ML20151Z205
| ML20151Z205 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/29/1988 |
| From: | Fogarty E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Butler W Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151Z208 | List: |
| References | |
| NUDOCS 8805050225 | |
| Download: ML20151Z205 (8) | |
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o PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHI A, PA 19101 (n s) su. sono April 29, 1988 E. P. FOG A RTY ave 6s an e'vn'*a, em ion 50-278 Mr. W. R. Butler, Director Project Directorate I-2 Division of Reactor Projects I/II U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555
SUBJECT:
Peach Bottom Atomic Power Station Procedures Generation Package for Emergency Operating Procedures 1
REFERENCES:
- 1) Letter from G. E. Gears, NRC Peach Bottom Project Manager, to E. G. Bauer, Jr., PECo, i
dated September 9, 1986 i
- 2) Letter from J. W. Gallagher, PECo, to W. R. Butler, NRC, dated January 15, 1988
Dear Mr. Butler:
4 The Reference 1 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.
The Reference 2 letter provided a partial response to the NRC's comments and stated that our writers guide and validation / verification guide (Administrative Procedure A-94) would be revised to address the NRC's comments (except comment 1.2) and be l
submitted by April 30, 1988 for NRC review.
Accordingly, this letter transmits A-94, Revision 2.
Also, we have enclosed a copy of the l
NRC's comments on A-94 with a reference next to each comment to j
identify the sections of A-94, Revision 2 and its appendices that address the comment.
Philadelphia Electric Company's justification for not incorporating NRC comment 1.2 was provided in the Reference 2 letter.
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' o Mr. W. R. Butlor April 29, 1988 Page 2 If you have any questions or require additional'information, please feel free to contact us.
Very truly yours, f
m ud Enclosures cc Addressee W. T. Russell, Administrator, Region I, USNRC T. P. Johnson, USNRC Senior Resident Inspector R. E. Martin, USNRC Project Manager T.-E.
Magette, State of Maryland
REQUEST FOR ADDITIONAL INFORHA710N RELATING TO THE PROCEDURES GENERATION PACKAGE PHILADELPHIA ELECTRIC COMPANY PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS 50-277 AND 50-278 ThePeachBottomAtomicPowerStation, Units 2and3(PBAPS) Procedures Generation Package (PGP) was reviewed by the Facility Operations Branch of the Division of Boiling Water Reactors and by the,NRC contractor, Battelle Pacific Northwest Laboratories (PNL). This staff review addressesthreeareasofthePGP,i.e.theWriter'sGuide(P-SWG),the Validation / Verification Program and the Training Program. The staff review of the Plant-Specific Technical Guidelines (P-STG) area of the PGP will be conducted separately. Based on PNL's Technical Evaluation Report (TER) and our initial review, wel~have detemined'that?the1following information 'is needed to' complete olifrevies The' inf6tniatioiPshould :be * *
'p'ro v i d e d [a s7a7e v i s i o'ni to. th e~ PG P.
1.0 PLANT SPECIFIC WRITER'S GUIDE (P-SWG)
The P-SWG description was reviewed to determine if it described acceptable methods for meeting the criteria of the Standard Review Plan (SRP) Section 13.5.2, Appendix A, Subsection 4.0.
Based on our review the following
,additiona,1jinfonnation 1,s;needed!
1.1 Subsection 5.1.2 of Appendix III, Concurrent Flow Paths This subsection on page 2 states that concurrent flow paths should have gPI' g
..their own identifying letter codes and. sequential numbers. Also include a Sg.5.i.3 statement that the number of concurrent flow paths should not be beyond the capability of the control room staff to perform them.
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 gr8558 j before the step to which it applies and that all "Cautions" and "Notes" referenced in a flowchart by number shall be written out and displayed in bv a Continue Rechecking Step symbol, an example of which is provided in
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Attachment III of Appendix III.
i/is/as The preferred method for placement of Caution statements is their insertion W er 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," i.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.
1.3 Subsection 5.6.2 of Appendix III, General Guidance ThissubsectiononpageIaddressesreadabilityoftheflowcharts.
AE Include in the printi,ng instructions for the flowcharts, specific ff Sec. 6.7,l information about the size of the symbols to be used, acceptable spacing between the symbols, and specify the minimum size of printing on the charts to ensure readability. J In acoltion, state inat inf ormation De Ag presented so that interruptions in the flow of information to the operator PP are minimal, i.e. each procedure (or subprocedure) should begin on a new Sec. 6.l.5 page, and each action step should be wholly contained on a single page.
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1.4 Relationship of T-100 procedures to Control Room Staffino ConsiderationsSection II.B in the validation checklist in the PGP mentions staffing considerations.
In additio1, address the relationship of how the T-100 procedures are written to control room staffing considerations by including the following guidance based on Section 5.8 of NUREG-0899 and Subsection 4.3.6 of Appendix A of SRP Section 13.5.2:
A statement that the T-100 Series procedures be structured so that AE"
,they c'an be executed by the minimum shift staffing required by'the Sec.ff5.l.1 Technical Specifications.-
A statement that the T-100 Series procedures be structured so that App.IIL operator roles specified in the Transient Response Implementation Plan (TRIP) procedures i.e., PBAPS Emergency Operating Procedures and Sec.F.I.2 in the training program encourage control room personnel to operate as a team with pre-established leadership roles and division of responsibilities.
App.IU.
A statement that action steps be seq'lenced to minimize physical interference between operators and sequenced to avoid their Sec. 6.l. 5. 5 unintentional duplication by operators.
and
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1.5 Section 7.0 of A-94., Procedures A-99 The use o'f flowcharts represents a major portion of TRIP procedures implementation. Therefore, provide a-detailed description of the method S ec, 7.12.
used for implementing the flowcharts.
Include information on flowchart location in the control room, how they are used by the operators (e.g. how they are related to the division of responsibilities), how many there are, how they will be distinguished for easy access, and how tratisitions between flowcharts and narrative procedures are handled.
1.6 Subsection 7.5 of A-94, Production of Procedures A-H
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This subsection on page 5 discusses production'of the flowcharts and the sec.u.1 T-200 series procedures.
Include a statement that all copies of the flowcharts be clearly legible.
1.7 Section 2.0 of Appendix IX, Writing Style Guidance Expand this section to provide aidance on:
ff "Numerals", "Tolerances" and "Punctuation" as suggested in NUREG-Sec. 2.5,2.6 and 0899, Subsections 5.6.4, 5.6.7 and 5.6.8.
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TRIP Procedures Vocabulary - The PGP states that idrntification of components should be in everyday terms and that words and meanings should be used consistently.
In addition, include the following guidance based on NUREG-0899, Subsections 5.6.1 and 5.6.2 to ensure 4PP' y that the words used are readily understood by both the procedure Sec. 2.3 preparers and operators:
,(1) ivoid using adverbs that are' difficult to define in'a pre ~cise manner (e.g., frequently, slowly, etc.). -
(2) use short words and words that accurately convey the intended meaning.
(3) use concrete and specific words that describe precisely what tae operator is to do or observe.
A
' y_ui (4) the sarr.e aboreviation should not be used #or more than one word and minute)ppendix VII, P. 1, "Min." is used for both minimum PP (e.g.,inA 1.8 Check-off Blank Symbol The check-off blank symbol shown on page 4 of Attachment I 'to Appendix A 'P.E III, is not the same check-off blank symbol used on page 13 of Attachment f
11 to demonstrate acceptable positioning of check-off blanks.
Revise the 8C
?"Y P-SWG '.o be censistent.
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1.9 Cross-Referencing Within and Among Procedures Cross-referencing other procedures and branching techniques are described A(('" g in Attachment I to Appendix III. ~ However, in addition to specifying the
~ A-MMI procedure number in the arrow and the step number to the right of the arrow, note the sheet number on which the next steD is located.1 Also, describe the criteria that procedure writer's are to use to determine when APP E the steps of a referenced procedure or of a subprocedure should be
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reproduced on the flow path to minimize cross-referencing.
1.10 Location Information Provide placement information in the P-SWG so that operators are able AH to easily locate equipment, controls, and dis, nays that are used PP Se,2,7 infrequently or are difficult to find and specify when and how to present location information.
2.0 VERIFICATION AND VALIDATION PROGRAM The Verification and Validation Program description was reviewed to determine if it described acceptable methods for meeting the criteria of SRP Section 13.5.2, Appendix A, Sui)section 5.0.
Based on our review the following additional information is needed:
2.1 Program for Verification and Validation (V/V)
A-w Sex-. 7.7,1 The V/V sections (Appendix VI and Appendix VII of A-94) of the PGP discuss
- ang this program in the context of "revisions" ^.o TRIP procedures. However, clarify that the V/V program also applies to new or upgraded TRIP bM procedures.
S Age.haar 2.2 Methods Used to Meet Each of the Objectives Appendix VII, Subsection 5.3 on page 2 states that the validator will A'E determinewhichvalidationmethodisappropriateandwillselect(hasedon If the validation method selected and the nature and extent of the revisions)
Sec. 5.3. 2 which portions of the checklist (Table I, Appendix VII) are applicable.
and Describe the specific method or combination of methods (i.e., desk top review; seminars, workshops, operating team review; control room walk-bC 5 3 b throughs; simulator, either plant specific or generic; computer modeling/
analysis) that will be used for meeting each objective (checklist items) to ensure that the objectives of the overall V/V program are met.
2.3 Verification and Validation Program Personnel Specify the types of personnel involved in the V/V process (i.e., plant bPP.E,_M operators, subject matter experts, procedure writers) and include a Gec& n.s_
description of their roles and responsibilities.
- 2. 2,d2. 3 3n A - 9 4, sec. 7.7. 2__
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2.4 Subsection 4.2, Simulator Exercises A 'g This subs'ection on page 3 of the "Training Program" section states that FP the TRIP procedures will be exercised on the Limerick Simulator, which is Sec. 5.3. l, a non-plant specific simulator.
Identify which parts of the TRIPS can be validated on the simulator and then *specify the validation method that will be used for the parts of the TRIPS that cannot be validated on the simulator.
2.5 Procedure Validation Form App.E This form in Appendix VII, Attachment 1, states that any discrepancies Soc M discovered during the validation process will be corrected.
In addition, A'E include in the PGP the following information based on SRP Section 13.5.2 PF S ec. 5.5 Appendix A, Subsections 5.3.6 and 5.3.7: a description of the plan for correcting and revising TRIPS as a result of the V/V process;1a statement A-jy Sec.1,7 of commitment to validate and verify revisions to the TRIPS when g,g ggappropriate; and the conditions under which revisions should be verified and validated.
Sac,4.1 2.6 Verification'and Validation Program for Unit Differences A
II re S ec. 5,7 The V/V program does not indicate the methods by which differences, if Agg. yrt any, between Units 2 and 3 will be handled. Therefore, provide as S ec. 5.3.7 applicable, a description of the method by which multiple units will be handled in the V/V process to account for unit diffdrences.
3.0 TRAINING PROGRAM Rernaind e r Mdresse) The Training Program description was reviewed to determine if it described acceptable inethods for meeting the criteria of SRP Section 13.5.2 Appendix A, S0bsection 6.0.
Based on our review the following additional g)'
information is nnded:
l/85/&S 3.1 Subsection 2.0, Training Program Description le,ffe r Include in this subsection, a commitment to:
train all' operators on all TRIP procedures prior to TRIP procedure implementation, ev'aluate all operators as part of the training program, and provide appropriate follow-up training where needed.
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6-3.2 Subsection 4.0, Initial TRIP Training Methods
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. The "Training Program"- as described in the PGP consists of classroom instruction and simulator exe'rcises on a generic simulator.
In addition, indicate the following:
1.
the method for training operators in areas not covered by simulator exercises, 2.
the use of control room walk-throughs on all TRIP pr6cedures by all operators, the use of control 'oo.s walk-throughs to demonstrate planned 3.
r operator roles and team work, and 4.
the use of a simulator and control room walk-throughs to demonstrate a wide variety of scenarios including multiple (simultaneous and sequential) and consequential failures.
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