ML20205C930

Forwards Procedures Generation Package in Support of Development & Implementation of Upgraded Emergency Operating Procedures,Per Generic Ltr 82-33,in Response to 850610 Request.Rev 3 to Emergency Procedure Guidelines Also Encl

ML20205C930
Person / Time
Site:	FitzPatrick
Issue date:	09/11/1985
From:	Brons J POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
To:	Vassallo D Office of Nuclear Reactor Regulation
Shared Package
ML20205C937	List: ML20205C930 ML20205C946 ML20205C970
References
GL-82-33, JPN-85-66, NUDOCS 8509230357
Download: ML20205C930 (15)

Text

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123 Main Street White Plains, New York 10601 914 681.6240

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September 11, 1985 JPN-85-66 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Domenic B. Vassallo, Chief Operating Reactors Branch No. 2 Division of Licensing

Subject:

James A. FitzPatrick Nuclear Power Plant Docket No. 50-333 Request for Submittal of a Revised Procedures Generation Package

References:

1. NYPA Letter JPN-83-60 dated June 30, 1983 from J. P. Bayne to D. B. Vassallo regarding Require-ments For Emergency Response Capability

2. NRC Letter dated June 10, 1985 from D. B. Vassallo to J. C. Brons regarding Interim Safety Evaluations On The Procedures Generation Package The NRC Generic Letter No. 82-33 required the Authority to submit a Procedures Generation Package (PGP) in support of the development and implementation of upgraded Emergency Operating Procedures (EOPs). The PGP consisted of four parts: Plant-Specific Technical Guidelines, a Writers Guide, a validation program description and a description of the training program for upgraded EOPs. The Authority submitted a PGP for our FitzPatrick plant via reference No. 1. The EOPs themselves were implemented December 29, 1984 in accordance with our commitment to the NRC.

Via Reference No. 2, the NRC requested that the Authority submit a revised Procedures Generation Package to address each of the items included in your Interim Safety Evaluation. The four attachments to this letter constitute our response to your request.

Attachment No. 1 is a point-by-point response to each comment in the Interim Safety Evaluation. Attachment No. 2 is the revised FitzPatrick Emergency Procedure Guidelines (EPGs) (Rev. 3),

(Revision 3 of the BWROG Generic EPGs formed the basis for the Fitzpatrick EOPs.) Attachment No. 3 is the Writers Guide (Administrative Procedure 2.2). Attachment No. 4 is a summary of significant differences between the FitzPatrick EPGs (Rev. 3) and the BWROG EPGs (Rev. 3).

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nuring the two years between our submittal of the PGP and our receipt of your comments, significant changes were made to the

!: Writers Guide to resolve difficulties in implementing the EOPs.

Also during this time, the Authority has participated in the BWROG effort to prepare a new revision of the generic CPGs. ,

Additional changes to the FitzPatrick EPGs and Writer's Guide will be incorporated as specified in Attachment 1. Further changes will also be incorporated as required by the final issuance of the generic EPGs by the BWR Owner's Group. (This next revision is scheduled for subrcittal to the NRC in late 1985. ) Due to the nature of the Emergency Operating Procedures and the training required to support significant changes in them, major revisions to the EPGs, Writer's Guide and EOPs will not be undertaken until final issuance and approval of-the generic EPGs.

If you have any further questions regarding FitzPatrick's PGP,

! please contact Mr. J. A. Gray, Jr. of my staff.

Very truly yours M

ohn . Brons i ienior Vice President f luclear Generation

! cc: Office of the Resident Inspector l U.S. Nuclear Regulatory Commission j P.O. Box 136 i Lycoming, NY 13093 f

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. NEW YORK POWER AUTHORITY James A. FitzPatrick Nuclear Power Plant ATTACHMENT 1 TO JPN-85-66 Response to NRC Letter Dated June 10, 1985,

" Interim Safety Evaluation on the Procedures Generation Package" A. Technical Guidelines for Emergency Operating Procedures General

1. Comment: The P-STG should identify safety significant deviations from the EPG's along with a justification for each deviation.

Response: Attachment 4 summarizes the significant deviations of FitzPatrick's P-STG (Attachment 2), as compared to the Boiling Water Reactors Owners Group (BWROG)

EPG's, (Revision 3 dated December 8, 1982) which were approved by the NRC staff in November 1983.

2. Comment: Attachment 1, AP 2.2, Item 7.1.4 is not clear on how " problems" are resolved; "The checklist is returned to the water (SIC) for resolutions of problems".

Response: AP 2.2 has been revised (Attachment 3) to require that the reviewer sign the technical guidelines cover sheet thus signifying agreement. The paragraph implies that the writer resolves the problems with the reviewer. If agreement cannot be reached, plant procedures require plant management and/or PORC resolution.

3. Comment: Provide a description of the process for using the EPGs and background information_to identify' control room operator tasks and information and control needs.

This process can be described in either.the revised PGP or in the Detailed Control Room Design Review (DCRDR) program plan with appropriate cross referencing.

Response: The Authority transmitted a supplement to the FitzPatrick DCRDR Program Plan via letter dated August 31, 1983 (Reference 7). This supplement included details about control room operator tasks and information and control needs.

The methodology used for the CRDR task analysis relies heavily on the " Graphic Display Development" project of the BWROG Display and Procedures Integration Committee. This l

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' project, which was funded by EPRI and the USDOE, under the direction of.the BWROG, produced, among other products, a functional analysis of the BWROG Generic Emergency Procedure Guidelines. The information requirements (both

implict and explict), decisions and actions required by the

operator were identified for each step of the generic EPGs. In accordance with the direction from the USNRC Human Factors Engineering Branch, the Authority has worked

to maintain the independence of the process for determination of the information and control requirements from the specifics of the FitzPatrick control room. For this reason, the human factors contractor retained by NYPA for the DCRDR project task analysis was instructed to use this generic functional analysis of the BWROG/EPGs as the j starting point in the determination of the information and control needs for the task analysis. The contractor will use the information and control needs of the generic analysis and-then identify the information and control needs'from the plant specific EPGs for those steps which are at variance with the generic guidelines. These needs will be determinded without regard to the design of the Fit 2 Patrick control room by examining the generic analysis and its plant specific adaptation, the Fitzpatrick EPGs.

The " process" is thus to simply examine actual steps of the EPGs and determine the information and control needs for those steps which vary from the generic analysis, for which these needs have already been determined.- Note that while

the generic analysis does not identify specific control requirements, it does identify required actions. The human factors consultant will use his BWR experience to determine the required controls to carry out these actions.

A summary description, similar to the one above, will be included-in the FitzPatrick DCRDR Summary Report.

i specific i 1. Comment: Page 14, RC/P-1 Graph - Caution #18 reference

should-be Caution 98 (ref. generic guideline RC-5).

Response: This correction has been made. (See Attachment 2.)

2. Comment

Page 16, RC/P Part of last bullet is~ relevant to the first two bullets and is thus improperly placed ....

Response: This correction has been made. (See Attachment 2.)

l 3. Comment: Page 17, RC/Q Why is the CRD system the only l system identified for boron injection as the alternative to ,

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r-Response: CRD system modifications to allow a relatively easy and quick alternate boron injection path are currently under consideration. Some of the other systems listed, although potentially available, do not lend themselves to easy use and therefore were not included.

4. Comment: Page 22, DW/T Discuss the bases for the drywell spray flow rate restrictions of less than 1800 gpm and the derivation of the drywell spray initiation pressure limit.

Response: The drywell spray flow rate has been increased

'to 10,000 gpm (see Attachment 2) as a result of further refinements in the BWR Owner's Group calculation procedures. The drywell spray initiation pressure limit is based on the BWR Owner's Group calculation procedure 9.0, (Revision 3A, dated March 1, 1984 in Appendix C of the BWROG Generic EPG's).

5. Comment: Page 23, PC/P The word " pressure" was left out between " chamber" and " exceeds".

Response: The word " pressure" was added. (see Attachment ,

2.)

6. Comment: Page 25, PC/P Where is plot associated with limit? (As per guideline?)

Response: The drywell spray initiation pressure limit plot was erroneously omitted and has been added. (See Attachment 2.)

7. Comment: Page 26, SP/L - Do you have SPMS?

Response: FitzPatrick does not have a separate SPMS.

Several methods are available for suppression pool water make-up.

8. Comment: Page 28, SP/L-3.2 - As Mark 1 containment, other parts of step should be included as per guideline.

Response: The generic guideline includes other sections which are applicable for Mark l containments with internal suppression-chamber-to-drywell vacuum breakers.

FitzPatrick does not have internal breakers: PitzPatrick is equipped with external vacuum breakers.

9. Comment: Page 30, Operator Actions - Actions in the EPGs isolate only HVAC. Actions in the P-STGS imply more than HVAC is isolated.

Response: The FitzPatrick EPGs have been revised (Attachment 2) to clearly specify that Reactor Building (secondary containment) ventilation be isolated and SBGT (Standby Gas Treatment System) be initiated. These actions L______________________________________________

are required by the generic guideline to terminate any radioactive release and to assure negative pressure within secondary containment.

10. Comment: Page 32, Table 1 - Under secondary containment parameter / location, why has refuel floor been left out?

Response: The refuel floor temperature and instrument 66-TI-106 (66-FN-13A and B inlet temperature) are the same. The wording has been clarified. (See Attachment 2.)

11. Comment: Page 37, Cl Why is the fire system not included in alternate injection systems?

Response: The alternate systems listed are "hard-piped" and can be easily lined up for injection. The fire system would require a lot of jumpers and " jury-rigs" to use it for alternate injection.

12. Comment: Pa guidelfnes, ge it 44, C5-6.3 would appear....that Based the on the generic minimum RPV flooding pressure should be higher than the minimum SRV re-opening pressure. Please clarify.

Response: This has been corrected. (See Attachment 2.)

The minimum RPV flooding pressure is 84 psig; minimum SRV re-opening pressure is 50 psig.

B. FitzPatrick Writer's Guide for Emergency Operating Procedures General As a result of difficulties encountered when preparing the Emergency Operation Procedures, the Writer's Guide was significantly revised prior to EOP implementation. The revised Writer's Guide (AP 2.2) is included as Attachment 3.

The Writer's Guide includes a new EOP layout which has a logic format with entry conditions and' operator actions on right-hand pages, and corresponding override statements and figures on left-hand pages. This new format was reviewed by a human factors consultant who reacted favorably.

Specific Comments

1. Comment: Information should be presented in procedures so that interruptions in its flow are minimal. To achieve this, each procedure should be written so that an action step, a warning (caution), or a note should be completed on the page where it began. This guidance should be included in the writer's guide.

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Response: The Writer's Guide (Attachment 3) requirement for conciseness and precision in instructions naturally achieves these results. More specific guidance will be provided in a future revision of the Writer's Guide.

2. Comment:' Placekeeping aids can assist the operators in keeping track of their position within a procedure. They are of particular importance when performing concurrent steps or procedures and in situations when the user's attention may be diverted. Thus, the writer's guide should be revised to specify some type of placekeeping aid.

Response: The Authority agrees with this comment and several placekeeping aids are presently being considered.

A mechanism for placekeeping will be incorporated in the EOP revisions which result from the completion of the BWROG's work.

3. _ Comment: It is important that an operator be able to quickly access the relevant EOPs or portions of the EOPs.

The writer's guide should address the accessibility of the EOPs and their various parts and sections. See NUREG-0899, Subsections 6.1.3, for additional guidance.

Response: The EOPs, (as with all operating procedures),

are readily accessible to the on-shift operators. Each EOP is clearly. identified with a cover sheet as specified in Appendix A, Section 2.1 (Attachment 3). In addition, the EOPs located in the control room have been tabbed to allow easy access to key parts of the procedure. The Writer's Guide, will be revised to include guidance on the use of tabs.

4. Comment: The writer's guide should include guidance for units of measure for use in instructional steps, and they should be the same as the rules for the use of units of measure in tables and figures discussed in Subsection 4.9.1, on page 22 of 53.

Response: Guidance for numerical values is given in Subsection 5.5 of Appendix A. (See Attachment 3.)

5. comment: Abbreviations, acronyms and symbols are discussed in Section 5.6 on page 29 of 53. To ensure that these items are recognizable by the operators, a list of acceptable abbreviations, acronyms and symbols should be included in the writer's guide. See NUREG-0899, Subsection 5.6.2, for additional guidance.

Response: The plant-specific EPG lists, in Table 1, common abbreviations used in the EOPs. Additionally, NUREG-0899, Subsection 5.6.2 suggests that the abbreviations used are familiar to operators so that there is no need to consult a glossary. No further list is necessary.

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6. Comment: To minimize confusion, delay, and errors in execution of the EOPs steps, the following concerns should be addressed in the writer's guide: (1) EOPs should be structured so that they can be executed by the minimum shift staffing and minimum control room staffing required by the facility's Technical Specifications, (2) instructions for structuring the EOPs should be consistent with roles and responsibilities of the operators, (3) actions steps should be structured so as to minimize the movement of personnel around the control room while carrying out procedural steps, and (4) action steps should be structured to avoid unintentional duplication of tasks.

See NUREG-0899, Section 5.8, for additional guidance.

Response: Emergency Operating Procedures were written to implement the requirements of the EPGs. The generic EPGs were generated with appropriate consideration of control room operator's performance capabilities and requirements.

The EPGs, and consequently the EOPs, do not address time sequences since this would imply specific events rather than symptoms. The roles and responsibilities of the operating shift are defined in AP 1.1 " Composition and Responsibilities of Plant Organization", and other required procedures. All operating procedures take this into account. Therefore, no further instructions are necessary.

7. Comment: Action steps need to be written for a variety of situations. The writer's guide should address the formatting of the following types of action steps: (1) verification steps which are used to determine whether the objective of a task or sequence of actions has been achieved, (2) steps which are repeatedly performed, (3) steps for which a number of alternative actions are equally acceptable, and (4) steps performed concurrently with other steps. See NUREG-0899, Section 5.7, for additional guidance.

Response: The revised Writer's Guide (Attachment 3) specifically addresses the formatting of various types of action steps. Additionally, the procedure format was specifically designed to accommodate instructional steps which may become applicable at any time while executing the procedure (i.e. " override" steps).

8. Comment: Section 4.2 on pages 18 and 19 of 53 contains a good discussion on the use of logic terms. Logic statements Could be Confusing if the statements are not written in a consistent format. Therefore, this section should be expanded to specify the format and include an example of how these logic statements should be written.

See NUREG-0899, Subsection 5.6.10 and Appendix B, for additional guidance.

Response: This section has been expanded and now includes examples. (See Attachment 3.) -

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9. Comment: Subsection 3.2.b on page 16 of 53 discusses the content of the entry conditions, which are to be placed in the Symptoms section of the EOP. However, the format of the Symptoms section also needs to be specified. The format used in Figure 2 on page 15 of 53 is in paragraph form, which could be confusing to the operators if there are a large number of entry conditions and symptoms. This subsection should be expanded to specify that a list of type of format should be used to present the symptoms and entry conditions in the EOPs.

Response: This section has been substantially changed and addresses these concerns. (See Attachment 3.)

10. Comment: Use of equipment and control label information in the EOPs should be applied consistently. The writer's guide should identify the specific information to be included and the format for presenting the equipment and control label information.

Response: Section 4.7 of The Writer's Guide (Attachment 3) provides guidance on component identification.

11. Comment: Section 2.4 on page 14 of 53 states that each page of the procedure will be identified by the procedure title designator and number, the revision number and the page number. The example of Page Format, on page 15 of 53, includes the title of the EOP. If the licensee intends to include the title on each page of the EOP, the writer's guide should be changed to so specify.

Response: A comma between title and designator was erroneously omitted. The title will appear on each page.

12. Comment: The left and right hand margins are discussed in Section 6.2 on page 30 of 53. This section should be expanded to include a specification for the top and bottom margins.

Response: Figure 2 of The Writer's Guide (Attachment 3) provides the page format and consequently controls the top and bottom margins. The applicable section will be expanded to include discussion on top and bottom margins in the next revision of AP 2.2.

13. Comment: The methods of reproduction are described in Section 7 on page 33 of 53. Since copies of the EOPs should be complete (contain all of the information from the original) and legible, the criteria regarding completeness and legibility of the reproduced copies should also be addressed in the writer's guide. See tiUREG-0099, Subsections 6.2.2, for additional guidance.

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Response: This section will be expanded in the next revision of AP 2.2 to more thoroughly address the criteria for completeness and legibility.

14. Comment: The following inconsistencies or errors in the writer's guide should be corrected:

a. The line spacing in Figure 2 on page 15 of 53 does not correspond with the text in Section 6.3 on page 30 of

53. The spacing in Figure 2 appears to be single line spacing with double line spacing between headings and text. Section 6.3 calls for 3 line spaces between headings and text and 1 1/2 line spaces for the text.

The example should be made consistent with the instructions in the writer's guide.

b. Section 3.2 on page 16 of 53 states that the procedures will have four section headings: TITLE, SYMPTOMS, AUTOMATIC ACTIONS (not applicable in symptom-oriented procedures) and OPERATOR ACTIONS.

(i) However, the example in Figure 2 on page 15 has TITLE, SYMPTOMS and IMMEDIATE ACTION as the three section headings. The example should be corrected.

(ii) In Subsection 4.9.3, on page 22 of 53, it is stated that "Section numbering for attachments should be in accordance with subsection 3.3".

This indicates that ATTACHMENTS are meant to be a major section, and should be listed in Section 3.2.

c. Subsection 4.9.3, on page 22 of 53, states that attachment page numbering is to meet the requirements of Subsection 2.5. This should be corrected to say it '

is to meet the requirements of Subsection 2.4.

d. The page numbers in the Table of Contents for the writer's guide do not match the page numbers in the writer's guide. The Table of Contents should be corrected.

Response: The most recent revision of Ap 2.2 (Attachment

3) has an accurate Table of Contents. The remaining comments do not apply to the current revision of Ap 2.2.

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C. Emergency Operating Procedure Verification / Validation

1. Comment: The verification program as outlined.in Section 7.3 on page 5 of 53 and in Appendices B and C of the

" Procedures for E0Ps" contains most of the necessary elements that are required to meet the objectives of NUREG-0899. However, in order to ensure the technical'and human engineering adequacy of the EOPs, the verification and validation programs should specify that the teams performing the verification and validation include both subject matter experts and procedure writers in addition to the reactor operators who are already included in the program. See NUREG-0899, subsection 3.3.5, for additional guidance.

Response: The E0Ps were prepared by consultants who are heavily involved with the BWROG's Generic EPG work (subject experts) and who also utilized a human factors engineer in the procedure development. In addition, the consultants were significantly involved with the validation process.

The Writer's Guide will be revised to more clearly specify that future verification and validation events will include a subject matter " expert" and a procedure writer (s). The subject matter " expert" will be knowledgeable in Appendix B (technical basis) of the EPGs and the procedure writer (s) will be familiar with the requirements of the Writer's Guide.

2. Comment: The use of scenarios in the validation process are described in Subsection 7.4.1.1 on page 6 of 53. This subsection should be expanded to specify that the scenarios include multiple (sequential and simultaneous) failures.

Response: This subsection will be expanded in the next revision. The simulator exercises performed in 1984 for EOP validation and operator training did include multiple failure scenarios.

3. Comment: The discussion of simulator sessions in Subsection 7.4.3.2 indicates that a normal crew of operators will be used. The PGP should indicate that the EOPs will be exercised during plant walk-throughs and simulator events with the minimum control room staff size required by the facility's Technical Specifications.

Response: Section 5.8.1 of NUREG-0899 recommends that E0Ps not require mare than minimum shift staffing as defined by Technical Specifications. AP 2.2 (Attachment 3), reflects this in Section 7.4.3.2 and in AP 2.2, (Appendix D, part B2) which requires a validation assessment to the following question, "Could the procedure action steps be performed by the operating shift?" PitzPatrick's EOPs strongly parallel the EPGs and delineate required actiona, but not time, L----____--___---_--_--_----____----_--_-.-_____--- - - - - _ _ _ _ _ - - - - - - - - - - - - - - - - . - _ - - - - - - - _ _ _ _ _ _ _ - - - _ _ _ _ - -

m since this would be event-oriented. Therefore, it would be inappropriate to mention minimum control room staff size since the remainder of the shift is readily available.

4. Comment: To assure verification / validation of all the EOPs, the program description should include an indication that the full complement of EOPs will be exercised.

Response: The validation and verification steps of the Writer's Guide must be accomplished before each EOP is approved. Therefore, it would be redundant to add this wording.

5. Comment: There are discrepancies between the writer's guide and Appendix B, "EOP Verification Checklist

• that should be corrected. These are as follows:

a. The writer's guide includes instructions on procedure organization and step numbering in Section 3.0, component identification in Section 4.0, and vocabulary, abbreviations and typing instructions in Sections 5.0 and 6.0. These items are not covered in Appendix B.

b. Conversely, Appendix B checklist, Item 7 deals with listing or specifying the recipient of a communication in the EOP which is not mentioned in the writer's guide,.and checklist item 9 asks whether provisions are made for verifying automatic actions associated with the emergency were actually observed, whereas the writer's guide, and checklist item 9 asks whether provisions are made for verifying automatic actions associated with the emergency were actually observed, whereas the writer's guide stated the automatic actions are not applicable in symptom-oriented procedures.

Response: Appendix B was significantly changed in the revised AP 2.2 (Attachment 3). Most of these comments have been resolved in this revision.

D. Emergency Operating Procedure Training Program General Since the EOPs have already been implemented, inclusion of additional wording in the PGP is unnecessary. Our reply to each question will respond to the comment and describe what was done in 1984 to support EOP implementation.

Specific

1. Comment: The program description should clearly state the training objectives, e.g., t'tainees should understand the philosophy behind the approach to the EOPs, and how these objectives will be accomplished by the training program.

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Response: Lesson plans were prepared and used to support the classroom training phase of EOP training. Each lesson plan stated the training objectives.

2. comment: Since the licensee must use a generic simulator for training, discuss the methods to be used to train the operators in areas where the simulator is not like the control room or does not react like the plant, and in parts of the EOPs that cannot be run on the simulator.

Response: Operators were trained on the EOPs, including tabletop discussions, prior to simulator training. At the simulator, additional tabletop discussions were conducted on the differences between the simulator and FitzPatrick.

l A staff instructor and a representative of the consultant responsible for EOP preparation were also present at the t simulator to assist in training and to discuss differences between FitzPatrick and the simulator.

! 3. comment: Indication that operators will be trained as a i team to use the EOPs and that each operator is trained in the role that they would be expected to take in case of an actual emergency.

Response: Training was conducted using normal shift complements. Licensed operators rotated positions at the simulator to receive training outside their normal roles.

This was in addition to their normal role training.

l 4. comment: Indication that a wide variety of scenarios will be used to fully exercise the EOPs on the simulator (within the constraints of the simulator).

1 Response: This was done at the simulator, (in addition to multiple failure scenarios), to exercise and train operators on all EOPs.

l 5. comment: Indication that all the EOPs will be exercised in some fashion by all the operators.

Response: The simulator training included exercise on all EOPs with all operating shifts.

6. Comment: The description of the training program should i include a statement of commitment that all operators will '

l be trained on the revised EOPs prior to their I implementation.

l Response: The extent of operator training on revised EOPs l necessary before implementation depends on the extent of the revisions. Prior to implementing the original EOPs, l revisions were made after simulator training to correct problems identified at the simulator. Operators were ,

required to read these changes before standing watch.

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7. Comment: The description of the training program should state that the operator's knowledge and performance on the EOPs will be evaluated and that appropriate follow-up training will be conducted in deficient areas.

Response: This evaluate and follow-up feature is a routine part of the FitzPatrick training program mandated by other regulatory requirements. The original simulator training included this evaluation and follow-up training. Future training programs will also include this feature.

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References

1. NYPA letter, J. P. Bayne to D. B. Vassallo, dated October 24, 1983 (JPN-83-90) regarding Supplement No. 1 to NUREG-0737, item I.D.1, Control Room Design Review.

2. NRC letter, D. B. Vassallo to J. C. Brons, dated June 10, 1985 regarding Interim Safety Evaluations on the Procedures Generation Package.

3. NRC Generic Letter No. 82-33, Supplement No. I to NUREG-0737, dated December 17, 1982.

4. NYPA letter, J. P. Bayne to D. B. Vassallo, dated June 30, 1983 regarding Supplement 1 to NUREG-0737, Requirements for

, Emergency Response Capability. Includes: Administrative Procedure 2.2 (Procedure for Emergency Operating Procedures; and a summary of the EOP training program.

5. NRC Generic Letter No. 83-05, dated February 8, 1983, safety Evaluation of " Emergency Procedure Guidelines, Revision 2" NEDO-24934, June 1982.

6. NRC letter dated November 23, 1983, D. M. Crutchfield to T.

Dente, regarding Safety Evaluation of " Emergency Procedure Guidelines", Revision 3.

7. NYPA letter dated August 31, 1984, J. P. Bayne to D. B.

Vassallo , (JPN-84-57) regarding Supplement No. 1 to NUREG-0737, Item I.D.1, Detailed Control Room Design Review (DCRDR).

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