ML20107C177

Forwards Method of Developing plant-specific Emergency Operating Procedures,In Response to Request for Addl Info Re Draft SER Open Item 98.Info Will Be Contained in Revised Procedure Generation Package Scheduled for 850401 Submittal

ML20107C177
Person / Time
Site:	Vogtle
Issue date:	02/14/1985
From:	Bailey J SOUTHERN COMPANY SERVICES, INC.
To:	Adensam E Office of Nuclear Reactor Regulation
References
GN-526, NUDOCS 8502210209
Download: ML20107C177 (4)

Text

s- . Southern Company Servces. Inc, p ,

Post Offce Box 2625

. Birmingham, Alabama 35202

- ' Telephone 205 870-6011 February 14, 1985 Vogtle Project Director of Nuclear Reactor Regulation File: X7BC35 Attention: Ms. Elinor G. Adensam, Chief Log: GN-526 Licensing Branch #4 Division of Licensing U._S. Nuclear Regulatory Commission Washington, D.C. 20555 NRC DOCKET NUMBERS 50-424 and 50-425 CONSTRUCTION PERMIT NUMBERS CPPR-108 AND CPPR-109 V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 DRAFT SER OPEN ITEM 98 PROCEDURE GENERATION PACKAGE

Dear Mr. Denton:

Attached for your review please find five (5) copies of information re-quested by your staff in our draft SER open item 98 concerning the method for drieloping VEGP plant specific emergency operating procedures, as noted in the attachment, this information will be contained in the revised pro-cedure generation package scheduled for submfttal to the NRC on April'1, 1985.

If your staft requires any additional information, please do not hesitate to contact me.

Sincerely, t

=

J. A. Bailey Project Licensing Manager

. JAB /sp xc: D. O. Foster R. A. Thomas G. F. Trowbridge, Esquire J. E. Joiner, Esquire C.'A. Stangler L. Fowler-M. A. Miller L. T. Gucwa G. Bockhold, Jr.

8502210209 850214 PDR ADOCK 05000424 F PDR .__.

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ATTACHMENT Method of Developing Plant-Specific Emergency Operating Procedures (EOPs)

From The Generic Guidelines VEGP Emergency Operating Procedure (E0P) step documentation forms will be prepared .for all ERG /EOP steps per procedure 10013-C, " Writing Emergency Operating Procedure From Westinghouse Emergency Response Guidelines". Step documentation forms will document all deviations of plant specific E0P's from the Westinghouse ERG's and will provide justification for the deviations.

E0P step documentation forms will be supplied to the NRC shortly after issuance of approved E0P's.

The Emergency Operating Procedure Generation Package will be revised to include the process for using the generic guidelines and background documentation to identify the characteristics of needed instrumentation and controls. This will be done by adding an addendum to the Method section referencing our contract with Westinghouse (PAV-25307) to generate a plant specific setpoint/value calculation document containing all plant specific setpoints and values contained in HP Rev. 1 of the WOG Emergency Response Guidelines.

Safety-significant, plant -specific deviations from the ERG instrumentation and control requirements will be documented using the step documentation forms referenced in 10014-C ' Verification of Emergency Operating Procedures'.

Justifications for such deviations will be submitted for staff review.

Writer's Guide (1)

To provide a mechanism to allow operators to keep their place when using E0Ps under stressful conditions, operators will use a mechanical page marker when transitioning to another procedure.

(2) (a) 10012-C 'EOP AND A0P WRITERS GUIDE', Rev.1 includes the following defini-tions of ' check' and ' verify' to provide operators with a destinction between the two action verbs.

Check is defined as to perform a comparison with a procedural requirement.

Example: " Check if SI can be terminated."

Verify is defined as to observe if an expected characteristic or condition exists. Typically the expectation comes from some previous automatic or operator action. The appropriate contingency, either stated or implied, is to establish the expected condition. Example: Veri fy Reactor Trip".

These types of action directive are used where appropriate in the proce-dures to ensure that equipment responses and operator actions have occurred and are correct.

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(2) (b)

Emergency Operating Procedures are already written to provide time restraints where necessary. These time frames are provided within steps, cautions, or notes consistent with ERG useage. Directives to provide these time frames was given in procedure consistency review meetings.

Also to distinguish between steps that should be performed sequentially and independently, the use of letters and bullets are used respectively as indicated in 10012-C.

(2) (c)

Emergency Operating Procedures are written using diagnostic flow format.

The operator is directed to sequential steps. If an Action / Expected Response (AER) step cannot be performed ERG rules of useage directs operator to the Response Not Obtained (RN0) step adjacent to it. If the AER or RNO cannot be performed, ERG rules of useage directs operator to the next AER step. Directives in the Emergency Operating Procedures sometimes directs operator to "G0 T0" or " RETURN T0" another step or another procedure. If no procedure step is given, ERG rules of useage direct operator to the first step in the procedure. Continuous action steps are implemented by use of such action verbs as Maintain or Control or by use of When/Then statements. Useage of such operator directives-is consistent with HP version Rev. 1 ERGS where appropriate.

(3) 00100-C ' QUALITY ASSURANCE RECORDS ADMINISTRATION' provides guidance for assuring that good quality or legibility of E0Ps is maintained.

Validation and Verification (V & V) Programs

.(1)

The control room walkthrough of each E0P will be performed as part, of the control Room Design Review Program. The E0P validation prog' ram (on simulator) will validate selected E0Ps.

We plan to walkthrough E0Ps on simulator prior to validation to facilitate the validation effort.

(2)-

The Validation program scenario selection will be based on the following criteria:

(1) Plant-specific E0P differences from the ERG Rev. 1, HP reference plant.

(2) The basic ERG set has been validated at similar plants and will not be duplicated, per se, here.

(3) Plant conditions or events that have been identified as presently a challenge to correct E0P usage or to plant safety as determined by an in-house E0P review process and from other plant's validation programs.

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,. 1 (4) Scenarios that are requested by the Control Room Design Review Group.

(5) Sufficient multiple failure scenarios to provide validation of E0P transition points and correct usage.

(6) Scenarios from nuclear industry events.

(3)

Since one of the criterion for scenario selection is choosing scenarios having multiple failures, this is covered in item (2) above.

(4)

The E0P verification team is made up of a mixture of Westinghouse Electric Corporation and Georgia Power Company Operations Department personnel.

The two Westinghouse team members held R0 licenses at other Westinghouse PWRs and have extensive operating experience at these plants as well as in the Navy program. Four Georgia Power Company members have a variety of experiences including 9 man-years experience at other operating nuclear plants. half of which was participation in STA related activities. Two Georgia Power members hold SR0 certification and one member spent 9 months in SR0 observation training at another Westinghouse PWR. One of the Georgia Power members is a Shift Supervisor and the other three are STAS. All Georgia Power members have engineering degrees and plan to continue participation in the operations of Plant Vogtle.

All E0P verification team members are subject matter experts in ERG background and E0P development and have various operations experiences.

The E0P verification team effort is separate from the validation team effort and will have a different team composition as indicated in the E0P Validation Program.

Training Program Description The E0P training program includes classroom instruction or salf study on each E0P on an annual basis but does not necessarily exerciso all E0Ps on the simulator; however, the Operator training program does include exercising scenarios that ' transitions the operator through as many E0Ps as possible.

Performance of these scenarios will require the operator to exercise the major E0Ps. Entry into many of the E0Ps depends on individual operator perfor-mance of the E0Ps or on the number of multiple failures programed.

The VEGP Procedure Generation Package will be revised to reflect the information provided in this response and submitted to the NRC by April 1, 1985.

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