ML20125C007

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Ack Receipt of 921013 Response to NRC Re Weaknesses Noted in Insp Rept 50-271/92-80 Re EOPs
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:

.

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

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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

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VERMONT YANKEE

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NUCLEAR POWERlCORPORATION

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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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cc:

USNRC Region l Administrator

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USNRC Resident inspector - VYNPS

USNRC Project Manager - 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.

.

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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FORMAT

PSTG

DIFF-1

DIFF-2

OE(s)

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A.1

' Transitions from Other Guidelines

X

X

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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

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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

X

X

X-

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

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E.4.4-

HPV Venting-

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MRC SEC14.ON #2 COMPARISOtt OF VY PSTGS & VY FOPS

COMMENT TYPE

REVISE

REVISE

BEVISE

REVISE

SECTION

TITLE

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FORCAT

PSTG

DIFF-1

DIFF-2

OE(S)

OTilER

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A.1

Shutdown Conditions

X

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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

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Control

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H.2.b

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

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FORMAT

REVISE

REVISE

REVISE

REVISE

PSTG

DIFF-1

DIFF-2

OE(s)

OTilER

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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

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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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NRC SECTION #1: COMPARISON OF BWROG EPGs & VY PSTGS

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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.

4

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

,

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

.

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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B.2.b

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

I

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.

.

B

Isolation of Systems

Procedure ON 3153 and 3158 will be changed to agree with.OEs.

Discharging Into Secondary

Containment

C

Emergency RPV'

.

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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