ML20212R414
| ML20212R414 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/20/1987 |
| From: | Shelton D TOLEDO EDISON CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20212R417 | List: |
| References | |
| 1368, NUDOCS 8704270164 | |
| Download: ML20212R414 (25) | |
Text
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TOLEDO EDISON Docket No. 50-346 DONALO C. SHELTON Licenne No. NPF-3 iN58~
Sorial No. 1368 April 20, 1987 United Staten Nuclient Regulatory Comminnion Document Control Desk Washington, D. C. 20535 Centlement Toledo Edinon han reviewed your draft Safety Evaluation Report (Log No.1998, dated May 9,1986) of the Davis-lienne Procedures Cenoration Package. Serin 1 No. 1030. Toledo Edison acknowledges the innuen raised with respect to the package.
The attached report providen our responnen an requested in the draft !
Safety Evaluation Report.
Very tru,1 yours, ll- ,fw ..
DCSiJCStp1f Attachment cc D!l-1 NRC Renid6nt Innpector A. B. Dnvin, Acting Regionni Administrator (2 copien) l 0704270164 070420
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P Dit ADUCK 05000346 p POR s M Titt 10t100 IDISON COMi'ANY [0130N l't AIA 300 MA0130N AVINUf: 10Lt00, Ottiu 43052
RESPONSE TO NRC DRAFT SAFETY EVALUATION REPORT CONCERNING Ti!E PROCEDURE GENERATION PACKAGE FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT I tiarch 1987 4
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RESPONSE TO NRC DRAFT SAFETY EVALUATION REPORT CONCERNING TRE PROCEDURE GENERATION PACKAGE FOR DAVIS-BESSE NUCLEAR POWER STATION UNIT 1 TABLE OF CONTENTS P_ age 1.0 Introduction. ........................ 1 2.0 Responses to Draft SER. . . .. .. . . . ... .. .. ... 2 2.1 Plant-Specific Technical Guidelines. ... . . . .... 2 2.2 Plant-Specific Writer's Guide. . . . .. . .... ... 9 2.3 Verification / Validation Program. . . .... ... ... 15 2.4 Training Program . . . .. . . . . . .. . . . ..... 19 Enclosure 1: Davis-Besse Procedure Writers Manual, Volume IV, Operations Procedures Guidelines Enclosure 2: Davis-Besse Emergency Procedure Verification and Validation Program L _ _ _ _ __ _ __ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
1 1.0 Introduction Toledo Edison completed the development and implementation of the Upgraded Emergency Operating Procedure (EP) during the 1984 refueling outage. Since initial implementation, the EP has been upgraded as a result of plant design changes, operational / training experiences, technical evaluations and the issuance of the B&W Owners Group E0P Technical Basis Document, #74-1152414 (TBD). Since its development, the EP has been successfully used during several significant plant transients. The EP, developed in accordance with the Procedure l Generation Package (PGP), supports safe plant operations.
The responses to the draft SER concerns are divided into the four major sections of the PGP (i.e. Plant-Specific Technical Guidelines, Writer's Guide, Verification / Validation and Training Program). For l case of review, the SER " Concern" is listed followed immediately by l the Toledo Edison " Response". To support certain responses, two enclosures are included in this report. Enclosure 1 is the revised plant-specific Writer's Manual. This manual replaces the Writer's Guide submitted in the March 1, 1984 PGP. Enclosure 2 is a draft of the EP Veriff cation and Validation Program. This program will be implemented . Davis-Besse to ensure technical and human engineering adequacy for revisions to the EP.
As a result of the issuance of the revised Writer's Manual and the B&W Owners Group E0P Technical Basis Document (submitted September 11, 1985, M.A. Linn (B&W) to G. C. Vissing, B&W Doc. No. 74-1152414),
further procedural enhancements will be made to the Davis-Besse EP.
These enhancements are expected to be completed by December 31, 1987.
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2.0 ' Responses to Draft SER >
2.1 Plant-Specific' Technical Guidelines ,
2.1.1 SER CONCERN: "End conditions at stabilization are not always expected to coincide with entry conditions for normal cooldown procedures. -Therefore, the approved 0conee ATOG provides five cooldown procedures (CP-101 through CP-105) to accomplish the. transition from ATOG end conditions to conditions for normal plant proce--
dures. In addition to providing steps to accomplish an orderly transition, these Oconee ATOG procedural guidelines.(CP-101 through CP-105) also are subject to the overriding specific rules, System Auxiliary Diagrams (SADs), and subcooling/ inadequate core cooling (ICC) checks which apply to other ATOG guide-lines. Since.CP-102 is actually a " transition"- '
guideline as opposed to a " normal condition cooldown" guideline, it is not clear that all the transitional checks and' actions provided by Oconee ATOG CP-102 can be achieved by the. referenced normal cooldown proce-dure. The: licensee should verify that the transition of conditions is achieved in the. plant-specific guidelines and procedures for Davis-Besse. Also, since the approved Oconee ATOG transition is performed subject to the protective checks and provisions of the specific rules, SADS, and subcooling/ICC verifica-tions, the licensee should provide confirmation that all the precautions of CP-102 are provided by the Davis-Besse guidelines and procedures."
2.1.1 RESPONSE
The transitional checks and actions provid-ed by Oconee ATOG CP-102' address the following items:
(1) Starting Reactor Coolant Pumps (RCPs)
(2) Routing to CP-103 if a Small Break Loss of Coolant Accident (SBLOCA) has occurred (3) Preparing for cooldown with a dry Steam Generator (SG)
Transition of conditions is achieved in the DB ATOG. -
and the Davis-Besse procedures.
Item one (1) above is adequately covered with appro-priate precautions in PP 1102.03, Trip Recovery and PP 1102.10, Plant Shutdown and Cooldown.
Item two (2) above is adequately covered by routing within EP 1202.01. If a SBLOCA has occurred, the operator *is routed to EP 1202.01, Section 11, (equiva-lent to ATOG CP-103) from one of the following sec-tions of EP 1202.01:
- Section 5, Lack of Adequate Subcooling Margin E_________ -_z
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- Section 6, Lack of Heat Transfer
- Section 9, Inadequate Core Cooling
- Section 10,-A Large LOCA has occurred and the.
Core Flood Tanks are Emptying
- Section 12, Transient' Termination Following an.
Occurrence That Leaves the RCS.Being Cooled by' HU/HPI Cooling. .
Exiting from EP 1202.01 and entry into PP 1102.03, Trip Recovery or PP 1102.10, Plant Shutdown and Cooldown is made when the plant is in a stable,
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j subcooled condition with no major primary or secondary
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boundary failures. If plant conditions change, as l directed by EP. 1202.01, the operator is to' implement EP 1202.01, at which time all over-riding Specific
~ Rules, SADS, and subcooling/ICC verification's are-in effect. ,
Item (3) above is adequately covered with appropriate precautions in PP 1102.10, Plant Shutdown and Cooldown.
, 2.1.2 SER CONCERN: "In Davis-Besse Guideline CP-104 (Tran- f sient Termination Following an Occurrence that Leaves the RCS Being Cooled by HPI Cooling), both core exit l thermocouples and hot leg RTD's are specified to be l consulted for lack of subcooling as the criterion for ensuring maximum HPI flow. The analogous step in Oconee ATOG consults only core exit thermocouples.
While the staff concurs with the intent of this-change, the wording in the Davis-Besse-guideline should be clarified. .It is the staff's belief that the present wording could be misinterpreted by the operator to mean check either the core exit thermocouples or hot leg RTDs (but not both) to verify subcooling.
The actual intent of the instruction is to have the operator check both the core exit thermocouples and the hot leg RTDs to verify subcooling and, if either one of-these indicators shows inadequate subcooling, then maximum HPI flow should be ensured."
2.1.2 RESPONSE
When using hot leg RTDs as an indication of Loss of Subcooling Margin, the corresponding loop must have loop flow (either forced or natural circulation).
As soon as flow ceases, the hot leg RTDs will not provide an accurate indication-of core temperatures.
The incore thermocouples (T/Cs) are the only valid method of core temperature measurement without RCS circulation and should be used as'the' main indication-1
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when:subcooling margin (SCM)'does not exist (i.e.
saturated' conditions). .As soon as SCM-is lost, the incore T/Cs'should be'used,for determining the Reactor
. Core temperature.' Therefore the: operator .should not i rely.on hot leg RTDs, as a nole source for determining maximum HPI. flow requirement, unless RCS, flow exists.
-Currently, EP11202.01, Section 12,_ directs'the operator-to control MU/HPI using' Specific Rules 1 and 2. ~These rules require maximum MU/HPI during loss of subcooling margin. However, EP 1202.01, will be upgraded to include enhanced. instructions to operators on the use of hot leg RTDs and incore T/Cs when determining subcooling margin. (Reference TBD Chapters IV.B, IV.D, and V.A).
The wording in Davis-Besse Guideline CP-104 will not be misinterpreted by operators since the cperators do not use the guideline in the Control Room. Also, this a wording does not appear in EP 1202.01 (which is the-document approved for use by operators).
2.1.3 SER CONCERN: "The licensee's discussion states that,-
in CP-104, Davis-Besse_ step 9.0 combines the functions of Oconee steps 10.0 and 11.0. In substep 9.1, Davis-Besse guidelines call for verification of natural circulation using incore thermocouple tempera-tures (as does Oconee in theLcorresponding verifica-tion); however, Davis-Besse deletes use .of hot ' leg
-temperature (T hot) monitors. This-deletion was not identified as a deviation in the Davis-Besse submittal and should be justified."
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2.1.3 RESPONSE
Davis-Besse Guideline'CP-104 conservatively uses incore T/Cs to verify natural circulation. When the RCS is subcooled, incore T/Cs or hot leg RTDs can provide a good indication of natural circulation. If the RCS is saturated,-incore T/Cs'should be the.
primary indication used to verify natural. circulation.
However, EP 1202.01 will be upgraded to include enhanced instructions to operators on the use of hot leg and cold leg temperature _ indication and incore T/Cs for the determination of natural circulation 4
(reference section III.G and IV.D of the TBD).
2.1.4 SER CONCERN: "The Davis-Besse Specific Rule 2 -("KPI Control" - also Specific Rule 2-in Oconee ATOG).has-been restructured to separate HPI termination and HPI throttling criteria. The HPI throttling criteria do-
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not include RCS. level / inventory or Pressurizer. level checks, as does the approved Oconee ATOG. Since the i- licensee's deviations' document does'not address this difference, TED should clarify and justify the impact of this change to the HPI Control Specific Rule 2."
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2.1.4 RESPONSE
Use-of Pressurizer level and pressure / temper-ature relationrhip was inadvertently: deleted from the Davis-Besse'ATOS, Specific Rule 2, HPI and MU throt-:
tling guidelines. . However, Specific Rule 2 of EP 1202.01 (approved for use by operators) does'contain'the
. required information,regarding the throttling of NU~-
and'HPI.
2.1.5 SER CONCERN: "The licensee's discussion indicates' that for a SGTR event (ATOG,.Section III-D), the Davis-Besse emergency procedures direct that once the' -
reactor coolant system (RCS) has been cooled down to 500*F and depressurized to 1000 psig, the damaged steam generator will be isolated. Since the' licensee has determined that Davis-Besse steam' lines can. i withstand loads after being filled with water (in.
non-seismic situations), the damaged steam generator will not be subsequently _ steamed for steam generator inventory control or to maintain natural. circulation, as in the approved Oconee ATOG. Since this change is a deviation from the referenced.0conee ATOG, it should be justified considering potential complications which may result. Examples of complications which the licensee should address include:
(a) waterhammer effects-(if any) in overfilling steam generators into steamlines, (b) inability to cool:an isolated steam generator (voiding in " candy cane",
etc.), and (c) potential malfunctions (such as spuri-ous feedwater initiation, etc.).which might repressurize the isolated (and water-solid) steam generator / steam- !
line above its safety valve setpoint."
2.1.5 RESPONSE
The Oconee ATOG treatment of a SGTR' differs from the Davis-Besse Luergency Procedure, EP 1202.01,.
methods after the plant has cooled down to.500*F and-1000 psig. At this point in the Oconee ATOG, if the non-tube ruptured SG can be-steamed for continued plant cooldown, the tube ruptured SG is only steamed
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as required to keep the-water level from increasing above 95% on the Operate hange instrumentation. .If the non-tube ruptured SG cannot be steamed for. contin-ued plant cooldown, the cooldown is continued on the tube' ruptured SG. :The Davis-Besse EP 1202.01 method would isolate the Main Steam Line Isolation Valve on-the tube ruptured SG and allow:it to fill the SG and the Main Steam line up to-the Main Steam Isolation Valve.' The Davis-Besse method is included within the scope of the TBD Chapter III.E.
The advantages and disadvantages of each of the above methods is listed in the TBD, Chapter III.E. The Davis-Besse method was selected, as the preferred-
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- method, since'the Davis-Besse steam-lines can h'andle the weight of the; water. Early isolation of the tube
- ruptured SG can result in lower offsite radiation releases'and lower secondary side radioactive contamination.
. Water hammer,.resulting from the sudden. stoppage of moving. fluid, will be negligible when the SG is being filled by the primary to secondary tube leakage. (even if multiple tube failures exist). .This is due to the relatively low velocity of the fluid entering the SG or steam line. Condensation-induced water hammer, resulting'from cold water / piping coming in contact-with steam / hot fluid,'will be virtually non-existent.
The temperature of the water entering the steam lines will be nearly the same as the saturation temperature of the steam in the steam lines and the SG.
Single loop forced flow cooldowns (or single loop natural. circulation cooldowns) require special opera-tor care: to prevent reactor vessel head or idle loop void formations; to ensure idle SG shell cooling; and to prevent exceeding tube to shell delta T.limita-tions. The Plant Shutdown and Cooldown procedure, (PP 1102.10), which is referenced by EP 1202.01, provides operators the necessary~ instructions for off-normal cooldown methods.
Pressurizing a water solid SG, above the maximum safety valve setpoints, can only occur with failure of several Main Steam lLine Safety. Valves..to open' concur-rent with: turbine driven feedpump(s) speed control failure; SG level control system failure; or inadver-tent opening of feedwater. control valves. The proba-bility.of these events occurring is considered extremely unlikely. The water relief capacity of the Main Steam Line Safety Valves on one SG is sufficient' to handle the maximum flow from a Main Feedwater Pump or the steam or motor driven auxiliary feedwater pumps.
Another complication includes the situation where the operators cannot steam the non-tube ruptured SG after-the tube ruptured SG is isolated and thus' unavailable for cooling (i.e. steam lines filled with water). The alternate cooldown method would be MU/HPI cooling as discussed in our November 30, 1984 letter (Serial No. 1106). The initiation of MU/HPI cooling (feed and bleed) may be avoided by keeping the' isolated tube
s 7-ruptured SG level,below the main steam lines (and hence. ready for cooldown if called upon). . The use of
-SG drainsLand Tube Rupture Alternate Control Criteria (TRACC), as illustrated in TBD Chapter III.E, is being evaluated for possible incorporation into EP 1202.01.
- 2.1.~ 6 SER CONCERN: "The Davis-Besse guideline (CP-101) for cooldown following a large break. loss-of-coolant accident (LOCA) refers to plant procedures for.chemis-try control to address.the ECCS concern of boron precipitation during.long-term cooling. Oconee ATOG addresses.this item in the guideline by a realignment ,
of the ECCS. It is not clear that Davis-Besse plant procedures treat'the boron precipitation ECCS concern in a manner consistent with ECCS requirements. The-licensee should describe how ECCS qualified methods of addressing ECCS long-Term cooling boron precipitation are.available to the operator when using the Davis-Besse -
guidelines."
2.1.6 RESPONSE
Operators at Davis-Besse do not use the-guideline (CP-101) in the Control Room. Operators use the approved Emergency Procedure developed from the' guideline. The methods of addressing ECCS long-term cooling boron precipitation are available to the operator when using the approved Emergency Procedure.
2.1.7 SER CONCERN: " Davis-Besse guidelines call for entry '
into the Lack of Heat Transfer guideline section (III-B) when it cannot be confirmed that " adequate primary to secondary heat transfer exists" and into the Excessive Heat Transfer section (III-C) when it-cannot be confirmed that " primary to secondary heat transfer is not excessive." The Davis-Besse guide-lines do not specify criteria to assist the operator in making the determination whether primary-to-secondary heat transfer is " adequate," "not adequate," "exces-sive," or "not excessive." The licensee should ,
clarify the entry interface for these' guideline sections by specifying definitive criteria for making.
entry decisions. The licensee should also determine if there are other situations in the Davis-Besse guidelines where section entry criteria are not; definitive."
2.1.7 RESPONSE
Guidelines are not used by operators to assist them in identifying upsets in heat transfer.
Proper criteria to assist operators in making deci-sions to enter the Lack of Heat Transfer Section and Excessive Heat Transfer Section appear in the approved -
plant Emergency Procedure, EP 1202.01. Entry criteria for all sections of EP 1202.01 are definitive.
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-2.1.8' SER CONCERNi " Supplement 1;of'NUREG-0737 specifically calls for the identification of "information and control requirements" as a part.of the reanalysis of transients and accidents. .The need for such analysis is to ensure that.the. parameters as well as instru-mentation and controls ~ called out in the E0Ps, and available in the' control room for emergency-opera-tions, are based on operator information 'and control requirements.(derived from the functions and systems ,
as. defined by the ATOG) rather than on what-is already available in the control. room. On November 15, 1984, a meeting was held with' representatives of the B&W Owners Group Operator Support Subcommittee to discuss the task analysisL requirements of Supplement 1 to NUREG-0737. The meeting determined that because the-ATOG, in many cases, does not explicitly identify information and control needs beyond the safety.
function level, which are necessary for preparing E0Ps:
and determining the adequacy of existing instruments and controls,'further analysis and documentation are .
required. .Therefore, each licensee and' applicant must describe the' method (s) used to determine: (1)linfor-mation and control needs of operators and (2) the l adequacy of the control room instrumentation and control (i.e., if the control room instrumentation and controls meet the information-and control needs of the operators). The licensee eny' describe its function.
and task analysis as part of the P-STG or validation /
verification portion of the PGP, or in the Detailed Control Room Design Review (DCRDR) Summary Report with appropriate cross-referencing."
2.1.8 RESPONSE
The method (s) used to determine: (1) information and control needs of operators; and, (2) .
the adequacy of the Control Room instrumentation and controls; are described in Section 5.0 of the. Detailed Control Room Design Review (DCRDR) Summary Report submitted June 29, 1984 (Serial No. 1057). NRC concerns outlined in the July 2, 1985 DCRDR audit report are being addressed by.the plan described in Appendix C.5.1 of the Davis-Besse Course of Action submitted September 10, 1985 (Serial No. 1182.and Serial No. 1208).
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9 2.2 Plant-Specific Writern Guide 2.2.1 SER CONCERN: "Although the revision number is includ-ed in the procedure number, the writer's guide does -
not specify how the revision date will be recorded.
Section 4.3 mentions a record of revisions section; however, no details are included. Specifications for including the revision date should be added to the writer's guide."
2.2.1 RESPONSE
Sections 1.4.3 and 2.3.3 of the Davis-Besse Procedure Writers Manual, Volume IV, Operations Procedures Guidelines, Enclosure 1 (hereafter called Writer's Guide), provides instructions for the record-ing of the most recent revision date.
2.2.2 SER CONCERN: "The writer's guide does not clearly indicate what the organization of the E0Ps will be.
While a title page, entry conditions, automatic actions, immediate operator actions, supplementary operator actions, and attachments are discussed at various places in the writer's guide -(pages 1, 2,15, 16, and 21), it is never clearly stated in what order they are to be placed in the E0Ps."
2.2.2 RESPONSE
Section 2.3.1 of the Writer's Guide clearly indicates the organizational structure.
2.2.3 SER CONCERN: "The writer's guide does not clearly indicate what E0P identifying information is to be placed on the title page and what identifying informa-tion is to be placed on each of the pages in the E0P.
Guidance for the format of this information, to include a sample cover page should also be provided.
See NUREG-0899, Subsection 5.5.1, for additional guidance."
2.2.3 RESPONSE
Section 2.3.3 and 3.1 of the Writer's Guide provides instructions on the information to be placed on the title page and each page of text. Sample pages are provided for each.
2.2.4 SER CONCERN: " Instructions should be written for various types of action steps that an operator may take to cope with different plant situations. Thus, in addition to the discussion of nonsequential or recurrent steps, time-dependent steps, and equally preferable steps in Section 9.1 (pages 4 and 5), the writer's guide should address the definition and formatting for use of the following types of ~ action steps:
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- a. . Steps that are used to verify whether the objec-
. tives of a task or sequence of actions has been -
achieved.
- b. ' Steps performed concurrently with other steps."-
2.2.4 RESPONSE
Sections 3.3.1 and 3.3.6 of the Writer's-Guide address verification and concurrent steps.
2.2.5 SER CONCERN: "The writer's guide states in:Section 7 (page 18) that special checkoff provisions are not required as a placekeeping aid and that an operator can always mark the margin or x-over step numbers if he' feels the need. However, placekeeping aids can assist the operators in keeping track of their.posi-tion within a procedure. They are of particular importance when performing concurrent steps of proce -
dures and in situations where the user's attention is diverted. Thus, the writer's guide should specify the-use of some type of placekeeping aid."
2.2.5 RESPONSE
Special checkoff provisions have not been provided in the E0Ps. If plant conditions are not maintained or if plant conditions change, routing _
within the.EOP can cause operators to-reperform steps-or sections of the E0P. Reperforming a step or section that has been previously checked off may cause inad-vertent omission of required actions. As a result, special checkoff provisio'sn are not considered appropriate for the emergency procedures.
2.2.6 SER CONCERN: " Emphasis techniques are discussed in Section 9.8 (page 12) of the writer's guide. The guidance given for capitalization appears to be more applicable to normal operating procedures than it does to E0Ps. For instance, it is not clear what consti-tutes a section heading vs. a subsection heading in an E0P. Additionally, the examples given in Appendix A show capitalization of column headings such as ACTIONS AND DETAILS that are not discussed in Section 9.8 or in Appendix A. Guidance for using emphasis in E0Ps should be more clearly defined."
2.2.6 RESPONSE
Sections 3.6 and 4.5 of the Writer's Guide provide instructions for emphasis techniques and capitalization.
2.2.7 SER CONCERN: "The writer's guide states in Section 4 of Appendix A (page 16)-that emergency and abnormal procedures can use a standard single column procedure.
format or a two column format. The benefits of both formats are presented. In order to produce consistent j
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. procedures-from moreithan one writer, a-single format (single or dual _ column) for presenting .the action steps'should be specified in the writer's guide for use on'all E0Ps."
2.2.7 RESPONSE
. As explained in the Writer's Guide, there are benefits associated with each type of. column j format _(i.e.-dual or singleLcolumn). Selection of single' column or dual column format for E0P(s) at i
Davis-Besse is based on how accurately and quickly information can be located and acted upon by opera
. tors. Procedure writers at Davis-Besse will not 4 arbitrarily change from single to dual column. format-and vice versa unless the benefits gained allows operators to comprehend essential information more. .
efficiently and effectively.
2.2.8 SER CONCERN: "The relationship of how the E0Ps are written with regard to control room staffing consider-ations.is very important. Thus, the writer's guide should' address the following issues:
- a. E0Pc should be structured so that_they can be executed by the minimum shift staffing as re-quired by the Technical Specification.
? b. The struccure of the E0Ps should be consistent with tha roles and responsibilities of the operators.
- c. Action steps should be structured to minimize the physical conflicts of personnel moving around the control room while carrying out procedural steps.
- d. Action steps should be structured to avoid _their unintentional duplication by different operators."
2.2.8 RESPONSE
The EP Verification and Validation Program
- ~ (Enclosure 2), as referenced by Section 1.5 of the Writer's Guide, addresses Control Room staffing considerations.
2.2.9 SER CONCERN: "The Writer's guide states'in Section 4.7 (page 2) that materials that are essential to carrying out the E0P but are not available in the control room should be appended to the E0P. These appended materi-als include tables, figures, and/or flowcharts. For consistency among E0Ps, the writer's guide should specify detailed guidance for the appended materials and the order in which these materials-should be-placed in the E0Ps."
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e 12 2.'2.9- RESPONSE: Sections :2.3.21, 2.3.22,~ 2.3.23 and 3.8 of the writer's guide provide guidance. for appended
. materials.
2.2.10 SER CONCERN: "It is important that an-operator be able to quickly access the relevant E0Ps or portions of E0Ps. The writer's guide'should address the availability and accessibility of the E0Ps and their various parts and sections. See NUREG-0899, Section 6.1, for additional guidancel Guidance should be provided to ensur6 that photocopies of E0Ps should be complete (contain all of the infor -
mation from the master copy of the EOP).and legible."
2.2.10 RESPONSE: Adequate numbers of controlled copies of the E0Ps are'available to operators in the Control Room. Controlled copies are also available in other
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locations, such as the Technical Support Center. All copies have been placed in distinctive, color-coded (orange / white) binders. This allow operators to easily distinguish and quickly access the EOPs.
Davis-Besse procedures control the distribution,
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legibility, completeness and copy quality of the E0Ps.
These procedures are IMP-102, Document Distribution Control and IMP-117, Distribution Control of Station Procedures / Manual.
2.2.11 SER CONCERN: " Conditional statements and logic statements will be used in the E0Ps, and some guidance for their use has been provided in Subsection 9.1.2 (page 4) and Section 11 of Appendix A (Page 19) of the Writer's Guide. Since conditional and logic state-ments have the possibility of being confusing given the conditions under which
- hey will be used, a consistent format'should be used fot all conditional and logic statements. In idition to-the guidance provided, this section of te writer's-guide should be expanded to include the fot st that is to be used for presenting the statements. The logic term THEN in Example 2 is underlined bat is not capitalized,.as specified in Section 11 of Appendix A (page 19), and should be corrected."
2.2.11 RESPONSES: Section 3.2.3 of the Writer's Guide provides guidance for conditional and logic statements.
2.2.12 SER CONCERN: . " Abbreviations, acronyms, and symbols are discussed in Section 9.6 (page 11 and 12) of the writer's guide. It is stated that an updated list of I
13-abbreviations, acronyms, and symbola.will be.available after the control room indications and controls'are re-labeled. When the list'is available, it should be added to the writer's guide."
2.2.12 RESPONSE: Plant Abbreviations and Acronyms are included in the~ Writer's Guide.
2.2.13 SER CONCERN: "The use of " Plant Instrumentation.
Values" in precedures is discussed in Section 9.7 (page 12) and Sections 12 and 13 of Appendix A (Pages 19 & 20) of the writer's guide. These sections should be expanded to give similar guidance for the use~of
" numerals" in EOPs. Guidance should address'the type oof numerals to be used and the use of decimals."
2.2.13 -RESPONSE: Sections 4.7 and 4'.8 of the Writers Guide provide instructions for the use of units, numerals and tolerances.
2.2.14 SER CONCERN: "The organization of the writer's guide-is confusing. .The instructiors for preparation of E0Ps are located in Appendix 2, and Appendix A to-Appendix 2. The E0P writers need clear and coordi-nated guidance in order.to prepare consistent E0Ps.
The PGP should be modified to include either a de-tailed table of contents or a checklist that referenc-es where in the administrative procedure or the appendix the writer can locate the information they need."
2.2.14 RESPONSE: The Writer's Guide has been totally reor-ganized to provide clear, concise guidance to proce-dure writers.
2.2.15 SER CONCERN: "The following disclaimer is:given in-the introduction to Appendix A to the writer's guide:
"The guidelines within this appendix should be used whenever possible, but strict adherence to these principles is neither required nor desired, since good procedure design.is a matter of-considerable compromise." ,
This disclaimer indicates doubt on the.part of TED concerning the adequacy of the guidance contained in the Davis-Besse writer's guide. If the licensee finds that guidance which they have provided to be unwork-able or incorrect, the writer's guide should be revised accordingly. This disclaimer should be removed from the PGP and replaced with a stated commitment.to use and adhere.to the standards present-ed in the writer's guide in the development of E0Ps and in subsequent revisions."
L______________ -
14 2.2.15 RESPONSE: The " disclaimer" has been removed from the Writer's Guide.
2.2.16 SER CONCERN: "In order to ensure consistency and'to-enhance the readability of the E0Ps, typing instruc-tions regarding'page' layout information in Section 9.10 (pages 13 andl14)aof the writer's guide should also include line spacing'information."
2.2.16 RESPONSE: The Davis-Besse Word Processing Department has developed typing instruction for their use in procedure preparation.
'i 15 2.3 Verification / Validation Program 2.3.1 'SER CONCERN: "In.Section 3.0.of the PGP submitted, TED states that.an independent review of the E0Ps will be undertaken to compare the E0Pa with:the ATOG. As part of this discussion,'the PGP.should describe.the methodology that will be used to conduct.this review and who will be conducting the review. An explanation of how this review will result in assurance that the-E0Ps are technically accurate'also should be included.
The description of the additional review to be con-ducted by TED engineering persouael (Section 3.0 of the PGP submittal) should. indicate the purpose for this review and explain how it differs from and/or relates to the " independent review" which compares the E0Ps with the ATOG."
2.3.1 RESPONSE
During the 1984 Verification and Validation Program, several reviews of the Davis-Besse Emergency Procedure, EP 1202.01, occurred. These reviews included an EP versus ATOG review, Training reviews, Simulator Validation reviews, and a Safety Review Board (SRB) review. Descriptions of each are listed in a. through d. below.
Since the initial verification and validation exercis-es, the B&W generated E0P Technical Basis Document (No. 74-1152414) has been issued. In addition, the Writer's Guide has been revised. As.a result, addi-tional reviews will be conducted. A description of 1 these reviews is presented in e. and f. below. p
- a. EP VS. ATOG REVIEW -'This review was condu'cted by Messrs. Sushil Jain and Mike Derivan. Mr. Jain, who has a BSME and MS in Nuclear Engineering, is currently serving.as Nuclear Engineering Director and Independent Safety Engineering Group Direc-tor. He has over nine years experience at Davis-Besse.
Mr. Jain's-review verified that the Davis-Besse EP 1202.01 was consistent with the underlying philosophies of the ATOG Program. The review was conducted by comparing the B&W generated Davis-Besse ATOG, section by section, with EP 1202.01.
Mr. Jain concluded that EP 1202.01 contained numerous enhancements from the DB ATOG. He. felt the enhancements supplemented the specificity, continuity and completeness of the procedure.
The enhancements also related to restructuring, '
reformatting and improved nomenclature and
16 supporting information. Also'provided in Mr.
Jain's review was an engineering justification for difference,between the ATOG and the EP 1202.01 approach to mitigation strategies.
Mr. Derivan (resume attached to original PGP submittal), after preparation of the draft EP=1202.01, documented,a step by step review /compar-ison of the Davis-Besse ATOG with EP 1202.01.
.This post preparation review verified that procedural integrity ~was maintained between ATOG and Davis-Besse EOP(s),
- b. TRAINING REVIEWS - During E0P simulator and classroom training, numerous documented comments were received from licensed operators and engi-neers. These reviews were aimed at providing input to the procedure preparer concerning procedure usability. Usability was defined as whether the procedure could be easily understood, there was correspondence between the procedure and plant hardware, the language and level of information was compatible with the experience of the user and the procedure routing was correct for mitigating transients.
- c. SINULATOR VALIDATION REVIEWS - During E0P simula-tor validation, numerous documented review comments were generated by Mr. Derivan (procedure preparer), Mr. Spalti (B&W subject matter expert) and Mr. Michaelis (Davis-Besse Shift Supervisor).
- d. SRB REVIEW - A special Station Review Board meeting, to review the E0Ps, was held in February 1984.
This review evaluated the following:
- Whether the level of detail presented on the E0P was consistent with Operator training.
and normal operational practices.
- If the E0Ps was in compliance with good human factors principles.
- Whether the E0P reflected compliance with the Writer's Guide.
The SRB review team included the following individuals:
- S. M. Quennoz, Plant Manager
- D. A. Huffman, Nuclear Reliability Manager
- D. L. Miller, Operations Superintendent
17
- J. R. Lingenfelter, Technical Engineer
- M. J. Derivan, Procedure Preparer
- - J. M. Michaelis, Shift Supervisor
- e. E0P vs._TBD - This review will be conducted by an individual .with experience as a Senior Reactor Operator at Davis-Besse and will compare the emergency procedure with the requirements of the B&W generated TBD. This review is expected to be completed by December 31, 1987.
- f. E0P vs. Writer's Guide - This review will be conducted by an individual familiar with the revised Writer's Guide and will be completed by December 31, 1987.
2.3.2 SER CONCERN: "In Section 4.0 of the submittal, "other observers" shculd be identified. A multi-disciplinary team (plant operators, procedure writers, subject matter experts, human factors specialists) should be involved in the validation program."
2.3.2 RESPONSE
Validation exercises were observed by Mr.
Derivan (procedure writer) and Ross E. Spalti (B&W subject matter expert). Human Factors personnel witnessed E0P walkthroughs on the Davis-Besse Control Room mockup as a part of the DCRDR. This activity was described in the DCRDR Summary Report submitted June 29, 1984 (Serial No. 1057).
2.3.3 SER CONCERN: "Section 4.0 of the submittal should describe the roles played by the participants (i.e.,
how will operators, subject matter experts, etc.
participate in the validation process?)"
2.3.3 RESPONSE
During simulator validatien, operators played roles they would normally perform in response to transients. Since Mr. Derivan (procedure writer) was intimately involved in the preparation of EOP(s) and associated source documents, his involvement during the simulator validation was from an objective viewpoint. He did not guide operators through the transients but merely observed their implementation of the E0P(s). Mr. Spalti (B&W subject matter expert) directed the scenarios necessary to validate the E0P(s) and evaluated operator performance.
so 18 2.3.4 SER CONCERN: "The PGP submittal should include:
- a. An indication 'that .the full' complement of E0Ps are exercised, including multiple failures (simultaneous and sequential),
- b. Criteria for selecting scenarios that will be
-used for simulator validation with specific attention to addressing the differences between the simulator and the actual control room.
- c. .The PGP should describe how parts of the E0Ps that cannot be exercised during validation on the generic simulator will be validated."
I 2.3.4 RESPONSE: The full compliment of E0P(s) was exercise'd including multiple failures. _The procedure writing _
j; and training department personnel selected scenarios 4 to ensure complete coverage of procedure routing (within EP 1202.01 and from EP 1202.01 to referenced-
- procedures). 'All sections of EP 1202.01 were validated.
- on the B&W simulator. The validationLof_those hardware
- portions of EP 1202.01 that differ from the simulator (i.e. control room labeling, system nomenclature, switch locations etc.) occurred during walkthroughs on the i Davis-Besse control room mockup or the Davis-Besse j Control Room.
s 1
2.3.5 SER CONCERN: "The validation and verification program should include a description of the plan for correct-ing and revising E0Ps as a result of the validation i and verification process."
2.3.5 RESPONSE
Comments and associated resolutions-result-l ing from the Verification and Validation process were
! documented. The plan for correcting and revising future revisions to the Davis-Besse Emergency proce-dure as a result of the Verification and Validation j- exercises is included in Enclosure 2.
2.3.6 SER CONCERN: "The Validation and Verification program should include a commitment to validate and verify revisions to E0Ps."
2.3.6 RESPONSE
Verification and Validation of revisions to the Davis-Besse Emergency procedure will be accom-
! plished using the guidance provided in Enclosure 2.
i t
4 4
4
19 2.4 ) TRAINING PROGRAM 2.4.1 SER CONCERN:
- 1. "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 regarding the simulator training:
- 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 and in parts of the E0Ps that cannot be run on the simulator,
- b. Indicate that operators will be trained to use the E0Ps as a team and that each opera-tor is trained in the role that he would be expected to take in case of an actual emergency.
- c. Indicate the use of a wide variety of scenarios including multiple (simultaneous and sequential) to fully exercise the E0Ps '
on the simulator and thus expose the opera-tors to a wide variety of E0P uses.
- d. Indicate that all E0Ps will:be exercised by all operators.
- 2. The PGP states that walkthroughs will be used for operator training. The training program descrip-tion should be expanded to address the following items regarding the walkthrough training:
- a. Discuss the extent to which the E0Ps will be covered by all operators, particularly if walkthroughs will be used to train aspects of E0Ps not taught in the generic simulator.
- b. Indicate planned operator roles during walkthroughs.
- 3. The PGP should state that the operators' knowl-edge and performance of E0Ps will be evaluated after training and that, when appropriate, follow-up training will be conducted.
- 4. The training program should include a commitment to train all operators on all E0Ps prior to E0P implementation in the control room."
- w. __ - - . . _ _ _ _ _ - - - - _ _ _ _ _ _ . _ _ _ _ _ _ _ - . - - - - _ _ - _ _ - _ _ _ _ _ _ _ . _ - . - _ - . _ _ - _ _ . _ - _ - _ . - _ - - - - - - _ _ . - - . _ _ _ . _ - . _ . _ _ - - - - . _ _ _ _ _ _ _ _ - _ . - _ _ _ _ - . . _ . _ -
IT ,
20
) 2.4.1 RESPONSE: Training for all licensed operators on EP 1202.01 and supporting procedures was conducted in a four phase program. A description of this program follows:
Phase 1: Two hour introductory course giving opera-tors a general overview of the ATOG approach to handling transients. This course was given by Davis-Besse Training Department.
Phase 2: Forty hours of classroom instruction (given by B&W) to review the following:
- a. Lessons learned from TMI
- b. Pressure-Temperature relationships and associated heat transfer concepts
- c. Natural circulation (subcooled, satu-rated and condenser cooling)
- d. Overcooling and undercooling transients
- e. Multiple failures during transients
- f. LOCAs (various sizes)
- g. SGTR
- h. Loss of offsite power i Overview of new procedures J. Work through various scenarios with new procedures Phase 3: Forty hour course at the B&W Simulator
- a. Twenty hours classroom training related to E0Ps
- b. Twenty hours simulator training using new E0Ps Phase 4: Sixteen hour course at Davis-Besse conducted by Davis-Besse Training Department
- a. Eight hours classroom training on EP 1202.01 and supporting procedures.
- b. Eight hours walkthrough training on the control room mockup supported by computer generated P-T plots for numerous scenarios.
The Emergency Procedure writer and the Training Departme'.t selected a wide variety of scenarios to be used in classroom, simulator and walkthrough training.
This ensured all sections of the E0P would be exer-cised by all licensed operators. It also ensured a proper understanding of procedure routing both inter-nal to EP 1202.01 and external to interfacing proce-dures. From this exercise of EP 1202.01, numerous
21
.) comraents were generated by operators. These comments resulted in further procedure enhancements.
Phase 3 training was conducted at the B&W simulator.
Operators quickly adapted to hardware differences between the B&W simulator and the Davis-Besse Plant.
This was accomplished either by instructor / student discussion or previous experience on the simulator.
Although the B&W simulator is not identical to the Davis-Besse control room, simulator response to transients is well modeled. Therefore the simulator was successfully used to cover all transients neces-sary to give operators a thorough understanding of Davis-Besse E0Ps. Repetition of some transients with varying severity was used along with multiple failure scenarios. This ensured proper coverage of E0P routing at the simulator.
Phase 4 walkthrough of transients using E0Ps at the Davis-Besse control room mockup provided the necessary transitional training from the B&W generic simulator to the Davis-Besse Plant.
During Phase 3 and 4 training operators were trained as a team. Each operator played the role that he is expected to take during actual transients at Davis-Besse.
During Phase 3 simulator training, the Davis-Besse Training Department selected one management SRO to act as a lead Training Department representative for each of the groups sent to the simulator. A directive was issued to these management SR0s to establish objec-tives for E0P training. This directive established the requirement of the team concept for E0P implemen-tation, stressed the importance of proper communica-tions in the Control Room and provided other guidelines for the conduct of E0P training.
Operator knowledge and level of performance using E0Ps was determined to be satisfactory based on written exam scores, performance during simulator training, and performance during mockup walk-throughs. As a result of operator comments during Phase 3 simulator training and corresponding procedural enhancements, follow-up training was provided during Phase 4 walk-through training.
The four (4) phase training program described above was completed prior to implementation of E0P(s) at Davis-Besse. Licensed operators will be trained on
[ .i 22 l
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.). future revisions of EP 1202.01 prior to implementation i or prior to returning to Control Room duties after absences. Minor editorial procedure revisions will be exempt from this training requirement.
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