ML20138H396

Forwards Section 13 of Sser 3,documenting NRC Review of Operating Procedures Based on Rev 1 to Westinghouse Emergency Response Guidelines,Per 851021 Results of Preliminary Review.Related Correspondence

ML20138H396
Person / Time
Site:	Seabrook
Issue date:	10/24/1985
From:	Perlis R NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Harbour J, Luebke E, Wolfe S Atomic Safety and Licensing Board Panel
References
CON-#485-914 OL, NUDOCS 8510290027
Download: ML20138H396 (5)

Text

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a te :g"o UNITED STATES e o NUCLEAR REGULATORY COMMISSION WASHINGTON, D, C. 20555 g gg 7; 7 ,,

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%...../ October 24, 1985 Sheldon J. Wolfe, Esq., Chairman Dr. Jerry Harbour Administrative Judge Administrative Judge Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Conmission -qm Washington 0.C' / 20566 //,O Dr. Emmeth A. Luebke jf ,

Administrative Judge /N .

Atomic Safety and Licensing ,'

/ M Board Panel j(7 _ '

1 .

hT '2 f@s U.S. Nuclear Regulatory Commission i .

Washington, D.C. 20555 i j?

x ,,..e D In the Matter of ,i PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al.N'O (Seabrook Station, Units 1 and 2) - -

Docket Nos. 50-443 OL and 50-444 OL On-site Emergency Planning and Safety Issues

Dear Administrative Judges:

In my letter to the Board of October 21, 1985, I provided to the Board the results of the Staff's preliminary review of the Westinghouse Emergency Response Guidelines, Rev. 1. For the Board's information, the Staf f has performed a review of Seabrook operating procedures based on Revision 1 of the Westinghouse Response Guidelines. That review is documented in Section 13 of SER Supplement 3 (a copy of which was provided to the parties by letter dated July 31, 1985 from Knighton to Harrison). A copy of Section 13 is attached.

Sincerely,

, 1 y % , 2 ( ' , f y,_ _ _

s Robert G. Perlis Counsel for NRC Staff

Attachment:

As stated cc w/att: Service List 8510290027 051024 PDR ADOCK 05000443 3507

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13 CONDUCT OF OPERATIONS 13.5 Station Administrative Procedures 13.S.2 Operating and Maintenance Procedures

' Reanalysis of Transients and Accidents; Development of Emergency 13.S.2.3 Operating Procedures l '

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! In the SER, the staf f described the status of the development of generic techni-cal guidelines by the Westinghouse Owners Group (WOG) and the staf f's develop- '

pent of guidelines for the long-term upgrading of emergency operating procedures ,

NUREG-0899, " Guidelines for the Preparation of Emergency Operating

' (EOPs).

Procedures," represents the staf f's long-term program for upgrading E0PS and des-

cribes the use of a procedures generation package (PGP) to prepare E0Ps. Sub- ,

mittal of the PGP was made a requirement by Supplement 1 to NUREG-0737 (Generic Letter 82-33). The generic letter requires each applicant to submit a PGP that

- includes:

(1) plant-specific technical guidelines ,

(2) writer's guide

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(3) description of the program to be used for the validation of E0Ps (4) description of the training program for the upgraded E0Ps.

I t This report describes the results of the staf f's review of the applicant's l t

response to Section 7 of Generic letter 82-33 related to the development and I implementation of E0Ps for Seabrook Station, Units 1 and 2. i

!,l The staf f's review was conducted to determine the adequacy of the applicant's ,

l program for preparing and implementing E0Ps. Criteria for the review of a PGP

.: are not currently in the Standard Review Plan (SRP). Therefore, this review i oi was based on NUREG-0899, the reference document for the E0P upgrade portion of { (

Supplement 1 to NUREG-0737 (Generic Letter 82-33). l T'e applicant provided a PGP and supporting materials in letters dated January 17 f' and September 18, 1984, and March 29, 1985. In addition to an introduction, the  !

PGP provided with the January 17, 1984, letter included the following sections. i (1) Plant-Specific Technical Guidelines  !

(2) Writer's Guide for E0Ps I (3) User's Guide I (4) E0P Verification ]

(5) E0P Validation (6) Training Because the Seabrook Station was the verification and validation site for WOG's Revision 1 to the generic guidelines and because the PGP did not f ully describe the E0P ef forts at Seabrook Station, the following documents were included in the review materials by the September 18, 1984, letter:

Seabrook SSER 3 13-1 ,

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(1) WCAP-10599, Emergency Response Guidelines Validation Program, WOG 1etter Ih.

0G-129, dated August 14, 1984 (2) Seabrook Station Procedure, AQl.002, " Station Operating Procedures" tr As additional information, the applicant also provided the following with the q March 29, 1985 letter:

4 (1) PGP amendments (a) Writer's Guide (b) Plant-Specific Guidelines (c) Training (2) Station Operating Procedure 051300, Rev. 00 (AQl.002A), " Generation of Emer-gency Response Procedures" (revised Writer's Guide) ,

The discussion of the staff review of these materials is organized according to the four areas of the PGP required by the generic letter.

i The materials addressing the plant-specific technical guidelines were reviewed f to determine if ' hey provided acceptable methods to meet the objectives of NUREG-0899. The applicant described the methods used to develop E0Ps based on Revision 1 to the WOG generic guidelines. The staff recently approved these guidelines 'or implementation in a letter from D. G. Eisenhut (NRC) to J. J. Sheppard (WOG) dated December 27, 1984 As ths reference plant for the WOG validation effort, the generic guidelines were made directly applicable to the Seabrook Station as part of that effort. In the amendment to the PGP, the applicant stated that neither his review nor the vencor's identified any safety-significant deviations from the generic quidelines in the Seabrook procedures.

Therefore, the applicant's plant-specific technical guideline program has met the objectives of NUREG-0899 and is acceptable.

As part of the technical basis for operator procedures, Supplement 1 to NUREG-0737 also required an analysis of the operators' tasks to identify the information and controls necessary to support emergency operations. The information and ccatrol needs are used in the development of E0Ps and in the detailed control room design review. The applicant's submittals and the staff's review and approval are dis-cussed in Section 18 of the SER.

The materials addressing the Writer's Guide were reviewed to determine if they provided acceptable methods for accomplishing the objectives stated in NUREG-0899.

The applicant stated that the purpose of the Writer's Guide is to provide admin-istrative and technical guidance on the preparation of the E0Ps. The guide pro-vides instructions for writing E0Ps, including format, action steps, mechanics of style, and examples. The Writer's Guide states that each E0P shall provide the basic purpose and scope for the procedure, symptoms or entry conditions, and in the body of the procedure, contingent operator actions based on interpretation of parameters and conditions. The operator action steps are described at being in a two-column format with the left-hand column for instructions and expected plant responses, and the right-hano column for contingency actions. With the revision of the Writer's Guide published as Station Operating Procedure 051300, Revision 00, the Seabrook Writer's Guide provides acceptable methods for accom-plishing the objectives stated in NUREG-0899. Use of the Writer's Guide should Seabrook SSER 3 13-2 k

1 p j t i t

j help ensure that the E0Ps are usable, accurate, complete, readable, convenient j to use, and acceptable to control room operators.

The descriptions of the validation and verification programs were reviewed to determine if they address the objectives in NUREG-0899, that is, to establish I the accuracy of information and instructions, to determine that the procedures can be accurately and ef ficiently carried out, and to demonstrate that the pro-l cedures are adequate to mitigate transients and accidents.

i As the site of the WOG generic guidelines validation effort, the Seabrook-  ! i 1 specific E0Ps were the bases for the generic evaluation. The evaluation in- I

cluded checking the E0Ps with their source documents, exercising the E0Ps using  !

q the Seabrook-specific simulator, observing operators' performance by multidisci- '

plined observation teams, and debriefing of the operating crews and observation teams for each scenario. These efforts resulted in many recommendations for Seabrook's Writer's Guide. User's Guide, and training program but identif f ed no safety-significant technical deficiencies. ' '

The WOG generic validation was completed before the applicant's submittal of "

< the PGP. As a result, most of the recommendations had already been incorporated and the PGP included both before and af ter versions of the Writer's Guide and I a

User's Guide. The training program was revised after submittal of the PGP and I

was described in the March 29, 1985, submittal. '

r On the basis of the documentation of the validation and verification progran results, the program appears to have adequately incorporated the guidance of the Writer's Guide and the plant-specific technical guidelines and will guide the operator in mitigating the consequences of accidents and transients. There- j j fore, the staff finds it acceptable.

The applicant's amended description of the training program on the E0Ps was l reviewed to determir.e if it addressed the objectives in NUREG-0899. The des- h cription included the use of classroom instruction, control room walkthroughs, l i and plant specific simulator exercises. The applicant also provided some train- 1 1 ing materials in the form of student handouts. On the basis of the review of 1 ,

the program description and the student handouts, the implementation of this '

l training program should provide operators with the philosophy of the E0P approach, I

i the strategy and technical basis of the E0Ps, and a working knowledge of the con-j tent of the E0Ps suf ficient to enable them to execute the procedures under oper- ,

I ational conditions. Although the trainir.g program on the E0Ps was described i as part of the overall operator training program, the applicant did not commit j i to train all operators on the upgraded E0Ps. The staff will confirm that all '

j operators have received the described training before licensing.

! Contingent on confirmation of the above item, the staff concludes that the train-ing program meets the guidance of NUREG-0899 and should provide assurance that 1 the E0Ps will adequately guide the operators in mitigating the consequences of ,,

accidents and transients. Therefore, the training program is acceptable, j l

On the basis of its review, the staff concludes that the PGP for Seabrook Sta- I tion, Units 1 and 2, meets the requirements of Supplement 1 to NUREG-0737 and provides acceptable methods for accomplishing the objectives of NUREG-0899 for ,

the technical guidelines, Writer's Guide, and the verification and validation f and training programs. The staff will confirm that the applicant adequately l

l Seabrook SSER 3 13-3 j l .

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completes the operator training. Future changes to the PGP should be made in N. <

accordance with 10 CFR 50.59. .

4 Seabrook SSER 3 13-4 L