ML20206L845

Forwards Request for Addl Info Re Procedures Generation Package Submitted on 840629.Review of Package by NRC & Bnwl Performed Per Section 13.5.2 of Srp.Response Requested within 60 Days of Ltr Receipt

ML20206L845
Person / Time
Site:	Cooper
Issue date:	06/20/1986
From:	Long W Office of Nuclear Reactor Regulation
To:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
References
NUDOCS 8606300443
Download: ML20206L845 (8)

Text

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Docket No. 50-298 June 20, 1986 Mr. J. M. Pilant Technical Staff Manager Nuclear Power Group Nebraska Public Power District Post Office Box 499 Columbus, Nebraska 68601

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) PROCEDURES GENERATION PACKAGE Re: Cooper Nuclear Station By letter dated June 29, 1984, you submitted the Procedures Generation Package (PGP) for Cooper Nuclear Station. Our contractor, Battelle Pacific Northwest Laboratories (PNL), and the NRC staff have reviewed your submittal. The review was performed in accordance with Section 13.5.2 of the Standard Review Plan.

In order to complete our review, we need additional information as described in the enclosure. Please respond within 60 days of receipt of this letter.

The reporting and/or recordkeeping requirements contained in this letter affect fewer than ten respondents; therefore, OMB clearance is not required under P.L.96-511.

Sincerely,

/S/

William 0. Long, Project Manager BWR Project Directorate #2 Division of BWR Licensing

Enclosure:

Request for Additional Information cc w/ enclosure:

See next page Distribution: VBenaroya

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Mr. J. M. Pflant Nebraska Pt.blic Power District Cooper Nuclear Station cc:

Mr. G. D. Watson, . General Counsel Nebraska Putilic Power District P. O. Box 4999 Columbus, Nebraska 68601 Mr. Arthur C. Gehr. Attorney Snell & Wilmer 3100 Valley Center Phoenix, Arizona 85073 Cooper Nuclear Station -

ATTN: Mr. Paul Thomason, Division Manager of Nuclear Operations P. O. Box 98 Brownville, Nebraska 68321 Director Nebraska Department of Environmental

-. Control P. O. Box 94877 State House Station Lincoln, Nebraska 68509 Mr. William Siebert, Comissioner Nemaha County Board of Comissioners Nemaha County Courthouse

!' Auburn, Nebraska 68305 t

! Resident Inspector i U.S. Nuclear Regulatory Comis.iion

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Regional Administrator, Region IV

, . U.S. Nuclear Regulatory Comission l 611 Ryan Plaza Drive Suite 1000

j Arlington, Texas 76011 9' H. Ellis Simons, Director

, Division of Radiological Health Department of Health 301 Centennial Mall, South P. O. Box 95007 Lincoln, Nebraska 68509

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\*.../ REQUEST FOR ADDITIONAL INFORMATION RELATING TO THE PROCEDURES GENERATION PACKAGE (PGP)

NEBRASKA PUBLIC POWER DISTRICT (NPPD)

COOPER NUCLEAR STATION DOCKET NO. 50-298 The Cooper Nuclear Station (CNS) Procedures Generation Package (PGP) submitted by letter dated June 29, 1984 from J. M. Pflant to D. G. Eisenhut was reviewed by our contractor, Pacific Northwest Laboratories (PNL).

Based on our review and on PNL's Technical Evaluation Report (TER) we have determined that the following information is needed to complete our review. The infor.ut'.on should be provided as a revision to the PGP.

1.0 PLANT SPECIFIC TECHh! CAL GUIDELINES (P-STG)

I The P-STG program was reviewed to determine if it contained acceptable methods for meeting the criteria of the Standard Review Plan (SRP),

NUREG-0800, Section 13.5.2 Appendix A, Subsection 3.0. Our review identifies the need for additional information in the following areas:

1,1 Emergency Containment Venting The BWROG EPGs call for emergency containment venting as the last step in

a sequence of procedural steps involving operator actions designed to reduce primary containment pressure. The staff in its Safety Evaluation dated November 23, 1983, of the BWROG EPGs addressing this issue l , identified the need for additional analysis. Specifically, the criteria -

for defining primary containment venting pressure needs to be established.

In the interim, the staff proposed a limit of twice the design pressure

( for venting, subject to a plant-unique analysis to demonstrate containment l integrity. Therefore, provide the following additional information relevant to the emergency containment venting for our review:

(a) Identify the bases for selecting the primary containment venting pressure limit.

, (b) A rapid containment depressurization from venting may result in l' suppression pool flashing and hydrodynamic loads. Provide the analyses performed to determine if the resulting hydrodynamic loads j would exceed the design capability of the suppression pool.

l (c) Identify and provide the bases for all venting flow paths to be used,

! and consider setting priorities for the selected emergency vent paths to minimize radioactive release rates, L

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(d) Since the use of any vent path in the E0P is for an action beyond design-basis events, provide a best estimate evaluation of the remote manual or automatic vent path valve operability (i.e., capability to open and reclose consistent with the selected venting pressure limit).

(e) Provide the analyses performed to demonstrate the effect of containment venting on ductwork failure (if used as a pathway) and the resulting consequence of subjecting equipment near the failed duct to the steam / radiation environment.

1.2 Documentation of Deviations from BWROG PGP, Revision 3 Identify and document the deviations (or additions) from Revision 3 of the BWROG EPG and provide an analysis or technical justification for the deviations and additions that have safety significance. The documentation of the deviations and additions should be performed and included as part of the PGP. Also, all plant specific values that are required in Revision 3 of the BWROG EPG should be provided in the CNS PGP.

1.3 Combustible Gas Control

) Combustible gas control guidelines were not addressed in the BWROG EPGs,

. which you referenced in the Procedures Generation Package for Cooper.

Therefore, discuss your approach in developing plant specific E0Ps for combustible gas control.

2.0 PLANT SPECIFIC WRITER'S GUIDE (P-SWG)

The Plant Specific Writer's Guide (P-SWG) 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. Our review identified the need for additional information in the following areas:

2.1 Control Room Staffing and Division of Responsibilities As Is Applies

• To the Use of E0Ps To minimize confusion, delay, and errors in the execution of E0P steps,

the following concerns should be addressed in the P-SWG (See NUREG-0899, l Section 5.8, for additional guidance):

(a) E0Ps should be structured so that they can be executed by the l minimum shift staff and the minimum control room staffing required I

by the Technical Specifications.

(b) Instructions for structuring the E0Ps should be consistent with the roles and responsibilities of the operators.

(c) Action steps should be structured so as to minimize movement of personnel (carrying out actions at the same locations at the same l time) around the control room while carrying out procedural steps.

(d) Action steps should be structured to avoid unintentional duplication of tasks.

2.2 Section 2.4.b Procedure Revisions Page 2 of the P-SWG states that revisions to the E0Ps will be made in accordance with the P-SWG and Administrative Procedure 1.3. The PGP or the Administrative Procedure 1.3 should state that E0Ps will be revised i ' due to design changes, changes to the Technical Specifications, changes to other procedures referenced by the E0Ps, or changes to the control room.

See NUREG-0899, Section 6.2.4, for additional guidance.

2.3 Section 7 Reproduction E0P reproduction is discussed in Section 7, on page 30 of the P-SWG.

However, since all copies of the E0Ps must be clearly legible, the quality of the reproduced copies of the E0Ps should elso be addressed in the writer's guide. See NUREG-0899, Section 6.2.2 for additional guidance.

2.4 Section 6.2 Page Arrangement For readability, especially to the plant operating staff, it is important that page margins are sufficient for reproduction and binding. Therefore, you should consider addressing margin size in Section 6.2, on page 24 of the P-SWG.

2.5 List of Effective Page Revisions Page ii, " List of Effective Page Revisions", lists pages iii, 43 and 44 as Rev. O, while on the actual pages they are listed as different revisions. Please correct these discrepancies.

3.0 VERIFICATION AND VALIDATION PkOGRAM The description of the Verification and Validation Program was reviewed to determine if it described acceptable methods for meeting the criteria of SRP Section 13.5.2, Appendix A, Subsection 5.0 and Subsections 3.3.3 and

• 3.3.4. Our review identified the need for additional information in the following areas:

3.1 E0P Verification and Validation Programs Discuss how the deviations from and additions to the EPGs (that are of l safety significance) are to be verified and validated. This is needed to determine whether the E0Ps are technically correct. See SRP Section 5.3.1.1 for additional guidance.

3.2 Items to be Verified and Validated

. The PGP should describe the specific items (i.e., provide checklists) that are to be verified and validated. This should include appropriate l items from both the P-STG and the writer's guide. See SRP Section 5.3.1 for additional guidance.

3.3 Identification of participants in Verification and Validation Programs The E0P verification program states that independent engineering organization verification and human factors review are a part of the verification process.

Procedure writers and operations personnel should also be included as members of the verification team. The criteria for selection of these individuals and the roles and responsibilities of these individuals should also be specified. See SRP Sections 5.3.2 and 5.3.3 for additional guidance.

3.4 Use of Scenarios The CNS validation program states that "the team will select and develop scenarios which best exercise each E0P." The validation program should be expanded to include a description of the criteria that will be used to select the scenarios to be run during the validation process. The criteria should be developed on the basis of what is needed to validate the procedures and should ensure that single, sequential, and concurrent failures are included. See SRP Section 5.3.4 for further guidance.

3.5 Simulator Verification and Validation For the parts of the E0Ps that cannot be validated on the simulator, the

. criteria for selecting any additional validation that may be needed and the methods to be used, such as a control room walk-through or a mock-up walk-through, should be described. See SRP Section 5.3.5 for further guidance.

3.6 Plan for Correcting and Revising E0Ps The verification and validation program should include the criteria or methods that will be used for determining the need to reverify and

, revalidate any changes in the E0Ps, resultant from either the verification and validation program or from subsequent E0P revisions.

3.7 Compatibility of E0Ps With Minimum Staffing f

l The E0Ps will require a certain number of operators to carry out the various activities and steps as specified. The verification and validation program should indicate that the E0Ps will be exercised, during simulator exercises or control room walk-throughs, with the minimum control room staff size required by the facility Technical Specifications.

3.8 Correspondence Between E0Ps and Instrumentation and Controls The verification and validation program must determine if the instruments and controls are the ones that are referred to in the E0Ps, are available in the control room and are adequate. A discussion of this should be included in the PGP.

l 3.9 Control Room Operator Information and Control Needs The PGP should describe an adequate method to identify plant-specific information and control needs to be used as a basis for performing the tasks specified in the technical guidelines. The description should l

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. include a discussion of the process used to identify plant-specific parameters and other plant-specific information and control capability needs and describe how the characteristics of needed instruments and controls will be determined. These processes can be described in the detailed CRDR Program Plan.

4.0 TRAINING PROGRAM The description of the Training Program was reviewed to' determine if it i described acceptable methods for meeting the criteria of SRP Section 13.5.2 Appendix A. Subsection 6.0. Our review identified the need for further information in the following areas:

4.1 Use of Simulator Exercises Although the PGP states that a generic simulator will be used for operator training, the training program description should be expanded to address the following items:

(a) Discuss the method 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. For the parts of the E0Ps that cannot be run on the simulator, the PGP should describe the method that will be used to cover areas missed in the simulator exercises. See SRP Section 6.3.2 for additional guidance.

(b) Indicate the use of a wide variety of scenarios, including multiple (simultaneous and sequential) failures, to fully exercise the E0Ps on the simulator and thus expose the operators to a wide variety of E0P uses. See SRP Section 6.3.2.5 for additional guidance.

4.2 Use of Control Room Walk-throughs Although the PGP. states tnat walk-throughs will be used for operator training, the trainin the following items (g program See SRP Section description 6.3.3 for should be expanded additional guidance):to address (a) Discuss the extent that the E0Ps will be covered by all operators, particularly if walk-throughs will be used to train aspects of E0Ps not taught in the simulator.

(b) Indicate the use of a wide variety of scenarios to fully exercise the E0Ps during the walk-throughs.

4.3 Indication That All Operators Will Be Trained The PGP should include a commitment to train all operators on all E0Ps prior to E0P implementation. See SRP Section 6.4 for additional guidance.

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4.4 Indication That Operators Will Be Evaluated The training program states that further training needs wi'l be determined from the operators' performance. The PGP should state that operators' knowledge of and performance on the use of the E0Ps will be evaluated during and after initial training, during training on revisions to the E0Ps, and during refresher training. See SRP Section 6.5 for additional guidance.

4.5 Training Program Description The PGP notes that problems with the E0Ps may be detected during training or retraining programs. The PGP should state the process by which NPPD plans to deal with any discrepancies discovered during the implementation of the training program. The changes made as a result of any discrepancies should be revalidated and reverified.

4.6 Use of Classroom Instruction The training program states that if operational considerations do not allow control room walk-throughs and a simulator is not available, training on major revisions will be conducted during classroom instruction. Therefore, provide a basis to justify that classroom instruction will provide an acceptable level of training on major revisions. ,

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