ML20203D051

Confirms Telcons Re Participation in NRC Procedures Generation Audit Program.Util Will Provide Emergency Operating Procedures,Including Status Trees,Function Recovery Guidelines & Operational Recovery Guidelines

ML20203D051
Person / Time
Site:	North Anna
Issue date:	04/09/1986
From:	Engle L Office of Nuclear Reactor Regulation
To:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
References
NUDOCS 8604210366
Download: ML20203D051 (3)

Text

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April 9, 1986 Docket Nos. 50-338 DISTRIBUTION and 50-339 Docket File J. Partlow NRC PDR L. Engle Local PDR D. Miller PAD #2 Rdg ACRS (10)

Mr. W. L. Stewart T. Novak Tech Branch Vice President - Nuclear Operations OELD Gray File Virginia Electric and Power Company E. Jordan V. Benaroya Post Office Box 26666 B. Grimes J. Bongarra Richmond, Virginia 23261 B. Kennedy

Subject:

NRC Procedures Generation Package (PGP) Audit Program -

North Anna Power Station, Unit Nos. I and 2 (NA-1&P)

The purpose of this letter is to confirm previous telephone conversations which we have had with your staff.

In conversations with Mr. W. G. Kennedy of the NRC staff, Mr. D. Vandewald of your staff has indicated that North Anna will participate in our PGP Audit Program. He has agreed to supply our staff, beginning April 4,1986, with several emergency operating procedures (E0Ps), including status trees, Function Recovery Guidelines (FRGs) and Optional Recovery Guidelines (ORGs), and the simulator malfunction list, in preparation for our site visit the week of May 5,1986.

Background of the PGP Audit Program:

In accordance with Supplement 1 to NUREG-0737, " Requirements for Emergency Response Capability," dated December 1982, licensees submit Procedures Generation Packages (PGPs) to the staff for review.

In the PGP, the licensee describes its program for preparing and implementing upgraded emergency operating procedures (E0Ps) by addressing four areas: the technical basis of the procedures; the preparation of text and visual aids for E0Ps (Writer's Guide); the verification / validation of the E0Ps; and the training of operators i

to use the E0Ps. The NRC staff evaluates PGPs rather than the actual E0Ps.

The staff believes that it is more important to ensure that the process used to generate procedures and their technical basis is sound and well documented, than to perform a one-time review of E0Ps, with no assurance that future E0P revisions are technically adequate and consistent with existing E0Ps.

Supplement 1 also indicates that the NRC will audit upgraded E0Ps at selected plants to determine how well the NRC's process of reviewing PGP's is working as a method for assuring that acceptable E0Ps are being developed and implemented by licensees.

In accordance with Supplement 1, audits at ten operating reactors and two near-term operating reactors are planned by the end of FY87 to identify any corrections, if needed, to the regulatory program for E0Ps.

8604210366 860409 DR ADOCK 05000338 PDR

i Mr. W. L. Stewart Conduct of PGP Audits:

The primary objectives of the audits is to serve as a basis for developing generigonclusionsaboutthestaff'sPGPprogram. The audits consist of two phases:

1) a desk top review of E0Ps and background information (e.g. plant-specific technical guidelines, deviation from the generic technical guidelines, technical specifications, simulator malfunction list) provided to the staff by the licensee, and comparison of the E0Ps to the PGP and technical guidelines

2) static and dynamic evaluations of procedures which are conducted at the licensee's site.

The staff typically begins the desk top review about six to eight weeks in advance of the site visit. The site visit generally requires two to three days. As part of the site visit, the staff meets with representatives of the licensee's management, operations, licensing and training organizations to discuss findings from the desk top review.

Following this meeting, several hours during the site visit are devoted to walking through the procedures in the control room (or with a current control room mock up) and exercising them on a plant-specific or generic simulator (if either is available) with the participation of an operating crew (the complement of personnel that would use the E0Ps during actual emergency conditions). An exit discussion of the audit results is conducted with the licensee, before the staff departs the site. A report of the staff's findings frcm the audit will be provided to the licensee.

Although the primary objective of the audit is to support a generic evaluation of the E0P upgrade program, if the audit identifies potentially safety-significant deficiencies with the licensee's E0Ps or approved PGP, the staff will report these findings in a Safety Evaluation Report (SER) for appropriate followup by the Region, I&E, and/or the NRC's licensing project manager.

If you have any questions regarding this audit, please contact James Bongarra (301-4.92-4882) or William Kennedy (301-492-4578) of the NRC staff who are coordinating the PGP Audit Program.

Also, we would like to express our thanks to the staff of your Corporate Office and NA-182 for their willingness to participate in our PGP Audit Program.

Sincerely, hl Leon B. Engle, Project Manager PWR Project Directorate #2 Division of PWR Licensing-A Office of Nuclear Reactor Regulation LA 2

P D: PAD #2 r

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Mr. W. L. Stewart North Anna Power Station Virginia Electric & Power Company Units 1 and 2 cc:

Richard M. Foster, Esq.

Atomic Safety and Licensing Appeal Cockrell, Quinn & Creighton Board Panel 516 Cherry Tawer U.S. Nuclear Regulatory Commission 920 South Cherry Street Washington, DC 20555 Denver, Colorado 80222 Regional Administrator, Region II Michael W. Maupin, Esq.

U.S. Nuclear Regulatory Comission Hunton, Williams, Gay and Gibson Office of Executive Director P. O. Box 1535 for Operations Richmond, Virginia 23212 101 Marietta Street N.W., Suite 2900 Atlanta, Georgia 30323 Mr. W. T. Lough Virginia Corporation Comission Mr. E. W. Harrell Division of Energy Regulation P. O. Box 402 P. O. Box 1197 Mineral, Virginia 23117 Richmond, Virginia 23209 Old Dominion Electric Cooperative Ellyn R. Weiss, Esq.

c/o Executive Vice President Hannon, Weiss and Jordan Innsbrook Corporate Center 2001 S Street NW 4222 Cox Road, Suite 102 Washington, DC 20009 Glen Allen, Virginia 23060 Mr. J. H. Ferguson Mr. Richard C. Klepper Executive Vice President - Power Board of Supervisors Virginia Electric and Power Co.

Louisa County Courthouse Post Office Box 26666 P. O. Box 27 Richmond, Virginia 23261 Louisa, Virginia 23093

y Mr. Anthony Gambardella Office of the Attorney General Supreme Court Building 101 North 8th Street Richmond, Virginia 23219 Resident Inspector / North Anna c/o U.S. NRC Senior Resident Inspector Route 2, Box 78 Mineral, Virginia 23117 Mrs. Margaret Dietrich Route 2 Box 568 Gordonsville, Virginia 22042 Mr. Paul W. Purdom Environmental Studies Institute Drexel University 32nd and Chestnut Streets Philadelphia, Pennsylvania 19104 1

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