ML20151L348
| ML20151L348 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/15/1988 |
| From: | Brown S Office of Nuclear Reactor Regulation |
| To: | Leonard J LONG ISLAND LIGHTING CO. |
| References | |
| NUDOCS 8804220031 | |
| Download: ML20151L348 (15) | |
Text
.
1 April 15, 1988 l
l Docket No. 50-322 Mr'. John D. Leon.:-d, Jr.
Vice President-Nuclear Oparations long Island Lighting Co.
Shoreham Nuclear Power Station P.O. Box 618, North Country Road Wading River, NY 11792
Dear Mr. Leonard:
SUBJECT:
PROCEDURES GENERATION PACKAGE RE:
SHOREHAM NUCLEAR POWER STATION In your letter of March' 12, 1987 you submitted the Shoreham Nuclear Power Station Procedures Generation Package (PGP).
This submittal was made to fullfill the requirement in Operating License NPF-36, Attachment I, iten' 4a.
The NRC staff and its consultants at the Battele Pacific Northwest Laboratories found that additional information is necessary inorder to complete this PGP review.
Enclosed is the NRC staff's request for additional information (RAI). 'LILC0's responses, to this RAI, should be provided within ninety days from receipt of this letter.
Sincerely,
{
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stewart W. Brown, Project Manager Project Directorate I-2 Division of Reactor Projects I/II
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Enclosure:
AS stated cc:
See next page
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UNITED STATES E"
NUCLEAR REGULATORY COMMISSION
,j WASHINGTON, D. C. 20555 4,
,o Docket llo. 50-322 APR I 51888 Mr. John D. Leonard, Jr.
Vice President-Nuclear Operations Lerg Island Lighting Co.
Shoreham Nuclear Power Station P.O. Rox G18, North Country Poad Wadina River, liY 11792
Dear Mr. Leonard:
SUBJECT:
PROCEDURES GENERATION PACKAGE PE:
SHOREHAM NUCLEAR POWEP STATION In your letter of March 12, 1987 you submitted the Shoreham Nuclear Power Station Procedures Generation Package (PGP).
This subnittal was made to fullfill the requirement in Operatina License NPF-36, Attachrent I, item 4a.
The NPC staff and its corsultants at the Battele Pacific Northwest Laboratories found that adoitional information is necessary inorder to complete this PGP review.
Enclosed is the NPC staff's request for additional inforretion (RAI).
LILCO's responses, to this PAI, sFould be provided within ninety days from receipt of this letter.
Sincerely, Stewart W. Brown, Project Manager Project Directorate I-2 Division of Reactor Projects 1/II
Enclosure:
As stated cc:
See next page I
l
Mr. John D. Leonard, Jr.
Shorehan Nuclear Power Station Long Island Lighting Company (list 1)
CC:
Stephen B. Latham, Esq.
Gerald C. Crotty, Esq.
John F. Shea, III, Esq.
Ben Wiles, Esq.
Twomey, Latham & Shea Counsel to the Governor Attorneys at law Executive Chamber Post Office Rox 390 State Capitol 33 West Second Street Albany, New York 1227A Riverhead, New York 11901 Herbert H. Brown, Esq.
Alan S. Rosenthal, Esq., Chairman Lawrence Coe Lanpher, Esq.
Atomic Safety & Licensing Appeal Board Karla J. Letsche, Eso.
U.S. Nuclear Regulatory Comission Kirkpatrick & Lockhart Washington, D.C.
20555 South Lobby - 9th Floor 1800 M Street, N.W.
Washington, D.C.
20036-5891 W. Taylor Reveley, III Esq.
Hunton & Williams Dr. Monroe Schneider Post Office Box 1535 North Shore Committee 707 East Main Street Post Office Box 231 Richmond, Virginia 23212 Wading River, New York 11792 Howard A. Wilber Fabian G. Palomino, Esq.
i Atomic Safety & Licensing Appeal Board Special Counsel to the Governor 11.5. Nuclear Regulatory Commission Executive Chamber - State Capitol Washington, D.C.
20555 Albany, New York 1222d Atomic Safety & Licensing Board Panel Anthony F. Earley, Jr., Esq.
U.S. Nuclear Pegulatory Comission ber.eral Ccunsel Washington, D.C.
20555 Long Island Lighting Company 175 East Old County Road Atomic Safety & Licensing Appeal Board Hicksville, New York 11801 Panel U.S. Nuclear Regulatory Commission Mr. Lawrence Britt Washington, D.C.
70555 Shoreham Nuclear Power Station Post Office Box 618 Gary J. Edles. Esq.
Wading River, New York 11792 Atomic Safety & Licensing Appeal Board U.S. Nuclear Regulatory Comission Martin Bradley'Ashare, Esq.
Washington, D.C.
20555 Suffolk County Attorney H. Lee Dennison Building Richard M. Kessel Veteran's Memorial Highway Chafrman & Executive Director Hauppauge, New York 11788 New York State Consumer Protection Board Room 1725 Resident Inspector 250 Broadway Shorehan NPS New York, New York 10007 U.S. Nuclear Regulatory Comnission Post Office Box R Jonathan D. Feinberg, Esq.
Rocky Point, New York 11778 New York State Department of Public Service Regional Administrator, Region I Three Empire State Plaza U.S. Nuclear Reoulatory Comission Albany, New York 12223 475 Allendale Road King of Prussia, Pennsylvania 19406 i
ENCLOSURE LONG ISLAi:D LIGHTING COMPANY SHOREHAM NUCLEAR POWER STATION RE00EST FOR ADDITIONAL I!: FORMATION PGP REVIEW OPERATING REACTORS MARCH 1988
REQUEST FOR /CDITIONAL INFORMATIrc PROCEDURES GENERAT:0N PACKAGE SHOF.EHAM NUCLEAR POWER PLANT 1.
INTRCDUCTION Fo11 ewing the Three Mile Island (TMI) accident, the Office of Nuclear Reactor Regulatien developed the "TMI Action Plan" (NUREG-0660 and NUREG-0737) which required licensees of operating reectors to reanalyze transients and acciderts and to upgrade emergency operating procedures (EOPs) (Item I.C.1).
The plan also required the NRC staff to develop a long-term plan that integrated and exparded efforts in the writing, reviewing, and monitoring of plant procedures (Item I.C.9).
NOREG-0899, "Guidelines for the Preparation of Emergency Cperating Procedures,"
represents the hRC staff's long-term program for upgrading E0Ps, and describes the use of a "Procedures Generation Package" (PGP) to prepare E0Ps. Submittal of the PCP was made a requirement by Generic Letter 82-33, "Supplement 1 to NUREG-0737 - Recuirements for Emergency Response Capability."
The generic letter requires each licensee to submit to the LRC a PGP which includes:
(i)
Plant-specific techrical guidelines (ii) A writer's guide (iii) A descriptien of the program to be used for the validation of E0Ps (iv) A description of the trainire program for the upgraded E0Ps.
This report describes the review of the Long Island Lighting Cerpany (LILCO) response to the generic letter related to development and implementation of E0Ps (Section 7 of Generic Letter 82-33) for the Shoreham Nuclear Pcwer Station (SNPS).
Our review was conducted to deternine the adequacy of the LILCO program icr preparing and implementing upgraded E0Ps for SNPS. This review was based on NUREG-0800 (formerly NUREG-75/087), Subsection 13.5.2, Standard Review Plan (SRP) for the Review of Safety Aralysis Reports for Nucicar Power Plants.
Section 2 of this report briefly discusses the LILCO submittal, the NRC staff review, and the acceptability of the submittal.
Section 3 contains the conclusions of this review.
As indicated in the following sections, our review determined that the precedure generation pregram for SNPS has several items that must be satisfactorily addressed before the PGP is acceptable. LILCO should address these items in a revision to the PGP, or provide justification for why such revision it not necessary.
The revision should be subnitted in acccrdance with a schedule deternined by the NRC's lict1 sing project manager.
Our review of the LILCO response te these items will be included ir, a subsequent safety eva'uation report (SER). The revision of the PGP, and subsequently of the E0Ps, should not impact the scheoule for the use 1
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of the E0Ps. The revision sFould be made in accordance with Section 3,.
Conclusions, of this report, the SNPS administrative procedures, and 10 CFR 50.59.
2.
EVALUATION AND FINDINGS In a letter dated March 12, 1987 fron John D. Leonard Jr. (LILCO) to the NRC, LILCO submitted its PGP for SNPS. The PGP contained the following sections:
Plant Specific Technical Guidelines Writers Guide for E0Ps E0P Verification & Valioation Program E0P Training Progran The NRC staff review of the SNPS PGP is documented in the following subsections.
A.
Plant-Specific Technical Guidelines (P-STG)
The plant-specific technical guidelines section of the PGP was reviewed to determine if it adoressed the ebjectives stated in NUREG-0899 and' was in conformance to the review criteria of NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Pcwor Plants, Section 13.5.2, Operating and Maintenance Procedures dated July 1985.
This review identified the following items which should be addressed by the licensee:
1.
The licensee should describe how operator information and control needs will be derived and used to specify instrumenta-tion and centrol recuirements.
The P-STG should be based en the identification of plant systems and functions and, be supported by an analysis of operator tasks to identify operator informa-tion and centrol requirements.
This description nay be in the PGP, or in the Detailed Control Room Design (DCRDR) Program Pian.
If the licensee adoresses this item as part of the DCRDR, the licensee should state this (cross-reference) in the P-STG portion of the PGP.
?.
The licensee should submit all ceviations frem the Owners Group's Generic Technical Guidelines that are potentially safety significant (e.g., related to systens, functions, or methods),
with justification for each deviation.
Exerples of deviations may be found in SRP Section 13.5.2.
B.
Writer's Guide The writer's guide was reviewed to determine if it described accept-able methods for accerplishing the cbjectives stated in NUREG-0899.
The SNPS writer's guide provides information on E0P flowchart precedure preparation, textual precedure preparation and rechanics of style.
SFPS intends to have a set nf textual procedures with flewchart procedures as appendices. Our review of the SNPS writer's
?
cuide identified the following concerns with respect to the ficwchart preparation cuidance:
1.
Notes and cautions provide operators with irportant supplemental information concerning specific steps or sequences of steps in the E0Ps. The infermation on cautions and notes in Figure 1-3 and in Sectico 1.4.10 sbeuld be expanded and revised with regard to the folicwing:
a.
Figure 1-3 implies that the reme symbol is used for both a caution and a note.
Because caution statements provide information used to prevent actiers by control room operators that ceuld injure personnel or endanger public health or safety, it is important that they be distinguished from nctes, which provide less critical information. Further, in i
Section 1.4.10 the symbol is used only for a caution and no symbol is designated for a note.
This format discrepancy should be clarified; and scme emphasis technique, such as a different symbol, should be used to distinguish cautions frem notes to alert control room personnel to their more critical nat &
b.
Section 1.4.10b describes the format and placcrrent of the caution s)Tnboi but not for the note. This section should be expanded to include the format and the placement of a note sytr.bol.
c.
The writer's guide does not describe the format of the cautions and rotes to be placed at the bcttom of the flowchart or the numbering schere to be used for each note and each c.ation.
The writer'r guide should be revised to specify the fermot for cautions and notes at the bottom of the ficwcharts, hew cautiens and notes are to be numbered, and the emphasis techniques te t,e used, l
d.
Section 1.4.10 states that it is acceptable to express conditional actions in a note or caution.
Notes are l
intended to provide supplemental infornatien and cautions are intendeo to attract a tention to essential er critical information in procedures; neither is intended to include any instructions, directions, or operator actions. The writer's guide sheuld be revised to indicate that actions of any kind are not acceptable in notes and cautions.
3 2.
Conditional and logic statements should be used in E0Ps to describe a set of conditions or a sequence of actions. Because of their irportance and complexity, it is irpcrtant to provide explicit cuidance for their use.
The guidance provided in Sections. 5.5 and 1.5.6 should be revised with regard to the fo11 ewing:
3 1
a.
The terms UFILE and BEFORE are not considered logic terms ard are not in NUREG-0899.
Statements can be worded to avoid the use of WHILE and BEFORE as pseudo-logic terns.
The writer's guide should be revised to eliminate their use as logic terms, b.
Section 1.5.5c describes the use of the logic tern OR. The loaic term OR can be used in an irclusive sense and an exclusive sense. This section should be revised to provide instructions for formatting legic statements that include OR used in either sense, and when to use er not to use either.
c.
Section 1.5.11 states that logic terms are to be underlined for emphasis.
It also allows other words to be underlined for crphasis.
Lcgic terms should be uniquely emphasized so that they stand cut in the text and are easy for operators to recognize.
The writer's guide should be revised to exclude any other words to be underlined for erphasis.
3.
Section 1.5.7c discusses referencing and branching.
It shoulo state that the precedure title, and where applicable the entire step number, be included in a reference or branch; e.g., GO TO i
SP 29.023.05 "TITLE", STEP WP-3.
4.
Instructions shculd be written for the various types of action steps that an operator may take to cepe with different plant situations.
a.
The writer's guide should define the following types of action steps:
(1) steps that verify an action; and (F.)
steps which are performed continuously or periodically.
b.
The writer's guide shculd define, describe the fctmat of and provide examplas cf (1) steps for which a rumber of alternative actions are equall diagnose a situation; and (3) y acceptable; (2) steps which steps which are tire-dependent.
5.
Procedure writers should be given sufficient infornation to produce procedures that are correctly ard consistently formatted.
In order to ensure consistency thrcughout E0Ps, instructions and i
examples in the writer's guide should be revised as follows:
a.
The writer's guide does state the size of the ty)e for wording on the flowcharts, but not the size of tie symbols used, lire width, and arrew size.
The writer's guide should specify the size of symbols, line width, arrow size and ery other aspect of the flewchart that wculd affect readability.
b.
Because of the complexity of flowcharts, it is reccmmended that an example of a properly formatted flowchart be included in the writer's guide.
6.
Section 1.5.10 provides guidance with respect to the verbs to use in the action steps.
The nurber of verbs listed however is linited and there may be other acceptabic verbs the writers will want to use. The writer's guide should provide an inclusive list of acceptable and defined verbs available for use by the writers.
7.
Because operators will use E0Ps in stressful conditions and under time constraints, the procedures must be easily accessible to eperators and should be accurate and current at all tines.
The guidance provided in the PGP should address the following:
a.
The location of the flowcharts in the control room for easy end quick access by the operators, b.
The method by which the E0Ps are easily distinguishable from other plant procedure.
8.
To minimize confusion, delay, and errors in execution of E0P steps, the following concerns should be addressed in the writer's guide:
I a.
Action steps should be structured to be consistent with the roles and responsibilities of the operators, b.
Action steps should be structured to enable the control rocm supervisor to follow staff actions and monitor plant status.
9.
Section 1.4.2 of the writer's guide discusses the review and approval of the E0P flowcharts.
This section shculd state whe (by title) is authorized to review crd approve the flowcharts.
This irfornation should also be indicated on the flewchart signature block.
- 10. Section 1.4.13 "Text Procedure Ste) Numbering Scheme" esplies to text preparatien and therefore s1ould be moved from tie flowchart section to the text preparation section of the writer's guide.
i Our review of the SNPS writer's guide identified the following concerns with respect to the text procedure preparation guidance:
11.
Section 1.7.5 discusses the emphasis and placement of cautiens and the definition ard placement of notes, ard states that notes sheuld not contain instructions. However, there are other aspects of nctes ard cautions which need to be addressed, a.
The writer's guide should provide a definition of cautions, state that they must be cerrplete on a page and do not contain irstructions.
i j
5
b.
The writer's guide should describe how notes are emphasized (differently than cautions) and state that notes are complete on a page, c.
Examples of notes and cautions which are consistent with the text should be provided.
d.
The writer' guide states that cautions are pieced adjacent to the step they refer to and notes should be place as close as possible.
However, both notes and cautions sFould be place directly above the step they refer to, so they l
can be read before the step is read.
- 12. Logic statemerts are used in E0Ps to describe a set of cerditions or sequence of actions.
Because of their importance erd complexity, it is inportant to orovide explicit guidance for their use.
Section 1.7.4 of the writer's guide addresses certain aspects of 1
iogic statements including the use of the words IF, WHEN. THEN, JF NOT, and AND; the use of a list format and the exclusion of MD and OR in the same action.
Examples are also provided.
However, there are other aspects of logic statements which need to be addressed, a.
The writer's guide should discuss the use of MD and OR as.
logic terns versus conjunctions, and how legic terms are t'o be enphasized.
See NUREG-0899, Section 5.6.10 and Appendix B for further guidance.
b.
The examples provided in Figure 1-13 are not consistent 2
with the text.
For example, the GOOD statements do not contain the word THEN ard the logic terms used are not emphasized as they are in the text. Examples of all types of logic statements, and those to evoid, should be provided in the writer's guide and they should be consistent with the guidance in the text.
- 13. The writer's guide should state that vague serbs such as rapidly or slowly should be avoided, and should provido an inclusive list of verbs to be used in the E0Ps.
14 During the execution of E0Ps it is often necessary to refer operators to other procedures or sections of precedures.
Such referencing and branching can be disruptive and cause unrecessary delays. To minimize disruptions and delays the writer's guide needs to address referer.cing and branching, s.
The writer's guide should include a statenent of comitment to mirinize referencing and branching by providing criteria 4
to be used when deciding if the steps should be included in the text or cross-referenced.
6
i b.
The content and fornat of the reference / branch statement including step runber, precedure/section title and number, and a consistent conventions such as GO T0 and REFER T0, should be specified, i
c.
Examples of referencing and branching formats that are consistent with the text should be provided.
d.
Some nethod such as tabbing for easily identifying sections or subsections in the E0P should be specified.
j
- 15. The proper use of emphasis techniques makes the procedures easier to urderstand.
The writer's guide needs to be revised to describe h0w various types of enphasis techniques such as capitalization, boxes, etc., are to be used.
- 16. The writer's guide needs to include guidance for writing the varicus types of action steps that an operator may take to cope with different plent situations. The writer's guide should address the definition and foreat of the following types of action steps and should provide examples consistent with the text: verification steps, ecually acceptable steps, recurrent steps, time. dependent steps, ccocurrent steps, and diagnostic steps.
See NUREG-0899. Section 5.7 for further information.
17.
Information should be presented so that interruption in the flow of inforretion in an E0P is minimized, a.
Action steps should be presented ecmpletely on one page, b.
Procedures and sections of a procedures should begin on a new page.
c.
.a simple method for accessing attachments or appendices should be provided. Examples consistent with the text should be included.
18.
It is inportant that a consistent method of section heeding and step numbering be used throughout E0Ps. The manner in which the text is organized and divided should be evident through the use of headings and a nunberino system so that cperators can keep track of where they ere in the procedure and know how to move easily and quickly to other parts of the procedure. The writer's guide does provide a list of headings and state that a SNPS station procedure is used for section numbering, but it should also address the fo11 ewing:
a.
The methods of pagination shculd be specified. The total number of pages should be included in the pagination.
b.
Step and section numbering, as applied to the dual column precedure format, should be specified.
If an existing station procedurc is referenced, a copy of the station precedure should be provided to the NRC.
7 l
a c.
Examples of the above topics, including section numbering, should be provided censistent with the text.
19.
An inclusive list of acrorps and abbreviations and their definitions should be provided in the writer's guide so that they are used consistently by both precedure preparers and operators.
20.
Figures and tables assist operaters to make decisions and to locate information. Section 1.7.7 discusses the identification of figures and tables, but should also address their other aspects.
a.
The criteria fer deciding when to use a figure or table should be previded.
b.
The location of figures and tablet within the E0P should be specified.
21.
It is impertant that the operaters know where to find all of the instrumentation and centrols that are referenced in the E0Ps.
The writer's guide should discuss the criteria fer determining when the 1ccation of instrumentr and controls should be specified in the E0P, the format for this location information and should, provide an example corsistent with the text.
2?.
Consistent, well-crganized and well-labeled E0Ps increase the case with which operators understand and use the procedures.
Section 1.7.1 of the writer's guide discusses procedure organiza-tion and lists the major section headings and general content of each. However, the writer's guide shculd address the following:
a.
A cover page should be used and the identifying it.forration on this page shculd be identified.
b.
The format of entry corditions should be specified.
See NUREG-0899, Section 5.4 for further inferration.
23.
So that operators are always certain that they are using the correct procedure, the procedure should include identifying infernation in a consistent place on each page. The writer's guide should require that every page contain a block of informa-tion consistently placea on each page.
This informatien should include a brief title or unique number, and revision nurber and/cr date.
24 The vriter's guide should discuss the use of placckeeping aids (checkoffs) for all steps and substeps not just for steps with nultiple objects as ttated in paragraph 1.7.3e.
Placekeeping aids car t.ssist operators in keeping track of their positions within a procedure. These aids are of particular importance when perfornirs steps or procedures concurrently, and in situe-tions wFere the operator's attertion is diverted.
8
- 25. The writer's guide should address the use of punctuation, capitalization, margins, line spacing, units of measure, numerals, tolerances, ard how titles / nomenclature of instruments and controls are to be referred to. See NUREG-0899, Sections 5.5.?
and 5.6.3-5.6.8 for further information.
- 26. The PGP should address the issues of accessibility of procedures, their unique identification, and quality of reproduction as the procedures must be easily accessible and readable to operators and should be uniquely identified to distinguish them fron other plant procedures.
- 27. To minimize confusion, delay, and errors in the execution cf E0P steps, the following issues should be addressed by the writer's guide:
a.
Action steps should be structured so that they can be executed by the minimum control roen staffing required by the Technical Specifications.
b.
Action steps should t'e structured to be consistent with the roles and responsibilities of operators.
c.
Action steps should be structured to minimize the physical.
interference cf personnel in the control room (where technical guidelines permit),
d.
Action steps should be structured to avoid unintentional duplicatien of tasks.
e.
Action steps should be structured to enable the control room supervisor to follow staff actions and monitor plar.t status.
See NUREG-0899, Section 5.8 for further information.
With adequate resolution of the above items, the ShPS writer's guide should accomplish the objectives stated in NUREG-0899 and should provide adequate guidance for translating the technical guidelines into E0Ps that will be usable, accurate, complete, readable, convenient to use ard acceptable to control room operators. The NRC staff will confirm thet LILCO adequately addresses these items and will report its review in a subseouent
- SER, C.
Verification and Validatier Prr,qram The descriptien of the verification erd validation progran was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899. The SNPS verification ard valication descriptions censist of a set of ebjectives ard the process to achieve these objectives.
The PGP gives as cbjectives for the verification and validation process:
1 9
i The E0Ps are technically correct.
The E0Ps are written ccrrectly.
The language and level of information presented in the E0Ps is compatible with the ninimum number, qualification, training and experience of the operatine staff.
There is a correspondence between the control roc.m/ plant hardware and the E0P.
The E0Ps are usable:
1.e., they can be understood and followed without confusion, deleys and errors.
That there is a high level of assurance that the procedures will work:
1.e., the procedures guide the operator in mitigating transients and accidents.
Our review cf the SNPS verification ard validation progran description identified the following concerns:
1.
The verification and validation programs should specify that, at a ninimum, plant operators, subject matter experts, procedure writers, and human factors experts will be involved in verification and validation. Althoug1 the PGP states that independent reviewers and operating crews will be used, the use of a wider variety of verifiers erd validators will help to ensure that all aspects of E0Ps are completely and accurately verified and valideted. The verification i
and validation program should also specify their roles and responsibilities.
2.
The validatien progran should include the criteria for the selection of scenarios that will be used to exercise E0Ps.
This criteria should ensure that the full set of E0Ps are valideted to their fullest extent and should ensure that a wide variety of scenarios, ircluding multiple (simultaneous and sequential) failures are included.
The validation program should also contain a comitment te apply 4
these criteria in developing scenarios for validation of E0P revisions.
3.
The validation progran descriptier states that the SNPS sinulator will be used for the validation process. The description should state the trethod to be used to valicate those parts of the E0Ps where the simulater does not react like the plant or cannot be run on the simulator.
4 The PGP should specifically address the manrer in which feedback frem the validation and verification process will be used to address the accuracy, readability, ccmpleteness, and usability of the E0Ps. While a few of these peints are noted on pages 9 and 10 of the validation plan, they should be specifically addressed in the verification and validation program descriptions.
10
u 0
5.
The verification erd validaticn progran should include the criteria or method that will be used to determine the need to reverify or revalidate any changes to the E0Ps, resulting from either verifica-tion and validation prograns or from subsequent E0P revisions.
6.
The E0Ps will require a certain number of operators to carry out the varicus activities and steps as specified. The validation program should clearly indicate that the E0Ps will be exercised during simulator exercises or control room walk-throughs with the minimum control room staff required by SNPS Technical Specifications.
7.
Particular attentien should be paid during the validation program to deviations from and additions to the generic technical guidelines that are cf safety significance. These validation steps can be aceceplished separately or as part of the validetion program. The PGP should discuss how the deviations from and additions to the generic guidelines arc to be validcted.
8.
The verification erd validation progran descriptions refer to the use of documentation such as checklists, discrepancy forms, completion forms, and validation documentation.
These checklists, forms, records, etc., should be included in the PGP.
With adequate resolution of the above items, the SNPS verification and vclidation program shculd accomplish the objectives stated in NUREG-0899 and should provide asrurance that the E0Ps adequately incorporate the guidance of the writer's guide and the technical guidelines and will guide j
the operator in mitigating emergency conditions.
The hRC staff will cerfirm that LILCO adequately addresses these items and will report its review in a subsequent SER.
D.
Training Program The description of the operator training pregram on the SNPS upgraded E0Ps was reviewed to determire if it described acceptable methods for accom-plishing the cbjectives stated in NUREG-0899. The E0." trainine program censists of classroom instruction, simulator exercises, and simulator control rocm walkthroughs. The overall training goals are:
to enable the ope *ators to aderstand the structure of the E0Ps
~
including the flowcharted version of the E0Ps.
i to enable the operators to ur.derstand the technical bases of the E0Ps.
j to enable the operators to have a working knowledge of the technical content of the E0Ps.
1 to enable the operators to use the E0Ps under operational cerditions.
Gur review of the SNPS training program description for E0Ps identified the folicwing concerns:
11
~.
1.
It is crucial that all operators be trainea on all aspects of each E0P so that they are prepared to execute each E0P to its fullest extent.
Each trainirg approach, classroom and simulator, should cover all aspects of each procedure to the fullest extent possible.
The E0P training program description should be modified accordingly.
2.
The PGP states that the SNPS simulator will be used for training.
The E0P training program description should address the following:
a.
Indicate the use of the simulator using SNPS Technical Specification minimum control room staffing, b.
Indi(ete the use of a wide variety of scenarios, including multiple (sinultaneous and sequential) failures, to fully exercise (to the extent pessible) the E0Ps on the simulator and thus expose the operators to a wide variety of E0P uses.
3.
The training pregram description should be expanded to include a discussion of the method to be used to train operators in creas where the simulator does not react like the plant and in parts of the E0Ps that cannot be run on the simulator. These areas would include differerces between the simulator and the control room.
4 The training progran should include a statenent of consnitment to train all operators on all E0Ps, including revised E0Ps, prior to iroplementing the E0Ps in the control room.
5.
The trainino prcgram should describe the method for evaluating all operators after classroom and simulator training, and for appropriate fo11cw-up treining in any deficient areas.
With adccuate resolution of the above itens, the SNPS training program should acccmplish the objectives stated in NUREG-0899 and should result in appropriate training for the SNPS operators on the upgraded E0Ps. The NRC staff will confirm that LILCO adequately addresses these items and vill report its review in a subsequent SER.
3.
CONCLUSIONS Based on our review, we conclude that, the PGP submitted by Long Islerd Lighting Company for Shnreham Nuclear Power Station in a letter from J. D. Leonard, Jr., to the NRC, dated March 12, 1987, to adequately address the requircinents stated in Generic Letter 82-33 (Supplerent 1 to NUREG-0737) and provide acceptable methods for accomplishing the objectives stated in NUREG-0899 in accordance with the guidance provided in the Standard Review Plan (NUREG-0800, Section 13.5.2), should be revised to address the itens 1
described in Section 2 of this RAI. The PGP should be '.*esubmitted with a sample of at least one Energency Operating Procedure and its associated documentation (e.g., step deviation document, verification and validatior documents). This sample procedure will not be reviewed for approval, but rather will be used as an indication of how the PGP is being applied to E0P preparation.
This evaluation was performed with the assisterce of Battelle Pacific Northwest Laboratories' personnel.
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