ML20203G791

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Requests Emergency Operating Procedures,Abnormal Operating Procedures,List of Deviations from Generic Technical Guidelines & Simulator Scenario List for Site Audit of Procedures Generation Package Scheduled for 860818
ML20203G791
Person / Time
Site: River Bend 
Issue date: 07/23/1986
From: Stern S
Office of Nuclear Reactor Regulation
To: William Cahill
GULF STATES UTILITIES CO.
References
NUDOCS 8608040061
Download: ML20203G791 (5)


Text

DISTRIBUTION iDocket Fil]

M 23 E NRC PDR LPDR Docket No.: 50-458 PD#4 Rdg.

RBernero Mr. William J. Cahill, Jr.

Dewey, OGC Senior Vice President EJordan River Bend Nuclear Group BGrimes

' Gulf States Utilities Company JPartlow Post Office Box 220 NThompson St. Francisville, Louisiana 70775 SStern Attn:

Nuclear Licensing Department-MA-2 M0'Brien ACRS (10)

Dear Mr. Cahill:

SUBJECT:

PROCEDURES GENERATION PACKAGE AUDIT PROGRAM As part of the Nuclear Regulatory Comission's oversight of operating power plants, the staff is planning to audit the Procedures Generation Package (PGP) in place at River Bend Station.

This audit program consists of two phases: a staff review of several operating procedures, followed by a site visit.

To facilitate this audit, please provide our staff with several emergency operating procedures (E0Ps); abnormal operating proce'dures (A0Ps); a listing 4

of deviations from the generic technical guidelines with their justifications; the simulator scenario list; and other background information in preparation for our site visit. After we receive and review the materials, we will contact your staff to further discuss the schedule and details of our site visit.

The staff has tentatively scheduled the site visit for the week of August 18, 1986.

J. Bongarra of t'RC has informally discussed this matter with R. King of your licensing staff. Mr. Bangarra and I will contact Mr. King with a firm date for the site visit as well as a list of NRC and contractor personnel requiring access to the facility.

The attachment to this letter contains additional information on the PGP Audit Program.

For further information or amplification of this request, please contact me.

Sincerely, Original mgned by Stephen Stern, Project Manager Project Directorate No. 4 Division of BWR Licensing

Enclosure:

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Docket No.:

50-458 Mr. William J. Cahill, Jr.

Senior Vice President River Ber.d Nuclear Group Gulf States Utilities Company Post Office Box 220 St. Francisville, Louisiana 70775 Attn: Nuclear Licensing Department-MA-2

Dear Mr. Cahill:

SUBJECT:

PROCEDURES GENERATION PACKAGE AUDIT PROGRAM As part of the Nuclear Regulatory Commission's oversight of operating power plants, the staff is planning to audit the Procedures Generation Package (PGP) in place at River Bend Station.

This audit program consists of two phases: a staff review of several operating procedures, followed by a site visit.

To facilitate this audit, please provide our staff with several emergency operating procedures (EOPs); abnormal operating procedures (A0Ps); a listing of deviations from the generic technical guidelines with their justifications; the simulator scenario list; and other background information in preparation for our site visit. After we receive and review the materials, we will contact your staff to further discuss the schedule and details of our site visit.

The staff has tentatively scheduled the site visit for the week of August 18, 1986.

J. Bongarra of NRC has informally discussed this matter with R. King of your licensing staff. Mr. Bongarra and I will contact Mr. King with a firm date for the site visit as well as a list of NRC and contractor personnel requiring access to the facility.

The attachment to this letter contains additional information on the PGP Audit Program.

For further information or amplification of this request, please I

contact me.

Sinc're10, I

r hb\\

k

/ tep$ n Stern, Project Manager S

~ Project directorate No. 4 Division of BWR Licensing

Enclosure:

As stated cc w/ enclosure:

See next page i

t.

Mr. William J. Cahill, Jr.

Gulf States Utilities Company River Bend Nuclear Plant cc:

Troy B. Conner, Jr., Esq.

Ms. Linda B. Watkins/Mr. Steven Irving Conner and Wetterhahn Attorney at Law 1747 Pennsylvania Avenue, NW 355 Napoleon Street Washington, D.C.

20006 Baton Rouge, Louisiana 70802 Mr. William J. Reed, Jr.

Mr. William H. Spell, Administrator.

Director - Nuclear Licensing Nuclear Energy Division Gulf States Utilities Company Louisiana Department of P. O. Box 2951.

Environmental Affairs Beaumont, Texas 77704 P. O. Box 14690 Baton Rouge, Louisiana 70898 Richard M. Troy, Jr., Esq.

Assistant Attorney General in Charge Mr. J. David McNeill, III State of Louisiana Department of Justice William G. Davis, Esq.

234 Loyola Avenue Department of Justice New Orleans, Louisiana 70112 Attorney General's Office 7434 Perkins Road Resident Inspector Baton Rouge, Louisiana 70808 P. O. Box 1051 St. Francisville, Louisiana 70775 H. Anne Plettinger 3456 Villa Rose Drive Gretchen R. Rothschild Baton Rouge, Louisiana 70806 Louisianians for Safe Energy, Inc.

1659 Glenmore Avenue Baton Rouge, Louisiana 70775 President of West Feliciana Police Jury Regional Administrator, Region IV P. O. Drawer N.

U.S. Nuclear Regulatory Commission St. Francisville, Louisiana 70775 Office of Executive Director for Operations 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011 Mr. J. E. Booker Manager-Engineering, Nuclear Fuels &

Licensing Gulf States Utilities Company P. O. Box 2951 Beaumont, Texas 77704 9

m Background of the PGP Audit Program:

Following the Three Mile Island (TMI) incident, the NRC issued the "TMI Action Plan" (NUREG-0660) and " Clarification of TMI Action Plan Requirements" (NUREG-0737) which requires licensees to reanalyze transients and accidents and upgrade emergency (EOPs).

The plan also requires the NRC operating procedures staff to develop a long term plan that integrated and expanded efforts in writing, reviewing, and monitoring plant procedures.

" Guidelines for the Preparation of Emergency Operating (NUREG-0899), provides guidance necessary for Procedures",

licensees to prepare and implement EOPs and describes the use of a " Procedures Generation Packgage" (PGP) to prepare EOPs.

Submittal of the PGP was made a requirement by Generic Letter 82-33, " Supplement 1 to NUREG-0737-Requirements for Emergency Response Capability".

In the PGP the licensee describes its program for preparing and implementing upgraded EOPs by the technical basis of the procedures; the addressing four areas:

preparation of text and visual aids for EOPs (Writer's Guide);

the verification / validation of the EOPs; and the training of The staff evaluates PGPs rather than operators to use the EOPs.The staff believes that it is more important to.

the actual EOPs.

ensure that the process used to generate procedures and their technical basis is sound and well documented, than to perform a future EOP one-time review of EOPs, with no assurance that revisions are technically adequate and consistent with existing indicates that the staff will audit EOPs.

Supplement 1, however, upgraded EOPs at selected plants to determine how well the NRC's process of reviewing PGP's is working as a method for assuring l

that acceptable EOPs are being developed and implemented by In accordance with Supplement 1, we plan to perform licensees.

audits at ten operating reactors and two near-term operating if i

reactors by the end of FY87 to identify any corrections, needed, to the regulatory program for EOPs.

9


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The PGP Audit:

is to create a data base frcm The primary objective of the audit i

which generic conclusions about the staff's PGP program may be The audit consists of two phases:

developed.

1) a desk top review of EOPs and background information (e.g.

plant-specific technical guidelines, deviations from the' generic technical specifications, simulator technical guidelines, malfunction list) provided to the staff by the licensee, and comparison of the EOPs to the PGP and technical guidelines static and dynamic evaluations of procedures which are 2) conducted at the licensee's site.

The staff begins conducting the desk top review about four to six The site visit generally weeks in advance of the site visit.As part of the site visit, the staff requires two to three days.

meets with representatives of the licensee's management, licensing and training organizations to discuss Following this meeting, operations, findings from the desk top review.several hours during the site visit are through the procedures in the control room (or with a currentand exerc control room mock up) generic simulator (if either is available) with the participation of an operating crew (the complement of personnel that would useAn exit discussio the EOPs during actual emergency conditions).of the audit resu A report of the staff's findings from staff departs the site.

the audit will be provided to the licensee.. Although the primary objective of the audit is to support a generic evaluation of the if the audit identifies potentially EOP upgrade program, safety-significant deficiencies with the licensee's EOPs orthe staff approved PGP, for appropriate follow up by the Region, (SER)

Evaluation Report and/or'the NRC's licensing project manager.

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