ML20136F201
Text
.
_ =
/
[
g)o UNITED STATES g
~, -
d NUCLEAR REGULATORY COMMISSION g
WASWNGTON, D. C. 20555 g.l4
- g. g
%g* ". a,/
September 11, 1984 s
f ms Docket Nos. 50-424/425 MEMORANDUM FOR: Thomas M. Novak, Assistant Director /
for Licensing K
Division of Licensing FROM:
William T. Russell, Deputy Director Division of Human Factors Safety
(
SUBJECT:
DRAFT SAFETY EVALUATION REPORT INPUT:
V0GTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 OPERATING AND MAINTENANCE PROCEDURES AND ANTICIPATED TRANSIENTS WITHOUT SCRA14
, is our draft SER input for Section 13.5.2, Operating and Maintenance Procedures and Section 15.8, Anticipated Transients Without Scram (ATWS). Section 13.5.2 includes consideration of TMI Task Action Plan (TAP)
Items I.C.1, Short-Tenn Accident Analysis and Procedures Revision, I.C.7, NSSS Vendor Review of Procedures, and I.C.8, Pilot Monitoring of Selected Emergency Procedures for Near-Tenn Operating License Applicants. Our input is based on review of the information contained in Section 13.5.2 of the
~
!/ m
'3 FSAR, Amendment 8 to the FSAR which contains responses to our questions, and a letter to the Director of Nuclear Reactor Regulation, Attention:
Ms. Elinor Adensam dated May 1,1984, enclosing " Emergency Operating Procedure Generation Package, Vogtle Electric Generating Plant."
The review was based on NUREG-0800, " Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," July 1981, Sections 13.5.2 i-and 15.8. The review includes an evaluation of the applicant's program for the development of emergency operating procedures (EOPs) in response to Supplement 1 to NUREG-0737 (Generic Letter 82-33). The E0P program review was conducted in accordance with Supplement 1 guidance and guidance in its reference document for E0Ps,.NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures." Criteria for this review are not currently in the Standard Review Plan (SRP).
Review criteria based on the guidance of i
NUREG-0899 have been developed for inclusion in the next SRP revision.
As discussed in the enclosure, the staff considers TAP Items I.C.7 and I.C.8 resolved for Vogtle 1 and 2.
The PGP, as specified in Generic Letter 82-33, consists of fcur parts:
(1) Plant-Specific Technical Guidelines, (2) Writer's Guide, (3) a description of the Validation / Verification Program for E0Ps, and (4) a description of the Training Program for Upgraded E0Ps. This DSER identifies i
the items that must be addressed to complete the review of each of the above
~
parts of the PGP. We will provide a supplement to our Safety Evaluation Report and our SALP input when these items are resolved.
The remainder of the applicant's program for maintenance and operating procedures is acceptable.
N p':
W92Loao( n
%g
Thomas M. Novak 2-September 11, 1984 This review is being conducted by Sam Bryan (X29852). The reviewer is not aware of any " Differing Professional Opinions" associated with this review.
Questions regarding this review should be directed to Mr. Bryan.
W $-
M William T. Russell, Deputy Director Division of Human Factors Safety
Enclosure:
Draft Safety Evaluation Report cc w/ enclosure:
E. Adensam M. Miller u,.
0 e
.er_
DRAFT SAFETY EVALUATI0fl REPORT INPUT 1
V0GTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 OPERATIflG AND MAINTENANCE PROCEDURES AND ANTICIPATED TRANSIENTS WITHOUT SCRAM e
13.5.2 Operating and Maintenance Procedures A.
General The staff has reviewed the applicant's plan for development and implementation of operating and maintenance procedures according to SRP 13.5.2.
The review was conducted to determine the adequacy of the applicant's program for assuring that routine operating, offnormal, and emergency activities will be conducted in a safe manner. The review was i
based on information in the FSAR, including the Amendment 8 response to a i
staff request for additional information and correspondence from the applicant.
Thestaffreviewincludedevaluationof(1)theapplicant's' classification t
fm system for procedures that are performed by licensed operators in the I
. control room, and for other operating and maintenance procedures; (2) the applicant's plan for completion of operating and maintenance procedures during the initial plant testing program to allow for correction prior to I
fuel loading; (3) the applicant's program for compliance with RG 1.33, Revision 2 " Quality Assurance Program Requirements" regarding the minimum procedural requirements for safety-related operations; (4)conformancewithANSIN18.7-1976/ANS3.2,"AdministrativeControls i.
and Quality Assurance for the Operational Phase of Nuclear Power Plants;"
and (5) the applicant's program for compliance with the requirements of Supplement 1 to NUREG-0737.
B.
Operating and Maintenance Procedures In the FSAR, the applicant has committed to a program in which activities important to safety are to be conducted in accordance with detailed
' written and approved procedures meeting RG 1.33, Revision 2, and ANSI /ANS 3.2-1978.
= -
=...
7
. As described in the FSAR, the applicant will use the following procedure categories for those operations performed by the plant operating staff:
o Phnt/ Unit o
System
,o Surveillance jo Annunciator Response o
Abnormal o
Emergency j
o Maintenance
.o Health Physics o. Laboratory o
Refueling
-o Emergency Plant Implementation We have concluded that the applicant's program for use of operating and maintenance procedures meets the relevant requirements of 10 CFR 50.34, and is consistent with the guidance provided in RG 1.33, Revision 2, and ANSI /ANS 3.2-1978.
In a submittal dated April 14, 1983, the applicant comitted to develop emergency operating procedures (EOPs) as required by Supplement 1 to NUREG-0737, " Requirements for Emergency Response Capability."
In this submittal, the applicant agreed to provide the staff its procedures generation package (PGP) approximately 28 months before scheduled fuel load, September 1986. The applicant also stated that the E0Ps written in accordance with the PGP will be developed and implemented approximately 24 months prior to fuel load. To preclude the possibility of training' operators on procedures developed using an unacceptable PGP, the PGP should be submitted 3 months prior to the start of operator training.
In a letter dated May 1,1984, from D. O. Foster
.to Elinor G. Adensam, the applicant submitted its PGP in accordance with the above comitments. Our evaluation of that submittal follows.
The staff finds the applicant's commitment to Supplement I to NUREG-0737 to
~.
be acceptable.
c
. C.
Reanalysis of Transients and Accidents; Development of Emergency Operating Procedures 1.
Introduction In letters of September 13 and 27, October 10 and 30, and November 9, 1979, the staff required licensees of operating plants, applicants for operating licenses, and licensees of plants under construction to (1) perform analyses of transients and accidents, (2) prepare E0P guidelines,(3)upgradeE0Ps,and(4)conductoperatorretraining (see also NUREG-0737, Item I.A.2.1).
E0Ps are reouired to be consistent with the actions necessary to cope with the transients and accidents analyzed. Clarification of the scope of the task and appropriate schedule revisions were included in NUREG-0737, Item I.C.1 and Supplement I to NUREG-0737, which require development and submittal of PGPs to NRC. The PGP will describe how the Vogtle 1 and
~
2.EOPs will be written using the generic Emergency Response Guidelines (ERGS) developed by the Westinghouse Owners Group.
The NRC staff reviewed the proposed Westinghouse Owners Group ERGS as described in Westinghouse Owners Group letters of November 30, 1981; July 21, 1982; January 4,1983; November 30, 1983; and May 4, 1984; and in the material accompanying those letters. The staff determined that the guidelines are based on reanalysis of transients and accidents and concluded that the guidelines are acceptable for implementation.
In accordance with NUREG-0737, Item I.C.7, NSSS vendor review of low power testing, power ascension, and E0Ps was necessary to further verify adequacy of the procedures. Because the applicant has connitted to implement procedures based on the NRC-approved Westinghouse ERGS, the staff does not consider an additional NSSS vendor review of the E0Ps necessary.
In addition, because the NSSS vendor will review preoperational and initial startup testing preceduras (14.2.2.2 of the FSAR), the staff considers MU2EG-0737, Item I.C.7 resolved.
.=
. Since the incident at TMI-2, applicants have been required to meet
~
NUREG-0737, Item I.C.8, " Pilot Monitoring of Selected Emergency i
Procedures for Near-Term Operating License Applicants." This pilot monitoring program was used on an interim basis for evaluation of applicant's E0Ps prior to staff approval of generic technical guidelines and staff development of the long-term program for upgrade of E0Ps. This is no longer necessary because the NRC has approved the Westinghouse ERGS and the applicant has connitted to develop E0Ps based on the ERGS. Therefore, the staff considers Task Action Item I.C.8 resolved.
In addition to the Westinghouse Owners Group efforts, we have published guidelines for long-term upgrading of E0Ps (NUREG-0899) in accordance with TMI Action Plan Item I.C.9.
These guidelines should
's be used in the preparation of the Vogtle E0Ps.
The Georgia Power Company submitted a PGP for Vogtle Units 1 and 2 in accordance with the requirements of " Supplement 1 to NUREG-0737 -
Requirements for Emergency Response Capability (Generic Letter 82-33)." The Generic Letter requires each licensee and applicant for an operating license to submit to the NRC a PGP, which includes:
(1) Plant-Specific Technical Guidelines (ii) A Writer's Guide (iii) A Description of the Program to be Used for the Validation of E0Ps (iv) A Description of the Training Program for the Use of Upgraded E0Ps.
j Based on our review, we determined that the procedure generation program for Vogtle 1 and 2 was acceptable with the exception of the
.i
, items identified in the following sections. The applicant should address these items in a revision to the PGP, or justify why such revisions are not necessary. Our review of the applicant's response to these items will be included in a supplement to this SER.
2.
Evaluation and Findings l
In a letter dated May 1,1984, from D. O. Foster to the Director of l
Huclear Reactor Regulation, Attention: Ms. Elinor G. Adensam, the applicant submitted its PGP. The PGP contained the following sections:
a.
Method of Developing Plant-Specific Emergency Operating Procedures from the Generic Guidelines
. ("%
b.
Writer's Guide c.
Validation Program d.
Training Program Description.
The staff reviewed the Vogtle PGP to determine the adequacy of the program for preparing and implementing E0Ps.
Criteria for the review of a PGP are not currently in the Standard Review Plan (SRP).
~
l Therefore, this review was based on NUREG-0899, the reference document for the E0P upgrade portion of Supplement 1 to NUREG-0737 (Generic Letter 82-33). Review criteria based on this guidance will be developed for the next SRP revision.
a.
Method of Developing Plant-Specific Emergency Operating Procedures from Generic Guidelines The Method of Developing Plant-Specific Emergency Operating Procedures from Generic Guidelines was reviewed to determine if f
it provided an adequate means of accomplishing the objectives l
l
-.a
~
of NUREG-0899. The applicant has elected to develop plant-specific E0Ps using the generic Westinghouse Owners Group ERGS, Revision 1.
The applicant submitted Procedure 10013-C, " Writing Emergency Operating Procedures from the Westinghouse Emergency Response Guidelines." This procedure is the administrative control for the instruction and direction of E0P writers.
It prescribes three phases:
preparation, generation, and documentation. The E0Ps are to follow the ERGS step-by-step except when plant-specific design is not consistent with ERGS.
Furthermore, steps should not be added or deleted except as required to conform with plant design.
h The applicant identified ten differences between the Vogtle plant and the reference plarit used for developing the Westinghouse Owners Group ERGS. The applicant concludes that these differences do not preclude the use of the ERGS as a basis for writing the Vogtle E0Ps. Since the Westinghouse Owners Group wrote the ERGS to encompass the basic Westinghouse design with provisions for plant-unique differences in the guidelin'e structure, we agree. ?!evertheless, these differences will require some deviations between the E0Ps and the ERGS. Such' deviations from the approved ERGS having safety significance should be submitted for staff review.
In addition, any analysis needed to assure that these deviations are acceptable should be provided.
Each procedural step that was changed because of equipment differences need not be described, but how the diffet 2nces affect specific E0Ps, any procedural strategy changes, and the analysis or evaluation to support acceptability should be provided.
e
'. No description of the process for using the generic guidelines and background documentation to identify the characteristics of needed instrumentation and controls is provided. For the information of this type that is n't available from the ERG and o
background documentation, Georgia Power Company should submit a description of the process to be used to generate this information(e.g.,fromtransientandaccidentanalyses)to derive instrumentation and control characteristics. This process can be described in either the revised PGP or DCRDR Program Plan with appropriate cross-referencing.
For potentially safety-significant, plant-specific deviations from the ERG instrumentation and controls need, a list of the deviations and their justification should also be provided.
r With adequate resolution of the abcVe items, the staff concludes that the applicant's procedure 10013-C, " Writing Emergency Operating Procedures from the Westinghouse Emergency Response Guidelines," will provide adequate guidance to accomplish the objectives sta,ted in NUREG-0899 for incorporating guidance in the ERGS into plant E0Ps. The staff will confirm that the applicant adequately addresses the above items.
b.
Writer's Guide The writer's guide was reviewed to determine if it provided acceptable methods for accomplishing the objectives stated in NUREG-0899.
The applicant selected a dual column E0P format with the left column designated for user actions and expected responses, and with the column on the right for contingency actions to be taken if the performed actions were not or could e"'
not be performed.
Our review of the writer's guide identified tha folicwing concerns:
3,.7. m, s
l u
C '
s
~~
=
(1)]?Since_EOPsareoftenusedundercircumstanceswhichcould
, produce significant stress on operators, placekeeping aid (s) sh.ould be provided or justify not having such aids.
(2)
In Section 5.0,'several important instructions are provided for writing instructional steps. However, instructions are not provided for the following types of steps.
n
?
s
{.
(a) Verification ~Staps - Verification steps are used to determine whether the objective of a task or a seque'nce of actions has been achieved. There are three comon methods for verification:
Checking that an action has resulted in a comand hh, signal to a piece of equipment. A more. positive indication should be used.
Checking that an action has resulted in a positive indication that the equipment has responded to a command.
Checking that an operator has correctly performed an action or has carried out a series of steps.
These types of verification steps should be used where appropriate in the procedures to ensure that equipment responses and operator actions have occurred and are correct.
d-
s.
9-(b) Time-Dependent Steps - Time-dependent steps are those that are required of the operator at some specified time interval, or some time after an action has taken place. A means should be provided to assist the operator in performing the step (s) within the required time frame.
(c) Diagnostic Steps - Diagnostic steps are those which lead the operator to the appropriate section of the E0Ps. These stops should assist the operator in diagnosis, and provide clear and unambiguous guidance leading to the diagnostic decision, as well as clear and unambiguous referencing to the appropriate section of the E0P. These steps may include the use of
/3 flow-diagrams, graphs or other operator aids.
Methods should be described in the guide for writing the above types of ste.os.
(3) Excellent guihnce for construction of a procedure and presentation of instructional information and attachments is provided. Guidance should also be included for assuring the quality of procedure copies. The copy quality or
" legibility" of E0Ps is essential so the operator using the E0P during an emergency has no question about its contents.
With adequate resolution of the above items, the staff concludes that the Vogtle writer's guide provides adequate guidance for translating the technical guidelines into E0Ps which should be useable, accurate, complete, readable, convenient to use and acceptable to control room operators. The staff will confirm C.
that the applicant adequately addresses these items.
'~'.
c.
Validation and Verification Programs The description of the applicant's validation / verification programs were reviewed to determine if they acceptably address the objectives stated in NUREG-0899. The validation / verification programs have two purposes:
(1) to ensure that the heedures are written consistent with the writer's guide, and (2) to ensure that precedures are technically correct. The applicant's stated basis for all validation criteria is to assure that the E0Ps provide direction to place the plant in a safe, stable condition regardless of imposed structural and equipment failures. As stated by the applicant, safe means that the reactor is shutdown and has adequate cooling; stable means either that conditions are in equilibrium, or are changing in response to tf-operator control. During our review of the verification /
4 validation programs, we noted the following iteins:
(1) A control room walkthrough of each procedure in the program should be conducted. The programs state that a demonstration of correspondence between the control room and hardware must exist; however, no method to accomplish this objective is specified.
(2) The programs do not provide criteria for the selection of scenarios to be used in simulator exercises for validation /
verification.
(3) The programs do not indicate that the simulator exercises will include multiple failures (simultaneous and sequential).
,. n,
.. - = -. -
- n 1
i
' (4) Page 9 Step 2.1.1 of the Verification of E0Ps states, "The Operation Procedures Coordinator shall designate personnel to verify E0Ps." The verification team should include subject matter experts as well as members of the operating crews.. Team composition should be identified by discipline.
With addition of appropriate guidance on the preceding items, the Validation / Verification programs would meet the objectives of NUREG-0899 and, therefore, would be acceptable.
The staff will confim that the licensee addresses these items.
d.
Training Program Description The applicant's description of the program for training operators on the E0Ps was reviewed to determine if it acceptably addresses the objectives stated in NUREG-0899. The training program as described in the PGP consists of classroom and simulator instructions.
Criteria for evaluation of trainees are included in the program. The program does not require each trainee to exercise all E0rs on the simulator. This requirement should be clarified.
With adequate resolution of this item, we believe the training plan will adequately address the objectives stated in NUREG-0899 and should result in appropriate operator training on the E0Ps.
I 3.
Conclusions The PGP submitted by Georgia Power Company for Vogtle 1 and 2 adequately addresses the guidance of NUREG-0899, except for the items noted in Section 2.
The PGP should'be revised to address these items A
and submitted to the NRC for review.
The results of our review will be' reported in a supplement to this SEE.
I
~
=.
' Based on our review, we conclude that, with the exceptions noted, the Vogtle 1 and 2 PGP meets the requirements of Supplement I to NUREG-0737 and describes acceptable methods for acccmplishing the objectives stated in NUREG-0899. The staff therefore has reasonable assurance that E0Ps developed'and implemented in accordance with the program described in the applicant's PGP should be adequate for control room _ personnel to effectively mitigate the consequences of a broad range of accidents and multiple equiprrent failures.
Future changes to the PGP shall be documented in accordance with 10 CFR 50.59.
15.8 Anticipated Transients Without Scram Anticipated Transients Without Scram (ATWS) are events in which the scram system (reactor trip system) is postulated to fail to operate as required.
This subject has been under generic review by the Ccmission staff for several years.
In December 1978, Volume 3 of fiUREG-0460, " Anticipated Transient Without Scram for Light Water Reactors" was issued describing the proposed type of plant modifications the staff believed necessary to reduce the risk from anticipated transients with failure to scram to an acceptable level. The staff issued requests for the industry to supply generic analyses to confirm the ATWS mitigation capability described in Volume 3 of NUREG-0460, and subsequently the staff presented reccmendations on plant modifications to the Comission in September 1980. The staff recommended to the Commission that rulemaking be used to determine.the required modifications to resolve ATWS concerns as well as the required schedule for implementation of such modifications. Vogtle Electric Generating Plant is subject to rulemaking on this matter. Rulemaking was accomplished with publication in the Federal Register Jene 26, 1984 of the final rule, " Reduction of Risk from Anticipated j
rs Transients Without Scram (ATWS) Events for Light-Water-Cooled Nuclear Power Plants. The staff has not yet ccmpleted action to implement the rule in accordance with the Comission directive in the rule.
)
]
4
. In the meantime, the following discusses the bases for operation of Vogtle Electric Generating Plant at full power while the schedule for final implementation of the ATWS rule is being developed.
NUREG-0460, Volume 3, states:
"The staff,has maintained since 1973 (for example, see pages 69 and 70 of WASH-1270)and reaffirms today that the present likelihood of severe consequeces arising from an ATWS event is acceptably small and presently there is no undue risk to the public from ATWS. This conclusion is based on engineering judgement in view of:
(a)the estimated arrival rate of anticipated transients with potentially severe consequences in the event of a scram failure; (b) the favorable operatingexperiencewithcurrentscramsystems;and(c)theIfmited number of operating reactors."
In view of these considerations and action to be required by the new rule, the staff concludes that the Vogtle Electric Generating Plant can operate because the risk from ATWS events in the time period to implement the rule is acceptably small. As a prudent course, to further reduce the risk from ATWS events during the interim period before completing the plant modifications determined by the Coranission to be necessary, the staff requires that emergency procedures be developed to assist operators in the recognition and mitigation of an ATWS event.
These procedures shall include consideration of scram indicators, rod position indicators, flux monitors, pressurizer level and pressure indicators, pressurizer relief valve and safety valve indicators, and any other alarms annunciated in the control room, with emphasis on alarms not pro. cessed through the electric portion of the reactor scram system. When implemented, these procedures will provide an acceptable basis for interim O
operation of the Vogtle Electric Generating Plant based on the staff's understanding of the plant respcn::a to postulated AT'JS events.
r As noted in Section 13.5.2 B of this Safety Evaluation, the applicant has comitted to implement E0Ps based on the Westinghouse ERGS that have been endorsed by Generic Letter 83-05. These guidelines include instructions for coping with ATWS. The staff concludes that the applicant's comitment to implement procedures based on t.iese guidelines is acceptable on an interim basis for full power operation.
Future modifications will be necessary to implement the ATWS rule and the required schedule for implementation of such modifications will be determined by staff action.
9
/%
,c I.
..f.
e.,
e w-
,rg v
t
-w-
-T-. -
-wy e--
P-P T
- &