ML20100K690

Responds to 841109 Request for Addl Info Re Implementation of Emergency Operating Procedures.Mod of Existing Procedures,Addition of Interim Procedures & Verification/ Validation Process Discussed

ML20100K690
Person / Time
Site:	Point Beach
Issue date:	12/06/1984
From:	Britt R WISCONSIN ELECTRIC POWER CO.
To:	Harold Denton, John Miller Office of Nuclear Reactor Regulation
References
TAC-56311, TAC-56312, TAC-56602, TAC-56603, NUDOCS 8412110249
Download: ML20100K690 (4)

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WR W POWER COMPANY 231 W. MICHIGAN, P.O. BOX 2046, MILWAUMEE, WI 53201 December 6,-1984 CERTIFIED MAIL Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U. S. NUCLEAR REGULATORY COMMISSION

-Washington, D. C. 20555 Attention: Mr. J. R. Miller, Chief Operating Reactors, Branch 3 Gentlemen:

DOCKET NOS. 50-266 AND 50-301 UPGRADED EMERGENCY OPERATING PROCEDURES POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 In'a letter dated October 26, 1984 we notified you that we would be unable to implement the revised Emergency Operating Procedures (EOP's) by the January' 31, 1985 date specified in your July 3, 1984 Confirmatory Order. We requested an extension for implementation of the upgraded EOP's to July 1, 1985.

On November 9, 1984 Messrs. Miller and Colburn of your staff called Messrs. Newton and Krause of my staff to discuss the October 26 request. The call concerned additional information regarding the basis for our request and a discussion of items related to the implementation of the EOP's. The NRC requested that we look at and provide additional information in four specific areas.

These areas are:

1. The need to modify existing procedures to utilize the new TMI backfit-related instrumentation that will be operational after the first of the year.

2. The need to add interim procedures during the additional time period requested.

3. A discussion of what is being done to speed up the verification and validation process so that the procedures could be implemented earlier than the requested July 1 date.

4. If the NRC requires that we meet the January 31 date, a discussion of what potential harm could result from meeting that date.

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Mr.'H.CR EDenton~

December.6,.1984 A

IWe anticipated a follow-up conference ct411.on. November 15,'

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.1984 to' discuss.these fouriitems. However, because of, unrelated

priority, conflicts and_ personnel scheduling problems,Dthis ca111was not completedLuntil November 29, 1984.. 7s discussed

- in these calls, we are providing.the following discussion of.

these) four ' items': -

11. 3 Modify ~ existing procedures. The-existing procedures,-

including interim procedures already in use at~ Point

. Beach,' utilize most'of the parameters covered

.by the new. instrumentation. For example, the procedures refer to the use.of-hydrogen ~ concentration to aid in the decision to vent the head.' Existing procedures provide 1 reference to subcooling monitors and containment sump level. Wide-range pressure is also being used.

in the existing procedures._ In addition to instrumentation references, the existing. procedures have already_been modified'for such' things as natural circulation steps in the LOCA procedure, including limiting of cooldown

- to less than 25'F. Procedures also include requirements.

~for manualvreactor coolant pumpftermination and safety injection. termination and reinitiation' criteria. Therefore, we believe it is not necessary to significantly modify the existing procedures. WhatLean be done is that the existing permanent and interin procedures can be reviewed and where the new instrumentation can be used in the place of old, the procedure will be' examined and revised as necessary to ensure that the new instrumentation is properly referencedLand,that-the operator is aware that he should use the new instrumentation.-

2. Addition of interim procedures. The need for additional interim procedures was reviewed by examining the existing set of emergency procedures and'already existing interim procedures. As- discussed Labove,) the plant staff is already using.'some. interim procedures to address the key TMI concerns.' Examples-of~these procedures'aiready' in use are the procedure forfloss of all AC power and the procedure for reactor vessel head vent. Steps have been added to the LOCA-procedure that address aspects of in~ adequate coreLcooling. We believe that no additional interim procedures are needed before the

,g new EOP's are implemented.

3. Speeding up the verification / validation process. The verification process started in May 1984. It was not until mid-July that the participants had developed a consistent method for procedure verification. It was another month, until August, before they felt they could

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S - ' perform' independent reviews--and still..be somewhat uniform in:their: verification-methods and procedures.

Starting;in September each member was assigned different

,'. procedures't'o perform-the. initial 1 verification. .However,>

' the committee asia whole still'aust meet to review each discrepancy the verification' team members'~ identify. It was not until'this process had progressed to a point-where~thelrate of verification could:be estimated that' we;could' reasonably determine how~much additional time

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, twould be necessarysto implement the'EOP's. The esti-mation was-then made in October'thatothe effort could ds .not be completed in time to implement procedures by the a" 'end of January 1985. At that time the requestifor delay -

was sent to- the NRC. To further speed up the. verification

^ process, outside consultant help has been contracted for

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to assist in the-preparation of-background material and in_the verification process itself if needed.' It is expected that this additional help will speed up:the process-by about one month.- A major factor that contributes to the length of time for proper verification iis the Lrequirement for proper documentation of the process.

Proper-. verification cannot be performed ~without detailed documentation recording the process. Before the EOP's can be implemented it will be necessary to make sure that all of the verification discrepancies have been satis-factorily resolved and so noted on the' documentation.

As. mentioned during our. November 9 telephone call, we have already had all members of the verification team on some overtime hours. Because of the training time involved to understand-the procedure writer's guide-and verificatio'n process =and the experience and qualification-

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levels necessary in the personnel performing this process, it is not realistic to expect'to speed up the process appreciably.by assigning more' company personnel.

4. Potential harm =of implementation "as is" by January 1985.

If the process is speeded up and.the procedures are implemented without' proper. verification, there exists some probability that. incorrect steps will exist in the procedures. .If the verification were to be done after procedure implementation, it would result in additional changes to the procedures'and confusion among the plant operators as to~the' quality and reliability of the Repeated procedural changes after procedures themselves.

implementation would also necessitate repeated retraining of the operators and subsequent additional inefficient utilization of training time and resources. It is our judgment that it is better to take additional time to perform the verification correctly and then bnplement the properly verified procedures.

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Mr. H. R. Denton -4 -

December,6, 1984 We will make every attempt to speed up the process within the above constraints and complete the verification and implement the Emergency Operating Procedures at the earliest practicable date. As discussed with your staff during the telephone call on November 29, we understand this request for approval of a schedule extension is subject to the application fee of 10 CFR 170. 12(c ) .

Accordingly, enclosed is a check in the amount of $150 covering this approval fee.

Very truly yours,

/,b$l President R. W. Britt Copy to NRC Resident Inspector Enclosure (Check No. 819844) l l

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