ML20106J228

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Forwards Response to NRC 840907 Comments Re Emergency Operating Procedures Generation Package,Per Generic Ltr 82-33 & SER Confirmatory Issue 41.GE Reviewing Procedures Per Requirements of NUREG-0737,Item I.C.7
ML20106J228
Person / Time
Site: Clinton Constellation icon.png
Issue date: 10/24/1984
From: Spangenberg F, Spangenberg F
ILLINOIS POWER CO.
To: Schwencer A
Office of Nuclear Reactor Regulation
Shared Package
ML20106J231 List:
References
RTR-NUREG-0737, RTR-NUREG-0835, RTR-NUREG-737, RTR-NUREG-835, TASK-1.C.1, TASK-1.C.7, TASK-1.C.8, TASK-TM GL-82-23, GL-82-33, U-0755, U-755, NUDOCS 8411010127
Download: ML20106J228 (20)


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. 054-84(10-24)L L30-84(10-24 )L 1A.120 ILLIN018 POWER COMPANY L

((E CLINTON POWER STATION, P.o. BOX 678. CLINTON. ILLINOIS 61727 October 24, 1984 4

IDocket No.~50-461-Director of Nuclear Reactor Regulation Attention: Mr. A. Schwencer, Chief Licensing Branch No. 2

! Division of Licensing U. S.-Nuclear Regulatory Commission

. Washington, D.C. 20555

Subject:

Clinton Power Station (CPS) Unit 1 Responses to NRC Questions Regarding Emergency Operating Procedures Generation Package

-(Generic = Letter ~82-33 and CPS-SER Confirmatory Issue #41)

Dear Mr..Schwencer:

In letter U-0708, dr.ted May 1, 1984, Illinois Power (IP)-provided the NRC Staff with the CPS Emergency Operating Procedures Generation Package (CPS-PGP) as required by Generic Letter 82-33 (NUREG-0737, Supplement #1).' The NRC Staff reviewer of this material, Mr. Bill Kennedy, contacted IP'on September 7, 1984, to provide us with the

~ Staff's cosmients. IP has fully evaluated each of these cosmients and has

-prepared responses to each item identified by the reviewer (see

' Attachment to this letter).

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IP understands, from discussions with Mr.

Kennedy, that the NRC staff has no major concerns with the adequacy of

.the CPS Emergency Procedures Guidelines to provide a well' organized operator response during postulated emergency conditions.

Safet'y Evaluation Report (SER: NUREG-0853) Confirmatory Issue #41

.is associated with development of Emergency Operating Procedures that.

comply with TMI Action Plan (NUREG-0737) Requirements I.C.1, I.C.7, and I.C.8. . General Electric (NSSS Vendor) is currently. reviewing the

upgraded CPS ~ Emergency Operating Procedures per the. requirements of TMI Action Plan Item I.C.7. Comments will be evaluated and factored into'-

revised procedures,_as appropriate, following completion of this review.

Per Item I.C.8, the CPS Emergency Operating Procedures are available for NRC I&E, review. .As indicated in our letter U-0708, it is anticipated that the BWR Owner's Group (BWROG)'for TMI activities will submit Revision 4 of the generic EPGs to the NRC Staff'in late 1984. Revisions to the CPS-EPGs which are committed to in the attached responses'will be

.made in conjunction with revisions made to implement Revision 4 of the generic EPGs.

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054-84(10-24 )L L30-84 (10-24 )L 1A.120-h Please contact us if: you have any questions on the information provided in this submittal.

Sincerely yours, F. ' A.

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it ange erg Director - Nuclear icensing and Configuration Nuclear Station' Engineering TLR/im.

Attachment cc: .B. L. Siegel, NRC Clinton Licensing Project Manager NRC Resident Office-Regional' Administrator,. Region III.USNRC Illinois Department of Nuclear Safety

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Attach 2nt to U-0755 1 054-84(10-24 )L L30-84 (10-24 ) L -

N 1A.120

. Illinois Power: Response to NRC Comments Concerning the Clinton Power. Station

. Emergency Operating' Procedures Generation Package

- Comments on CPS Emergency Procedure Guidelines (Draft CPS No. 1450.00, Rev. 0)

Comment #1

-The wording of Caution #14 of'the CPS-EPGs has a procedural " logic" problem.;

' Response #1 Thisicaution will be reworded as follows in the next. revision of the CPS-EPGs:

fIF Motor driven pumps, sufficient to maintain RPV water level, are not running and available for injection, and RCIC is available for injection.

THEN Do not depressurize the RPV below 50 psig.

Comment #2 Caution #15 should provide a recommended.SRV operating sequence if

-possible. This can'be accomplished by adding some' clarifying words, or

'perhaps a diagram, to provide guidance to the operator on the preferred SRV. operating sequence.

. Response #2 The actual SRV' operating sequence chosen by the operator is, to a large degree, event specific. However, as explained on page 81 of Appendix B

~ (CPS EPG Technical Basis), the Emergency "Off-normal" Procedures (EOPs) generated from the CPS-EPCs reference'the operating procedure for SRV

. operation, CPS.No.- 3101.01, MAIh STEAM'(MS, IS, ADS). This plant.

operating. procedure provides general guidance on'SRV operation and includes a figure ir "cating SRV discharge device -locations in the -

Suppression Pool. >

Comment #3 RPV Control Guideline, page 12 of 126, purpose (d) should read "<200*F.

Response #3'

-The correct reading should be "<200*F" as noted. This will be corrected during the next revision of'the CPS-EPGs.

. Comment #4 NUREG-0899, Sections 5.7.9 and 5.7.10, state that CAUTION statements and

. NOTES should contain information used to prevent actions by control room operators (WARNINGS) and'should provide operators with supplemental 1 of 17

4 information concerning specific steps or sequences of steps (NOTES). In

' general, however, as noted in NUREG-0899, these statements should not contain operator actions. Places within the CPS-EPGs where such statements direct the operator to take specific actions include, but are not limited to:

  • " Caution" before step RC/P-4;
  • " Caution" before step RC/CD-1;
  • " Note" before Step SP/HL-3;
  • " Note" before Step CN/T-2;
  • " Note" before Step PC/P-3; and
  • " Note" before Step C7-2.

In general, the NRC Staff's position is that such statements should not direct the plant operator to take specific actions.- Illinois Power should review the CPS-EPGs and provide proposed changes to resolve this concern as appropriate.

L Response #4 The CPS-EPGs were written based on the BWR Owner's Group Generic EPGs.

These generic EPGs, which have been reviewed and approved by the NRC Staff for implementation (reference NRC SER, dated November 23, 1983, regarding Revision 3 of the Generic EPGs), utilize CAUTION and NOTE statements in a manner identical to that utilized by Illinois Power in the CPS-EPGs. However, this NRC concern has been brought to the attention of the BWR Owner's Group Emergency Procedures Committee.

-Illinois Power is a participant in this Committee's activities and will monitor the resolution of this concern closely. If, as a result of this generic evaluation, the generic EPG format for the use of such CAUTION and NOTE statements is changed, then Illinois Power will reevaluate the need to change the CPS-EPGs for consistency purposes. Illinois Power's position is that the current use of such statements is consistent with the current generic EPGs and does not present a plant safety concern.

Comment #5 Page RC-7 of the generic EPGs (Revision 3G) was missing from the NRC copy submitted. This page addresses generic EPG Step RC/P-3 regarding RPV cooldown @ 100'F/hr. This step, or one appropriate to CPS, does not appear in this area of the guideline. Where in the CPS-EPGs is this action step addressed?

Response #5 The particular operator action step referenced (see generic EPG missing page provided here as Enclosure #1) is addressed in the CPS-EPGs in Section 3.4, Step RC/CD-2.1, of the Cooldown (RC/CD) guideline. As explained in the CPS EPG Technical Basis, Appendix B, on page 94, this guideline was created to be used by the operators as a common exit point from the CPS-EPGs.

Comment #6 Reactivity Control Guideline, page 17 of 126, purpose (b)(a) entry condition should read " Reactor Powerl 3% (APRM downscale trip)".

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Response #6 The-correct reading should be Reactor Power 13% (APRM dcwnscale trip)"

as noted. -This will be corrected during the next revision of the CPS-EPGs.

Comment #7 Step RC/Q-4.5, page 18 of 126: It is unlikely that " boron concentration

-in the RPV sufficient 'for cold shutdown (660 ppm)" could be determined by the plant operators prior to one of the other conditions being met. For example, it is likely that SLC Tank Level will reach "O gallons" before RPV boron concentration can be determined through a reactor coolant sample. Based on this, refarence to boron concentration could be deleted'from this step.

Response #7

, Illinois Power agrees that the other indicators referenced will "likely" occur before a reactor sample can be taken and fully analyzed. However, it-is desired that reference to RPV boron concentration be retained in this step. This will provide greater operator flexibility in the remote event that SLC Tank Level indication is lost, or there is some evidence

.of boron loss or incomplete mixing. Such " contingencies" are co mistent with the generic EPGs since the operator should base actions upon any available plant instrumentation and address the possibility of a loss of such instrumentation.

Comment #8 Throughout the CPS-EPGs, several "laters" are identified; e.g. the Combustible. Gas Control Guideline has not yet been prepared. Illinois Power should identify when such information will be available for NRC Staff review.

Response #8 Illinois Power is a member of the BWR Owner's Group (BWROG) EPG Committee, as noted in the response to an earlier Staff comment. The items currently identified in the CPS-EPGs as "later" are under.

cvaluation and preparation in close coordination with the BWROG Committee's work. This "later" information includes plant-specific calculations, operator action steps, and the corresponding plant-specific technical bases, in various sections of the guidelines.

These items are identified as "later" due to currently ongoing work by this BWROG Committee. Illinois Power will complete this work, as the generic guidance becomes available from the BWROG. The final CPS -EPGs will be completed to support the CPS Operator Training Program prior to fuel load. It is Illinois Power Company's understanding that, with respect to Combustible Gas Control, Revision 4 of the generic EPGs is planned for submittal to the NRC by the end of 1984. Remaining

. revisions to the CPS-EPGs will,'therefore, be in accordance with the BWRCG generic guidance, as appropriate. A schedule for providing the staff.with this information will be provided when Rev. 4 of the generic

-EPGs becomes available.

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. ' Comment #9

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EStep'RC/Q-4.6,' Page 18 of 126: . " Continue at step RC/Q-4.1".'should read

" Return to step RC/Q-4.1".-. Illinois Power should review the CPS EPGs for..other such steps where similar wording changes would be appropriate.

Response #9 I ,

The proposed wording change is appropriate and will be made, along with similar changes to other steps throughout the CPS-EPGs, as appropriate, during the'next revision of the CPS-EPGs.

E ' Comment #10 iStep SP/T-4, page 25 of 126, uses "AND" in a non-logical manner.

Illinois Power should consider using a more appropriate wording to avoid operator confusion.

,,a Response #10 Illinois Power has reviewed this step in the CPS-EPGs and will implement the "AND" portion as a separate step as follows:

_IF_ . Suppression Pool level is below 19ft. Sin.,

i: (maximum Suppression Pool water level LCO) p H THEN Initiate SPMS.

i The following additional steps will be changed as noted below:

  • " Note" before Step C6-1, page 49 of 126 -

L Delete "AND" and make this step read "THEN Enter Contingency #8, Alternate RPV Flooding, and do not enter this contingency until

' directed to do so by Contingency.#8."

  • Step C6-10, page 51 of 126 -

Delete "AND" and make this step read "THEN Enter RC/L, LEVEL CONTROL, and enter RC/CD, C00LDOWN."

.

  • Step C7-4, page 55 of 126 -

! Delete "AND" and make this step read "THEN Enter Contingency #2, EMERGENCY RPV DEPRESSURIZATION, and continue on with this guideline."

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ri; Comment #11 i

< Step CN/T-2, .page 30 of' 126: The use of the "but- only if" phrase may be confusing to the operator. A similar concern'is noted with respect.to l Step PC/P-3 on page 31 of-126. : Illinois Power should consider using a more appropriate wording to avoid operator confusion.

kesponse #11

~ Illinois Power has reviewed the concerns identified for the referenced

, CPS-EPG steps and will-change the wording of the "BEFORE" phrase such

,that "but only if" will be deleted and replaced with "and if".

. Comment #12 Step SC-4, page 35' of 126: The'use of "AND" as a " logical and" is not

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considered appropriate in the' context presented in this step. Illinois Power should review the wording employed and rephrase this step, as appropriate.

Response #12 The following word changes will be made to this CPS-EPG step to delete

use of-the "AND":

THEN- Perform the following:

1. Isolate all systems discharging into the area except:

.a. .........................

b. ...[ wording as before]...
c. .........................
2. . Establish or. verify Secondary Containment integrity.

Comment #13 Step SC-5, page 35 of 126: The use of the "IF-THEN-Before" wording

~1ogic~is potentially confusing to the operator. Illinois. Power should reevaluate the wording employed and rephrase this step,'as appropriate.

Response #13 The' fo110 wing word changes will be made to this CPS-EPG step to delete use of the "IF-THEN-Before" logic:

. IF A primary system is discharging into an area, before any area temperature, any area radiation level, or any area water level reaches its Maximum Safe Operating Level THEN- Perform the following:

a. ..........................
b. ...[ wording as before]...
c. .........................

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p acomment #14-Step SC-6, page 36.of 126: :The word,"either", following the word "AND" should be' capitalized for special emphasis to the operator.

Response #14 10ie suggested emphasis of the word "either" will-be made during the next

, revision ofLthe CPS-EPGs. .

Comment #15' IStep Cl-3, page 40 of.126: " Table-1" should be labeled with RPV

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Pressure" along the top and "RPV Water Level" along the left-hand side

, 'for operator information purposes.

Response #15 The suggested labeling of " Table 1" will be implemented during the.next

revision of;the CPS-EPGS.

Comment"#16

-Step C2-1, page'43 of 126: The use of "AND" is done in a non-logical manner. ' Illinois Power should review this step to determine if a more appropriate wording, with less potential for operator confusion, can be implemented. Also, this step. appears to be the'only. place in.the CPS-EPGs where the operator is directed to the Reactor Scram Procedure.

Justify.the appropriateness ot this step or explain why such a step should not be inserted in other portions of the guideline.

~ Response #16-Illinois Power has reviewed the use of the "AND" as described above.

The:following wording changes will be made (Delete the use of "AND" in then "THEN" phrase):

'THEN Perform the following actions:

1. Place the mode switch in shutdown.

2.- Perform Reactor Scram off normal procedure concurrently with the remainder of.this procedure.

Illinois Power will leave the reference to the Reactor-Scram Procedure in this step since it'is a good " transition" procedure for entering the normal shutdown procedures. The use'of this procedure is also implied Lin Step RC/CD-2.5 on page 23 of 126.

Comment #17 Step C2-2, page 43 of 126: This step contains two "IF-THEN" logic statements which may present confusion to the operator. Illinois Power should consider alternative wording for this step that will eliminate

.any potential for operator confusion.

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, ' Response'#17 The' referenced CPS-EPG step will be divided into two separate steps each' with one "IF-THEN" ' statement. for simplicity.

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' Comment #18

. Step'C2-3, page 43 of 126: This CPS-EPG step contains another "AND"

-that is used in a non-logical manner. . Illinois Power should consider

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? rewording this step to eliminate any potential for operator confusion.

Response #18 Wording' changes similar.to those described in Response #16 above will be implemented for this step to remove any potential for operator

-confusion.-

Comment #19 Step C6-3, page 50 of'126: The word "until" should read "UNTIL" for operator' emphasis purposes.- The same comment applies to step C7-1 on page.53 of.126, for use of-the word "until" in the "THEN" portion of the step.

,  ; Response #19 The suggested emphasis ("UNTIL") is considered appropriate and will be implemented during the next revision to the CPS-EPGs for each step -

identified in Comment #19.  :

Comment #20 Step C7-4.1, page 55 of.126: What actions will be taken by the plant

. operators if less than two SRVs cannot be opened?; The same question Lapplies to CPS-EPGs step C8-3 on page 58 of 126. Illinois Power should evaluate the consistency of this wording with lthe generic EPCs.

Response #20 The step before Step C7-4.1 directs the operator to enter Contingency

  1. 2, EMERGENCY RPV DEPRESSURIZATION, and perform Step C7-4.1 ' Contingency l
  1. 2 directs the operator to open seven SRVs, while Step C7-4.1 states '

y that if less than two SRVs can be opened, then continue in this L

~ procedure. It follows that if two or more SRVs can be opened, do not continue on in this procedure. The CPS-EPGs are worded exactly the same as the generic EPGs in this case.

t- Comment #21 Step C8-4, page 58 of 126: The wording of this step is unclear and

' confusing.- Again, the use of "AND" is done in a non-logical manner.

The same comment applies to Step C8-5 on page 59 of 126. Illinois Power should review the wording of'this step and determine more appropriate wording that will aid in the clarity of the information presented.

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Response #21 IllinoisLPower has reviewed this CPS-EPG Step and will implement the following wording changes:

-Commence and slowly increase injection into the RPV with the

-following systems:

a. .............................

b.. ...[ wording as before]......

c. ............................

UNTIL both of the following conditions occur:

1. At least 2 (minimum number of SRVs for which the minimum RPV Flooding Pressure is below the lowest SRV lifting pressure)

SRVs are open

2. RPV Pressure is above the Minimum Alternate RPV Flooding Pressure.

Similar changes will be made to Step C8-5 on page 59 of 126.

Comment #22 In the Reactivity Control Guideline, RC/Q, the CPS-EPGs direct the operators to try " individual rod scram" prior to " manual rod insertion".

The ordering of these actions, as such, appear to be the reverse of that proposed in the generic EPGs. Justify the proposed deviation from the generic guideline.

Response #22 The CPS-EPGs were written this way because it was believed that at this point in'the guideline event conditions may preclude containment entry required for " manual rod insertion". However, Illinois Power has reconsidered this position and will change the CPS-EPCs to be consistent with the ordering suggested by the generic EPGs.

Comment #23 The CPS-EPGs provide direction to the plant operators to vent the Primary Containment when containment pressure exceeds the " Primary Containment Pressure Limit" (reference step PC/P-7, page 32 of 126) as defined by the curve presented on page 69 of 126 (Appendix A). The NRC Staff's Safety Evaluation Report on Revision 2 of the generic EPGs (issued February 1983) has approved the use of twice design pressure as an interim limit provided containment integrity can be demonstrated.

The CPS limit proposed is 63 psig which is in excess of the design pressure by a' factor of about 4X. Justification must be provided regarding the basis for this pressure. In addition, the NRC Staff has identified a number of concerns to the BWR Owner's Group related to such post-accident venting, during an April 10, 1984 meeting, as fellows: i 8 of 17

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1. . Lack of a complete technical description of the containment venting system;
2. Depressurization rate of the containment to limit pool flashing;
3. The significance of dynamic loads resulting from Safety Relief Valve actuation at high containment pressures and temperatures should be evaluated. Further, information on the frequency and magnitude of the dynamic loads should be provided to the Staff;
4. Information on the environmental qualification data base that is being used to assure containment vent valve operability should be provided;
5. The methods which are used to determine the pressure at which the containment is vented from the standpoint of decay heat removal, rather from the standpoint of preventing containment gross failure, should be provided to the Staff and in the plant-specific EPGs; and
6. The criteria used for the preparation of the EPGs and for the operator guidance should also be provided to the Staff for ret ew, Response #23 With respect to the CPS Primary Containment Pressure Limit curve, this calculation was performed usiag the generic guidance contained within BWR Owner's Group generic EPG Calculational Procedure C14.0 in Appendix C of the generic EPGs. This generic calculational procedure entitled

" Primary Containment Pressure Limit", was modified for the CPS-specific maximum floodable level of the Containment. A containment ultimate strength limit of 63 psig has been determined based upon the structural analysis performed by Illinois Power on the CPS Containment as provided to the NRC in IP Letter U-0309, dated October 16, 1981. This analysis conservatively estimated the CPS Containment Ultimate strength to be 76 psig based on the stress capacity of the spherical equipment hatch.

Several additional submittals were made by Illinois Power to respond to questions regarding this analysis from the Staff. As a result of these transmittals and further discussions with the NRC, as noted in Section 3.8.1 of the CPS-SSER #1 (NUREG-0853), Illinois Power agreed to apply a safety factor of 1.2 to the analysis thereby reducing the calculated ultimate pressure retaining capability from 76 psig to 63 psig. Thus, the use of the 63 psig limit as referenced in the calculation. The actual calculation and the assumptions used are provided in Enclosure #2 herein. Therefore, based on the original guidance from the BWR Owner's Group, the basis for the CPS Primary Containment Pressure Limit curve is provided.

With respect to the additional Staff concerns identified to the BWROG on the general subject of post-accident containment venting, Illinois Power is continuing to participate with the other BWR owners to evaluato and 9 of 17 u

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. resolve these concerns on a ge'neric basis as much as is feasible. The CPS-EPGs will ultimately reflect the results of this generic work once

.such evaluations are completed. Such considerations as containment venting for combustible gas control, for example, will be part of this

.. review and evaluation.

It is anticipated'that the results of the BWROG efforts on this issue will be provided to the NRC Staff for review by May 1985.

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l o Comments on CPS EPG/EOP Writer's Guide Comment #1 The CPS EPG/EOP Uriter's Guide does not address the format to be used in preparing the CPS-specific E0Ps from the EPGs. Specifically, such items as pagination, columns, spacing, margins, emphasis techniques, etc.,

need to be addressed in the Writer's Guide. Illinois Power should reference NUREG-0899 for specific guidance in this area.

Response #1 The E0Ps are symptom-based emergency procedures as described in Step 8.1.2.1.2 of CPS Procedure No. 1005.01. This step states that symptom-based emergency procedures shall use the format described in Appendix C of that procedure. This appendix provides examples of such format techniques and states that the EPGs should be referenced when writing the E0Ps. The EPGs themselves then provide the basis for such formatting. The E0P/EPG format used is considered consistent with the guidance of NUREG-0899, Section 5.5 and INP0 guideline 82-017

" Emergency Operating Procedures Writing Guideline", dated July 1982.

Comment #2 The Writer's Guide should address the use and presentation of the various setpoints, numbers and parameter curves throughout the CPS E0Ps/EPGs. Specifically, the number of significant digits to be used and the units referenced should be identified in the Writer's Guide and compared to the actual instrumentation capabilities as available and labelled in the Main Control Room. Illinois Power should reference NUREG-0899 for specific guidance in this area.

Response #2 Appendix C of the CPS Writer's Guide, Section 3.0 f) 2) states that values should be in the same units as those that appear on plant instrumentation. Additional detail will be added to this section regarding the use of significant digits. The presentation, location, and relevancy of the information provided by the various graphs, tables, and numeric values is considered consistent with the guidance contained within NUREG-0899, Sections 5.5.8, 5.6.6, 5.6.7, and 5.6.8.

Comment #3 The Writer's Guide should address the format (s) for the logic statements used througheut the CPS E0Ps/EPGs. Illinois Power should reference NUREG-0899 for specific guidance in this area.

Response #3 Section 3.0 of Appendix C (pages 42 and 43) of the CPS Writer's Guide addresses and clearly defines the "IF-THEN" format as being used for decision steps. Conditional statements such as "WHEN-THEN" and "BEFORE-11 of 17 L

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., a THEN" will be added and criteria for their usage will be described in this section of the CFS Writer's Guide. The general guidance of NUREG-0899, Section 5.6.10 and Appendix B will be used in developing

.these additions to the Writer's Guide.

'Conssent #4' Criteria for providing references to and locations of equipment / instruments used within the EPGs/EOPs 'should be addressed in the CPS Writer's Guide. This is of specific concern for " emergency" equipment / instruments since they may be infrequently used by the control room operators.

Response #4 The CPS-EOPs will be reviewed and where emergency instrumentation which

.is not normally used by the control room operator is called for, the.

location will be given. This is consistent with Section 3.0 f) 3) of the CPS Writer's Guide which states that the level of detail for operator instructions should be consistent with operator knowledge and

. skill. Instrumentation normally used by the operator and also applicable to post-accident uses, is considered adequately covered by the operator training program due to the fact that routine usage is applicable. This is consistent with NUREG-0899, Section 5.7.11.

Comment #5 The Writer's Guide should address how the E0Ps will be used with respect to Main Control staffing requirements. Specifically, the Writer's Guide should explain the relationship between the E0P " user" and the E0P action step " doer".

Response #5 CPS Main Control Room manning and staffing requirements are currently described in CPS Procedure No. 1401.01, OPERATIONS DEPARTMENT

' ORGANIZATION, RESPONSIBILITIES, AND MINIMUM QUALIFICATIONS. CPS has already constitted to having an SRO and RO in 'the Control Room with another RO assigned to the Control Room. In addition, the location of the Shift Supervisors' office is such that he could very quickly be in the Control Room. This procedure's description of the position's responsibilities indicates which person will be "at the controls", which person will be assisting the operator, and which person will be supervising and/or directing operations. Illinois Power considers this

. procedure adequate to address the NRC concern identified above, and no changes to the Writer's Guide are necessary in this area. This procedure meets the guidance of NUREG-0899, Section 5.8.3.

Comment #6 The Writer's Guide should address the means by which future revisions of the CPS E0Ps/EPGs will be controlled.

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d-Response #6 CPS Procedure No.- 1005.04, DISTRIBUTION AND CONTROL OP STATION-PROCEDURES AND REVISIONS, defines the requirements for documentation control and replacement of CPS E0Ps and EPGs. Illinois Power considers this procedure adequate to address the NRC concern identified above, and no changes to the Writer's Guide are necessary in this area. This procedure meets the guidance of NUREG-0899, Section 6.2.

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Comments on the CPS.EPG/EOP Verification &

. Validation'(V&V). Program-H c Comment'il.

.. Illinois Power:should commit to performing the EPG/EOP V&V program on

'?all"..EOPs on-'the: plant simulator. .If the simulator design is'such that not all'the EOPs'can undergo.such V&V review, then the V&V Program

. should sidentify. alternative means of' V&V review (e'.g. Control Room operator walkthroughs).< Illinois Power should provide a list of

, , iplant-specitic scenarios that: will be run on the CPS simulator and how 5each scenario will exercise the use of each corresponding E0P.

i Response il 5

Reference:

u Detailed Control Room Design Review (DCRDR) . Program' Plan

.(Section 3.7) See. IP. letter U-0741, dated September. 28,'1984.

ThaiEOP V&V and DCRDR will be an integrated' effort. The-validation

. portion of the.EOPs will use.both walk / talk-through (on mosaic mock-up)

< and simulator methods.-

Walk / Talk-Through Method'

.A procedure will be developed based on the photo-mosaic mockup of the control room.

The procedure will consist of the-following' principal elements:-

fuse of three observers with the lead observer: directing all activity using the appropriate. System Function and Task Analysis

.(SFTA) data sheets and diagrams from the Verification Phase.

Two operators will execute taske as directed,by the lead observer.

H Execution at the checklists and guides for compliance.

Video / audio recording of'all activity.

The execution of the walk / talk-through procedure will inherently include

~ the execution of the checklists and guides. Operator activity will be

' initiated by the lead observer giving plant symptoms or task

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descriptions from the SFTA data sheets. The operator response will be

' the : execution of 'a task sequence and/or steps to accomplish the tas::(s),

which will-then be evaluated by the observers for DCRDR and E0P guideline compliance. The evaluation process wiU include frequent discussions with the operators and references to the Control Room

inventory data base or E0?s as necessary.

For the documentation and resolution of E0P discrepancies, the provisions in the E0P V&V Program will be used.

Any.E0P discrepancies of a time-depedent nature found during this phase

'will'be noted for further evaluation on the simulator.

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Simulator--Method :

- - LA procedure for validation on the control room simulator will be

, developed and will consist of essentially the same elements as the walk / talk-through procedure.

0perator activity will be initiated with the simulator at plant conditions closest to'the plant symptoms or task as possible. Operator

-response (s) to the simulator will be evaluated by the observers for DCRDR and EOP guideline conipliance and will include frequent discussions with the operators and reference to the Control Room Inventory and E0Ps' as necessary.

'EOP discrepancies will be documented and' resolved per'the EOP V&V program.

~

The DCRDR Program Plan, Sections 3.5-3.7 describes the methodology to be

used for the E0P and DCRDR Integrated. System Function and Task Analysis (SPTA), Verification & Validation phases of-the review.

Although plant specific' scenarios that will be run on the CPS Simulator have.not yet been identified. Sectio'n 3.5.2.3 of the DCRDR delineates the~ criteria which will be used to select events for SFTA.

The following criteria will be used in the selection of events:

-- . Utilize a broad range of control room functions.

_ Require time-dependent action by the operator.

- Require multi-system operations and interaction by the operator.

Represent potentially high-stress situations for the operator.

-. Addresses all nonidentical E0P operator tasks.

- Addresses'all identical E0P operator tasks at least once.

These events will then be analyzed through a number of checklists,

^

diagrams,.and guidelines to avoid duplicated task and actions and group together similar actions.

The: verification phase will group tasks and activities to idencify a

~small number of selected operating events which will incorporate all EOPs.

These general: E0P V&V methods meet the tandards of industry practice found in INPO guidelines INPO 83-004, " Emergency Operating Procedures Verification Guideline", dated March 1983, and INPO 83-006, " Emergency

. Operating Procedures Validation Guideline", dated July 1983.

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F- Comment #2 The CPS EPG/ EOF V&V Program should provide an Illinois Power commitment

,to evaluate each EOP using the minimum required operator shift

~ compliment (i.e. minimum shift manning in the Control Room).

Rasponse #2

' Minimum shift compliment, per Tech Spec 6.2.2 (Table 6.2.2-1) for conditions 1, 2'and 3 is es follows:

.. Shift Supervisor 1 SRO .2 RO 2.

A0 2 STA 1 CPS Procedure No. 1401.02, Shift Complement, Step 6.1.2 says at least one licensed operator and one licensed senior. operator, functioning as the supervisor in the control room, shall be present in the control room during operation in Power Operation, Startup, or Hot Shutdown conditions.

'Our Detailed Control Room Design Review (DCRDR) Program Plan states we will use a lead observer giving plant information and two operators performing ths tasks.

This. commitment is considered adequate to address the NRC concern identified above.

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.. 1 Comments on the CPS EPG/EOP Operator Training Program

, General Response to NRC Comments on Training Program The EOPs< fall;in the category of procedures requiring regular-review by 10CFR55, Appendix-A.~ This. requirement will be satisfied by an on going

- E0P Training Program utilizing classroom instruction and the CPS

- Simulator.1 This program will continue to improve as modifications bring the Plant,.EOPs, and Simulator into alignment.

. Comment #1

^

The CPS Training Program should more specifically address how the 4

< operators will be trained on the use of " symptom-oriented" procedures.

Specifically, discussion should be'provided on how/why such procedures are really better than " event-oriented" procedures.

Response il

' The CPS E0P Training Program, as currently developed, addresses the

- difference in philosophy between event-oriented and symptom-oriented procedures. The operators are given a brief history.of the EPG development,l including the functional ~ requirements, the various organizations involved in that development, and how plant-specfic EPGs-are written.from' gene;1c.EPGs. Particular emphasis is given to the

" battleship in'the desert" orientation of the E0Ps; i.e. no matter what

- combination of.unlikely events placed the plant in a configuration, the 2 - EOPs provide.theLeorrect steps for restoring / maintaining plant safety

. functions.- From'this: standpoint, the CPS operators will be thoroughly

- trained'on the benefits of." symptom-oriented" E0Ps.

Comment #2-

- The CPS: Training Program does not specifically address the use of the plant-specific ~ simulator as'a means of operator training on the CPS EPGs/EOPs. Illinois Power should identify which, if any, E0Ps that the operators will not be trained / evaluated on using this simulator and what alternative training will be employed.

Response #2 The E0P Training Program will be expanded to utilize the CPS Simulator for the required license training in 1985.' All EOPs that are developed

. will be exercised by the' license candidates to the extent that the associated parameters can be modelled. Supplemental training will be conducted on' a case-by-case. basis for those E0Ps for which the Simulator does not respond well..iThis' training will involve'an operator procedure walkthrough-on the simulator or in the Main Control Room.

45 17 of 17

ENCLOSURE #1 3 .

e

.RWCU (recirculation mode) if no boron has been injected into the RPV.

e Main steam line drains e

RWCU (blowdown mode) if no boron has been injected into the RPV. Refer to [ sampling procedures] prior to initiating blowdown.

If while executing the following steps the reactor is not shutdown, return to [ Step RC/P-2].

RC/P-3 When either:

e All control rods are inserted beyond position [06 (maximum suberitical banked withdrawal position)], or e

[280 pounds (Cold Shutdown Boron Weight)] of boron have been injected into the RPV, or e =

The reactor is shutdown and no boron has been injected into the RPV, depressurize the RPV and maintain cooldown #14, #17 rate belov [100*F/hr (RPV cooldown rate l

1 LCO)].

If.one or more SRVs are being used to depressuri:e the RPV and the continuous SRV pneucacic supply is or beco=es

{-

unavailable, depressurize with sustained SRV opening.

RC/P-4 When the RER shutdown cooling interlocks clear, #18 initiate the shutdown cooling mode of RER.

(PC-IY Rev. 3G) p

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