ML20151C806
| ML20151C806 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 04/06/1988 |
| From: | Bird R BOSTON EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20151C809 | List: |
| References | |
| 88-066, 88-66, NUDOCS 8804130191 | |
| Download: ML20151C806 (22) | |
Text
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1 BOSTON EDISDN Pilgnm Nuclear Power station Rocky Hill Road Plymouth, Massachusetts 02360 Ralph G. Bird Apri1 06, 1988 Senior Vice President - Nuclear BEco Ltr. #88- 066 U.S. Nuclear Regulatory Commission Attn: Document C,ntrol Desk Hashington, DC 2v555 Docket No. 50-293 License No. DPR-35 REVISED PROCEDURE GENERATION PACKAGE AND RELATED COMMITHENTS As committed during the March 14-18, 1988 NRC onsite evaluation of Pilgrim's Emergency Operating Procedure (EOPs), we are providing:
1.
A revised Procedure Generation Package (PGP).
(This PGP is the latest revision, and is submitted for your review.
The "For Information Only" markings are required to indicate your copy is not a controlled document.)
2.
An F.0P Training Program Summary Description.
3.
Response to NRC open-items and Questions.
In addition, we intend to continue to maintain the Plant Specific Technical Guidelines (PSTG).
R. G. Bird Attachments:
1.
Revised PGP 2.
Responses to Open Items Remaining from the March 14 through 18, 1988 E0P Meeting.
3.
Pilgrim Nuclear Power Station Emergency Operating Procedures (EOPs) Training Program Summary Description.
PHK/jcp/1881 cc:
See next page 8804130191 880406 DR ADOCK 050 3
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BOSTON EDIS0N COMPANY U. S. Nuclear Regulatory Commission April 6, 1988 Page 2 cc:
Mr. D. G. Mcdonald, Project Manager Division of Reactor Projects I/II Office of Nuclear Reactor Regulation Mail Stop: 14D1 U. S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville,, MD 20852 U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Senior NRC Resident Inspector Pilgrim Nuclear Power Station
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ATTACHMENT 1 to BECo Letter 88- 066 Revised Procedure Generation Packaae (121 pages)
Procedure No.1.3.4-10. "Writers' Guide for Emergency Goeratina Procedures" 1
Procedure No.1.3.4-13. "EOP Verification Proaram" Procedure No. 1.3.4-14. "EOP Validation Program"
ATTACHMENT 2 to BECo Letter 88- 066 Resoonses to Ooen Items Remainina from the March 14 through 18. 1988 E0P Meetina (19 pages) t i
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Introduction The NRC identified a number of open items while reviewing the E0P Procedures Generation Package (PGP). Many of the open items were resolved during the March 14 through 18, 1988 onsite review.
The remaining ones are addressed below. He have retained the NRC's numbering system to facilitate review.
E0P Hriters' Guide 1.
Cautions and Notes NRC Comment:
a.
Section III.A.13 states that "notes shall be... placed within the respective flowchart element, located immediately preceding or following the associated text." Notes should be read and comprehended by the operator prior to the step (s) they refer to, not after.
Notes should only be placed immediately prior to the step, not following it, as suggested in the guidance.
BECo Response:
The Writers' Guide has been revised to include the following explanation:
"Notes which simply provide information which enhances the operators ability to perform an action shall be located following the action test."
NRC Comment:
b.
Resolved BECo Response:
N/A NRC Comment:
c.
Section III.A.12 discusses "supplemental information." However, the Writers' Guide does not define supplemental information or how it differs from notes.
The Writers' Guide does not tell the writer when to use supplemental information instead of notes or vice versa.
The Writers' Guide needs to define supplemental 4
information and its use in comparison to notes.
BECo Response:
The Hriters' Guide has been revised to include the following information:
"Supplemental information is information which enhances the operators ability to perform an action statement but is either too bulky to be placed in the flowpath as a note or the information is referenced from several locations within a flowpath."
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NRC Comment:
d.
There is no guidance provided as to the use of capitalization in caution and note statements.
The Writers' Guide should state whether all caps, or both caps and lower case should be used.
BECo Response:
Item III.D.2.1 has been added to the E0P Hriters' Guide which reads:
"Abbreviations and acronyms that are printed in upper case letters in Table 3" In addition the following statement has been added to item III.A.14 of the E0P Hriters' Guide:
"The word ' CAUTIONS' shall be located directly above the cautions which apply to a given flowpath and shall be underlined and in upper case boldfaced print.
(Refer to III.E.6.)"
NRC Comment:
e.
When cautions and notes contain multiple topics the importance of any one topic is obscured.
The Hriters' Guide should state that each caution and note should contain only one topic.
BECo Response:
Item III.A.13 of the E0P Hriters' Guide has been revised to include the following statement:
"Notes should contain only one topic" Item III. A.14, Cautions, of the E0P Hriters' Guide has not been revised because only the cautions given in the PSTG are used in the PNPS E0Ps. The PNPS PSTG cautions are identical to the EPG Rev. 4 cautions.
2.
Logic Statements NRC Comment:
a.
Resolved BECo Response:
N/A 2
b
NRC Comment:
b.
The logic term IF NOT (as described in NUREG-0899) is useful in conditional statements.
If this logic term is ever to be used, Table 1 should include the definition of this term and in the body of the guide its use should be described and examples provided.
BECo Response:
The PNPS E0Ps have been constructed to avoid the use of the logic term "IF NOT".
For consistency and simplicity the action statements are structured to use only the positive "IF" logic term.
The allowable logic terms for PNPS E0Ps are listed in Table 1 of the E0P Hriters' Guide.
The logic term "IF NOT" is not listed in Table 1.
NRC Comment:
c.
Table 1, includes the word EXCEPT.
In logic statements using EXCEPT, the conditions follow the actions which may lead operators to perform the actions before reading the conditions.
An approach should be used where all conditions go prior to the actions such as in a Note or Caution (which ever would apply);
or word the statement to specify only the actions to be taken and not exceptions.
For example, in Example 11 on page 11, the "sources" to be used could be specified instead of listing the exceptions.
BECo Response:
The PNPS E0Ps have been constructed so that one senior operator (control room supervisor) uses the E0Ps to direct the actions of the other operators in the control room.
The construction of action statement followed by conditional statements allows the supervisor directing actions from the E0Ps to understand the intent of an action i
first before factoring in conditions.
Operator performance using this structure was very effective as evidenced during the procedure validation program.
This structure will be reevaluated as a part of E0P enhancement during the next major revision to the E0Ps.
NRC Comment:
d.
Using the logic term THEN at the end of an action to instruct the operator to perform another action in the same step runs actions together which may be overlooked or may be confused with logie statements.
For example:
"Do A, THEN B THEN C, THEN D."
should not be used.
The Writers' Guide should state that THEN
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will not be used to run action steps together.
Further, the word "then" should not be used other than as a logic term to avoid operator confusion as to its meaning.
In the following example, "If A, THEN B and then C" the second then should not be used.
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BECo Response:
Based on the results of the E0P validation program the present structure is effective. As part of the next major E0P revision BECo will reevaluate the use of the logic term "THEN" as used in the PNPS E0Ps.
NRC Comment:
e.
Resolved i
BECo Response:
N/A 3.
Flow Charts NRC Comment:
a.
The Writers' Guide states that concurrent flows of steps should be spaced to "achieve a balanced presentation." This is very ambiguous guidance.
For example, does this mean that a short flowpath containing a few steps should be stretched out to balance out a concurrent long flow containing many steps for appearance sake? As another example, does this mean that certain symbols in concurrent flows should be placed side by side to achieve overall visual balance? More specific guidance is needed.
BECo Comment:
Item III.A.2 of the E0P Hriters' Guide has been revised to delete the statement:
"... so as to achieve a balanced presentation."
4.
Emphasis Techniques NRC Comment:
a.
The use of uppercase letters is discussed on page 20, but the 1
use of all caps versus the use of initial caps and lower case is somewhat ambiguous.
For example, it is clear that the word START is all caps, and Section designators are upper and lower case, because examples are given.
But the Writers' Guide should make it clear for application whether all caps are to be used,
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or initial caps only, and not rely on examples only.
BECo Response:
Section III.D.2 of the E0P Hriters' Guide has been revised to state that when uppercase letters are required, all letters shall be i
capital letters, 4
5.
Division, Headings, Numbering NRC Comment:
a.
The flow charts have a system of titles and a number system to identify procedures; and overall headings for flow sequences.
However, there is no alpha-numeric numbering system for sections or symbols within the flow chart.
This makes it difficult to refer to a section or symbol and an operator may not be able to keep track.
For example, if one operator wants to indicate a particular step to another operator there is no easy to way to verbally refer to the section or symbol.
Pilgrim should consider some type of alpha-numeric numbering system within the flow charts, particularly for sections / symbols.
BECo Comment:
This item is a finding from the BECo validation program of the E0Ps.
It has been evaluated by BECo and classified as an enhancement. A numbering system will be incorporated into the E0Ps during the next major revision.
6.
Tables / Figures / Printed Aids NRC Comment:
a.
The Writers' Guide states that the units used on the axes of graphs on page 15 should correspond to those of associate control room instruments, but the same guidance is not given for tables.
BECo Response:
Item III.A.16.b of the E0P Hriters' Guide has been revised to include the following statement:
"Table titles and numerical units and gradations shall correspond to those of associated control room instruments as applicable."
NRC Comment:
b.
Because unnecessary information may clutter figures and tables and confuse operators, all figures and tables should contain only information that is needed by operators and is relevant to the text.
The Writers' Guide should state that figures and tables will contain only information relevant to the procedures.
BECo Response:
Iten III.A.16 h. has been added to the E0P Hriters' Guide which states:
"Tables shall contain only information relevant to the E0P."
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7.
Location Information for Equipment, Controls, Displays NRC Comment:
a.
The Writers' Guide (on page 29) provides criteria to determine if location information should be put is a step.
However, this guidance does not state the basic formit for the information.
statement or provide an example.
The Writers' Guide should be revised to include this guidance.
BECo Response:
Section IV.E.3 has been revised to include a description of the basic format for component location and an example has been provided.
8.
Placekeeping Aids NRC Comment:
a.
Resolved BECo Response:
N/A 9.
Formatting NRC Comment:
a.
The Writers' Guide states that for boldface type a slightly larger type size (than 9) should be used.
This larger type size should be specified.
The guide also mentions varying thicknesses of lines to be used in the flow charts.
The guide should provide guidance on thickness sizes.
BECo Response:
Type size and thickness of lines is an open item from the E0P Validation Program.
This item has been evaluated as an enhancement and will be corrected as part of the next major E0P revision.
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E0P Verification and Validation Proarams NRC Comments:
1.
The verification and validation programs should be revised to specify that, at a minimum, plant operators, subject matter experts, procedure writers, and human factors experts will be involved in verification and validation.
The verification and validation program description provide personnel qualifications for those to be involved in the verification and validation programs, but do not include all of the types of disciplines which should be involved.
The descriptions should state that at, a minimum, plant operators, subject matter experts, procedure writers, and human factors experts will be involved in i
the verification and validation process.
Further, the roles these disciplines should play in each of the processes should be stated.
BECo Response:
The E0P verification and validation programs have been revised to state that plant operators, subject matter experts, procedure writers and human factors experts shall be involved in verification and validation of the E0Ps.
This was always the intent of the program and a multi-discipline team was used to verify and validate the PNPS E0PS.
NRC Comment:
2.
The validation program should be revised to include the criteria for the selection of scenarios that will fully exercise E0Ps under complex accident scenarios.
Pilgrim has provided a set of criteria for scenario development, but they do not insure that multiple and complex failure scenarios will be used.
The validation program description should include criteria to insure that multiple (simultaneous and sequential) failures are a part of some of the scenarios used for validation.
BECo Response:
The E0P validation program has been revised to state that the i
validation scenarios shall include multiple (simultaneous and sequential) failures.
The scenarios that were used to validate th?
PNPS E0Ps did include multiple failures.
NRC Comment:
3.
The verification and validation programs should be revised to include the criteria used to determine how revised E0Ps are to be reverified and revalidated.
The verification program description does state that "the requirements and instructions specified herein apply... revising existing E0Ps." However, no guidance is given for determining what revisions will require reverification and which will not; and how each will be (continued on next page) 7
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NRC Comment (continued) reverified.
For example, will the addition of a new "entry condition" require reverification? Similarly the validation program description states that revised E0Ps will be validated according to the program description, but does this mean that every revision will be revalidated? As above, will the addition of a new "entry condition" require a simulator exercise? Some type of criteria need to be stated to determine what types of revisions need to be rever* fied and revalidated; and for each type how.
BECo Response:
Currently any change to the E0Ps requires a verification and validation in accordance with the established programs.
This position will be maintained until a solid criteria is established which can be used to define the level of review required for a proposed change.
BECo is working to develop this criteria. Until the criteria is finalized the conservative approach of verifying and validating all E0P changes will be followed.
NRC Comment:
4.
The validation program should be revised to state the E0P validation and revalidation will be conducted with minimum control room staffing.
BECO Response:
The E0P validation program has been revised to state that E0P validation will be conducted with the normal minimum control room staffing.
The PNPS validation was conducted with the normal minimum control room staffing.
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Emergency Ooeratina Procedure Flow Charts 1.
Cautions, Notes and Supplemental Information NRC Comment:
a.
Resolved BEC0 Response:
N/A NRC Comment:
b.
Blocks of supplemental information are used in E0Ps 01, 02, 06, and 09.
The information included in these blocks are possible systems to be used, operator actions, and references to other procedures (also considered operator actions).
Nortrally, operator actions are placed in action step blocks not in notes, cautions or supplemental information. Although the Pilgrim Hriters' Guide does not provide guidance as to what information is to be placed within supplemental information blocks, Pilgrim should reconsider placing operator actions and references to other procedures and cautions in the supplemental information blocks. This type of information belongs in action steps.
BECo Response:
The E0P Hriters' Guide has been revised to provide guidance on what information is placed in supplemental information blocks.
The action statements in the E0P flowpath are written at the "What to Do" level of detail.
The supplemental information blocks direct the operator on how to do things or provide the reference which contains the "How to Do" level of detail.
The PNPS E0P validation demonstrated that this is an effective way for the control room supervisor to maintain an understanding of the intent of E0P actions and at the same time provide information necessary to accomplish the required action.
NRC Comment:
c.
Resolved BECo Response:
N/A 2.
Logic Terms and Conditional NRC Comment:
a.
Resolved BECc Response:
N/A 9
NRC Comment:
b.
Resolved BECo Response:
N/A NRC Comment:
c.
The nesting of the Override Statements may also cause some difficulties.
It is understood that the override statements apply to whatever is grouped underneath.
Sometimes this includes a nested set of override statements.
If an operator is working within a nested override statement, he or she could overlook or not remember the higher override statement.
Perhaps some type of reminder could be used.
BECo Response:
The formating of E0P override statements in an open item from the E0P validation.
This item has been evaluated and determined to be an enhancement that might improve procedure usability. Override statement formating will be studied as part of the next major E0P revision.
NRC Comment:
d.
Resolved BECo Response:
N/A NRC Comment:
e.
In E0P-03, Drywell Temperature, second action block, the BEFORE statement does not follow the format stated in the Writers' Guide.
This also occurs in E0P-04.
BECo Response:
This item will be corrected as part of the next major E0P revision.
NRC Comment:
f.
The term EXCEPT is used several times in E0P-04 and 03.
The problem with this word is that it places exceptions after an action step.
In these statements, the operator is told to do something which he or she may go ahead and do before reading the rest of the statement which includes the exceptions.
Pilgrim should consider rewriting the statements which use the word EXCEPT.
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BECo Response:
The PNPS E0P validation demonstrated that the present format works effectively.
BECo will examine reformating the "EXCEPT" logic term as part of the next major E0P revision.
3.
Action Steps NRC Comment:
a.
Throughout the procedures there is an action step which states "ALTERNATE RPV DEPRESSURIZATION (E0P-07) IS REQUIRED." However, there is no indication what the operator is to do.
It is not clear whether this is a reference step requiring the operator to refer to E0P-07, or to go to the next step.
Further, the next steps after this action step sometimes do not appear to relate to depressurization.
For example, in E0P-03, H&O Concentrations, this step is used and then the operator is to use E0P-01.
Finally, why the statement is emphasized with all caps is not clear.
This same comment also applies to the phrase, "PRIMARY FLOODING (E0P-09) IS REQUIRED" found in E0P-06.
BEco Response:
The significance of EPG phrases which appear in uppercase letters (e.g., ALTERNATE RPV DEPRESSURIZATION IS REQUIRED, STEAM COOLING IS REQUIRED, PRIMARY CONTAINHENT FLOODING IS REQUIRED, etc.) is perhaps the most unhersally misunderstood concept presented in E0Ps based on the BHR EPGs. When the phrase, ALTERNATE RPV DEPRESSURIZATION IS REQUIRED," appears in upper case letters, it is a mechanism employed by the E0P writers to inform the operator that an override governing the RPV pressure control section takes precedence over the currently active RPV pressure control actions.
This same convention is used for the other phrases which appear in uppercase letters.
This convention is covered heavily in training.
NRC Comment:
b.
Resolved BECo Response:
N/A NRC Comment:
c.
Resolved BECo Response:
N/A NRC Comment:
d.
Resolved 11
BECo Response:
N/A NRC Comment:
e.
Some of tha steps in the sample flowcharts are too 1.ong and complicated.
For example, in E0P-04, "Reset the secondary containment isolation and restart reactcir building H&V, defeating high drywell pressures and low RPV water level isolation interlocks if necessary." This step contains too many actions.
Portions of this step could easily be overlooked by operators, especially because the typeface used is small, the text of the step is single-spaced, and placekeeping aids are not provided.
Furthermore, this step does not explain under what conditions it would be necessary to defeat the high drywell pressure and low RPV water level isolation interlocks, "if necessary" may not be sufficient guidance. Another example of a step that is too long is from E0P-01, "Irrespective of whether adequate core cooling is assured, terminate injection into the RPV from sources external to the primary containment UNTIL primary containment water level and torus pressure can be maintained below the MPCHLL." These types of statements should be split up in a fashion that makes it easier for the operator to read and carryout.
BECo Response:
The length of some action statements is an open item from E0P validation.
The validation demonstrated the E0Ps are acceptable as is and this item is not significant to the usability of the procedures because of the heavy training investment BECo has made.
This item is a definite enhancement and BECo will be actively working to reword the lengthy action statement during the next major E0P revision.
NRC Comment:
f.
In E0P-02, near the end of Reactor Power, there is a BEFORE statement whose action reads, "BORON INJECTION IS REQUIRED."
This action statement does not follow the format for BEFORE statements.
In the next instruction block, the two numbered actions are prefaced with the work "either." The word "either" implies that the operator can perform either step 1 or step 2.
However, this may not be the case.
Pilgrim may want the operator t perform step 1, and if this does not work, pe'eform step 2.
This should be clarified.
NRC Comment:
The "BEFORE" statement format is an open item from the E0P verification and it has been evaluated to be an enhancement which will be corrected as part of the next major E0P revision.
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NRC Comment (continued)
The E0P Hriters' Guide,Section III.B only allows steps to be numbered when items must be performed in sequence.
Thus, the action l
statement as written informs the operator that either boron injection method is acceptable but the order of preference is system 1 then system 2.
4.
Initial Verbs NRC Comment:
a.
Resolved BECo Response:
N/A 5.
Referencing and Branching NRC Comment:
a.
Resolved BECo Response:
N/A NRC Comment:
b.
Throughout the procedures the phrase "appropriate section of Procedure..." is used to refer the operator to another procedure.
How does the operator know the appropriate section?
The section should be specified in the reference statement.
BECo Response:
The E0Ps are designed to be used by the control room supervisor to direct the actions of the operators.
The actions in the E0Ps are at the "What to Do" level of detail.
The "How to Do" level of detail is contained in the satellite procedures.
The satellite procedure action steps will be performed by. operators at the control panels or locally in the plant.
In accordance with NUREG 0899 section 5.2.2:
"Information necessary to perform a task should be consolidated in one place, if possiole.
The need to go from one procedure (or part) to anothee during a sequence of actions is disruptive and can cause errors or unn:cessary delays..."
The indexes in the satellite procedures contain the detailed information on section in keeping with the above philosophy.
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c.
The Writers' Guide specifies a number of methods to refer the operator to other procedures.
However, there are reference statements wnich do not follow any of the methods in the Hriters' Guide.
For example, in E0P-01 the phrase "enter and concurrently execute Procedure 2.1.5..." is used.
In E0P-02 the phrase "Insert dontrol. rods using one or nore of the methods detailed in Procedure S 3.23..." is used.
The reference phrases y
used in the E0Ps should follow the guidance previded in the Writers' Guide.
1 BECo Response:
This is an cpen item from the E0P verification and it has been evaluated to be an enhancement.
It will be corrected during the next major revision to the E0Ps.
6.
Exits NRC Comment:
a.
Resolved BECo Response:
N/A
'r NRC Comment:
b.
Resolved BECo Response:
N/A 7.
Flow of Information NRC Comment:
i a.
In E0P-02, path A is difficult to follow and arrows might be used to indicate the direction of flow.
BECo Response:
The level control path in E0P-02 is complicated and an.soen item from the E0P validation is to attempt to simplify this section of E0P-00/
The validation demonstrated that the operator is able to use thc?
procedure effectively as it is currently constructed. As part of the next major E0P revision BECo will attempt to simplify the level control section of E0P-02.
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8.
PI'acekeeping Aids and Section/ Symbol Numbers NRC Comment:
a.
Resolved BECo Response:
N/A 9.
Miscellaneous NRC Comment:
a.
In E0P-03, Torus Water Level, the first action step the acronym PASS is used, but this acronym is not defined in the Pilgrim Hriters' Guide and should be.
BECo Response:
The acronym PASS has been added to the list of standard acronyms and abbreviations in the E0P Hriters' Guide.
NRC Comment:
b.
In E0P-03, Drywell Temperature, the first six-sided symbol does not contain a comma after the IF or AND statements. Also, in the last two BEFORE symbols a comma is not placed after the before statement.
BECo Response:
These items will be corrected as part of the next major E0P revision.
NRC Comment:
c.
In E0P-03, Hydrogen and Oxygen Concentrations, when H0 l
concentrations are referred to the first instance a decimal is used, i.e., 1.0% and in the remainder instances no decimals are used, i.e., 51. and 6%.
BECo Response:
This will be corrected as part of the next major E0P revision.
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Satellite Procedures NRC Comment:
1.
Resolved BECo Response:
N/A NRC Comment:
2.
There are discussion sections at the end of each procedure.
Sometimes this discussion section will contain information which may be of use to the operator before he or she begins the procedure.
For example, in 5.3.23, the discussion section provides useful information and judgement criteria to the operator concerning the rod insertion methods provided in the procedure.
This information could be provided at the beginning of the procedure in the form if a note just after the Purpose.
This is also true of 5.3.25.
Pilgrim should review each discussion section of each procedure to determine if useful information exists which might be placed at the beginning of the procedure.
BECo Response:
The E0P satellite procedures have been structured such that the discussion will not get in the way of the action steps.
The satellite procedures are expected to be used under stress situation where the operator will have little time to read a lot of supplemental information.
The operator needs to be presented his required actions in a clear t.nd simple format.
The operators are trained on the E0P satellite procedures and the discussion at the end of each procedure allows the operator to understand the intent of the satellite procedure when he is studying it.
Each procedure has been carefully reviewed to decide what information is in the action section and what information is in the discussion section.
NRC Comment:
3.
The attachments to 5.7.3.2 are very difficult to read and should be made more readable.
BECo Response:
Procedure 5.7.3.2 will be reissued with the attachments made readable.
NRC Comment:
4.
Resolved BECo Response:
N/A 17
Mdit Ouestioni 1.
Question Several PSTG steps are not located in the E0Ps.
They are located in satellite procedures.
Please provide the justification for locating PSTG steps in satellite procedures.
BECo Response:
In accordance with NUREG 0899 Section 5.2.2:
"Information necessary to peeform a task should be consolidated in one place, if possible.
The need to go from one procedure (or parO to another during a sequence of actions is disruptive and can cause errors or unnecessary delays. Consequently, once the sequence of actions has begun, they should continue without interruption."
"For example, an E0P may call for initiation of the standby liquid control system for boron injection. This action should be carried out following the steps specified in the system procedure, and it may be within the operator's capability to initiate boron injection without providing the steps to do so in the E0Ps."
The PNPS E0Ps are flowcharts and the detail of information is designed to be at the "What to Do" level.
The E0Ps are used by the control room supervisor to direct the actions required to stabilize the plant during a transient and are specifically constructed so that the supervisor can easily maintain the total picture.
Actions which are performed by operators at the control room panels or locally in the plant are contained in detailed satellite procedures which are designed to be at the "How to Do" level, the actions which are performed in the satellite procedures are verified and validated in accordance with PNPS procedure 1.3.4-15, "Verification and Validation Program for E0P Support Procedures."
2.
Question NUREG 0800, Standard Review Plan, Section 13.5.2 requires a control room instrumentation function and task analysis be performed.
Please describe where this item will be performed.
BECo Response:
A function and task analysis to determine operator information and control needs as referenced in NUREG 0800 SRP 13.5.2 "Operation and Maintenance Procedures" will be performed as part of BECo's Control Room Design Review Process.
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3.
Question 4
Hill the PSTG be maintained current and update as new BHROG EPG revisions are issued and when the NRC issues its approval of Revision 4 of the EPGs?.
BECo Response:
BECo has put in place NED Procedure 6.08, "Maintaining the Plant Specific Technical Guidelines for Emergency Operating Procedures."
Any changes to the BHROG EPGs, NRC requirements or PNPS Plant Modifications which effect the PSTG will be evaluated.
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appropriate the PSTG and E0P s will be revised.
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