ML20197G133
| ML20197G133 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/17/1983 |
| From: | Russell W Office of Nuclear Reactor Regulation |
| To: | Novak T Office of Nuclear Reactor Regulation |
| References | |
| CON-WNP-0683, CON-WNP-683, TASK-1.C.1, TASK-1.C.7, TASK-1.C.8, TASK-TM NUDOCS 8312140339 | |
| Download: ML20197G133 (7) | |
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- D DTSTRTBUTTON DMB PSRB Reading DHFS R/F Dockot No. 50-397 DLZiemann HBClayton WCMiddleton RJUrban HOV 17 1983 RFroelich MEMORANDUM FOR: Thomas M. Novak, Assistant Director for Licensing Division of Licensing FROM:
William T. Russell, Deputy Director Division of Human Factors Safety
SUBJECT:
SUPPLEMENTAL SAFETY EVALUATION REPORT WASHINGT0fl PUBLIC POWER SUPPLY SYSTEM, UNIT 2 OPERATING AND MAINTENANCE PROCEDURES AND ANTICIPATED TRANSIENTS WITHOUT SCRAM Enclosed is our SSER input for Section 13.5.2, Operating and Maintenance Procedures, which includes consideration of the TMI Task Action Plan (TAP)
Items I.C.1 - Short-Term Accident Analysis and Procedures Revision, I.C.7 - NSSS Vendor Review of Procedures and I.C.8 - Pilot Monitoring of Selected Emergency Procedures for Near-Term Operating License Applicants and Section 15.8 - Anticipated Transients Without Scram (ATUS).
It was reported in Section 13.5.2.2 of NUREG-0892, "SER Related to the Operation of WPPSS Nuclear Project No. 2." that the applicant's program for use of operating and maintenance procedures is acceptable.
It was also reported, in Section 13.5.2.3 of the SER, that the staff will not review TAP Item I.C.8 because the applicant comitted to undertake an adequate pr gram for the development of improved Emergency Operating Procedures E0Ps). On this basis we consider TAP Item I.C.8 resolved.
The enclosed SSER input discusses the applicant's program for preparing E0Ps. This program was developed in response to TAP Item I.G.1, as clarified in NUREG-0737, with schedule and review requirements modified by Supplement 1 to NUREG-0737.
The applicant's program for E0Ps was found to be acceptable, with the exception of the need for additional analysis to identify operator tasks and information and control needs.
This analysis (identified as function and task analysis) is required l
by Supplement I to NUREG-0737 to support both E0P development and the Detailed Control Room Design Review (DCRDR). We request that the operating license be conditioned to require that the function and task analysis be completed to support E0P and DCRDR requirements.
The license condition should require that the Procedures Generation Package or the DCRDR Program Plan contain a detailed description of the function and task analysis fort, with suitable cross-reference in the other
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Thomas M. flovak U/ i 7 G63 document.
The detailed description of the furetion and task analysis effort should be submitted for NRC review no later than two months after licensing. With this exception, TAP Item I.C.1 has been acceptably resolved.
The applicant has met the requirements of TAP Item I.C.7 because the plant E0Ps are based on the approved BWR Owners Group En'ergency Procedures Guidelines, and additional review by the flSSS vendor is not required.
The criteria of Standard Review Plan Section 15.8 (AtlS) have been satisfied because the approved BWR Owners Group Emergency Procedures Guidelines include actions for mitigating an AB1S.
This review was conducted by R. Urban (X28339) and W. Middleton (X24719) of the Procedures and Systems Review Branch. The reviewers are not aware of any " Differing Professional Opinions" for the review of Operating and Maintenance Procedures.
Or!-l:s! :!;;nad by William T. Russell, Deputy Director Division of Human Factors Safety
Enclosure:
SSER for WilP-2 cc '4 enclosure:
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SUPPLEMENTAL SAFETY EVALUATION REPORT WASHINGTON PUBLIC POWER SUPPLY SYSTEM, UNIT-2 I.C.1 SHORT-TERM ACCIDENT ANALYSIS AND PROCEDURES REVISION The staff guidance for upgrading Emergency Operating Procedures (EOPs) was provided in NUREG-0892, "SER Related to the Operation of WNP-2r" March 1982.
The schedule and review requirements for TMI Task Action Plan (TAP) Item I.C.1 have been nodified by Supplement 1 to NUREG-0737, " Requirements for Emergency Response Capability" (Generic Letter No. 82-33), dated December 17, 1982.
8fSupplement 1 to NUREG-0737 requires that technic 4L guidelines be submitted to NRC for review.
For WNP-2, this requirement was satisfied by:
(1) the applicant's commitment in FSAR 94-Amendmenth17, dated July 1981, to implement an upgraded E0P program based on the BWR Emergency Procedures Guidelines, when' approved by the staff, and (2) NRC approval of Revision 2 of the BWR Owners Group Emergency Procedures Guidelines (Generic Letter 83-05, dated February 8, 1983).
IfSupplement 1 to NURE 0737 also requires that each licensee shalL submit to NRC a Procedures Generation Package (PGP) at least three months prior to the date it plans,to begin formal operator training on the upgraded procedures.
The PGP shalL include:
1.
Plant-specific technical guidelines 2.
A writer's guide
. 3.
A description of the program for validation of E0Ps 4.
A description of the training program for the upgraded E0Ps Review criteria for the PGPs are not currently included in the Standard Review Plan (SRP).
Review criteria for PGPs are being developed based on the experience gained in performing the TAP Item I.C.8 reviews and on NUREG-0899, " Guidelines for the Preparation of Emergency Operating Proceduress" which is the reference document for the E0P upgrade portion of Generic Letter 82-33, Supplement 1 to NUREG-0737.
NUREG-0899 identifies the elements necessary for licensees and applicants to prepare and implement E0Ps that will provide the operator with directions to mitigate the consequences of a broad range of accidents and multiple equipment failures.
In addition to identifying these elements, NUREG-0899 also outlines the process by which licensees and applicants should develops implementi and maintain E0Ps.
Finally, to ensure that the elements are addressed in the new or upgraded procedures and that acceptable processes of developments implementation and maintenance are used, the staff will review the PGPs to gain confidence that E0Ps written or upgraded according to a given plant's program will be acceptable.
The staff has reviewed the WNP-2 PGP, submitted by a letter from G.
D.
Bouchey to the Director, NRRi dated March 23, 1983,
and additional information, requested by the staff, which was submitted by letters from G.
C.
Sorensen to the Directori NRR, dated July 29, 1983 and October 11, 1983.
Our review was conducted to determine the adequacy of the applicant's program for preparing and upgrading E0Ps.
NUREG-0899 and Supplement 1 to NUREG-0737 were used as the bases for the review.
The review consisted of an evaluation of (1) the applicant's plant-specific technical guidelines, including the planned method for developing plant-specific EOPs from approved generic technical guidelines which are based on the reanalysis of transients and accidents, as described in NUREG-0660,Section I.C.1, as clarified in Item I.C.1 of NUREG-0737, (2) the applicant's plant-specific writer's guider detailing the specific methods to be used in preparing E0Ps based on the technical guidelines to ensure that the E0Ps are useabler accurater completer readables convenient to use, and acceptable to control room personnels (3) the applicant's program for verifying and validating E0Ps to ensure that they accurately reflect the technical guidelines and the writer's guider and that the E0Ps will guide the operator in mitigating transients and accidents, and (4) the applicant's p r o g r'a m for training operators on EOPs to ensure that the operators will be adequately trained prior to implementating the upgraded E0Ps.
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'ffThe applicant's program provides reasonable assurance that their EOPs will be consistent with approved technical guidelines and an appropriate writer's guider that the E0Ps will be verified and validated, and that the operators will be adequately trained prior to the implementation of EOPs.
The staff concludeh that the applicant's program is acceptable for issuance of the full power operating license.
- However, there is a need for additional analysis to identify operator tasks and information and control needs.
This analysis Cidentified as function and task analysis) is required by Supplement 1 to NUREG-0737 to support both E0P development and the Detailed Control Room Design Review (DCRDR).
The additional work required to support E0P development is concerned with the need for a systematic determination of operator information and control needs, independent of the instrumentation and controls now available.
The operating License will be conditioned to require that both the PGP and l
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the DCRDR Program Plan contain a detailed description of th'e function and task ~ analysis efforts or the detailed description be provided in one documents with suitable cross-reference to the other document.
The detailed description of the function and task analysis effort should t
j be submitted for NRC review no later than two months after l
licensing.
With this exceptione we find the applicant has adequately responded to TAP Item I.C.1.
5-I.C.7 NSSS VENDOR REVIEW OF PROCEDURES hkThe requirement for vendor review of E0Ps has been satisfied by the involvement of the General Electric Company in the development of BWR Emergency Procedures Guideliness as reported under TAP Item I.C.1 of this supplement.
15.2.1 ANTICIPATED TRANSIENTS WITHOUT SCRAM (ATWS) i[' A s stated in Section 15.2.1 of NUREG-0892, "SER Related to the Operation of WNP-2," the applicant is required to have procedures for mitigating ATWS events.
As reported under TAP Item I.C.1 of this supplement, the staff has approved the BWR Emergency Procedures Guidelines, and the applicant has committed to implement a program of EOP development based on these guidelines.
Since the guidelines include appropriate actions for mitigating an ATWS, the staff concludes that the applicant has adequately responded to the guidance of NUREG-0460 for having E0Ps for mitigating an ATWS.
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