ML20151N596

Forwards Rev 2 to Procedures Generation Package (Pgp),In Response to & SER Outsanding Issue 14.Revised PGP Will Be Incorporated Into App 131 of FSAR by Amend 14. Response to Items Re plant-specific Guidelines Also Encl

ML20151N596
Person / Time
Site:	Hope Creek
Issue date:	12/30/1985
From:	Corbin McNeil Public Service Enterprise Group
To:	Adensam E Office of Nuclear Reactor Regulation
Shared Package
ML20151N601	List: ML20151N596 ML20151N603
References
NUDOCS 8601030025
Download: ML20151N596 (9)

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Public Service Electric and Gas Company Cerb.n A. McNeill, Jr. Public Service Electric and Gas Cornpany P.O. Box 236, Hant ocks Bndge,NJ 08038 609 339-4800 Vice Pr tsident -

Nuclean DEC 3 01985 Director of Nuclear Reactor Regulation United States Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 Attention: Ms. Elinor Adensam, Director Project Directorate 3 Division of BWR Licensing

Dear Ms. Adensam:

PROCEDURES GENERATION PACKAGE SER OUTSTANDING ITEM #14 HOPE CREEK GENERATING STATION DOCKET NO.~50-354 In response to the letter from Mr. W.R. Butler (Nuclear Regulatory Commission - NRC) to Mr. R.L. Mittl (Public Service Electric and Gas Company - PSE&G) dated November 19, 1985, PSE&G hereby revises the Procedures Generation Package (PGP) for the Hope Creek Generating Station (HCGS) as last submitted on July 29, 1985 (Mittl to Butler).

Attachment 1 to this letter itemizes the concerns raised in the letter dated November 19, 1985 and references revisions, if necessary, incorporated in the PGP, Revision 2 (Enclosure 1). Appendix A (Emergency Operating Procedures Writers Guide) and Apnendix B (Work Plan for EOP Verification and Validation) to the PGP do not require revision and hence are not included with the submittal; however, they are still considered appendices to the PGP. Information contained in this submittal provides a partial response to Safety Evaluation Report (SER) Outstanding Issue #14.

The enclosed PGP, Revision 2 will be incorporated in Appendix 13L of the HCGS Final Safety Analysis Report (FSAR) via Amendment 14. Should you have any questions on the subject filing, do not hesitate to call us.

Sincerely, C

B60103OO25 851230 PDR ADOCK 05000354 ,

F PDR EB (LIAW)

PSB (L. HULMAN)

1. 8/ EICSB (WINIVASAN)

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Director of Nuclear 2 Reactor Regulation Attachments Enclosure C D.H. Wagner USNRC Licensing Project Manager R.W. Borchardt USNRC Senior Resident Inspector

a ATTACHMENT 1 Page 1 of 3 This Attachment itemizes the major comments / questions raised in the November 19, 1985 letter to PSE&G from the NRC, and where applicable, provides a cross-reference to the revised portion of the PGP.

Section 2.1 - Plant-Specific Technical Guidelines

1. Drywell Spray Initiation Pressure Limit This issue was closed by the NRC staff in the November 19, 1985 letter.

2. Primary Containment Pressure Limit The six itemized criteria will be considered by PSE&G in establishing the pressure limit for emergency venting of the primary containment and addressed in a separate submittal.

3. Function and Task Analysis As identified in the November 19, 1985 letter, this information is available in the Detailed Control Room Design Review (DCRDR) Summary Report and Supplementary Report and with approval of these reports, this issue will be closed for the PGP.

Section 2.2 - Plant-Specific Writer's Guide

4. "While the applicable administrative procedures should be referenced in the PGP, the procedure itself should not be included as a part of the PGP or as an attachment to the PGP."

In response, the July 29, 1985 PSE&G to NRC letter submittal of PGP Revision 1 included 5 enclosures.

The first enclosure (which included two appendices) specifically detailed the PGP. Enclosures 2 through 5 were supplementary information provided in response to the requests for additional information detailed in the May 14, 1985 NRC to PSE&G letter. Specifically, enclosure 5 contained a 15 page system operating procedure guideline to show a similar format for which Series 300 EOPs (EOP Support Procedures) are written. This enclosure was referenced and discussed in the response to RAI Item #5; however, it has been misconstrued as a part of the PGP. Enclosure 5 to the July 29, 1985 is not part of nor an attachment to the PGP. This can be confirmed by reviewing FSAR Appendix 13L which contains the entire PGP.

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5. The PGP should indicate that the procedures are located so that they do not obstruct controls or displays during storage or use, that they are easily accessible and are convenient to use."

In response, see new Section 3.2 on page 10 of the PGP (Enclosure 1).

6. "The PGP should indicate how the flowcharts will actually be implemented in the control room."

In response, see new Section 3.3 on page 10 of the PGP.

7. "The PGP should indicate how access to the needed flowchart (s) will be facilitated through placement, layout, format, etc."

In response, see new Section 3.2 on page 10 of the PGP.

Section 2.3 - EOP Verification / Validation 1

8. " Explain how [the] approach to exercising the EOPs will adequately challenge them [the EOPs) to ensure the EOPs are fully tested, or describe how it [PSE&G) will modify its approach to meet this objective [ usable by the operating crew and capable of mitigating the consequences of a broad range of accidents]".

In response, Essex Corporation, under contract to PSE&G, developed the Work Plan for EOP Verification and Vali-dation and in Attachment 2 of this letter explains how this approach challenged the EOPs to ensure that they were fully tested.

Section 2.4 - EOP Training Program

9. "Although [Section 7.4.1-] of the [PGP] is responsive to [ Item 34 - see RAI letter dated May 14, 1985}, the word "all" was not included in the response ' ...to provide operators with instruction...'"

In response, Section 7.4.1 of the PGP was referenced in the response to RAI Item #34 which stated all operators should have the opportunity to work with the full comple-ment of EOPs. Unfortunately, the word "all" was not reiterated and hence an inconsistency arose. As shown in Enclosure 1, Section 7.4.1 as well as 7.4.2 (pages 16 and 17), have been revised with the addition of "all_ licensed" operators. This assures adequate and equivalent classroom training and simulator exercises for all licensed operators.

W.

Page 3 of 3 Section 2.5 - Supplemental Items

10. -PSE&G appreciates the identification of various flowchart

-characteristics which if revised would exhance human factors: (1) consistent yes/no branch directions, (2) larger directional arrows, (3) caution designator placement,.and (4) flowchart bordering placement.

These suggestions will be considered in future EOP

. revisions since they were provided for information only.

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ATTACHMENT 2 k

ESSEX ,

n December 18, 1985 10: M.E. Rogers FROM: 8. Paramore

'SUBJ: NRC concern about simulator validation 'o f E0PS Per your request, we have reviewed the SER section-in which the NRC '

staff states a concern about the simulator exercises conducted for E0P Verification and Validation (V&V). If we understand the SER correctly, the basic question underlying their_ concern is as follows: -

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... Were the scenarios poten tia l failure or accident situations, or were the procedure flowpaths simply a d o p t e d 'a's .s c e n a r i o s ?

We believe that this question may have arisen because of wording in Section 4.5 of the V&V Work Plan, which might be interpreted to mean something that we did not intend. ,

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y N- T The first-part of Section 4;.5 was intended to ensure that the scenarios selected would fully exi~rcise the procedures in t' w o respects:

a. The scenarios would r e c,u i r e response to degra?a' tion of all of the parameters that were i,d e n t i f i e d as critical,to ,

plant sqfety in the generic and giant-specific analyse 6 of s e emergen'cy 4.esponse requirements tirat led to the bymptom-based ,

procedures. This was to ensure that the, procedures meet the , x

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objective of providing sufficient guidance to enable the s 3

operators-to maintain / restore all critical parameters or ,

shut down safely, regardless of the cause of' parameter degradati,on.- ,

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b. The scenarios would require the procedures -t ) be used in any manner that might be necessary -- e.g., select and follow a single path within a procedure; enter, exit, change, and reenter paths in a multipath procedure; follow simultaneously two or more paths in a procedure; move between procedures; and follow simultaneously two or more paths in different procedures. We emphasized this because the precedure format is new and '

relatively untested, as.the NRC pointed out. We thought it was of the utmost importance to make sure the operators could move

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arcund in the procedures as required by conditions without m getting confused and I,osing place in any path.

Thus the beginning of_Section 4.5 (page 4-3) talk's about addressing procedures and paths ra ther 'than about events. This was not-intended to cean th"at events would not.be specified, it wis just intended to make sure that'the events cho.sen would test the procedures fully.

ESSEX CORPORATION e' 333 North Fairfax Street, Alexandria, VA 22314-2691 e (703) 548-4500 Teler 90-1901

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The second part of Section 4.5, which defines what should be included in a scenario description, addresses events. However, since the ovents are not listed in the Work Plan, it is understandable that the NRC aight be uncertain about whether the scenarios addressed an appropriate colection of events, . including the design basis events in Chapter 15 of the FSAR. Chapter 15 type events and others were of course addressed, e.g.,

A T_W S k J. o s s of of f s i te power with failure of emergency diesels and an ATHS; LOCA:.SRV stuck open: inadvertent SCRAM. As you know, it was necessary to d e v e l o p ,'s s c e n a r i o s in'volving multiple faiiures that go beyond the design basis, events is order to test the procedures fully.

I hope' that this will be helpful to you in resolving the NRC's concern about scenario selection. If we can be of any further assistance, please let me know.

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