF. The responsible TSC personnel input the i meteorological conditions and release mode into the PRIME computer via microwave communications and a dial-up port. The program provides
- estimated doses at selected polar coordinates and at selected special points. This information is displayed in a matrix format on hard copy terminals in the TSC and EOF. Data can also be inputted at the EOF terminal. However, the results are not available at the TSC.
Predictive Dose Assessment Model __ __ This model will be operated with real-time meteorological data provided by the equipment described in Section I. The program will be run on the , PMIS computer system as discussed in Reference 3. Development cannot j therefore be pursued until design of the PMIS has progressed far enough I to establish the type of computers that will be used. i i
Page 9 Proposed Schedule As previously addressed, the SPDS is a segment of a larger task, the PMIS, for which a System Integrator is currently being selected. A contract for design and development of the PMIS is planned to be let in the third quarter of 1983. Due to the magnitude and complexity of such a project, any schedule developed without the input of the System Integrator would have no sound justification to it. A valid schedule for the PMIS should be available approximately March 1984. A sample of an anticipated schedule typical of that to be used for tracking purposes is included as the following figure. Provided below are the key activities:
- 1. Submittal of Safety Analysis which describes the basis for parameter selection and a SPDS implementation plan.
- 2. Start of pre-implementation review (submit validation and verification plan) by NRC.
- 3. SPDS will be operable and operators trained.
4 Completion of NRC review. This schedule is indicated in Attachnent 2. Upon employment of a Sy ster. p Integration (March 1984), the following figure will be deleted and a revision V provided in accordance with the overall PMIS schedule. The District currently intends to request a pre-implementation review by the NRC. The final decision will be made prior to awarding the PMIS contract.
s
~
SAMPLE OF - ANTICIPATED PHIS SCllEDULE Sheet 1 of ? l 1983 1984 1 MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB HAR APR MAY JUN JUL AUG SEP OCT NOV DD: AWARD COfff RACT ------ ------------- - --- - -- ------- --- -- -- A NRC PREIHPLEMENATION ----------------------------------------------------------------- ------- XXXXXXXXXXXXXXXXXX REVIEW
- t SITE PREPARATION ------------------------------------------- XXXXXXXXXXXXXXXXXXXXXXXXXXX HVAC, SPACE, POWER EQUIIMENT ORDER --------------------------------------------------- XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX PROJECT ORGANIZATION I DATE ACQUISITION ----------------------------------------------------------------------------- XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX f EQUIP DELIVERY
& INSTAIJATION S UBH ITTA L & N RC ------ --- --------- ------ -------- - - - - -- --- - - ----- - -- - ---- - - -- -- - - - - -- - - XXXXXXX X XX XX REVIEW OF SAFETY ANALYSIS REPORI I N ITI A L COMPUTE R --- ----- ------ --- - ------ -------- ---- - - - --- - - - - --- - --- ------ - --- ---- XXXX XX DELIVERY & INSTALL.
PROCESS COMPUTER ------------------------------------------------------------------------- XXXXXX UPCRADE INSTALL
& TEST COMPUTER SO FlWA RE - - - -- -------- - ------ ------ ---- ----- - - - - --- -- - - - -- - --- - - -- - -- - - --- - XXX XXXX XXXXXXXX XXX XXX
& MAINT TRAINING SPDS SO F1 WARE DEVELOfHEfff --------------------------------------------------------------------------
XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX i & FACTORY DEMONSTRATION S PDS COM PLffER DE LI VE RY ------------------------ --- - - ----- ---- -- - ---- ---- - -- - - - - - --- -- --- - --- -- - - ----- -- - -- - --- -- -- - XXXXXXXXX
& INSTALLATION SPDS SYSTEN It! STALL -------------------------------------------------------------------------------------------------------------- XXXXXXXXX & TEST n
{ f s \ . ANTICIPATED PHIS SCllEDULE . Sheet 2 of 7 1984 1985 1986 JUL AUG SEP OCT NOV DEC JAN FEB HAR APR HAY JUN JUL AUG SEP OCT NOV DEC JAN ITI. SYSTEM OPERATOR ------------------------------- YYYYYYYYYYYY,Y TRAINING THANSIENT HECORDING ------------ XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX SOFIWAdE DEVEIDlHENT
& FACTORY DEMONSTRATION TRANSIENT RECORDING SYS -------------------------------------------------- XXXXXXXXXXXXXXXXXXX
- INSTALL & TEST O PE RAT I NG T R A I N I N G - - - - - - - -- - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - XXX XXXXXXXXXXX COMPUTERSOITWARE--------------------------------------------------------------------------------------------------------XXX
& NAINT TRAINING PROCESS COMPUTER ---------------------------------------------------------------------- XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX REPLACEMENT SOFIWARE DEVEl.0P ; FACTORY TEST PCR I N STA LL . - - - - - - --- - - - - - -- -- - --- - -- - - - - - - -- - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -- - - - - - - - - - XXXX XX XXX XX
& TEST SYSTEM INTECRATION & ----------------------------------------------------------------------------------------------------- XXXXXXXXXXXXX BACK-UP FACTORY DEth)
SYSTEMBACK-UP INSTALLATION IfGECHATION & ----------------------------------------------------------------------------------------------------------------- XXXXXXX ' 1000 IIR FIELD TEST -------------------------------------------------------------------------------------------------------------------------------- XXXXX NRC REVIEW ----------------------------------------------------------------------------------------------------------------------------------- XXXXXXXXXX T
ACACHMENT 7 Training Plan SPDS Training courses will be developed and delivered for users as well as plant operators prior to completion of operation of the system. The training program will be provided for SPDS users prior to completion of the system shop test and for plant operators at the completion of the 1000-hours test. E0P As part of the validation and verification of the new emergency procedures, a + training program on these procedures will be provided.
. A site-specific lecture course (approximately one week) will provide instruction in the use of E0Ps based on EPGs. This course includes a detailed discussion and explanation of all EPG concepts as they apply to each site-specific procedure.
This course will be delivered two months af ter . completion of the write-up of site-specific EOPs.
. A simulator course (appro::imately three days) will be provided covering the applications and use of procedures developed from the EPGs during simulated transients and accidents. This schedule is O
subject to availability of " slots" at the simulator.
. A site-specific control room walk-through course (approximately two days) utilizing site specific emergency procedures will be given to the supervisory and operating personnel. Operators are referred to control room panel indications and controls in specific emergency scenarios.
ERF Utility personnel manning the TSC (Technical Support Center) and EOF (Emer-gency Operation Facility) have been trained on manning assignments and responsibilities and equipment operation as presently exists in ~ the facilities.
. Classroom instruction followed by a written exam has been provided.
. Periodic drills to evaluate practical performance and to reaccess procedures and training have been performed.
Reg. Guide 1.97 Training will be provided as necessary where new instrumentation is in-troduced into the control room as a result of the R.G. 1.97 assessment. A training program consisting of training material. formal instruction and written exams will be established in a timely manner.
Page 2 O CRDR Any control room (CR) modifications which are introduced as a result of the control room design review will be addressed in the training plan. Integrated Training Plan An integrated Training' Program will be formulated to include training sessions on E0Ps, SPDS, ERF and control room modifications introduced as a result of the R.G. 1.97 assessment or the Detailed Control Room Design Review. The objectives of the integrated training program will be based on an analy-sis of the operator's performance requirements in each of the areas ad-dressed. The course lectures will be instructed by the specific objective method. The training program utilizes examinations and quizzes as necessary to evaluate the performance of trainees. In addition, individual performance during drills will be evaluated and critiqued to determine if the training program is meeting the specified objectives. Provisions will exist for revising the training program based on the evaluation of operator performance during the critiqued drills and normal job activities following training. Outline for Training E0P: - develop E0P training program O - classroom lecture training on E0Ps simulator training using newly developed
- E0Ps control room training using E0Ps ERF: -
training program already in place; District-developed as part of Emergency Plan implementation CR modifications resulting from Reg. Guide 1.97 ~ assessment and CR Design Review: - training to be implemented as needs are identified SPDS: - operator training on system use and operation Integrated Training Plan - implementation of. training incorporating C \/ all changes and revisions. i I
. .. 1 ATTACHMENT 8 Schedule Commitments / Estimates In accordance wi.S Supplement 1 to NUREG-0737, the District is submitting a proposed schedulo (Attachment 2) for completing each of the basic requirements for emergency response capability. Elements of this schedule indicate major milestones, particularly the necessary NRC submittals, in the implementation of the various emergency response improvements.
In order to establish a meaningful schedule, it is necessary to divide the submitted dates into two distinct categories: commitments and estimates. Commitment dates (denoted in Attachment 2 by a C) are provided for those items where we currently have sufficient information and control over the implementation process to establish a firm date for completion. Estimate dates (denoted in Attachment 2 by an E) are provided for those items where provisions for completing the individual item have not been finalized. Therefore, t h, estimated dates are based on review cycles and procurement times which are judged to be typical throughout the nuclear industry. To properly administrate the development and implementation of our schedule, we propose to establish a systematic dialog and review system between NPPD and the NRC. Through this process, we will be able to upgrade previous estimate dates to commitments while keeping the NRC fully informed of our status on the completion of commitments and upgrade of the estimated dates. O The systematic dialogue and review process would take place through a series of meetings between NPPD licensing personnel and c tr NRC project manager. At these meetings (or telephone conversations), we will brief the NRC on: (1) status of the completion of previous commitment dates, (2) proposed upgrade of estimated dates to commitments based on information acquired since the last update meeting or telephone contact, and (3) discussion of pertinent changes in the basis for either the estimated or commitment dates which may affect the ability of t;he District to comply with those dates. Excerpts from the District's Action item Tracking System (AlTS) and revised pages to this April 15, 1983, NRC submittal will be the vehicles by which the District's ! current status will be documented with the NRC Project Manager. For each meeting, NPPD will coordinate the overall licensing approach to j address all aspects of the emergency response improvements. Attention will be given to each of the licensing activities in addition to the integration of all the activities. We at NPPD feel that we have proposed a uorkable process for establishment of a schedule which is meaningful and agreeable to the NRC. We hope to continue in a cooperative effort with the NRC toward the implementation of the required emergency response improvements. l l lO
ATTACRMENT 9 () Emergency Response Facilities (ERF's) The District has essentially completed construction of the ERF's as defined in NUREG 0737, Supplement 1. Some of the requ:.rements of the Supplement renain to be met as part of the PMIS or Regulatory Guide 1.97 ef forts. The status of District activities in this regard are contained in the attached " Action Item Tracking" (AIT) table. The District will ensure that each requirement (or action item) in Supplement 1 is met by tracking all items on our AIT system. The NRC Project Manager will be provided similar tables for the other issues (i.e., SPDS, E0P's, RG 1.97, and DCRDR) at the routine meetings discussed in the schedule implementation program of Attachment 8. (:) - O
O o O . IIPPD ACTION ITEMS FOR .- RESPONDING TO SUPPLE 11EllT 1 TO NUREC-0737 DISTRICT RESPONSE ITEM REQUIREMENT EMERGENCY RESPONSE FACILITIES IS.8.2.1.a Technical Support Center (TSC) The TSC is the onsite technical support The TSC currently meets the intent of this center for emergency response. When requirement. Detailed information is contained in activated, the TSC is staffed by pre- the CNS Emergency Plan as follows: designed technical, engineering, senior CNS Staffing - Section 5.2.2(B) management, and other licensee personnel, Figure 5.2-2 and five predesignated NRC personnel. During periods of activation, the TSC will Table 5.2-1 operate uninterrupted to provide plant management and technical support to plant TSC Functions - Section 7.2.1 operations personnel, and to relieve the . TSC Floor Plan (Figure 7.2-1) further defines the reactor operators of peripheral duties and communications not directly related to functional requirements to be performed in this reactor system manipulations. The TSC will facility, as well as identifying the area reserved perform EOF functions for the Alert Emergency for five predesignated NRC personnel, class and for the Site Area Emergency class nnd General Emergency class until the EOF is functional. The TSC is located within the site protected area. IS.8.2.1.b The TSC will be located within the site Furthermore, the engineering portion of the TSC is protected area so as to facilitate necessary located in the Control Room; the remainder of the interaction with Control Room, OSC, EOF, and other personnel involved with the emergency. TSC is adjacent to the Control Room (see Figure 7.2-1 of the CNS Emergency Plan). Y The TSC will be sufficient to accommodate The TSC meets this requirement (see Figure 7.2-1 of i IS.8.2.1.c and support NRC and licensee predesignated the CNS Emergency Plan). personnel, equipment, and documentation in the center. IS.8.2.1.d The TSC will be structurally built in accord- The TSC is comprised of areas fabricated during ance with the Uniform Building Code. the construction of CNS; therefore, they meet structural standards of the UBC. 4
DISTRICT Resp 0NSE .' ITEM REQUIREMENT IS.8.2.1.e The TSC will be environmentally controlled The TSC ventilation system is comparable to the to provide room air temperature, humidity, Control Room ventilation system. Although not and cleanliness appropriate for personnel seismically qualified or redundant it does provide and equipment. the necessary environment for personnel and I equipment. IS.8.2.1.f The TSC will be provided with radiological As indicated in Figure 7.2-1 of the CNS Emergency protection and monitoring equipment necessary Plan, a portion of the TSC is in the Control Room. 1 to assure that radiation exposure to any Accordingly, the habitability of this portion of person working in the TSC would not exceed the TSC is identical to that of the Control Room 5 rem whole body, or its equivalent to any and therefore meets the intent of this requirement. part of the body, for the duration of the The portion of the TSC outside the Control Reom is accident. provided with radiological protection and , monitoring equipment to protect personnel under l most conditions, the exception being core I degradation and leakage to the area above the refueling floor. In the unlikely event that this type of accident were to occur at CNS, TSC l personnel would relocate to the Control Room, l the OCS's, and/or the EOF as defined in the CNS Emergency Plan implementing Procedures (EPIP'S). To ensure adequate radiological protection of the TSC personnel, a radiation monitoring system is provided in the TSC. This system consists of monitoring equipment dedicated to the TSC. capable of centinuous indication of dose rates and airborne radioactivity concentrations. 1.ocal alarms provida early warning to TSC personnel. The TSC ventilation system is comparable to the Control Room ventilation system. Although not seismically qualified, redundant, or automatically activated, it does include high efficiency particulate air filters and charcoal filtere. System capacity is based on design basis accident airborne radioactivity levels, independent of thyroid blocking provisions (potassium iodide).
.._m
O O O . ITEM REQUIREMENT DISTRICT RESPONSE IS.8.2.1.g The TSC will be provided with reliable voice The TSC is provided with adequate and reliable and data communications with the Control Room communications facilities. These are delineated and EOF and reliable voice communications in Section 7.2.1 of the CNS Emergency Plan (see with the OSC, NRC Operations Centers, and page 7-4). state and local operations centers. IS.8.2.1.h The TSC will be capable of reliable data The intent of this requirement will be met with collection, storage, analysis, display, and the implementation of P111S and RC 1.97. communication sufficient to dctermine site and regional status, determine changes in status, forecast status, and take appropriate actions. The following variables shall be available in the TSC: The variables in the appropriate Table I or 2 of Regulatory Guide 1.97 (Rev. 2) that are ensential for performance of TSC functions; and The meteorological variables in Regulatory Guide 1.97 (Rev. 2) for site vicinfty and National Weather Service data available by voice communication for d.e region in which the plant is located. Principally, those data must be available that would enable evaluating incident sequence, determining mitigating actions, evaluating damages, and determining plant status during recovery operations. - IS.8.2.1.1 The TSC will be provided with accurate. The TSC will have the necessary documentation to complete, and current plant records support TSC personnel. It should be noted that all (drawings, schematic diagrams, etc.) the records are not permanently stored in the TSC. essential for evaluation of the plant under They will he brought to the TSC as defined in accident conditions. EPIP 5.7.7, " Activation of Technical Support Center." IS.8.2.1.j The TSC will be staffed by sufficient Table 5.2-2 of the CNS Emergency Plan provides technical, engineering, and senior designated activation response times, all of which meet the liceasee officials to provide needed support, time frame specified. and be fully operational within approximately one hour after activation.
sx 7-~
\ .
ITEM REQUIREMENT DISTRICT RESPONSE . IS.8.2.1.k The TSC will be designed taking into account The TSC is already designed and good human factors good human factors engineering principles. are evident from the TSC function descriptions in the Emergency Plan. IS.8.3.1.a Operational Support Center (OSC) When activated, the OSC will be the onsite CNS has three such facilities. As indicated in area separate from the Control Room where Section 5.2.2(B)(2) of the CNS Emergency Plan, the
. predesignated operations support personnel liaintenance and OSC Coordinator, located in the will assemble. A predesignated licensee TSC, supervises the activities of the personnel official shall be responsible for cootdi- located in the electric /I&C and mechanical OSC's.
nating and assigning the personnel to tasks The Chemistry and itP Coordinator, Incated in the designated by Control Room, TSC, and EOF TSC, supervises the activities of the CNS Chemical / personnel. IIP OSC. It should be noted that each OSC has its own OSC supervisor. See Figure 5.2-2 and Section 5.2.2(C) of the Emergency Plan for further information. IS.8.3.1.b The OSC will be located ons'ite to serve as All three CNS OSC's are located onsite as follows: an assembly point for support personnel and to facilitate performance of support Chem / IIP OSC - Chem and llP Office functions and tasks. El. 918 of the Office Building Hechanical liaintenance OSC - Maintenance Shop El 903 of the Machine Shop ISC/ Electrical OSC - Electrical Shop El 932 of the Turbine Building (across the hall from the TSC) See Section 5.2.2(C) of the Energency Plan for further information. IS.8.3.1.c The OSC will be capable of. reliable voice All three OSC's are provided with reliable voice communications with*the Control Room, TSC, communications, and EOF.
r O O .O . ITEM REQUIREMENT DISTRICT RESPONSE IS.8.4.1.a Emergency Operations Facility (EOF) The EOF is a licensee controlled and operated These functions of the EOF are provided for in facility. The EOF provides for management of the Emergency Plan. The required data will be overall licensee emergency response, coordi- provided as a part of I'HIS. nation of radiological and environmental l assessment, development of recommendations for public protective actions, and coordi-nation of emergency response activities with federal, state, and local agencies. When the EOF is activated, it will be staf fed by predesignated emergency personnel identi-fied in the emergency plan. A designated senior licensee official will manage licensee activities in the EOF. Facilities shall be provided in the EOF for the acquisition, display, and evaluation of radiological an'd meteorological data and containment conditions necessary to determine protective measures. These facilities will be used to evaluate the magnitude and effects of actual or potential radioactive releases
-from the plant and to determine dose proj ections.
IS.8.4.1.b The EOF will be located ~ and provided with The new primary EOF that is located within 10 milet. radiation protection features as described of Cooper Nuclear Station (actually within 100 yard: in Table 1 (previous guidance approved by was designed and built to provide a protection the Commission) and with appropriate factor that satisfies the required factor of 5 in radfological monitoring systems. ' Table 1 and is equipped with IIEPA and charcoal filters. IS.8.4.1.c The EOF will be sufficient to accommodate The CNS EOF has been sized to provide sufficient and' support federal, state, local, and space for emergency response personnel to perform licensee predesignated personnel, equipment, their duties (see Figure 7.2-2 of the CNS and documentation in the EOF. Emergency Plan. IS.8.4.1.d The EOF will be structurally built in The EOF meets the structural requirements of the accordance with the Uniform Building Code. UBC (1979 Edition).
O O O . ITEM REQUIREMENT DISTRICT RESPONSE l Is.8.4.1.e The EOF will be environmentally controlled The EOF llVAC system provides ar environment to provide room air temperature, humidity, appropriate for personnel and equipment. and cleanliness appropriate for personnel and equipment. IS.8.4.1.f The EOF will be provided with reliable voice The CtIS EOF has the necessary communication and data comm:inications facilities to the facilities to support these goals. I TSC and Control Room, and reliable voice communication facilities to OSC and to NRC, state, and local emergen'cy operations centers. , IS.8.4.1.g The EOF will be capable of reliable collect- The intent of this requirement will be met with ion, storage, analysis, display, and communi-the implementation of PMIS and RG 1.97. cation of information on containment conditions, radiological releases, and meteorology sufficient to determine site and regional status, determine changes in status, forecast status, and take appropriate actions. Variables from the following categories that are essential to EOF functions shall be available in the EOF: Variables from the appropriate Table I or 2 of Regulatory Guide 1.97 (Rev. 2), and
-The meteorological variables in Regulatory Guide 1.97 (Rev. 2) for site vicinity and regional data available via communication from the National Weather Service.
IS.8.4.1.h The EOF will he provided with up-to-date The EOF has the necessary documentation to plant records (drawings, schematic diagrams, adequately support the functions to be etc.), procedures, emergency plans, and performed in it. environmental information (such as geophysical data) needed to perform EOF functions.
+
O - O O - ITEM REQUIREMENT DISTRICT RESPONSE a IS.8.4.1.1 The EOF will be staffed using Table 2 The number of preassigned individuals who will (previous guidance approved by the report to the EOF will provide adequate staffing Commission) as a goal. Reasonable exceptions in the event of an emergency. to goals for the number of additional staff personnel and resposise times for their See Tables 5.2-1, 5.2-2, and Figure 5.2-3 of the arrival should be justified and will be CNS Emergency Plan, considered by NRC staff. IS.8.4.1.j The EOF will be provided with industrial Once activated, security will be provided by the security when it is activated to exclude CNS Contract Security Force. (See EPIP 5.7.9, unauthorized personnel and when it is idic Attachment E.) to maintain its readiness. IS.8.4.1.k The EOF will be designed taking into account In the design of the EOF, good human factors good human factors engineering principles, engineering principles were used. In addition, a building with both a comfortable atmosphere and a pleasant environment in which to work. Provided in the EOF is a kitchen equipped with a refrigerator, a drinking fountain, men's and women's restrooms equipped with showers, sinks, water closets and lockers, and dressing sections located in the Whole Body Count Room. IS.8.4.2 Documentation and NRC Review The design of the ERF's satisfies the intent of . the NRC requirements as discussed above. Licensees should assure that the design of ERFs satisfies these requirements. Exemp-tions from or alternative methods of implementing.these requirements should be
- discussed with NRC staff and in some cases could require Commission approval. I.fcensees should continue work on ERFs to complete them according to schedules that will be negotiated on a plant-specific basis. NRC will conduct appraisals of completed facili-ties to verify that these requirements have been satisfied and that ERFs are capable of performing their intended functions.
Licensees need not document their actions on each specific .itgm contained in NiiREG-0696 - or 0814. .
i. l . .. . l 1 Nebraska Public Power District Octo'ver 18, 1983 Mr. Byron Siegel M/S 308 Project Manager - Cooper Nuclear Station Operating Reactors Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Byron:
Subject:
Revised Response to NUREG-0737, Supplement 1,
" Emergency Response Capability" - Revision 3
Reference:
(1) NPPD Letter from J. M. Pilant to D. G. Eisenhut dated April 15, 1983, LQA8300129, " Response to NUREG-0737, Supplement 1" Reference (1) is the District's response to Generic Letter 82-33, Supplement 1 to NUREG-0737, " Requirements for Emergency Response Capability", for Cooper Nuclear Station. Enclosed is Revision 3 to Attachment 2 to Reference (1) which includes changes in two dates. The changes are indicated by revision bars on the right-hand side of the page. These changes have been discussed with our NRC Project Manager and are necessary for the following reasons:
- 1. Regulatory Guide 1.97 Assessment Report Submittal Date Efforts to date in coordinating all Supplement 1 projects have shown that the instruments and parameters associated i with the Regulatory Guide 1.97 Assessment Report are also impacted by the SPDS, CRDR, and EOP upgrade projects.
It would be premature for the District to justify deviations or propose alternatives on November 30, 1983, when the other projects will not be completely assessed until March 1, 1984.
- 2. CRDR Summary Report Submittal Date I
! Efforts of tlse District's contractor have resulted in a better estimate of this submittal date. l M yP. 39f *
. .. , e, . , .
Page 2 October 18, 1983 O As discussed in Attachment 8 of Reference (1), the District will continue to keep you informed of the status of these projects. Sincerely, M - J. D. Weaver Licensing Manager JDW:emzl8/2 Enclosure bc: L. G. Kuncl J. M. Pflant R. E. Wilbur G. S. McClure K. C. Walden P. V. Thomason J. M. Meacham K. R. Wire D. A. Whitman R. O. Peterson O . e k O
.. . -- __________________.___.._._.____.____.__._._._________.___ij
y- ..m
' ::le: .7, ;"$2 ATTACHMENT 2 Impicmentation Schedule
( ! () INITIATIVE SPDS/PMIS MILESTONE Award of SPDS/PMIS Contract DATE Sep. 30, 1983 STATUS
- C Submittal of Safety Analysis Mar. 1, 1984 C and submit firm completion dates for remaining sched- ,
ule milestones SPDS Computer Deliver July 31, 1984 E and Install System Integration Complete Dec. 31, 1985 E SPDS Operable Feb. 28, 1986 E Operators trained Feb. 28, 1986 E Pre-Implementation Review by NRC (Verification & Valida-tion Review)
- Start Mar. 1, 1984 E
- Completion May 31, 1984 E
- Audit of installed Feb. 28, 1986 E system by NRC CRDR Select Contractor Aug. 1, 1983 C Submittal of Program Plan Mar. 1, 1984 C and submit firm completion dates for remaining sched-ule milestones Submittal of Summary Report June 30, 1984 E l Regulatory Submit firm completion dates Mar. 1, 1984 . C Guide 1.97 for remaining schedule milestones and submit Assessment Report Implement Requirements June 30, 1985 E E0P Upgrade Submittal of Generic Dec. 22, 1982 C Technical Guidelines Select Contractor Aug. 1, 1983 C Submit firm completion dates Dec. 30,'1983 e for remaining schedule milestones Submittal of Procedures June 30, 1984 E Generation Package Implementation of E0P's Dec. 31, 1984 E ERF/PMIS Emergency Plan Exercise April 6, 1983 C verifies facilities complete at this time Submit firm completion dates Mar. 1, 1984 C for remaining schedule milestones ERF's operational per Feb. 28, 1986 E
() Supplement 1 Exercise to verify April, 1986 E j facilities complete per Supplement 1 -
- E = estimate (subj ect to change)
C = commitmant
s 4 e
. N GENERAL OFFICE P.O. box 499. COLUMBUS. NEBRASKA 68601-0499 Nebraska publc omer strict O TELEeNoNE <4o23 se4-essi August 15, 1983 Mr. John T. Collins Regional Administrator U.S. Nuclear Regulatory Commission Region IV Gill Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011
Dear Mr. Collins:
Subject:
Response to Order Modifying License; Management Appraisal of Corporate Management Docket No. 50-298 License No. DPR-46 EA 82-46 Th'.s letter forwards the District's response to recommendations contained in the report of an independent appraisal of site and corporate nuclear management organizations and functions performed by LRS Consultants, Inc., of Idaho Falls, Idaho. The appraisal was conducted during the period February through April, 1983, pursuant to the subject Order Modifying License Effective Immediately dated August 9,1982. Section IV of the Order required that within 30 days of receipt of the appraisal report the District was to submit an analysis of each report recommendation, action to be taken in response to the recommendations, and a schedule for accomplishing the actions . Your letter of June 21, 1983, extended the submittal date to August 15,1983,-in answer to our letter request dated June 9,1983. l The responses in the attachment are organized in the same l functional areas presented in the LRS Report. The i recommendations are numbered as in the- report and are repeated I l in the attachment for case of review. Milestone and completion dates for intended actions have been :specified where possible. The District 13 committed to maintaining the superior performance record of the Cooper Nuclear Station and its operations in a safe and reliable manner. Senior management has analyzed the Report's recommendations with this objective in mind.
/3
@ 9 j 36 f*
Mr. John T. Collins Page 2 August 15, 1983 O is you are awere. the District hes mede significent menegement l
> changes, both at the Cooper Nuclear Station and at the General Office in Columbus. Described in the attachment are further actions intended to enhance communications, support, training, operr.tions , and management overview within the District's
! nuclear organization to maintain, and improve where possible, the safety and efficiency of our total nuclear program. Progress toward completion will be closely monitored to assure the successful accomplis.hment of these committed tasks. The Board of Directors and I are committed to assembling and maintaining a nuclear management team which reflects the high standards of excellence which exists within the nuclear industry. We are confident that the steps we are taking will achieve this desired result. Our efforts in this regard will continue. We believe that this submittal completes all required actions relative to the Order Modifying License.
- Now that the management evaluation and our assessment of its ~'
recommendations have been concluded, we are not aware of any reason under applicable regulations to request that the LRS Report or inis submittal be withheld from public disclosure. . If you desire any other information, please advise. O sineereir. NEBRASKA PUBLIC POWER DISTRICT h Don E. Schaufelberger General-Manager DES / gat:emzll/3 Attachment be w/ attachment: l Board of Directors (cne each) E. N. Sloth D. E. Schaufelberger 4. M. Pilant G. D. Watson J. D. Weaver J. R. McPhail F. E. Williams l F. G. Yanney V. L.-Wolstenholm D. A. Blatchford C. D. Sayre C. R. Jones J. R. Bull (IP&L) w/LRS Report T. M. Kyster J. Brockmeier (R. W. Beck) , W. A. Merrill' B. Abernethy (LES) w/LRS Report L. G. Kunci (3) B. Siegel (NRC) R. S. Kamber D. L. DuBois (NRC Resident Inspector) G. S. McClure J. M. McGarrey'III (D&L) P. V. Thomason l l
- - rw --
- a-wg awi.-y ,,y.g-u gg e-r- w'e-tM---y +-er- .M'-*n vW P y, rwap v *rry - y +F a --
er er rp -g' -n'Y F-M' N d 4 F 8" " A
ATTACHMENT ORGANIZATION, MANAGEMENT. AND PERSONNEL O o RECOMMENDATION OM-1 The Board should develop some long-range overall Goals and Objectives for the District that could be adjusted from time to time but would survive Board member changes.
RESPONSE
The General Manager is currently =eeting periodically with the Board of Directors with the express purpose of developing long-range goals and objectives for the District. The work effort is already underway. An initial draft will be discussed with the Board prior to the Septe=ber =eeting and it is expected that the final document will be approved by the Board by year-end 1983 with further efforts continuing chereafter. o RECOMMENDATION CM-2 The staff should develop near-ter= and long-tern strategies, plans, and progra=s throughout the organization that will accomplish the Board's overall direction.
RESPONSE
The staff developed on July 15 a format and some initial goals and objectives based on anticipated overall objectives of the District. As the Board defines and pro =ulgates the District objectives, the specific goals of the nuclear organization will be modified, amplified, or revised to best support the Board's objectives. A first draft of the nuclear organization's goals as agreed upon by all key =anagers will be submitted to the General Manager by Nove=ber 15, 1983, for review and co= ment. The final set of approved goals and objectives will be issued by December 15, 1983, for the calendar year 1984 o RECOMMENDATION OM-3 The Board should consider more definitive delegation cf broader authority to the General Manager thus re=oving itself further from operational details. A clear job description would be necessary in this regard.
RESPONSE
The Board of Directors will consider further delegation of broader authority to the General Manager recognizing applicable limitations existing in Nebraska Statutes. The General Manager will develop a job description by September 15, 1983. The job description will be Os submitted to the Board of Directors for review at the September 1983 Board Meeting. The job description will be finalized in October, 1983, and approved at the October 1983 Board Meeting.
. > i
\
l ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) ; O o RECOMMENDATION OM-4 Top management needs to improve significantly its nuclear co=munications to the Board, which in turn needs to be receptive. , 1
RESPONSE
The Assistant General Manager - Nuclear has instituted a practice, as i=portant matters arise, of sending relatively brief, but ! informative letters to the Board to forewarn them of coming problems. The Nuclear Pcwer Group staff is currently considering
- additional mechanisms to ef fectively enhance information flow to keep the Board better informed. Key among these is a proposed recc==endation that the Board consider the establishment of a Nuclear Pcwer Co=mittee, which, during monthly =eetings, could be briefed in detail on nuclear industry activities specifically relevant to the operation of CNS. The Board, on the other hand, has significantly increased its attention to and awareness of nuclear matters. As a result, the Board has been very supportive of the efforts being =ade to i= prove the District's nuclear program, o RECCMMENDATION OM-5 t
Team work between the Board and =anage=ent based on mutual trust and i respect, needs to be developed.
RESPONSE
The Board and Distric =anagement are dedicated individually and collectively to developing and maintaining team work in order to best support the safe and efficient operation of the Cooper Nuclear Station. The Board President and the General Manager have as the District's top priority the forming of a strong team at NPPD that will work together to the benefit of all the District's customers. A Board Co=mittee is currently working with the General Manager to develop this tea = work statement. As a result of discussions between the Board and District =anagement, concerning the LRS audit findings, a more frank and open relationship has developed which, we believe, will result in mutual trust and respect. i
l ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) O U o RECOMMENDATION OM-6 Top =anage=ent needs to =ake some hard and possibly unpleasant decisions to gain credibility with the Board.
RESPONSE
Top =anage=ent has =ade some hard decisions in the very sensitive area of personnel changes. There have been several changes at the Assistant General Manager level, including one termination, two prc=otions, and two reassign =ents. A senior division position has been eliminated, a plant superintendent removed, and several division and department =anagers ter=inated, reassigned, or de=oted, depending on specific circu= stances. In addition, the nuclear organization has been restructured for = ore effective perfor=ance, efforts are being =ade to recruit experienced persennel for several key positions and an extensive effort has been
=ounted to clear up confusing organizational interrelationships.
o RECOMME'!0ATION OM-7 (} A planned progra= needs to be developed for assuring the continuing A/ provision to Board =e=bers of critical nuclear information. This should not be acco=plished with pounds of docu=ents but by carefully abstracting vital inf or ation f rc= NRC, NSAC, IN?O, NPPD and other utilities and providing approxi=ately a one or two page su==ary each week. This document might serve a useful function for senior staff also.
RESPONSE
The Assistaat General Manager - Nuclear will be briefing the Board on the status of nuclear generation at each Board =eeting. This level of contact is i=portant and ef fective in keeping the Board
=e=bers appraised of significant nuclear =atters.
In addition, the Assistant General Manager - Nuclear will provide a brief report of various nuclear topics to the Board of Directors, the General Manager, and senior staff at his discretion. Also, the Nuclear Power Group staff is currently considering additional
=echanis=s to ef fectively enhance infor=ation flow to the foregoing.
i
ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) O o RECOMMENDATION OM-8 Establish the position of Assistant General Manager - Nuclear, with clearly defined responsibilities, duties, and authority.
RESPONSE
The position of Assistant General Manager - Nuclear has been established. A draft position description has been prepared and is currently being reviewed. The position description, with clearly defined responsibilities, duties, and authority, will be approved by October 1, 1983. o RECOMMENDATICN OM-9 Either assign an AGM - Nuclear from within the District or if no one internally is dee=ed qualified, select an Acting AGM and initiate recruiting efforts prc=ptly.
RESPONSE
An individual to fill the position of Assistant General Manager - Nuclear has been selected f rom within the District and has been j O assigned the responsibilities of the position, o RECOMMENDATICN OM-10 Consider organizing the Nuclear Operations of the Dis rict in general accordance with the attached organization charts, Figu.es 2-1, 2-2, 2-3, and 2-4
RESPONSE
An organization chart of the Nuclear Power Grou;. including Depart =ent Manager level positions, was transmitted :6 NRC - Region IV by Mr. D. E. Schaufelberger's letter dated July . . 1983. This organization was discussed with various NRC staff personnel at a =eeting held at Region IV on July 21, 1983. O
ORGANIZATION. MANAGEMENT. AND PERSONNEL (Cont'd) o RECOMMENDATION OM-Il Develop jurisdictional statecents for the nuclear organization and for its components.
RESPONSE
Organizational descriptions will be prepared for the nuclear group and each subordinate division and department. These descriptions will specify functional responsibilities and organization structure and will define interface relationships between the subordinate units of the group and between the nuclear group and other NPPD organizations. These descriptions will be completed by January 1, 1984 In the interim, the nuclear organization will function under general guidelines premulgated by the Assistant General Manager - Nuclear. o RECCMMENDATION OM-12 Develop clear and accurate position descriptions ror all key nuclear and nuclear support personnel. RESPONSE (Proposed) Position descriptions for key nuclear =anagement personnel will be written as part of the nuclear group organizational development. These descriptions will be =aintained in a central file and will be reviewed and revised as necessary at cwo year intervals. Initial position descriptions for all key nuclear personnel vill be produced and on file prior to January 1,1984 o RECOMMENDATION OM-13 Several present line and support manage =ent personnel should be considered for removal from the nuclear =anage=ent structure of the District to allow for promotions and/or new personnel.
RESPONSE
Several line and support management personnel have been removed from the nuclear management structure of the District. These changes at the Cooper Nuclear Station and within the nuclear support organization at headquarters have permitted the District to advance certain District personnel to increased levels of responsibility. The District will consider the promotion / reassignment of existing personnel or the recruit =ent of new personnel to fill positions created by the establishment of the new nuclear group. O
I I ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) 1 o RECOMMENDATION OM-14 i Active involve =ent of General Office management in the CNS cust be developed. Conversely, CNS canage=ent needs to eliminate the isolation it has established and become active participants with the General Office.
RESPONSE
i l Recent =anagement changes have already resulted in an improvement in working relationships and effective communications between the General Of fice and the Cooper Nuclear Station. The new nuclear group organizational descriptions will emphasize close relationships and active participation in a " team" concept among all nuclear subordinate units. Meetings between Cooper Nuclear Station and General Office
- counterparts are occurring on a routine basis. The Division Manager of Nuclear Operations is involved in the planning and structuring of the Suelear Power Group. Two CNS personnel have been "on loan" to
- the General Of fice to aid in the reorganization, produce job descriptions, etc.
i fs Additionally, General Office personnel are visiting the CNS and discussing current situations and problems with CNS personnel on a routine and frequent basis. i } l ) i l i I O .
. . . .- - w. - . .~.-, , - .- - . - - . - . . . . . - . - , , . -,.w.- . .-, . , - - - , - , - - -
1 j ORGANIZATION, MANACEMENT, AND PERSONNEL (Cont'd) ! o RECOMMENDATION OM-15 Manage =ent training and development programs need to be implemented for the nuclear managers and supervisors.
RESPONSE
Management and supervisory training, as in the past, will continue to be available from the Columbus General Office Training Depart =ent to aid in the management training and development of the Nuclear staff. At present, the Colu= bus Training Department is offering courses on Supervisorv Skills, Interviewing Skills, Performance Appraisal. Ti=e Manage =ent, Motivation, Planning and Conducting Meetings. Individual Assessment Profile, and a course on Written Co==unications throughout the Nebraska Public Power District's organization, including Cooper Nuclear Station. Training programs to be available in the near future include Equal E=ployment Opportunity Training, Stress Management, and a Human Values System workshop. To enhance the scheduling and availability of these training progra=s to supervisor and =anage=ent personnel throughout the District, the Colu= bus Training Depart =ent will publish a schedule of these training activities. This schedule v'ill be available to management throughout Nebraska Public Power District including the Cooper Nuclear Training staf f and will aid in the coordination of activities between the Nuclear and Columbus General Office Training Depart =ents. o RECOMMENDATICN OM-16 The District needs to develop a succession planning program, especially for key positions such as CNS Superintendents, division sanagers, and the AGM - Nuclear. RES?0NSE The District recognizes that an overall succession program is a vital part of a s=oothly functioning organization. We believe that the development of such a program will require significant input and participation of all senior personnel in the Nuclear Power Group. Therefore, detailed planning will be initiated as soon as practicable upon completion of the key personnel staffing. We anticipate that the program will be functional by the end of calendar year 1984. I A k-)
ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) O o RECO>SiENDATION OM-17 Delegation of signature authority for routine matters should be encouraged and supported at all levels of management.
RESPONSE
Several actions, relating to delegation of signature authority, have already occurred. Some of these are as follows:
- 1. The General Manager has delegated approval of travel authorizations to the Assistant General Managers,
- 2. The Assistant General Manager - Nuclear has delegated approval of purchase orders, less than S20,000, which do not involve professional services, to the Division / Department Managers. Furthermore,. the AGM -
- Nuclear has asked that the Division / Department Managers i
review their operation to determine whether purchase order approval should be delegated further.
- 3. The Division Manager of Nuclear Operations (CNS) has delegated the signing of time sheets to his various depart =ents.
The General Manager and Assistant General Manager - Nuclear will O evaluate the delegation of additional signature authority to the Division / Depart =ent Managers. This evaluation will be complete by l the end of 1983. Some signature authorizations which will be evaluated are as follows: Payroll Change Authorizations Capital Budget Requests (Pila) less than $50,000 Work Orders less than S50,000 Work Order Supplements less than $50,000 above the original Work Order a=ount Travel Authorizations Overtime approval Some of these items may be delegated to area supervisors pending further review. O
l
\
ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) (:') ! o RECOMMENDATION OM-18 Management and the Board should recognize the hazards to safe and ef ficient operation resulting from high turnover of key personnel at CNS and take action to reverse this trend.
RESPONSE
Management and the Board of Directors do recognize the hazards to l safe and efficient operation resulting from high turnover of key personnel at CNS. Management has and will continue to implement programs that are intended to reverse this trend. Some actions have already been taken to reverse the high attrition rate .at CNS including the following: o Station management and personnel changes o District organization changes including expanded staffing o I= proved co==unications between the Station and the General Office o Development of integrated tea = work o I= proved the license bonus administration o Filled some long existing vacancies o Established a training organization (} o Initiated review and evaluation of salary levels I i 1 O _9_
7____. ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) O o RECOMMENDATION OM-19 Recruitment of supervisory personnel with nuclear and management experience for assignment to CSS and the General Office shot'.d be a high priority effort of the District. o RECOMMENDATION OM-22 Line nuclear management needs to work closer with the recruiting personnel to better assure meeting the staffing needs of CNS and supporting organizations.
RESPONSE
The Assistant General Manager - Nuclear is placing high priority on the recruitment of qualified and experienced personnel for assign =ent to positions established within the nuclear group. He is working in close coordination with the Personnel Manager in this effort. The Personnel Department will provide the Assistant General Manager - Nuclear a monthly report of nuclear group staff vacancies, su ary of recruiting efforts, job offers made, acceptances, rejections, and other related information. This report will be used to =enitor staf fing efforts such that corrective actions can be taken wnere appropriate. In addition, coordination between CNS and the General Office Personnel Department has been improved. For example, the Recruiting Supervisor is now periodically visiting the station to gain a better appreciation of the station's needs in order to do a more thorough job of screening resumes and assisting the site in obtaining the best qualified candidates for employment. O
9 ORGANIZATION. MANAGEMENT AND PERSONNEL (Cont'd)
- O
! o REC. 'DATION OM-23 i
; Personnel in supervisory or management positions that are impeding the growth potential of more productive employees, should be considered for reassign =ent to allow upward movement of present subordinates.
l
RESPONSE
4 Several individuals in supervisory or management positions have been removed from the management chain, thus opening up numerous a opportunities for promotion and advancement. o RECOMMENDATION OM-24 r The staf fing level and average competence / experience level of the staff needs to be increased through active recruitment and acquisition of experienced nuclear personnel, through improved training of present personnel and through significantly reducing attrition.
RESPONSE
The Assistant General Manager - Nuclear will direct the development
, of a Comprehensive Personnel Staffing and Development Plan for the , \ nuclear group. This plan will include the preparation of detailed ! descriptions for posittons within the group and an assessment of the j qualification and experience requirements for personnel filling these positions. Increased emphasis will be placed on meeting the ; nuclear group training needs through the General Of fice Nuclear ; Training Program. Mtile portions of this plan will be developed on a priority basis, the entire plan is expected to be in place by the end of calendar year 1984 1
i 4 i f 0 lO P , _ __-.-_. ,- _ _ ._ ,,_.-. _ _ ~-._._._.-.- ._,_ ,_.. -... _.._ _...__ ._,_.,.._.. _ ,_._,
i . I. . ORGANIZATION, MANAGEMENT, AND PERSONNEL (Cont'd) iO o RECOMMENDATION,OM-20 , The District should assure that their compensation policy is competitive I with the rest of the nuclear industry. l t
RESPONSE
l Comparative salary data has been obtained and efforts are underway 1 to expedite processing the necessary upgrading of salary ranges in
! many key areas. Although there will undoubtedly be further
, refinements required, we intend to have new salary ranges in place by the end of calendar year 1983.
]
i [ o RECOMMENDATION OM-21 3enefits should be evaluated and =odified, if required, to assure the i ability of the District to attract new, senior nuclear personnel and to transfer present personnel as needed between the GO and CNS.
- RESPONSE j The District evaluates benefits on an annual basis as requested by 2
the Board of Directors. Management =akes requests to the Board for 2 (Q/ changes in benefits and wages usually in the month of August of each year to be initiated either October 1 or January 1. In 1982, management submitted a proposal to pay interest differential for all new hires and transfers within the District; however, the proposal was not approved by the Board. We believe that, since discussions held with the Board subsequent to the =anagement audit, and pursuant to its recommendations, the
- merits . of having a competitive benefit program is currently more fully appreciated and, as'a consequence, will result in Board j approval of improved benefits where warranted.
A study of industry-wide benefit programs will be undertaken as a l supplementary part of our normal benefit evaluation program. The i results of this effort will be utilized in formulation of l recommendations for submittal and approval - by the Board of Directors. i I l O
- - . , - - . , . - , , _ . . ~ , , _ . - , , . . . _ , _ . , , _ . - - . - , . _ , _ . _ , _ . . . - . , - . , . , . , . , ,
~l
E SAFETY C01011TTEES O o REC 0F0iENDATION S-1 SRAB Consideration should be given to a more formalized review of items of potential safety significance in committee. 4 RESPONSE A subcommittee of SRAB recently reviewed the existing SRAB Charter and Procedures and produced an updated draf t of these documents. The draft was recently approved by NPPD Management. Included in the present SRAB Guidelines and Instructions are requirements for a more d formalized review of items of potential safety significance in
, committee. These new Guidelines and Instructions will be I
implemented by October 1, 1983. i 1 o RECOMMENDATION S-2 SRAB Consideration should be given (a) to expanding the Board size to enhance the coverage of all the necessary disciplines and technical competence required, (b) to designating members with more time to devote to the reviews, and (c) to including at least one member of SORC on the Board.
RESPONSE
O A subec ittee of SRAB hac recently reviewed the existing SRAB Charter and Procedures and has produced an updated draft of these documents which has been approved by NPPD Management. SRAB
; membership will be expanded from five members to seven meebers. In addition, a full-time non-voting SRAB Administrator will assist SRAB.
The membership of SRAB presently consists of managers with considerable line responsibility. The draft proposes a change whereby some or all of these managers may be replaced with staff technical people or people with less line management responsibility. This will permit SRAB members to devote more time to SRAB activities. In order to provide needed operational input to SRAB deliberations, one member of SORC will be designated by the SORC chairman to serve as an ex-officio member of SRAB. In addition, consideration is , being given to having shift supervisors participate in SRAB meetings i on a rotating basis to provide ' additional operations insight and increased intercommunications between CNS and the GO. l
- 0 t
l l l __ _ , _ . . _ . _ . , . . - . . _ . . . _ _ _ , . _ -- - . . , _ , _ _ -. _ _ . _ , . _ . . - _ _ . - .
SAFETY COMMITTEES (Cont'd) V o RECOMMENDATION S-3 SRAB A training program should be developed and implemented.
RESPONSE
The present SRAB Guidelines and Instructions contain a section on SRAB training. Essentially, this training consists of approximately 40 hours of instruction each year on SRAB duties and responsibilities, 10CFR50.59 and CNS systems. This training program will be imple=ented by October 1,1983. o RECOMMENDATION S-4 SRAB Assure tha active support of the General Manager to the SRAB and assure the independence of the Chairman.
RESPONSE
The revised SRAB Policy, promulgated by the General Manager, delegates the authority and responsibility for safety review activities to the Assistant General Manager - Nuclear. The AGM - Nuclear has designated a Chair =an for the Safety Review and Audit f") Board to become effective October 1, 1983, to allow for an orderly transition from the current Board, o RECOMMENDATION S-5 SRAB A review should be performed to assure that all activities specified for SRAB review or other activity (e.g., audits, witness of plant operations, procedure r? views, etc.) are being perfor=ed according to prescribed
=ethods and schedules.
RESPONSE
Quality assurance already performs audits of SRAB activities. The current examination and revision of the SRAB Charter and Procedures has also resulted in additional scrutiny of SRAB activities. The new SRAB Guidelines and Instructions and the reconstitution of SRAB membership, including a full-time SRAB Administrator, will cause SRAB activities to be performed more thoroughly and vigorously. I O l
SAFETY COMMITTEES (Cont'd) o RECOMMENDATION S-6 SRAB Consideration should be given to revieu by SRAB of the various industry and NRC operational event information.
RESPONSE
INFO SOER's have been routinely routed pursuant to SRAB procedures for review and evaluation. NRC bulletins, notices, and other documents related to nuclear safety have been routed to personnel involved in the District's nuclear activities, but not pursuant to SRA3 procedures per se. SRA3 routing of such documents is being imple=ented pursuant to revised SRAB Guidelines and Instructions. o RECOMMENDATION S-6 SORC Consideration shculd be given to assuring that all items of potential safety significance are reviewed in a meeting.
RESPONSE
CNS concurs that all ite=s of potential safety significance should be reviewed by SCRC, meeting as a committee (not privately by SORC () committee members as was done previously) . A new SORC Charter, which includes this require =ent, will be implemented by January 1, 1984
~~ ~~
o RECOMMENDATION S-7 SORC Any inconsistencies between the Administrative Procadures (i.e., 1.18, 1.3, 1.12, 1.10, 1.13) and Section 6.2.1 of the Technical Specifications need to be rectified.
RESPONSE
A review of the docu:2ents identified in the recommendation is underway. Inconsistercies have been found and noted and these inconsistencies will be rectified based upon the SORC reorganization. l Review and correction of the applicable administrativa procedures will be completed prior to January 1,1984 l O i
LICENSING
\
(d o REC 0501ENDATION L-1 The corporate signature authority in trans=itting official, attested infor=ation to the Nuclear Regulatory Coc=ission should be changed f ro= the Division Manager for Licensing and Quality Assurance to the Assistant General Manager having line =anagement responsibility over the operation of the Cooper Nuclear Station. While the licensing group would still play its extant role in disseminating and collecting licensing infor=ation, the official transmittal to the NRC would have the benefit of line =anage=ent authority and accountability.
RESPONSE
All future trans=ittals to the NRC, which are signed under oath or affir=ation, shall be signed by the Assistant General Manager - Nuclear. Signature authority for correspondence other than noted above has been delegated to the Manager, Technical Staf f, Nuclear Power Group. o RECOMMENDATION L-2 A for=al syste= should be i=plemented to track NRC co==it=ents made at
. CNS through LER's or other documents.
('v') RESPONSE Within the new CNS organization structure, the position of Regulatory Compliance Specialist has been established. Responsibilities of this position will include review of CNS correspcndence to the NRC and other organizations'to deter =ine whaT -
~
co==it=ents have been =ade. The co==itsents will be tracked and closed out upon co=pletion. Procedures for= ally defining the tracking syste= operation will be generated / reviewed / revised by January 1, 1984 o RECOMMENDATION L-3 Consideration should be given to expanding the licensing staff by one individual to allow proactive participation in future licensing issues.
RESPONSE
The need for additional licensing support is recognized and an evaluation was perfor=ed to deter =ine specifically what form such support should take. Under the new organizational structure, the Licensing and Safety Depart =ent will be responsible for various nuclear safety related functions. An authorization for an (] additional licensing engineer has been approved by District
=anage=ent.
t ENGINEERING 1 o RECOMMENDATION E-1 l l An overall document or charter should be prepared that defines how l I engineering support for the Cooper Nuclear Station is to be provided. Included in this document should be a discussion of how the configuration management of the engineering design bases and the as-built configuration
- of the plant are to be =aintained. In drawing up this engineering
! charter it is suggested that consideration be given to establishing one engineering function that reports on-site and is charged with the ! maintenance type engineering to maintain plant operation and an engineering group that reports off-site that is charged with the longer range, plant improvement proj ect s . As noted in the Organization, Management, and Personnel section of this report, both engineering groups should be in organizations that report to a single Assistant General Manager - Nuclear.
RESPONSE
The AGM - Nuclear has established general guidelines regarding the charters of the site and offsite engineering organizations. The managers of these two groups are to coordinate the development of the charters. The AGM - Nuclear and the Technical Staff Manager
- will review and approve the prepared charters. The finalized charter and interface docu=ent will be completed by September 15, 1983.
o RECOMMENDATION E-2 Active steps should be taken to provide the General Office engineering group with scheduled plant-specific systems training. Consideration should be given to including the General Office engineers in the systems training courses being given by the Cooper Nuclear Station engineering group.
RESPONSE
l A training program for General Office, nuclear work-related employees has been under development for several months. The General Office engineers will be scheduled to take the systems training courses currently given at CNS. This will have the immediate advantage of interaction between the two groups, development of personal relationships, ability to gain " hands-on" training when applicable and efficiency and standa-dization in CNS related trainiag. This program will be implementeu subsequent to
- STA training. It is anticipated the training will begin by January 1, 1984 O
2 3
-17
ENGINEERING (Cont'd) O o RECOMMENDATION E-3 An evaluation should be conducted as to how to minimize the transportation proble= caused by the remoteness of the Cooper Site. Consideration should be given to scheduled flights from Columbus to a suitable airstrip near the CNS to maximize the on-site hours a General Office engineer could provide when working on a CNS project. Alternatives should be considered such as moving the off-site engineering group to facilities that are closer to the Cooper Station (e.g., the EOF building or co==ercial space in one of the nearby towns).
RESPONSE
The problem regarding transportation of General Office engineers to Cooper Nuclear Station has been addressed several times in the past. Informally scheduled flights between Columbus and CNS are currently provided. An investigation of regularly scheduled aircraft use will be perfor=ed by February 1, 1984, for both outage and routine operations. Should such use prove to be cost-effective, a program will be proposed for District canagement approval. Relocation of the General Office engineering organization to facilities closer to CNS is not considered an acceptable alternative. o RECOMMENDATION E-4 With the departure of the recent Cooper Nuclear Station Engineering Supervisor, consideration should be given to effecting personnel changes in the General Office nuclear engineering group that would more readily assist in the build-up of a healthier interface relati'onship.~ RESPONSE _ A change has already been =ade in the General Office Nuclear Engineering Department. Through reorganization, the Manager of the Nuclear Engineering Department has been replaced. It is felt that this personnel change will enchance and i= prove the working relationship between the CNS Engineering Supervisor and the General Office Nuclear Engineering Department. o RECOMMENDATION E-5 A program of assignments of new General Office engineers to the Station for six to twelve months shoul_d be considered, as should a program of interchanging engineers between CNS and the GO.
RESPONSE
Integration of the interchange program into Engineering career path development is being considered. The Nuclear Services / Nuclear Operations Division Managers will be responsible for developing a O proposed program for =anagement review by July 1, 1984
OPERATIONS
~
(V) o RECO>SiUDATION 0-1 High priority should be given to the retention of licensed operators and to the development as soon as possible of a sixth shif t.
RESPONSE
A high priority is being given to the retention of licensed operators. Recently, a license bonus was established for SR0s and R0s in order to help reduce attrition. The necessary plans have been established to provide for sixth shift operation. As soon as there are enough SR0s and R0s to properly =an the required positions, a six shift rotation will be instituted at which time the sixth shift will be a training shift. Contingent on completion of the Engineering STA Training Program and operators receiving their licenses, the rotation is scheduled to be implemented by the end of 1983. A co=pensation survey has commenced. Upon receipt of the sur-rey results, competitive compensation levels will be established. o RECOMMENDATION 0-2 Consider increasing the comple=ent of Station operators to provide a larger pool from which to draw future R0 and SRO candidates.
RESPONSE
An additional four station operators have been included as part of the proposed reorganization. o RECOMMENDATION 0-3 If the two functions of shift supervisor and shift technical' advisor are combined, specific instructions must be issued to the shift supervisor that in upset plant conditions he must stand back and exercise control from the broader perspective of the total plant condition.
RESPONSE
Specific instructions have been issued to the shift supervisor. o RECOMMENDATION 0-4 Incorporation of the TSC in the control room should be reevaluated.
RESPONSE
A portion of the control room which is separate from the main control staging area is presently used as the Engineering operations section of the Technical Support-Center. There are no plans to
. further incorporate the TSC into the control room.
1 MAINTENANCE o RECOMMENDATION M-1 Improvements in the area of personnel recruitment and retention must be c:ade immediately with critical attention to the I&C area. In addition to attempting to understand and correct the causes for the high attrition rate in the I&C area, steps should be taken to expedite plant-specific training.
RESPONSE
In recognition of the need to upgrade the I&C area, the reorganization establishes the I&C area at a higher level equivalent to the =aintenance and operations organizations. In the restructured organization, the ISC Supervisor reports directly to the Operations Manager, the positions of Foreman and Lead I&C Technician have been established and four additional technicians have been authorized. I&C will begin systems training within the I&C group by Dece=ber 1, 1983. Additionally, the proposed Training Depart =ent includes the full time training position of ISC and Electrical Instructor. o RECOMMENDATION M-2 Estimates should be =ade of expected attrition rates and a personnel acquisition program should be put in place to provide a cadre of personnel in training to successfully counter the expected losses.
RESPONSE
The new organizational structure includes an additional eight positions in the maintenance area in crder to maintain an adequate number of experienced personnel in view of anticipated attrition. o RECOMMENDATION M-3 The manage =ent structure and qualifications of incumbent personnel in the maintenance organization should be reviewed to determine if changes would improve morale and inhibit attrition.
' ~ ~
RESPONSE
'~
The recent reorganization has taken this recommendation into account. Additionally, we believe that incumbent personnel qualifications will be improved through the upgraded formal training program. O MAINTENANCE (Cont'd) o RECOMMENDATION M-4 A review should be conducted to determine the advantage / disadvantage of changing CSS Administrative Procedure 1.7.1 to require that all work on Essential systems be covered by a Maintenance Work Request (MWR).
RESPONSE
Procedure 1.7.1 has been revised and implemented to require that all work on essential components is covered by an MWR, O
%.m -ea, O
TRAINING o RECO?EENDATION T-1 ! A Training Department should be organized under the leadership of a single supervisor with full responsibility for licensed and nonlicensed on-site training.
RESPONSE
A Training Department is included in the CNS reorganization plan which will provide adequate staffing to meet training requirements. The structure includes a Training Department Manager assigned responsibility for the entire on-site training program. At this time a Training Department Manager has been assigned. Additionally, General Electric will provide an on-site General Electric Training Manager and two General Electric licensed instructors to augment the CNS training staff which consists of one full ti=e Shift Supervisor /SRO acting as Operations Training Supervisor and one fell time Education Specialist.
, o RECOMMENDATION T-2 One of the first responsibilities of the new training supervisor should
,' be the generation of a comprehensive CNS training program detailing the . training needs and the resources to carry out the program.
RESPONSE
The Training Manager has been assigned full authority and 1 responsibility for development of a comprehensive training program. Resources to fulfill the expected program requirements have been specified in the CNS reorganization plan. 1 o RECOMMENDATION T-3 An additional licensed instructor and training clerk to maintain records should be added to the staff along with the assignment of the present j training shift supervisor full time to the Training Department. l
RESPONSE
The new training organization at CNS includes the above l recommendation except for clerical support.- Clerical' support will be provided by the CNS Administration Department. O
! . l TRAINING (Cont'd)
O' o RECOMMENDATION T-4 l The Training Manual should be upgraded and systems descriptions should be updated to more accurately reflect the present status of the plant. More l emphasis should also be placed on balance of plant systems training. ! RESPONSE ) The Training Manager has been assigned full responsibility for generation of a new Training Manual written to reflect the current
- status of the plant. The =anual will include additional emphasis on i
balance of plant training. The =anual will include updated system descriptions in a lesson plan format. The District has contracted i for various training services with the General Electric Company. As part of these se rvices , General Electric is to generate the foregoing documents during the course of the two-year contract. 4 o RECOMMENDATION T-5 Consideration should be given to relocating formal training to classroom
- facilities at the new EOF or at another centralized location.
RESPONSE
Relocation of the Training Department to the new EOF has been j () accc=plished. Additienally, accoc=odation of Training Department space requirements in planned warehouse facility expansion is under consideration. 1 o RECOMMENDATION T-6 The sixth shif t should remain in normal rotation and dedicated to
! requalification training of incumbents. ,
RESPONSE
{ The sixth shift will be used specifically as an In-training Shift. o RECOMMENDATION T-7 i NPPD should review the STA training situation and determine if remedial
- training is appropriate for incumbent shif t supervisors.
I RESPONSE ) The District has reassessed the STA staffing philosophy at CNS. As a result, an STA training program has been implemented to qualify Station Engineers to perform the duties of Shift Technical Advisor. This initial training will be completed by the end of December, 1983. In the interim, the District has determined that the !() currently approved STA program, using qualified shift supervisors, is satisfactory.
TRAINING (Cont'd) O o RECOMMENDATION T-8 The Training Department, when established, should develop, in cooperation with operations, a formalized training proEram and schedule for nonlicensed Station operators. The qualification card system should be revitalized and used as part of this training program.
RESPONSE
The training program will include for=alized non-licensed operator training. The CNS Training Department structure will provide resources to neet non-licensed operator training needs. This is to be accomplished subsequent to full implementation of enhanced licensed operator training. The qualification card system was reinstituted for all nonlicensed station operators starting August 1, 1983. o RECCMMENDATION T-9 The critical needs of enchanced I&C training should be reviewed to assure that the diminution of experience in that group is countered by increased plant-specific training,
RESPONSE
f} The training needs of I&C have been reviewed. An I&C and Electrical Training Instructor has been established as part of the new Training Department. I&C plans to begin plant systems training within the I&C Depart =ent by December 1, 1983. o RECOMMENDATION T-10 Consideration should be given to expand the systems training program given by the CNS engineering group to include General Office engineers.
RESPONSE
Please refer to the response to Recommendation E-2. O
- i. .
EMERGENCY PLANNING o RECOMMENDATION EP-1 l A single Emergency Planning Coordinator should be appointed with full responsibility for the NPPD emergency planning. Adequate staff support should be provided to this individual.
RESPONSE
The concept of a single EP Coordinator has been considered and rejected. k'e have an E=ergency Planning Coordinator at CNS and at the General Office. Basic division of responsibility is defined as the protected area at CNS; i.e., inside/outside the security fence. These individuals carry out their responsibilities in meeting overall NPPD's E=ergency Planning Objectives through the normal structure of the Nuclear Power Group. Adequate staff support will be provided on an "as required" basis. O O
.._.m.- . .%. .. .. .. .. .-..W
1 QUALITY ASSURANCE o RECOMMENDATION Q-1 4
! Consideration should be given to relocating the General Office QA l
Department closer to the CNS.
RESPONSE
Consideration has been given for such relocation, and it has been , decided that a QA Department at the General Office will be retained. QA has been elevated to divisional status with increased staffing in both Corporate and CNS QA Departments. o , RECOMMENDATION 0-2 Establish a routine reporting relationship of the status and adequacy of the QA Program to the General Manager.
RESPONSE
Monthly status reports of NPPD QA activities will be generated. These activities will be identified by the QA Department Managers based upon input from GO and CNS QA staf fs and will be submitted to the General Manager through the QA Division Manager. These reports () will be supple =ented by periodic personal briefings for the General Manager by the QA Division Manager. The briefing frequency shall be established by the QA Division Manager based upon program adequacy, i.e. , any perceived problems shall be reported in a timely manner in order that direction can be provided by the General Manager. o RECOMMENDATION Q-3 Increase the CNS QA staff by at least two people as soon as possible.
RESPONSE
One new position has been authorized and the position offer accepted as of June 3, 1983. This individual reported to CNS on July 1, 1983. The second position authorization is currently seing processed. O l
- QUALITY ASSURANCE (Cont'd)
O o RECOMMENDATION 0-4 l Identify the Essential and non-Essential structures, systems, and components that require QA involvement.
RESPONSE
Structures and systems have been identified and classified. Component identification and classification has been a continuing effort for several years. Finalization of the entire classification program, which is esti=ated to include approximately 50,000 components, will be ecmpleted by July 1, 1986. Interim t milestone schedule dates and system component priority establishment will be developed by November 6, 1983, in accordance with Generic Letter 83-28, Salem ATWS Events. o REC 051ENDATION Q-5 Initiate a QA training program for General Office =anagement personnel who are involved with the CNS. RESPCNSE l A QA Training Program has been in place for several years and has l been utilized to train GO engineering and support personnel. This training has been incorporated into the recently established General Office Nuclear Training Program for all appropriate corporate l personnel involved in nuclear support activities. o RECOMMENDATION Q-6 - _ _ _ A coordinated corrective action program that includes LER's , NCR's, MWR's, SRAB items, audit and surveillance findings and I&E findings should be developed. This should include a program to analyze trends of significant conditions adverse to quality.
RESPONSE
CNS has established the position of Regulatory Compliance Specialist (NIS) to track the status of action items initiated by LER's, NCR's, audit and surveillance findings and I&E findings. This program is now in effect. An Action Item Tracking System has been developed (similar to system G.O. Licensing currently utilizes) and an-Equipment History Trend Analysis system will be implemented. In addition, the Nuclear Plant Reliability Data System (NPRDS) will be implemented on the Prime computer. Additionally, procedures p) defining the operation of the above trackings systems will be u generated, reviewed, and revised as required to insure that all corrective action commitment completions are reported to the NIS.
QUALITY ASSURANCE (Cont'd) O o RECOMMENDATION Q-7 , Carefv consideration should be given to determining those systems, i structures, and components that have some significant importance to
- j. safety and therefore should require some level of QA program application.
1 Examples of those that should be reviewed are: Post-accident sampling system, radwaste system, security system, fire protection system, chemistry instrumentation, meteorological monitoring equipment, and the HVAC system. , S RESPONSE It is recognized that the classification of "important to safety" is receiving considerable industry and regulatory attention at this 1 time. We will participate in support of the effort to further i define "important to safety" systems, structures, and components as ] part of our ongoing BWR Owner's Group activities. ) O O
J RADIATION PROTECTION AND ALARA o RECOMMENDATION RP-1 Formalized training of HP technicians could be improved, including i plant-specific systems training.
RESPONSE
I The Training Department has been assigned the responsibility to establish a formalized Health Physics and Chemistry training program. Included will be plant specific systems training. l Chemistry and Health Physics training material has been procured from General Physics. The recently approved Training Department
; structure includes a full time Chemistry and Health Physics Instructor. The Chemistry / Health Physics Department reorganization
, includes sufficient personnel to provide for the increased training j commitment. Initially, a General Electric Chemistry and Health l Physics Instructor has been contracted to provide basic and
} technical training. This individual will develop a Chemistry and ; Health Physics training program including documentation on equipment t
operation and sampling techniques as well as integration of the l General Physics training =aterial into the program. 7 i o RECOMMENDATION RP-2 O The ALARA program being formulated should be implemented this year with a single individual designated as the ALARA coordinator.
RESPONSE
An ALARA procedure has been drafted and is in its final review within the Chemistry and Health Physics department. It is anticipated this procedure will be approved and implemented by January 1, 1984 Also, the position of ALARA Coordinator is part of the CNS reorganization. The individual in this position will review i Work Items, MW s and routine functions for dose tracking and evaluate methods of exposure reduction. 4 o RECOMMENDATION RP-3 An annual physical examination including blood cell count for radiation workers should be considered.
RESPONSE
The blood cell count examination will be included as part of the annual physical examination for CNS employees in the 1984 cycle. O
- - _ - _ - . . _- . .- . - - - . . _ = - ~ - -. . _ - - . . - . - . . _ . .
RADIATION PROTECTION AND ALARA (Cont'd) i o RECOMMENDATION RP-4 Consideration should be given to installation of a hand-and-foot counter for additional protection against undetected surface contamination. i RESPONSE ; I Consideration has been given to the installation of hand and foot ] counters at Cooper Nuclear Station. In our opinion, however, the ! currently available units would not provide a significant j improvement in the detection of surface contamination over methods J' presently in use at the station. The District will continue to monitor industry directions in this area and will take appropriate action when more effective equipment becomes available. i a' I i i O i l 1 } - - - ---___m_ _ _ , , , _ _ _ 1 O l i-i y,_. . , _ .,____,,,-._.y,_ _ - , , _ _ _ - . - _ . . - . . , _ . _ _ _.,,_,..,,_~,.._.w.,,,,_,_.,_,._-._ , , . , _ , , , _ . , . , , , ,-r,-, , y,_-
RADWASTE MANAGEMENT O No recot:::::endations made, i l l l l l Y
'l l
l 'O u f l 1 !O i
CHEMISTRY O o RECOMMENDATION C-1 The vendor training course should be supplemented with lesson plans specific to the Cooper plant design. Training of technicians should be formalized and i=plemented expeditiously.
RESPONSE
The new Training Department structure includes a full-time Chemistry and Health Physics Instructor. Training material has already been procured from General Physics Corporation. A General Electric Chemistry and Health Physics Instructor has been contracted for, to provide basic and technical training. He will develop a Chemistry and Health Physics training program including documentation on equipment operation and sampling techniques and will integrate the General Physics training material into the program. O O
._ ._ _ _ . -. ._ _ _ _ _ __ _ _ _._ = _ . _ .__ _.
9 l
- l
! ENVIRONMENTAL iO
- o RECOMMENDATION EV-1 1
1 l NPPD should ccnsider developing the capability of doing its own l meteorological assessment since experience at other sites shows this to
- be cost beneficial.
RESPONSE
NPPD is in the process of developing the in-house capability to perform the ceteorological assessments which are now being performed by outside consultants. The transition verification phase is l expected to occur in 1984 and use of consultants for this activity j terminated at the end of 1984 l o RECCMMENDATION EV-2 I A program should be adopted to reduce liquid releases. i
RESPONSE
Efforts are in progress to reduce liquid releases. These efforts include: reduction of the number of leaks responsible for a portion g p of liquid releases and the operation of the Augmented Liquid
- Radwaste System on a daily basis. Additionally, the new CNS
! Engineering Organi::ational Structure includes a full-time Process Control Engineer. A primary responsibility of this Engineer will be to review, evaluate, and propose design improvements necessary to further reduce liquid releases. I s O
- . _= _ _ = . _ . _- _ . -. ..
PROCUREMENT, INSPECTION, AND STORES,
, o RECOMMENDATION P-1 Increase the involvement of quality assurance in the early review of purchase requisitions that may relate to Essential structures, systems, and components.
RESPONSE
CNS Administrative Procedure 1.11, Revision 19, " Requisitioning, Receiving, Storage of Essential Parts, and Components," requires that " prior to submitting" an essential or essential " commercial grade" purchase order to the department supervisor for initialing,
; the CNS QA Department will perform an independent review of the purchase order, to insure that all the necessary quality require =ents have been specified.
CNS Quality Assurance has routinely performed a quarterly review cf nonessential purchase orders since August, 1981, which has revealed no adverse trends in purchase order classification. Additionally, i this review requirement will be fomalized by incorporation into QAP 1400 " Procure =ent and Control of Essential Spare Parts and Equipment" by October 1, 1983.
, o RECOMMENDATION P-2 Improve purchase order infor=ation to allow complete receipt inspection by a quality control inspector.
RESPONSE
The CNS Quality Assurance Department has established a training course covering proper receipt inspection. This course will become required training for all engineers beginning January 1, 1984 This training will provide the engineer with the knowledge necessary to i= prove purchase order information to allow proper receipt inspection. o RECOMMENDATION ?-3 i Upgrade information on MWR's to allow complete inspection by an inspector who may not be intimately familiar with the work and enforce the requirement to complete all portions of the fom.
~
RESPONSE
CNS Administrative Procedure 1.7.1, Revision 4, " Work Item Tracking
- Corrective Maintenance," has been revised to include a more
! detailed QC/ Testing Checklist and also requires a Level II QC l Inspector to review the overall work package for content and completeness prior to work item :losecut.. j i
-. ~-m _m. . ..
. . - . - ._ ~ - - .. . - - . -. _ _ - -- - - _ _ _ .
1 I - PROCUREMENT, INSPECTION, AND STORES (Cont'd) o RECOMMENDATION P-4 j { j I= prove the storage and control of weld rod and the identification of Essential spare parts.
RESPONSE
As part of the CNS organization, new positions have been added to better control storage of warehouse material and spare parts i acquisition. These positions include Inventory Control Coordinator, q Warehouse Fore =an, Material Controller and Material Data / Spare Parts Analyst. Identification of essential spare parts will be performed as action to satisfy LRS Recommendation Q-4 I o RECOMME'DATION P-5 I { Consider increased senior canagement attention to the nuclear fuels
- activity including review of the NPPD/Mommsen Associates / Energy Fuels l Exploration Company relationships, i
4 RESPCNSE i With the establishment of a Nuclear Power Group nuclear technical " activities, including nuclear fuel management, will receive , O. increased overview. s 4 L I O l l l
..es RECORDS MANAGEMENT AND DOCUMENT CONTROL l
- o RECOMMENDATION RM-1 Expedite changeover from the Zytron to the PRIME 650 system at CNS.
. RESPONSE Authori::ation for replacement of the CNS Zytron system with a Prime computer has been obtained and the procurement and changeover will i occur expeditiously in 1983. i
; o RECOMMENDATION RM-2 i
The two-year basis for microfilming the active records in the GO should be enforced.
RESPONSE
Procedures concerning the subject of quality records, their definition, storage and retention requirements, will be reviewed and 4 revised as necessary. Following this review, training will be ! conducted to insure that nuclear group personnel are aware of
- nuclear records recuirements. Thir, procedure review and training i will be completed during the first quarter of 1984 i
) 4 1 l O l
, _ . . , _ _ . . . . , . , _ _ . . . . _ . _ . . . - . _ . - - . _ - . . , - . . - . - , _r
GENERAL OFFICE Nebraska Public Power District * "?JEAYMEiffa^AM"*" o _ - - _ _ _ _ .- _- _ _ __ , September 6, 1983 U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Division of Licensing Washington, DC 20555 Attention: D. G. Eisenhut, Director
Subject:
Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)
Dear Mr. Eisenhut:
Referencc: 1) Letter, D. G. Eisenhut to All Licensees of Operating Reactors et al, " Required Actions Based on Generic Implications of Salem ATWS Events (Generic Letter 83-28)", dated July 8, 1983 ("j 2) EJR Owners' Group letter, T. J. Dente to i D. G. Eisenhut, " Schedule for Submittals in Response to NRC Generic Letter 83-28", dated September 6, 1983 This letter describes the District's intentions in submitting our response to NRC Generic Letter 83-28, Reference 1. The District has retained the services of a consultant to assist in the assessment of the capabilities of our Cooper Nuclear Station with respect to the NRC proposed actions resulting from the Salem event. In parallel with this effort we are actively participating in the BWR Owners' Group program to provide a uniform approach in addressing required actions that have a generic application to BWR plants. We endorse this program which is discussed in Reference 2. In addition, the District is a member of a Nuclear Utility Task Action Committee (NUTAC), formed on September 1, 1983, for the specific purpose of cefining an appropriate vendor interface program in response to Section 2.2.2 of Reference 1. In accordance with the referenced Generic Letter our 120 day respense will describe the current status of conformance with the positions stated therein. We anticipate, however, that the results of the afore-mentioned industry group programs will have an affect on our plans and schedules for any needed improvements. We will discuss this impact in our 120 day response letter when the group programs are more fully l } developed. , v - M9' e#
- p. . .
D. C. Eisenhut September 6, 1983 Page 2 O- Please contact my office if you have any questions on this matter. Sincerely, L t/J
,r ~ r;/ar.c L. G. Kuncl Assistant General Manager - Nuclear GAT:cmk bec: NRC Distribution J. M. Meacham K. R. Wire P. Holtz=an (EPM)
O 1 l l l l l 1}}