ML20148F033

Discusses NRC Comments Re Procedures Generation Package for Plant Emergency Operating Procedures.Util Agrees W/All Comments Except Comment 1.2 Re Placement of Caution Symbols. Supporting Info Encl

ML20148F033
Person / Time
Site:	Peach Bottom
Issue date:	01/15/1988
From:	Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Butler W Office of Nuclear Reactor Regulation
References
NUDOCS 8801260168
Download: ML20148F033 (10)

Text

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PHILADELPHI A ELECTRIC COM PANY ,

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2301 MARKET STREET i P.O. BOX 8699 PHILADELPHIA. PA.19101 ,

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,,,fy,)^fM'a January 15, 1988

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Docket Nos. 50-277 50-278 l I

Mr. W. R. Butler, Director 1 Project Directorate I-2 i Division of Reactor Projects I/II U.S. Nuclear Regulatory Commiss.' n ATTN: Document Control Desk Washington, DC 20555 l

SUBJECT:

Procedures Generation Package for Peach Bottom Emergency Operating Procedures

Reference:

Letter from G. E. Gears, NRC Paach Bottom Project Manager, to E. C. Bauer, Jr., PECo, daled September 9, 1986

Dear Mr. Butler:

The referenced letter forwarded the NRC's comments on Philadelphia Electric Company's Emergency Operating Procedures Generation Package (PGP) which was submitted on December 13, 1984 for NRC review. Shortly after receiving the NRC's comments in September 1986, it was agreed (between the Licensee and the NRC Project Manager) that a meeting should be held to discuss the comments before Licensee submits a written response. To date, a meeting has not taken place. The current NRC Peach Bottom Project Manager informed us that a meeting was not feasible and I requested that we submit our response as soon as possible to I expedite resolution of this issue. Accordingly, this letter provides our response.

1 The NRC's comments have been reviewed. We agree with all of the comments (approximately 28) except comment L.2. We agree in concept with comments 3.2.2 and 3.2.3; however, additional training must be conducted before these commints can be fully addressed, as discussed later in this letter. Our basis j for disagreement with comment 1.2 is also provided in th.a j letter. i P l 1 l

Mr. W. R. Butlcr January 15, 1988

. Page 2 "he Peach Bottom PGP consists of a writers guide and validation / verification guide (Administrative Procedure A-94),

and a training program description. The Transient Response Implementation Plan (TRIP) Training Program description has been revised to incorporate the NRC's comments, with the exception of comments 3.2.2 and 3.2.3, and is enclosed for NRC review. A vertical bar in the margin of the submittal identifies the revisions. The item number of the NRC comment that each revision addresses is indicated adjacent to the vertical bar.

Administrative Procedure A-94 is being revised to incorporate the NRC's comments, with the exception of comment 1.2, and will be submitted for NRC review by April 30, 1988.

Our discussion of comments 1.2, 3.2.2 and 3.2.3 follows.

Restatement of NRC Comment 1.2:

1.2."Subsection 5.5.3 of Appendix III, Cautions and Notes" This subsection on pages 5 and 6 states that a "Caution" is to be indicated with a* Caution Identification Symbol inserted in the flow path before the step to which it applies and that all "Cautions" and "Notes" referenced in a flowchart by number shall l be written out and displayed in a Continue Rechecking Step ,

symbol, an example of which is provided in Attachment III of j Appendix III.

l The preferred method for placement of Caution statements is their insertion in the flow path, i.e. in-line and immediately preceding the action, in a highlighted box. This would enable an operator in an emergency situation, to quickly read the Caution statement before proceeding with the action step rather than needing to: locate the Caution number in the flow path; locate the correct Caution number in the "Continue Rechecking Step symbol;" read the correct Caution statement; and then find their place in the flow path before proceeding with the action step.

However, if the Caution statement cannot be inserted in the flow path and a "Continue Rechecking Step symbol" is needed, it is important that the "Cautions" and "Notes" are listed in separate "Continue Rechecking Step symbols," 1.e. one for "Cautions" and one for "Notes" and that the "Caution" Continue Rechecking Step symbol be highlighted to easily differentiate it from the "Note" Continue Rechecking Step symbol. In addition, we recommend that the Caution and Note statements be written using upper and lower case letters for ease of readability rather than all upper case letters.

Mr. W. R. Butler January 15, 1988 Page 3

Response

These methods for placement of the Cautions and Notes were compared by human factors consultants and the Peach Bottom technical staff during the development of the TRIP flow chart procedures. Based on the points below, it was concluded that the present method of displaying the Cautions and Notes outside the flow path is the preferable method fr 1 a human engineering standpoint.

o Rach TP.IP flow chart procedure appears in its entirety on a single page and the Cautions and Notes that are incorporated into the procedure also appear on the same page. The statements are easy to locate.

o One TRIP flow chart procedure was prepared, on a trial basis, with each Caution and Note in the flowpath. The result was a busy page which was difficult to use. The size of the page had to be significantly enlarged to accommodate the additional material which made it too large and cumbersome to be handled on the tables in the control room.

o It is unlikely that Cautions will be confused with Notes because 1) Cautions are indicated in the flow path by a "stop sign" symbol and Notes are indicated beside a step by circles, and 2) Cautions are referenced in the "Continue Rechecking Step" by a one digit number in a "stop sign" symbol and Notes are referenced by a two digit number in a circle. There is a total of only eight Cautions for all cf the TRIP flow chart procedures.

o The check-off blank symbols make it easy for the operator to reenter the flow path at the correct place.

o These procedures have been in use for nearly four years and it has been repeatedly dcaonstrated that they can be used quite successfully.

We recognize that NRC comment 1.2 has merit; however, we  !

have concluded that, with all factors considered, the present method of displaying the Cautions and Notes is the most effective method. It has also been our experience that using all upper-case letters does not ad' arsely offect readability of the Notes and Cautions, and is preferred by the operators.

Consequently, we respectfully request that the NRC reconsider its suggestion to revise our method of displaying the Cautions and Notes based on this information.

Mr. W. R. Butler January 15, 1988 Page 4 Restatement of NRC Comments 3.2.2 and 3.2.3:

3.2."Subsection 4.0, Initial TRIP Training" The "Training Program", as described in the PGP consists of classroom instructions and simulator exercises on a generic simulator.

In addition, indicate the following:

2. the use of control room walk-throughs on all TRIP procedures by all operators,

3. the use of control room walk-throughs to demonstrate planned operator roles and teamwork.

Response

Control room walk-throughs on all TRIP procedures by all ,

operators were not performed during the initial TRIP training. l The simulator on which the operators were trained, although a l generic simulator, is very similar to the Peach Bottom control l room. Because control room walk-throughu would have been I disruptive to the on-shif t control room operators and control )

room activities, walk-throughs were not considered to be warrsnted at the time. Planned operator roles and teamwork were demonstrated on the simulator during initial TRIP training and have been repeatedly demanstrated during emergency drills and actual plant upsets in the Peach Bottom control room, and during operator requalification training on the simulator. However, to provide additional assurance that the operators are proficient with the TRIP 3, we now consider walk-throughs to be warranted.

Walk-throughs will be cenducted in the Unit 2 control room because its panels have recently been modified to incorporate Post-TMI Control Room Design Review improvements. (The Unit 3 l control room panel modification is in progress and scheduled to '

be comoleted during the current pipe replacement c'atage.)

A new Peach Bottom-specific simulator is being manufactured and is expected to be ready for limited training use at the factory in May 1988, and ready for use on-site in the last Quarter of 1988. Some walk-throughs may be conducted on the new simulator (after the simulator panels have been modified similar to those in the control room) instead of in the control room. However, walk-throughs will be conducted with the licensed operators either in the control room or on the new simulator prior to restart from the current NRC-required shutdown.

.ll M r . W . 11. Butler January 15, 1988 Page 5 If you have any questions or any further comments on the material provided herein, please feel free to contact us.

Very truly yours,

Enclosure:

"Transient Response Implemention Plan (TRIP)

Training Program", Revision 1, October 1987.

cc: Addressee I W. T. Russell, Administrator, Region I, USNRC T. P. Johnson, Resident Site Inspector R. E. Martin, Peach Bottom NRC Project Manager t

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Reuision 1 October 1987 i

PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION TRANSIENT RESPONSE IMPLEMENTATION PLpN (TRIP) TRAINING PROGRAM 1.0 GENERAL The. TRIP. training; program was developed to support implementation of the TRIPS. The TRIP writer interfaces with the Nuclear Training Section to ensure a supportive program.

l 2.0 PROGRAM DEVELOPMENT When developing the TRIP training program, the following  ;

major items were considered:

1. What type of operator training should be provided  ;

(initial, refresher). ,

2. What method of operator training should be followed

3. What operator knowledge and skill level is desired. )

4. What procedure tasks exist that require operator ,

decision-making.

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, 5. What training material is needed to support TRIP I training requirements. j i

6. What current operator licensing requirements exist.

7. What method should be provided for operator feedback into the training program and TRIP development.

8. What will be the effect on current plant operation while training operators on TRIPS not yet in place at the plant.

l The following description outlines the approach to be used to I train licensed operators on TRIPS and to ensure the-operators are informed and knowledgeable of future changes to the TRIPS.

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Revision 1 October 1987 Page 2 of 4 3.0 TRAINING PROGRAM GOALS The initial, overall training goals for the TRIP training program are as follows:

1. -To-enable.the. operators to understand the structure of the TRIPS.

2. To enable the operators to understand the' technical bases of the TRIPS.

3. To enable the operators to have a working knowledge of the technical content-of the TRIPS.

4_ To enable the operators to use the TRIPS under operational conditions.

Training program objectives to support these goals will be developed for each lesson plan.

4.0 INITIAL TRIP TRAINING METHODS The TRIP training program was established to instruct operators in the TRIPS. It consisted of classroom instructions and simulator exercises. An outline of the TRIP training course is included as Figure 1.

4.1 Classroom Instruction Classroom instruction sessions of approximately twenty hours were conducted. Included in the information presented during this method was the following:

1. The logic behind the development of TRIPS.

2. The entrance and exit conditions for each TRIP procedure.

3. The TRIPS themselves, including supporting technical and human-factors information, and a step-by-step discussion of each procedure including

, the basis for each step. This "table top" step-by-3 . 2 ",

step instruction is the method to cover areas which are outside the design capabilities of the simulator. ..

Revision 1 October 1987 Page 3 of 4 Each classroom session addressed specific TRIPS and was followed by a simulator session where the TRIPS were practiced in appropriate scenarios.

4.2 Simulator Exercises Training on the TRIPS was conducted for all licensed operators and Shift Technical Advisors (STA) using scenarios on the Limerick Training Center simulator for 3*2*h approximately. twenty. hours. ,A wide variety.of. scenarios inc)uding multiple and consequential failures were demonstrated.

Training was conducted with all operators performing their normal- control room functions. Additional training was conducted where the members of a crew alternate responsibilities. This additional training is important to promote understanding of the other l operators' responsibilities in the overall conduct of l the actions, and it should lead to enhanced  !

communications within the control room. i 5.0 REFRESHER TRAINING Refresher training on the TRIPS is a part of the normal

, licensed operator requalification program. For approximately 10% of the time devoted to requalification training, operators are presented with various sequences of events on the simulator whose symptoms require the operators to follow through the major flowpaths of the TRIPS. Realistic scenarios are developed to ensure that the critical aspects j f the TRIPS are exercised. All operators are trained on new '

k'1re TRIP procedures prior to procedure implementation. Training ite,~

on new procedures is more extensive than refresher training on existing procedures. New procedure training will include l classroom training as 69. scribed in Section 4.0, "Initial Trip '

Training Methods", and simulator exercises to the extent that j simulator design permits.

Training on TRIPS is conducted in such a manner that each crew responds to the symptoms with each operator simulating the actions that he normally would be responsible for during an emergency incident. Licensed operators not assigned to a shift participate in the scenarios as part of a control room crew. The plant trainzng staff participates in the development and execution of refresher training. The training staff is responsible for developing the scenarios, observing and evaluating the simulator demonstrations and

Revision 1 <

. October 1987 Page 4 of 4 critiquing the results. Any additional training needs are determined from the performance of the operators.

The scenarios are varied sufficiently to ensure the operators do not develop a set pattern of responses to incidents but

- 'are able to respond.to the symptoms as they develop.

3.1 All perators are evaluated during training. Written quizzes second are administered and operators' performance on the simulator 3

is critiqued. Appropriate follow-up training is provided third when needed.~ Assistance and-counseling -is provided whenever items appropriate or requested.

6.0 TRAINING ON REVISIONS Training on minor procedure revisions will be conducted through a program of required readings (self-taught),

preshift briefings, or lectures in the requalification program. Training on major revisions will be conducted by the use of classroom instruction and walk-throughs in the control room or on the simulator. If operational considerations do not allow control room walk-throughs, and the simulator is not available, training on major revisions will be conducted during classroom instruction.

7.0 INPUTS INTO TRAINING PROGRAM CHANGES 7.1 Supporting Training Material Changes Changes to supporting training material will be factored into updated lesson plans and operator training packages. Some of the supporting material identified to date is as follows:

1. EPGs

2. Background information

3. Applicable design changes 7.2 Operator Feedback Operator feedback resulting from TRIP verification, TRIP validation, and training critique forms will be used to keep the training program and TRIPS current and relevant.

PHILADELPHIA ELECTRIC COMPANY TRIP Procedure Training Program for Certified Operators CLASSROOM SIMULATOR i

1. Intro to TRIP format 1. IC-1 Startup and layout Day I 2. T-99 2. -Trainsients- consistent with T-100

3. T-100

1. T-101 1. Transients and Accidents con-sistent with Classroom training.

Day II 2. T-ll7

1. T-102 1. Transients and Accidents Consistent with Day III 2. T-112 Classroom training.

3. T-ll6

~

l

1. T-lli 1. Transient and Accidents Con-sistent with Classroom training.

Day IV 2. T-ll3

3. T-ll4

1. T-il5 1. Transient and Accidents Consistent with Day V Classroom training.

i Figure 1

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