ML20100F110

Forwards Writers guide,plant-specific Guidelines,Training & Rev 0 to Station Operating Procedure 0S1300, Generation of Emergency Response Procedures, in Response to 841011 Request for Addl Info

ML20100F110
Person / Time
Site:	Seabrook
Issue date:	03/29/1985
From:	Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:	Knighton G Office of Nuclear Reactor Regulation
Shared Package
ML20100F115	List: ML20100F110 ML20100F142
References
SBN-783, NUDOCS 8504040210
Download: ML20100F110 (8)

Text

PENHI March 29, 1985 New Hampshire Yonkee Division SBN-783 T.F. B7.1.2 United States Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing

References:

(a) Construction Permits CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444.

(b) PSNH Letter, SBN-616, dated January 17, 1985,

" Emergency Operating Procedures Generation Packages",

J. DeVincentis to G. W. Knighton.

(c) PSNH Letter, SBN-701, dated July 30, 1984, " Response to DCRDR In progress Audit; NUREG-0737 Item I.D.1",

J. DeVincentis to G. W. Knighton.

(d) Westinghouse Owners Group Letter OG-129, dated August 14,1984, "WCAP-10599, Emergency Response Guidelines Validation Program, Final Report",

J. J. Sheppard to H. L. Thompson.

(e) PSNH Letter, SBN-715, dated September 18, 1984,

" Emergency Operating Procedures Generation Package",

J. DeVincentis to G. W. Knighton.

Subject : Emergency Operating Procedures Generation Package

Dear Sir:

On October 11, 1984, Mr. W. Kennedy, NRC-PTRB Reviewer, briefly met with our project representatives in our Bethesda Office to discuss the concerns Mr. Kennedy had regarding the Procedures Generation Package (PGP) documen-tation which was provided via reference (e). The result of our discussions required us to provide some additional information so that Mr. Kennedy could complete his review.

In order to facilitate the review and closeout of this issue, we are enclosing the following documents:

• PGP Amendments (Attachment A)

1. Writers Guide

2. Plant Specific Guidelines p Training 8504040210 850329 PDR ADOCK 05000443 ig F PDR P.O. Box 300 Seabrook,NHO3874 Telephone (603)474-9521

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PWBc SeMoe d New HampsNuo Po9' 2 4

e - Station. Operating Procedure 021300 Rev. 00, " Generation of Emergency Response Procedures" (Attachment B)

I. hope this additional information will aid in Mr. Kennedy's review and expeditious closeout of our PGP. Should you or your staff have any concerns regarding-this issue, please do not hesitate to contact us.

Very truly yours,

, ,ps ./**4v John DeVincentis, Director Engineering and Licensing JD:WJH:lw Attachments cc: Atomic Safety and Licensing Board Service List i

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ATTACHMENT A PROCEDURE GENERATION PACKAGE AMENDMENTS

1. Writer's Guide

2. Plant Specific Guidelines

3. Training I

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3. Writers Guide for E0Ps 3.1 General A Writers Guide for EOPs is a plant-specific document that provides instructions on writing E0Ps, using good writing principles. In addition to establishing sound writing principles, the guide helps to promote consistency among all E0Ps and their revisions, independent of the number of EOF writers.

The tab labeled " Writers Guide" in Exhibit 3 describes the writers guide for the Emergency Response Procedures (ERPs) for seabrook Station that were used in the Westinghouse Owners Group ERG Validation Progras. As a result of lessons learned during the Validation Program, a revised writers guide was generated. This revised guide is contained in the tab labeled "Seabrook Writers Guide". The Seabrook Writers Guide will be

. revised, as necessary, based on feedback from operator training and experience.

32 Document Description Information on the following major items is included in the writers guide:

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• Purpose and Scope

• ERP Designation and Numbering

• ERP Poraat

• Writing the Procedure

• Status Tree Porsat

• Mechanics of Style

• Printed Pormat

• Reproduction 4

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Amendid Octcbar 25, 1984 AMENDMENT TO PROCEDURES GENERATION PACKAGE Pg. 2 item 2 titled - Plant-Specific Technical Guidelines Add a third paragraph.

After being reviewed by both Seabrook Station and Westinghouse personnel, neither participant found any items that could be considered safety sig-nificant. This review covered both equipment and instrumenc differences that exists between the plant specific prodedures and the generic guide-lines. In addition after the validation program was completed no problems were encountered because of these differences.

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p-Amendsd Octobsr 25, 1984-AMENDMENT TO PROCEDURES GENERATION PACKAGE Pg. 3 item 3-titled - Writers Guide for EOPs 3.1 General - change the last sentence of the second paragraph to read.

The Seabrook Writers Guide will be revised, as necessary, based on

' feedback from operator training and experiences. This feedback will be evaluated on two levels. Those request for word changes, notes or cautions will be made at the station and forwarded to the Westinghouse Owners Group for information. Those request for change that involve step changes either addition or deletion will first be forwarded to the Westinghouse Owners Group feedback program before the procedure revision. This contact with the WOG is to ensure that the generic-intent is not disturbed by the change.

In the course of review if the WOG feels the revision information d

. generic or has no value toward upgrading the generic ret of guidelines the station will make the final decision as to the use within the Seabrook Station procedure set.

In addition any issues that remain unresolved between Seabrook Stction an the WOG as to the outcome of a suggested revision are soley the stations responsibility to close out.

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2. Plant-Soecific Technical Guidelines The Westinghouse Emergency Response Guidelines (ERCS), Revision 1, were based on a," REFERENCE" plant desi'an. To correct the ERGS to Seabrook-specific guidelin'es, differences between the REFERENCE plant and Seabrook Station were identified. The combination of the ERGS (generic guidelines) and the Seabrock Station / REFERENCE plant cooperison satisfies the requirement for plant-opecific technical guidelines.

s Appendix F of Exhibit A contains the Seabrook Plant Description developed by comparing the Seabrook design to the REFERENCE plant systens description. Appendix F highlights the differences between Seabrook Station and the REFERENCE plant and was used to tailor the ERCS to Seabrook-specific EOFa.

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'Amendid October 25, 1984 AMENDNENT_f0_P,R0_CEDURES GENERATI_0NJAC_KAG,E, Training.

Since our original submittal we have formalized our training on Emergency Response Procedures to a greater detail. Presently we are introducing the stu-dent.to our ERPs in'a 3 day (8 hr/ day) classroom lesson. This is presented in our detailed' systems section of the training program. This portion of the

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progrea introduces the students to the ERPs as to the rules of usage, understanding a two column format and walkdowns of the MCB indicating where the expected parameters should be viewed to respond to these procedures. Following detailed system the simulator portion of the training program is scheduled.

This is an 8 week program where the operator actually stands a watch period on the simulator board. There is classroom instruction as to coming events and then 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> of continuous board operation and response to abnormalities. In the 8 week period there are 10 lessons directly related to emergency response procedure usage. Coupled, these portions of the program create 3 weeks worth of attention given to ERP usage.

As a guideline for judging the ef fectiveness of our program, enclosed as attach-ments are the 10 student handouts that show the direct association with ERPs.

In addition a listing of possible malfunctions that are available in our simula-t or. ' Those items circled are those that we are using to offer the first licensing students their upset conditions. (Retraining upsets have not yet been finalized.) As can be seen by review not all abnormalities will cause ERP usage. But if the operator does not respond properly to the abnormal condition, reactor trip is evident. This is mentioned to explain that during any time in the 8 week period that if a self induced trip is seen, the operators must

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respond with ERP usage until at least in post trip recovery or other appropriate plant operating procedures.

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