ML20087L457
| ML20087L457 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/14/1984 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Varga S Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, TAC-44282, NUDOCS 8403270215 | |
| Download: ML20087L457 (3) | |
Text
'Af Telephone (412) 393-6000 P.O. B x Shippingport, PA 15077-0004 March 14,1984 Diyector of fluclear Reactor Regulation fhited States Nuclear Regulatory Commission Attn: Mr. Steven A. Varga, Chief Operating Reactors Branch No.1 Division of Licensing Washington, DC 20555
Reference:
Beaver Valley Power Station, Unit No.1 Docket No. 50-334, License No. DPR-66 NUREG-0737, Supplement 1: Development of Emergency Operating Procedures Gentlemen:
The purpose of this letter is to provide follow-up documentation of a conference call held on February 28, 1984, to diccuss the development of plant specific Emergency Operating Procedures (E0Ps) from the generic Westinghouse Energency Response Guidelines (ERGS). The following indivi-duals participated in this conference call:
Peter Tam - flRC Operating Reactors Branch No.1 Sam Brian - NRC Procedures and Systems Review Branch William Middleton - NRC Procedures and Systen Review Branch Steve Sovick - DLC Licensing and Compliance Section Don Skidmore - DLC BVPS-2 Operations Group Curt Mather - DLC BVPS-1 Procedures Group Draft E0P ES-1.1, SI Termination, was provided as an example of a plant specific procedure developed from the generic guidelines. This precedure was selected because it contained examples of differences from the ERGS in wording, step order, deletion and addition of steps and the additinn of notes and cautions.
The Beaver Valley Unit 1 Procedures Generation Package (PGP) was described in part to the extent that it:
1.
documents the methodology and logic behind the development of the plant specific E0Ps from the generic guidelines.
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W, Beaver Valley Power Station, Unit No. 1 Docket No. 50-334 License No. DPR,NUREG 0737 Supplement 1:' Developnent of Emergency Operating Procedures Page:2 3 L
2.
provides a writers guide developed from the E0 PIA document which was referenced in NUREG-0899.
3.
requires ~ the identification' and documentation of. deviations with their justification from the generic Westinghouse guidelines.
4.
described verification and validation methods.
The purpose of the conference call was to obtain feedback from the.
, NRC on DLC's methodology for plant specific E0P development and clarifi-cation of the phrase!"... deviations from generic technical guidelines
-because of different plant equipment, operating characteristics, or design."
(Reference NUREG-0899, Paragraph 2.5.2.b.)
~The NRC_ clarified this phrase by stating that a deviation of this type;would be a change in a plant specific technical guideline and emergency operating procedure that changes the overall strategy (signifi -
'~~.
cant to safety) delineated by the generic technical guidelines. This type of deviation requires a thorough task and engineering evaluation.
Further-more, a description of these deviations, as well as a description of the method for detemining the acceptability of these deviations is a ' required component of-the Procedures Generation Package submittal.
.The following. deviation types were discussed and were determined to
~
not necessarily cause a change.in guideline strategy.
j 1.
. Changes in wording to clarify _ the intent of a step.
!2.1 ' Changes in step order to accomodate plant design.
3.
Deletion of a step to:accomodate plant design.
.4.
' Addition of NOTES, CAUTIONS, or STEPS based on existing emergency operating procedures, operator experience, or plant license' commitments.
-. - The NRC explained that these deviations, although acceptable without -
~
in depth task and engineering evaluation and documentation, should be -
-documented by the utility as a method of ensuring consistent E0P develop-ment..
The NRC initiated a discussion of accepted methods of identifying "infomation and control requirements" when developing plant specific E0Ps.
B: aver Valley Power Staticn, Unit No.1 o
D:cket N2. 50-334, Lic:nse N3. DPR-66
.NUREG-0737, Supplement 1: Development of Emergency Operating Procedures Page 3 It is DLC's understanding from this discussion that acceptable E0P development can proceed using the following general steps in identifying "information and control requirements."
1.
Examine the task, and the "information and control requirements" as determined by the WOG ERGS and background documents.
2.
Determine what existing control room instruments or controls are available to satisfy this task.
3.
Verify (by physical check) that the instrument, or control is is of adequate range, increment, position, etc., to accomplish the task.
The development of both plant specific E0Ps and the procedures genera-tion package will continue based on our understanding of this work as described above.
If it is determined that there is a misunderstaading, please advise so that our effort can be completed in a nanner consistent
.with NRC criteria.
If you have any questions concerning this submittal, please contact me.
Very t ly yours, J. Carey Vice President, Nuclear L.
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