ML20125C007
| ML20125C007 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 12/07/1992 |
| From: | Bettenhausen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Murphy W VERMONT YANKEE NUCLEAR POWER CORP. |
| References | |
| NUDOCS 9212110004 | |
| Download: ML20125C007 (3) | |
See also: IR 05000271/1992080
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7 1992
Docket No. 50-271
Mr. Warren P. Murphy
Senior Vice President, Operations
Vermont Yankee Noclear Power Corporation
RD 5, Box 169
Ferry Road
Brattleboro, Vermont 05301
Dear Mr. Murphy:
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SUBJECT: INSPECTION NO. 50-271/92-80
This refers to your letter dated October 13, 1992, in response to our letter dated
July 30,1992.
Thank you for informing us of the corrective and preventive actions documented in your
letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
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Lee H. Bettenhausen, Chief
Operations Branch
Division of Reactor Safety
OFFICIAL RECORD COPY
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Mr. Warren P. Murphy
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cc:
D. Reid, Plant Manager
J. %ayer, Vice President, Yankee Atomic Electric Company
L. Tremblay, Senior Licensing Engineer, Yankee Atomic Electric Company
J. Gilroy, Director, Vermont Public Interest Research Group, Inc.
D. Tefft, Administrator, Bureau of Radiological Health, State of New Hampshire
Chief Safety Unit, Office of the Attorney General, Commonwealth of Massachusetts
R. Gad, Esquire
G. Bisbee, Esquire
R. Sedano, Vermont Department of Public Service
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T. Rapone, Massachusetts Executive Office of Public Sa aty
Public Document Room (PDR)
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
K. Abraham, PAO (2) (w/ copy of letter dtd October 13, 1992)
NRC Resident inspector
State of New Hampshire, SLO Designee
State of Vermont, SLO Designee (w/ copy of letter did October 13, 1992)
Commonwealth of Massachusetts, SLO Designee
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OFFICIAL RECORD COPY
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Mr. Warren P. Murphy
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Region 1 Docket Room (with con urrences and IFS Forms)
DRS/EB SALP Coordinator
L. Bettenhausen, DRS
- R. Conte, DRS
J. Linville, DRP
E. Kelly, DRP
H. Eichenholz, SRI - Vermoni Yankee (w/ concurrences and IFS Forms)
N. Perry, SRI - Yankee Rowe
V. McCree, OEDO
P. Sears, NRR
W. Buti. r, NRR
-T Walker, DRS
DRS Files (1)
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OFFICIAL RECORD COPY
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VERMONT YANKEE
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NUCLEAR POWERlCORPORATION
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Ferry Road, Brattleboro, VT 05301-7002
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October 13,1992
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U.S. Nuclear Regulatory Commission
Washington, D.C. 20555
Attention:
Document Cor <r-%
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Refert.1ces:
a)
License No. DPR-28 (Docket No. 50-271)
b)
Letter USNRC to WNPC, inspection Report 92 80, NW 92-059, dated
4/14/92
c)
Letter, M JPC to USNRC, BW 92-071, Response to inspection Report -
92-80, dated 6/22/92
d)
Letter, USNRC to WNPC, Emergency Operating Procedures (EOP)
Inspection Response Meeting Inspection Report 50-271/92-80, NW
92145, dated 7/30/92
Dear Sir:
Subject:
Revised Response to inspection Report 92-80
This letter is wotten to provide a revised response to the weaknesses identified by an NRC
Emergency Operating Procedure _ (EOP) Inspection Team during the special announced safety .
Inspection conducted from February 24 to February 28, 1992, and documented in Reference b).
Included in this submittal is the additional information on specific actions Verment Yankee plans to take .
on each of the issues identified during our meeting, hd at the NRC Region 1 office on July 14,1992
and documented in Reference d).
Information is submitted in _the accompat. J attachments in response to - the- identified
weaknesses in (1) the technical adequacy of the Vermont Yankee Piant Specific Technical Guidelines -
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(PSTGs), EOPs, Reactor Pressure Vessel Control guideline and (2) the EOP programmatic controls as
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noted in Sections 3.1,3.2,3.2 and 4.2 and Sections 6.1 and 6.2, respectively, of Reference b).
It is our intent to fully resolve all issues related to both the specific weaknesses identified by the
NRC inspection as well as those arising from our own root cause analysis, within an updated Procedure
Generation Package (PGP), revised OE's and other plant operating procedures. Further, we will pursue
resolutions of any appropriate generic items by continued participation in the cognizant industry groups .
such as the BWROG Emergency Procedures Committee and the NUMARC Severe Accident Working
Group.
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VERMONT YANKEE NUCLEAR POWER CORPORATION
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U.S. Nuclear Regulatory Commission
October 13,1992
' Page 2
We plan to incorporate the updates to the PGP and the EOPs, incluaing correction of deficiencies
concerning OE 3100, " Scram Procedure", and the " Torus Temperature Control" guideline, such that
they may be used for training beginning in February 1993. Implementation will be completed and:
revised procedures issutsd, following completion of operatM training in 1993. Also, as agreed earlier,
a sufficient quantity of borax required by OE 3107, Appendix J, has been obtained.
We believe that the actions proposed are responsive to your concerns; however, shoul's you have
any further questions, please do not hesitate to contact us.
Very truly yours,
Vermont Yankee Nuclear Power Corporation
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Warren P.
rphy
Senior Vic President,
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USNRC Region l Administrator
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USNRC Resident inspector - VYNPS
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ROOT CAUSE ANALYSIS
AND
CORRECTIVE ACTION PLAN
LUMMARY OF N_R_Q FINDINGS RELATIVE TO TECHNICAL ADEQUACY:
Discrepancies were identified in the VY PSTGs that detract from the technical adequacy of the VY
accident mitigation strategies. Additionally, some problems were noted with the technical adequacy
of the EOPs and EOP support procedures, including some minorinconsistencies between the VY PSTGs
and EOPs. The technical adequacy of the VY PSTGs, EOPs and EOP support procedures is considered
to be unresolved pending licensee review and resolution (Sections 3.1,3.2, and 3.3).
VY RESPONSE:
Sections 3.1, 3.2, and 3.3 of the inspection report contain a total of 45 comments. Two of these
comments were resolved and require no further licensee action as a result of our July 14,1992
meeting and documented in Reference d). Vermont Yankee will resolve the remaining weaknesses,
criticisms, or acceptable alternatives to our current technical justifications by appropriate revision of
the PGP's, OE's and suppon procedures as identified in the attached matrix and supporting attachment
" Amplifying information to NRC Comments" Implementation will be completed and revised procedures
issued, following completion of operator training :' 1993.
BOOT CAUSE;
We have conducted our review of the identified weaknesses and have determined that there is no
single root cause for their occurrence. Some were due to insufficient management oven.ight and
others were due to weaknesses in the quality control process. The majority of the issues identified
as weaknesses have as their root cause the lack of clearly defined standards regarding what
constitutes sufficient justification for deviation from generic emergency procedure guidelines.
We believe the standards have and wi!) continue to evolve with practice and time as both the NAC and
industry gain experience with the issues. For example, as noted in the inspection report, Vermont
Yankee's EOP program was much improved as a resuk of response to inspection findings (USNRC
Inspection Report No. 50-271/91-02) as well as our own initiatives derived from the guidance provided
in NUREG-1358, t* Lessons Learned From the Special Inspection Program for Emergency Operating
Procedures").
SUMMARY OR NRC FINDINGS RELATIVE TO PROGRAMMATIC WEAKNESSES:
Weaknesses in the program have resulted in EOP appendices and support procedures that are not of
the same high quality (as the flowchart procedures).
The programmatic controls do not appear to be effective, for ensuring that tools and materials will be
available to support implementation of the EOP support procedures.
These weaknesses in the EOP programmatic controls are considered to be unresolved pending licensee
review and resolution (Sections 6.1 and 6.2).
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VY RESPONSE:
An OE appendix writers guide will be developed in accordance with the criteria established in NUREG 0899, and incorporated into Vermont Yankee's PGP. In addition, the Verification and Validation
programs will be revised to include the appropriate criteria when applied to OE appendices and support
procedures, and will address the utilization of multi-disciplined teams during procedure development.
Appropriate surveillance checklists for tools and materials will be developed and controlled via
administrative procedures. Scheduled surveillance intervals will be established based on past
experience with similar tool and material control processes. Implementation will be completed and
revised procedures issued. following completion of operator training in 1993.
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ROOT CAUSE:
The root cause for the programmatic weaknesses which resulted in EOP appendices and support
procedures not being of the same high quality as the flowchart procedures, has been determined to
be due to a change in the method for preparation of OE appendices which did not require a review
equivalent to the flowchart development process. A contributing equse was the erroneous assumption
that, as with other procedures, there would be adequate exercise of the OE appendices and support
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procedures by operators during training and practice to provide additional verification and validation
via the procedure change suggestion process. In addition, specific guidance was not provided in the
procedure writers guide for development of OE appendices in accordance with Vermont Yankee's PGP.
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The root cause for failing to ensure the availability of tools and materials needed for EOP
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implementation has been determined to be inadequate administrative controls.
In the past,
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uncontrolled checklists have been utilized for surveillance of materials and tools necessary for
implementation of OE appendices. In addition, there was no provision for ensuring that review and
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timely revision of the checklists were performed when necessitated by EOP or support procedure
changes.
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IIRC SECTIOli #1: Cot 1PAltISOrt OF BWHOG EPGs & VY PSTCS
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COMMEt!T TYPE
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SECTIOtt
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REVISE
REVISE
REVISE
REVISE-
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TECl!
FORMAT
PSTG
DIFF-1
DIFF-2
OE(s)
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A.1
' Transitions from Other Guidelines
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A.2.a
Injection Thru the RilR lleat Exchangers
X
X
X
X
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override to Repoen tiSIVs
X
X
X
X
3. b
, Initiation'of Shutdown Cooling
X
X
X
X
REV OP'OlO9
A
Initiation of Alt Rod Insertion & Reset
X
X
X
b
4 . c.
A.4.b
Incraasing CRD' Differential Pressure
X
X
X
X
f4EW EOP APP
B.I.a
ItPV Depressurization
X
X
X
X
B.2.a
Defeating Isol at. lon Interlocks
X
.X
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B.3.a
Termination of Injection at Vacuum ear Elev
X
X
X
X
B.3.b
Termination of Inject.'for. Primary Containment
X
X
X
X
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Water l evel- Limit
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B.4.a
Override Statement
X
X
B.4.b
Air Purge
X
X
.X
X
X
C.1
Entry Conditions-
X
X
X
' REVISE ARPs
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' Secondary Contair ment Vent. Override
X
X
X
X
C 3.a
Operation of Avattable fib Ve'ntilation
X
X
X
X
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C.4.a
Floor Drain Sump Water Levels
X
X
X
X
D .' l
Emergency Depressurization
X
X
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E.1.a
Inhibit ADS
X
X
X
X
E .1. b'
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Spray Cooling
X
X
X
X
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Transition from Spray Cooling to' Steam Cooling
X
X
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E. 2. a -
1ermination &' Prevention'of Injection
X
ISSUE-
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Defeating' Interlocks
X
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X
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f1EW EOP APP
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E.3.a
_RPV Wtr-Lvl Helow tiin Stm Cool Wtr Lvl
X
X
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E.3.b
Transition to' Primary Containment Flooding'
X
X
X
X
E.4.4-
HPV Venting-
X-
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'X
X
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flew EOP APP
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MRC SEC14.ON #2 COMPARISOtt OF VY PSTGS & VY FOPS
COMMENT TYPE
REVISE
REVISE
BEVISE
REVISE
SECTION
TITLE
TECil
FORCAT
PSTG
DIFF-1
DIFF-2
OE(S)
OTilER
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A.1
Shutdown Conditions
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X
X
B.1
Entry Conditions-RPV Water Level
cannot be Determined
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B.2.a
Override-Trsnaition to Level / Power
X
X
X
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Control
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Injection Through The f<llR !! eat
X
X
X
X
REVISE OP 2124
Exchangers
X
B.2.c
Use of Alternate Injection Systems
X
D.3.a
itent Capacity Temperature Limit &
X
X
X
REVISE OE 3100
SRV Tail Pipe Level Limit
REVISE OP 0109
X
B.3.b
RPV Depressurization
X
B.4.a
Defeating RPS Logic Trips
X
X
X
X
X
C.1 -
Suppression Pool Temperature
Control
C.2.a
Primary Containment Pressure
X
X
X
D.1
tilgh Reactor Building Dif f erential
X
X
X
REVISE OK 3153, 3158 &
OP 2116
Pressure Entry conditions
D.2.a
Floor Drain Sump Water Levels
X
X
X
X
REVISE ARS(s)
REVISE STUDY CUIDE
E.1.a
Transitions from Other Guidelines
X
ISSUE CLOSED
E.2.a
RPV Water Level Above the Minimum
X
Steam Cooling RPV Water Level
E.2.b
Exit from Level Power Control
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~ NRC SECTIOtt #3 TECl!!!ICAL ADEOUACY OF EOPS & SUPPORT PROCEDURES
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COMMEtiT TYPE
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TITLE
TECil
FORMAT
REVISE
REVISE
REVISE
REVISE
PSTG
DIFF-1
DIFF-2
OE(s)
OTilER
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A
Primary Containment' Water
X
CilANGE DRYWELL' HIGli WATER -
Level Indication
LEVEL ALARM SETPOINT
.B.
Isolation of Systems
X
-REVISE.ON 3153 &'3158'
Discharging Into Secondary
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Containment
-C
Emergency RPV
X
X
NEW EOP APPENDICES-'
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Depressurization with
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Alternate Systems
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Control' Rod' Insertion
X
REVISE OP 0109.l
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Throttling Fire Water
X
X
Injection
Royg (1)
PGP. APPENDIX As,PLAllT' SPECIFIC TECllNICAL GUILDEIN (PSTG)
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(2) IPGP APPENDIX E EPG TO PSTG:DIFFEREllCES (DIFF-1)
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-(3) ' PGP APPE!! DIX F: PSTG TO OE DIFFEREt3CES (DIFF-2)
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SECTION
TITLE
BRIEF DESCRIPTION OF CORRECTIVE ACTION
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A.1
Transitions from Other Guidelines
Revise PSTG to specify transition to RPV Control (OE 3101)
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Remove previous justification from Diff-1 and justify OE
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transi. tion to OE 3100 (Scram Procedure) in Dlff-2.
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A.2.a
Injection Thru the RHR Heat Exchangers
Revise PSTG to agree with EPGs, remove previous justification
from Diff-1 and justify the use of the operating procedure in
Diff-2.
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A.3.a
override to Reopen MSIVs
The bypassing of the high steam flow not in Run isolation
interlock will be removed fr.-n the PSTG.
Diff-1, OE 3101 and
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Appendix P will be modified to reflect change.
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A.3.b
Initiation of Shutdown Cooling
Revise PSTG to agree with EPGs; Diff-l will be changed to
reflect change; the use of OP 0109 will be justified in Diff-
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2 and OP 0109 will be revised to provide direction as to when
to shutdown to cold S/D.
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A.4.a
Initiation of Alt Rod Insertion & Reset
The PSTGs and OEs will be revised to agree with EPGs.
A.4.b
Increasing CRD Differential Pressure
Revise PSTG to agree with EPGs; the previous justification in
Diff-l will be deleted; the OEs will be changed to agree with'
the PSTGs and a new appendix will be written with direction
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for increasing cooling water delta P.
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D.1.a
RPV Depressurization
Rather than reliance on training, provide decision step which
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requires operator to determine if an ATWS condition exists.
prior to proceeding with depressurization in accordance with
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Tech. Specs.
This will require revision of PSTG, Diff-l and
EOPs.
B.2.a
Defeating Isolation Interlocks
Additional justification will be provided in Diff-l utilizing
existing design basis information.
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D.3.a
Termination of Injection at Vacuum Bkr Elev
The PSTG will be revised to agree with the EPGs; Diff-1
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justification will be deleted and OEs changed to agree with
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PSTGs.
B.3.b
Termination of Injection for Primary
The PSTGs will be revised to agree with the EPGs; Diff-1
Containment Water Level Limit
justification will be deleted and OEs changed to agree with
PSTGs.
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B.4.a
Override Statement
Revise Diff-1 to strengthen justification for not assuming
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unknown concentrations are above deflagration limits.
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B.4.b
Air Purge
The PSTG will be revised to agree with the EPGs and Diff-l
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justification deleted. The OE will be changed to permit air
purge with TSC concurrence and revise Diff-2 to justify
difference between PSTC and oE.
C.1
Entry Conditions
Move justification for differences to Diff-2 from Diff-l and
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revise alarm response procedures to include appropriate
accident mitigation strategy action steps.
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C.2
Secondary Containment Vect. Override'
Revise PSTG to agree with EPGs, delete previous justification
in Diff-1 and change OEs to agree with PSTGs.
C.3.a
Operation of Available RB Ventilation
Revise PSTG to agree with EPGs and move justification from
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Diff-1 to Diff-2.
C.4.a
Ploor Drain Sump Water Levels
Revise PSTG to agree with EPGs and move justification from
Diff-1 to Diff-2
D.1
Emergency Depressurization
Improve justification in Diff-l
E.1.a
Inhibit ADS
Revise PSTG to agree with EPGs; delete previous justification
from Diff-1 and revise OEs to agree with PSTG.
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E.1.b
Spray Cooling
Revise PSTG to agree with EPG logic, delete previous
justification from Diff-1 and change OE to agree with PSTG.
E.1.c
Transition from Spray Cooling to Steam Cooling
Revise PSTGs and OEs to indicate transition to Primary
Containment Flooding.
E.2.a
Termination & Prevention of Injection
The comments relative to this issue were resolved at the July
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14, 1992 meeting with the NRC, no further action required.
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E.2.b
Defeating Interlocks
Revise PSTG and OEs to allow isolation interlocks to be
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defeated and delete previous justification in Diff-1.
A new
appendix will be developed with direction on accomplishing
the bypassing.
E.3.a
RPV Wtr Lvl Below' Min Stm Cool Wtr Lvl
Revise Diff-l to include additional / complete and detailed
justification.
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E.3.b
Transition to Primary Containment Flooding
Revise PSTG to agree with EPG; delete previous justification
in Diff-l and revise oE to agree with PSTG.
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E64.a
RPV Venting
Revise PSTG to agree with EPG; delete previous justification
from Diff-1; revise Diff-2 to justify venting w/TSC
concurrence; revise ~OEs to use MSIVs to vent and write-new
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appendices for using systems to vent.
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AMPLIFYING INFORMATION TO NRC COMMENTS
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NRC SECTION #2 COMPARISON OF VY PSTGS & VY EOPS
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SECTION
TITLE
BRIEF DESCRIPTION OF CORRECTIVE ACTION
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A.1'
Shutdown Conditions'
Revise applicable steps in the OEs to state that..."the reactor' is and.
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will remain shutdown as indicated by any of the following conditions:"
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B.1
Entry Conditions-RPV Water Level
Revise Diff-2 to explain philosophy of using scram procedure (OE 3100)'and'1
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Cannot be Determined
revise OE 3100 and Appendix A to include "RPV water level cannot'be..
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determined".an a scram condition.
B.2.a
Override-Transition to Level / Power
Revise Diff-2 to explain philosophy of using scram procedure (OE 3100? and lE .
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Control
revise OE 3100 to include override.
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Injection Through The RIIR lieat
Revise PSTG to agree W/EPG, then justify in Diff-2 using the operating
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Exchangers
procedure and revise operating procedure.
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D.2.c.
Use of Alternate Injeccion Systems
Revise OE to agree wi.th PSTG.
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D.3.a
lieat Capacity Temperature Limit &
The scram procedure (OE 3100) will be revised to include override and
.
SRV Tail Pipe Level Limit
Diff-2 will be revised to delete previous justificaiton.
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D.3.b
RPV Depressurization
Revise OP 0109 to permit RPV depressurization regardless of main condenser
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availability, no other changes necessary.
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B.4.a
Defeating RPS Logic Trips
Revise OE 3101 and OE 3107 to agree with PSTG.
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C.1.a
Suppression Pool Temperature
Rather than reliance on training, provide decision step which requires.-
[
Control.
operator to determine if an ATWS condition existe prior to proceeding with
depressurization in.accordance with Tech. Specs. This will require
revision of PSTG, Diff-1 and EOPs.
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C.2.a
Primary Containment Pressure
Revise PSTG to say Drywell and explain in Diff-1.
D.1
Itigh Reactor Duilding Dif ferential
Revise OE to more clcaely agree with PSTG and change Diff-2.
OP 2116, ON
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Pressure Entry Conditions
3153 and 3158 will be revised to contain direction from PSTG.
D.2.a
Floor Drain Sump flater Levels
Revise PSTG to agree with EPG; delete previous justification'in Diff-1;
Revise Diff-2 to justify use of Alarm Response Procedures.(ARPs) and
revise ARPs to provide direction per PSTG.
E.1.a
Transitions from Other Guidelines
Revise study guide to incorporate expectations on use of transitions.
E.2.a
RPV Water Level Above the Minimum
Comments resolved & require no licensee action 7/14/92 mtg w/NRC
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Steam Cooling RPV Water Level
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fE.2.b
Exit from Level Power Control
Revise Diff-2.to' provide fmproved justification.
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AMPLIFYING'INFORMATION.TO NRC COMMENTS
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NRC SECTION #3 TECIINICAL ADEQUACY.OF EOPS:& SUPPORT PROCEDURES
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SECTIOtl
TITLE
BRIEF DESCRIPTION OF CORRECTIVE ACTION
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A
Primary. containment Water
The Drywell high water level alarm setpoint will be changed to provide
Level Indication
indication consistent with'OEs.
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B
Isolation of Systems
Procedure ON 3153 and 3158 will be changed to agree with.OEs.
Discharging Into Secondary
Containment
C
Emergency RPV'
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OEs will be revised to reference new appendices and new appendices will be
Depressurization with
written to address alternate systems.
_
Alternate Systems
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D
Control Bod Insertion
OP.0109 will be revised to direct insertion of any rode that'may be withdrawn.
even if'already shutdos..i.
'E
Throttling Fire Water
Revise OE 3107 to indicate correct valve to.be used for control.
Injection
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110TE _ (1)
PGP APPENDIX As PLANT SPECIFIC TECl!NICAL GUILDEIN (PSTG)
(2)
PGP APPENDIX E EPG TO PSTG DIFFERENCES (DIFF-1)
(3)
PGP APPENDIX'F: PSTG.TO OE DIFFERENCES (DIFF-2)
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