ML20093N035

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Forwards Procedures Generation Package for Beaver Valley Power Station,Unit 2, in Response to Generic Ltr 82-33, Describing Methods for Developing Function Oriented Emergency Operating Procedures,Per NUREG-0737,Item II.C.1
ML20093N035
Person / Time
Site: Beaver Valley
Issue date: 07/26/1984
From: Woolever E
DUQUESNE LIGHT CO.
To: Eisenhut D
Office of Nuclear Reactor Regulation
Shared Package
ML20093N042 List:
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.1, TASK-2.C.1, TASK-TM 2NRC-4-111, GL-82-33, NUDOCS 8408010154
Download: ML20093N035 (3)


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'Af 412 787 5141 (412) 923-1960 Nuclear Construction Division Robinson Plaza. BuHding 2 Suite 210 Telecopy (412) 787-2629 Pittsburgh, PA 15205 July 26, 1984 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:

Mr. D. G. Eisenhut, Director Division of Licensing

REFERENCE:

Beaver Valley Power Station Unit No. 2 DocketNo.50-4ttBlik Generic Letter 82-33; Procedures Generation Package for Emergency Operating Procedures Gentlemen:

In accordance with Beaver Valley Power Station Unit 2 (BVPS-2) submittal Reference (a) in response to Generic Letter 82-33, BVPS-2 is submitting a Procedures Generation Package (PGP) (Attachment 1) which describes the methods for developing and implementing function oriented Emergency Operating Procedures (EOPs).

These E0Ps are based on the re-analysis of transients and accidents described and clarified in Item I.C.1 of NUREG-0737 and the Westinghouse Generic Emergency Response Guidelines (ERGS), Rev. 1, and associated background documents.

Duquesne Light Com-pany participated with the Westinghouse Owners Group during the re-analysis of transients and accidents and the development of the generic ERGS.

It is BVPS-2's intent to follow these generic guidelines as closely as possible in order to take full credit for the analysis effort, the human factors principles applied, and the function and task analysis effsrt which has formed the basis for the operator information and control needs.

All pro-grams are described in detail in this submittal.

At present, the E0P development status and schedule is as fo llows.

The 48 E0P preliminary draf ts and background docutnents will be completed by August 1, 1984. The first iteration of the BVPS-2 E0P verification will be conducted on those procedures which have been revised to match BVPS-1 E0Ps after their initial verification.

In parallel with this task, the BVPS-2 Control Room Design Review Team will complete a task analysis of the E0P preliminary draf ts to detertaine the characteristics of needed instrumenta-tion and controls. When all BVPS-2 E0PS have been through these processes, a table-top validation and control room walk-through validation will occur.

The BVPS-1 plant specific simulator will be used to validate the BVPS-1 E0Pe.

For dual licensing purposes, the BVPS-1 and BVPS-2 E0Ps have been made very similar.

Any dif ferences between BVPS-1/BVPS-2 E0Ps will be 84080!O154 840726 PDR ADOCK 05000412 i

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Unit'.d Stct0a Nuc1G;r Regulctcry Commissien

' Mr. D. G.. Eis nhut, Dir:ctor Page 2 t ab le-t op and control room walk-through validated since BVPS-2 does not have a plant specific simulator.

An iterative process will follow, where necessary, vnich will resolve EOP discrepancies identified during the described verification and validation phases.

Through this stage of E0P development, there have not been any deviations from the ERGS identified as having safety significance.

If any significant deviations are ident ified, they will be submitted under sepa-rate cover in accordance with the PGP.

All deviations from the ERGS are documented and are available for NRC review at the site.

Clarification of what constitutes a deviation having safety significance from one which does not was obtained from the NRC.

BVPS-2's understanding of this classifica-tion is documented in Reference (b) and has served as BVPS-2's bas is for evaluating deviations.

Included with this submittal is Attachment 1, " Procedures Genera-tion Package for Beaver Valley Power Station, Unit 2," which describes the methods utilized in preparing EOPs from the generic ERGS.

Section 3 of At t achment 1 has been draf ted as a preliminary issue for incorporation into the Station Operating Manual and provides the adminis trat ive controls necessary for maintaining the EOPs af ter implementation. This section will receive additional reviews and is subject to revision following this sub-mittal.

However, the intent of Section 3 will not change and it is included in this submittal for your review.

This PGP is being sent fo r the NRC to review as committed in Reference (a) in suf ficient time to permit resolution of any NRC concerns in a timely fashion so as to not adversely impact operator training.

DUQUESNE LIGHT COMPANY SUBSCRIBED AND SW TO BEFORE ME THIS DAY OF L:,Mu 1984.

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E (/J.' Woolever o

Notary Public Vice President ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY SDH/nmii MY COMMISSION EXPIRES OCTOBER 20,1986 Attachment

REFERENCES:

(a) 2NRC-3-017, dated 4-15-83 (b) March 14, 1984, Mr. Carey to Mr. Vargo, Documentation of conference call to obtain clarification on the ident ifi-cation of significant deviations from Generic Technical Guidelines cc:

Ms. M. Ley, Project Manager (w/a)

Mr. E. A. Licitra, Project Manager (w/a)

Mr. G. Walton, NRC Resident Inspector (w/a)

HRC lbcument Control Desk (w/a)

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' Unit:d Sect 0s Nuclacr R gulctcry Conunissicn Mr. D. G. Eis nhut, Directer Page 3 COMMollWEALTH OF PENNSYLVANIA )

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COUNTY OF ALLEGHENY

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On this 22.// day of he

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, before me, i

e a Notary Public in and for said Commonwealth and County, personally appeared E. J. Woolever, who being duly sworn, deposed and said that (1) he is Vice President of Duquesne Light, (2) he is duly authorized to execute and file the foregoing Submittal on behalf of said Company, and (3) the statements set forth in the Submittal are true and correct to the best of his knowledge.

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Notary Public ANITA ELAINE REITER, NOTARY PUBLIC ROBINSON TOWNSHIP, ALLEGHENY COUNTY MY COMMISSION EXPlRES OCTOBER 20,1986

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