ML20115D634

Informs of Change to EOP Development Program,As Described in Response to NUREG-0737,Suppl 1 & 920716 Response to Deficiencies Noted in Requalification Exam Rept 50-413/92-300,per 920713 Mgt Meeting W/Nrc

ML20115D634
Person / Time
Site:	Catawba
Issue date:	10/07/1992
From:	Tuckman M DUKE POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 9210210065
Download: ML20115D634 (3)

Text

- s .a .

-.9+ -4 a

, in,tr nm er comi,any - ns remar Calataa Mudrar On.iratieri l'er,rtsheht h tcr hntJrni

• k&Oct:iWOrd500)

{&])MlOW Of?kt yhrk, SC ZyNi (M1)UIJ4:6 fu DUKEPOWER October _7,1992 U. S. Nuclear Regulatory Commission ATrN: Document Control Desk Washington, DC 20555 ,

Subject:

Catawba Nuclear Station Docket Nos. 50-413 and 50-414 Emergency Procedure Development Process NUREG 0737, Supplement 1 in a letter dated July 16, 1992, Catawba responded to tie deficiencies identified in Catawba .:

Requalification Examination Report 50-413/92-300. This information was also discussed in a management meeting held with th NRC on July 13,1992 at Region II in Atlanta. In the Jul) 16,1992 letter, we committed to upgrade / revise our existing Emergency Opera:ing Procederes as necessary to correct the deficiencies noted in the report and to ensure their usability. In addition, we have committed to completely upgrade all of the Catawba Emergency Operating Procedures (EOPs) to Revision IB of the Westinghouse Owners Group Emergency Response

-Guidelines (ER03). To make these changes, we feel it is necessary to change our EOP development program as described in our response to NUREG-0737, Supplement 1. ,

Currently, Catawba utilizes Duke Power specific Emergency Procedure Guidelines (EPGs) as the basis for the Catawba EOPs. These EPGs contain NRC approved safety significant deviations from die Westinghouse ERGS. Presently, the Catawba EOP development and revision process ensures that any changes to the EOPs are reviewed to ensure agreement with the EPGs.

We plan to climinate the EPGs when the new set of EOPs are issued since these'.:cw EOPs will be based solely on the Westinghouse ERGS with designated deviations.

We are presently revising certain EOPs to address the problems noted h the above mentioned report and those identified during simulator use. As these revisions are made, we are inco porating some of the Westinghouse ERG guiCance to improve (l'e procedures and to allow ~

for a smoother transition from the EPG guidance to the Westinghouse ERG guidance. Since we will be deleting the EPGs when we reach the point of changing out the EOPs, we feel that it would no longer be beneficial to continue to rpdate the EPGs as we make these changes.

19016 pg2288 ME!df hpD v

u n ene .te

U. S. Nuclear Regulatory Commission October 7,1992 Page 2 Therefore, as we revise the existing EOPs and incorporate some of the. Westinghouse ERG guidance, we will not revise th associated EPGs. In order to maintain traceability of these deviati ons from the EPGs, Catawba will maintain appropriate documentation that details how the EOP is different from the EPG. 'This documentation will be maintained until the EOP change out occurs. At that time, the EPGs and the documentation detailing EPG deviations will be de:eted.

In our response to NUREG 0737, Supplement 1, we described the methodology used to convert-the Westinghouse ERGS to plant specine procedures, this saine process will be used in the future with the exception that the EPGs will no long ., a part of the process. As a result, procedare RS-03,- Technical Verincation of Nucle.c Station Emergency Procedures and Guideliacs, which was attached to our response tc NUREG 0737, Supplement i and described -

the technical veriGeation process, is no lona, valid. Technical verification of the EOPs will still be performed when incorporating E:,0 gi idance, but EPGs will no longer be a part of the -

process.

In ::ummation, we are revising our EOP development program in that we will no longer revise our EPGs as changes are made to the EOPs during our transition from EPG based to ERG based EOP3. During this transition, we will maintain documentation which details how the EOPs are different from the EPGs. In addition, technical verincation of the EOPs will coatinue to be performed when incomorating Westinghouse ERG guidance, but the EPGs will be removed from this process. Please consider this letter as formal noti 6 cation of this change to our EOP development program. -

Very truly yours, lld At 6, I M. S. Tuckman L RKS/

l l

r

. , _ _ ~ , _ . . _ _ _ - . . _ - - , , . . _ , - . _ _ - _ .,,

g-y , , - . . . . . . . - . ,- - - - - - - - - - - - - - - - - - - - -- - - - -- - -

~

U. S. Nucl_car- Regulatory Commission

- October 7,1992 Page 3 xc: S. D. Ebneter Regional Administrator, Region II

~

- T. A, Peebles Operations Branch Chief, Region 11 ,

R. E. Martin, ONRR W. T. Orders Senior Resident Inspector mr^i f$

e 4

g ~.

s _ . _ _ _ _ _ m __. __.__.__ J