ML20213H061

Forwards Response to Draft Safety Evaluation Re Procedures Generation Package & Revs 1 & 2 to Emergency Plan Implementing Procedures FNP-0-AP-74, Emergency Response Procedures Verification

ML20213H061
Person / Time
Site:	Farley
Issue date:	05/12/1987
From:	Mcdonald R ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20213H063	List: ML20213H061 ML20213H072 ML20213H101
References
NUDOCS 8705190125
Download: ML20213H061 (12)

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Allbama Power Company 600 North 18th Strsst .

Post Office Box 2641 '

Birmingham, Alabama 35291-0400 -

Telephone 205 250-1835 rio ce P sident the southem electrc sys:em May 12, 1987 10CFRSO.90 Docket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commis:,f on ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

Joseph M. Farley Nuclear Plant - Units 1 and 2 Draft Safety Evaluation of Procedures Generation Package (PGP)

This letter responds to the draft safety evaluation of the PGP as forwarded to Alabama Power Company by your letter dated August 13, 1986.

Alabama Power Company submitted the PGP to the NRC on July 29, 1983. The Farley Nuclear Plant emergency procedures were upgraded based on Revision 1 of the Westinghouse Owners Group Emergency Response Guidelines in July 1984.

Operators were trained prior to implementation of the new guidelines and have since been trained annually utilizing the Farley Nuclear Plant simulator.

Alabama Power Company be'q%2s the Farley Nuclear Plant emergency response capability has been enhanced by the upgraded emergency procedures.

Attachment 1 provides a point-by-point response to all issues identified in the draft safety evaluation. For some issues the current practices are considered adequate, but for others the PGP will be modified. Attachments 2 and 3 are copies of the Farley Nuclear Plant Emergency Response Procedures

' Verification and Validation procedures which were finalized af ter the PGP was submitted.

If there are any questions, please advise.

Respectfully s ted,

/

__ '_ t/1 R. P. Mcdonald RPM / REM: dst-D-T.S.7 Attachments -

8 cc: See next page $ f F l

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U. S. Nuclear Regulatory Comission l, May 12, 1987

1. 9 cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford

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e ATTACHMENT 1 Plant-Specific Technical Guidelines

1. The discussion of the plant-specific technical guidelines needs to identify deviations and additions with respect to the generic guidelines and to identify their safety significance. More specifically, additional information is needed on:

A. Those plant-specific items not covered by the generic guidelines, e.g.,

additional steps, instrumentation values, plant conditions, and equipment identification.

B. Those items which are deviations from the generic guidelines also needed to be identified and the technical reason for the deviation included.

C. Additions to and deviations from the generic guidelines need to be analyzed to determine their safety significance. The PGP discussion should include the analysis or technical justification of the safety significance for the deviation.

APCo Response:

The ERG Review / Disposition sheet and the Step Change Documentation sheet, included in the original PGP submittal, provide an adequate mechanism for documenting deviations from the generic guidelines. Use of the ERG Review / Disposition and the Step Change Documentation sheets provides a step-by-step documentation of changes made to the generic guidelines including step additions, step deletions, and step alterations / deviations. A reference to the plant-specific setpoint document will be included in the PGP.

In converting from the generic guidelines, which are approved for implementation by the NRC, to the plant-specific procedures, the Westinghouse Owners Group (WOG) background information is used. Plant-specific items not covered by the generic guidelines are identified utilizing Emergency Response Procedures (ERP) source documents as described in Section 2.2.1.1 of the Farley Nuclear Plant PGP. These source documents, including the background documentation, are utilized as described in Section 2.2.1.2 in identifying plant-specific items. Technical justification for deviations is documented as shown on Figure 2 of the Farley Nuclear Plant PGP. The final product of the conversion, the emergency procedures, is reviewed using 10CFR50.59 to determine if an unreviewed safety question is involved. The 10CFR50.59 review process is utilized for evaluating safety related design and procedure changes and is considered adequate for the review of ERPs.

It should also be noted that the NRC conducted a detailed review of the Farley Nuclear Plant emergency operating procedure implementation during Unit 2 startup and observed the Farley Nuclear Plant operators and the use of the procedures at the Zion simulator.

Page 2

2. Control room instrumentation and controls used in operator steps need to be evaluated with respect to their necessity and adequacy. This may be done as a separate effort or as a part of verification / validation of E0Ps.

Additional information is needed in the PGP with regard to:

A. Description of the method used to determine needed control room instrumentation and controls used in operator steps.

B. Description of the method used to determine the adequacy of the present control room instrumentation and controls used in operator steps.

APCo Response:

During the development of the plant-specific emergency procedures that are based on Rev.1 of the WOG generic guidelines, final drafts were walked down in the main control room to ensure that proper instrumentation was available.

During the Control Room Design Review (CRDR), Westinghouse developed a detailed task analysis of the scoped emergency procedures. The detailed analysis was utilized to conduct Engineering Identification and Operator Walk Through phases of the CRDR. These phases identified Human Engineering Discrepancies (HEDs) with current control room instrumentation. Resolution of the identified HEDS will be made as part of the CRDR. A more detailed description of the HEDs is provided in Alabama Power Company's letter to the NRC dated December 29, 1986 .

The PGP will be upgraded to include a process that ensures the adequacy of instrumentation and controls. The process will be similar to the Engineering Idenfification and Operator Walk Through processes of the Alabama Power Company CRDR Task Analysis.

ERPs Writer's Guide

1. The organization of the ERPs is discussed in subsection 4.1 of the Writer's Guide on pages 3-5 of 14 where the guidance is given to organize action steps by their expected sequence of use, and how to organize the initial pages of the document. There should be additional guidance with regard to the separation of the action steps into immediate operator actions (those actions that operators should take immediately to stop the degradation of existing conditions when an emergency is clearly indicated) and subsequent actions (those action steps that operators use to return the plant to normal conditions). (NUREG-0899, Subsection 5.4.6 and 4.5.7)

APCo Response:

Guidance will be incorporated into the Writers Guide for identification of any required immediate operator actions.

Attachm:nt 1 Page 3

2. Page formatting is described on page 13 of 14 in the Writer's Guide and in Figure 6. In addition to the guidance that is provided in these locations, line spacing should be specified to ensure the legibility of the E0Ps.

(NUREG-0899, Subsection 5.5.2)

APCo Response:

Line spacing guidance will be included in the Writer's Guide.

3. The formatting of Notes and Action Steps is described on pages 3 & 4 of 14 (Subsection 4.1.3) . This guidance should be supplemented with the provision that Action Steps should be completed on a single page similar to the requirement for Cautions in Subsection 4.1.6 on page 5 of 14. (NUREG-0899, Subsection 5.5.2)

APCo Response:

In general, Action Steps /Substeps are wholly contained on a single page.

Unfortunately, there are instances in which a single page cannot contain an entire substep. One example is substep 18.2 of the Unit 2 EEP-0, Reactor Trip or Safety Injection. The step states, " Verify two trains of safeguards equipment running" and lists the safeguards equipment to be checked. The list of equipment exceeds the length of one page, but the operator should not have any trouble following the list even though it is on two pages. The page break is located at a reasonable location between two pieces of equipment.

It would be impractical to further subdivide this step into smaller substeps to enable it to fit on a single page. The current step is a reasonable division of the action required. The Writer's Guide will be modified to state that, if possible, each substep will be written on a single page; however, if the substep is over a page in length, the page break should come at a reasonable location, i.e., at the end of a paragraph, between two items in a list. No problems with this issue have been identified during simulator training at Farley Nuclear Plant.

4. The use of referencing and branching is discussed on page 12 of 14 in Subsection 5.6.1. In addition to the information presented, a good example or a description of the method by which procedures, sections or subsections of a procedure will be identified should be provided so that procedure writers will have a standard format for identifying branches or references.

(NUREG-0899, Subsections 5.2.2 and 5.5.7)

l Attachment-1 Page 4 APCo Response:

An example will be included in the Writer's Guide.

5. The variable nature of control rooms, control room events, staff capabilities and turnover in control room shift crews v.ake the following concerns important enough so that they should be addressed in the P-SWG:

A. E0Ps should be structured so that they can be executed by the minimum control room crew as specified in the. Technical Specifications.

(NUREG-0899, Subsection 5.8.1)

B. Action steps should be structured to minimize physical conflicts between personnel. (NUREG-0899, Subsection 5.8.3)

C. Action steps should be sequenced to avoid their unintentional duplication by operators. (NUREG-0899, Subsection 5.8.3)

APCo Response:

The Writer's Guide will be modified to state that ERPs should be written for execution by the minimum control room crew as specified in the Technical Specifications. The ERP verification and validation processes will be modified to check for physical conflicts and unintentional action step duplications. It should be noted that no conflicts were noted during the CRDR task analysis process.

6. Action steps need to be written for a variety of situations. Thus, the plant-specific Writer's Gaide should address the definition and formatting for the following types of action steps:

A. Steps that are used to verify whether the objective of a task of sequence of actions has been achieved. (NUREG-0899, Subsection 0899, Subsection 5.7.2)

B. Steps for which a number of alternative actions are equally acceptable.

(NUREG-0899, Subsection 5.7.4)

C. Steps that must be performed concurrently with other steps (NUREG-0899, Subsection 5.7.7)

APCo Response:

Specific guidance and examples for verification, alternative action, and concurrent action steps will be included in the Writer's Guide.

Attachment 1

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7. Tabbing to facilitate locating various procedures is discussed in Subsection 5.5.4. A similar method should be established to enable quick and easy access to various parts of the procedures. (NUREG-0899, Subsection 5.5.7)

APCo Response:

Based on experience at Farley Nuclear Plant, Alabama Power Company does not believe tabbing is necessary. No changes will be made to the Writer's Guide.

8. All reproductions of ERPs should be of comparable quality to the originals to ensure readability of the procedures. (NUREG-0899, Subsection 6.2.2)

APCo Response:

The ERP Verification Evaluation Criteria Checklist (Attachment 2) verifies the legibility of the procedures. This checklist is included in plant administrative procedures.

9. When changes occur in plant design, Technical Specification, Technical Guidelines, the P-SWGs or plant procedures that will affect the ERPs, the ERPs need to be revised, and the revision process should be subject to the PGP process. A statement of commitment to do this needs to be in the P-SWG.

(NUREG-0899, Subsection 6.4.2)

APCo Response:

FNP-0-AP-8, Design Modification Control, provides detailed direction for the revision of plant procedures, programs, and training based on design changes. In summary, the procedure requires all plant managers to review all design change description summaries and identify all plant procedures, plant programs, and training plans which would require revision. Each manager is responsible for developing the procedure changes related to their areas of control and implementing them on completion of the design change.

FNP-0-AP-4, Control of Plant Documents and Records, directs group managers to review vendor manuals and vendor manual revisions and determine the effects on procedures, programs and activities under their cognizance. Vendor manuals include the plant-specific set point document.

Additionally, FNP-0-AP-1, Development, Review and Approval of Plant Procedures, provides for periodic review of plant procedures to ensure they are current.

FNP-0-AP-74, Development and Maintenance of Emergency Response Procedures, provides guidance for the revision of the ERPs.

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Attachment 1 Page 6 Validation / Verification The initial PGP submittal did not include detailed explanations of the Validation / Verification process. Attachments 2 and 3 are the detailed procedures for the Validation / Verification process currently in use at Farley Nuclear Plant. The responses included below are based on these detailed procedures.

1. The following items should be included in complete validation and verification sections: (NUREG-0899, Subsection 3.3.5)

A. A description of how combination of desk-top reviews, simulator exercises ,

and control room walk-throughs will be used to validate the ERPs.

B. An indication that the full complement of ERPs will be exercised including multiple failure (simultaneous and sequential).

APCo Response:

The ERP Verification and ERP Validation procedures provide for both a desk-top review and simulator exercises during the validation and verification process. Section 5 of Attachment 2 describes the ERP Verification Process. This desk-top process consists of four phases:

preparation, verification, resolution and documentation. ERP verification will confirm the written correctness of the procedures.

The ERP Validation procedure directs that " scenarios which integrate the performance and interaction of the ERPs as a whole should be utilized". It then directs that, as a minimum, the following scenarios should be run:

1. Reactor Trip

2. Loss of Coolant Accident

3. Major Steam Break

4. Steam Generator Tube Rupture

5. Loss of Offsite Power

6. A Jeopardy (red path) challenge to any critical safety function.

A statement will be added stating that multiple failures (simultaneous and sequential) should be used. Currently there are no provisions for a walk-through since the simulator is utilized in the validation process.

2. The validation program should 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. The criteria should ensure that single, sequential, and concurrent failures are included. Then, a review of the capabilities and the limitations of the simulator will identify what can be validated on the

Attachm:nt 1 Page 7 i ' simulator. For the parts of the E0Ps that cannot be validated on the simulator, the criteria for selecting any additional validation that may need to be conducted by a control room walk-through should be described.

APCo Response:

The ERP Validation procedure describes the scenario selection process, states it must be approved by the Operations Manager, and provides a minimum list of emergency conditions. The validation process will be modified to include a consideration of single, sequential and concurrent failures and walk-throughs for ERP validation.

3. The criteria for selection of the ERP team should be identified and their roles and responsibilities should be clearly delineated. The size of the operating crew should be determined by Technical Specifications for minimum staffing.

APCo Response:

The size of the operating crew will be specified as the minimum crew allowed by Technical Specifications. Roles and responsibilities of personnel a performing the verification and validation process are described in section 4.0 of Attachments 2 and 3.

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4. The control room instrumentation and controls referred to in the ERPs need to be evaluated in terms of their adequacy and their correspondence with the actual instrumentation found in the control room, as follows:

A. Tne PGP should include a description of the plan for determining the information; and control needs for the ERPs. (NUREG-0899, Subsection 3.3.1)

B. The PGP should include the plan that will be used to determine whether the actual control room instruments and controls meet the information and control needs. (NUREG-0899, Subsection 3.3.5.1. (d))

APCo Response:

The Farley Nuclear Plant PGP will be modified to ensure that the following information requirements on the following page will be considered when converting from the generic Westinghouse ERGS:

Attachment 1 Page 8 Instrumentation

1. Information characteristic, e.g., less than, equal to, stable, increasing.

2. Value required.

3. Precision required, generally the place value of the least significant digit of the value required.

4. Units required.

Controls

1. Type of control required, e.g., discrete for specific, required positions or continuous for throttling flow.

2. Position required.

The Evaluation Criteria Checklist of the ERP Verification Procedure will be modified to include the following items:

1. Instruments provide information in the required units.

2. The required information can be read without interpolation, i.e.,

gradational marks provide the required precision. The maximum precision readable on a scale should be defined as one half of the smallest unit on the scale.

3 The required information can be read directly from the instrument without conversion.

4. The required iriformation characteristic, e.g., increasing or steady, can be detennined from the instrumentation.

5. The control can be placed in the required position. For example, if the procedure says start a pump, the pump control switch should have a

> ' start' position and not an 'on' position.

6. The controller type (i.e. , M/A station, potentiometer, handswitch, etc.)

is suitable for the action required.

7. Alternate displays and control which might improve operator performance should be noted.

8. Any potential problems for the operator should be noted.

Attachm nt 1 Page 9

5. There needs to be a description of the method by which multiple units will be handled in the verification / validation process to account for unit differences, if the differences are significant. (NUREG-0899, Subsection 3.3.S.2)

APCo. Response:

A method to account for unii differences will be added to the validation / verification process. Differences between Unit 1 and Unit 2 at Farley Nuclear Plant ara minor and are not expected to impact ERP verification.

6. The verification' program should include a description of the methods and the personnel that will be involved to ensure the ERPs are written correctly; that is, they are written according to the P-SWG, and that they conform to the plant-specific technical guidelines.

APCo Response:

The ERP Verification Procedure includes an Evaluation Criteria Checklist which includes the necessary criteria that will verify that the procedures are written in accordance with the Writer's Guide.

Training Program

1. There should be an indication that all ERPs will be exercised by all operators before implementation.

APCo Response:

Initial training for the ERPs was completed in 1984. Although all ERPs were not exercised by all operators, the training program goals described in Section 6.3 of the PGP were satisfied. These goals were:

to enable the operators to understand the structure of the ERPs to enable the operators to understand the technical bases of the ERPs to enable the operators to have a working knowledge of the technical content of the ERPs to enable the operators to use the ERPs under emergency conditions

Attachmint 1 Page 10 The ERPs were selected based on operator knowledge and experience with simulator procedures; therefore, only procedures with new response strategies were considered for detailed training. Prior to implementing the ERPs, classroom and simulator training was conducted for all licensed personnel.

Subsequently, requalification training is conducted in both the classroom and simulator on an annual basis. It should be noted that Farley Nuclear Plant personnel have been licensed by the NRC utilizing the Farley Nuclear Plant ERPs.

2. The bases for scenario selectior for both simulator exercises and walk-throughs (for initial and refresher training) need to be elaborated to ensure that a wide variety of scenarios incorporating simultaneous and sequential failures will be used. The only criterion preseqted is that scenarios will be varied to ensure that operators do not dcGalop a pattern of responses (page 8 of 9, Section 6.5). In addition, if there are scenarios that cannot be run on the simulator they should be incorporated into a control room walk-through part of the training program.

APCo Response:

Specific details for initial and refresher training for licensed personnel are contained in the Farley Nuclear Plant Master Training Plan and the Operations Curriculum Guide. These documents provide specific guidance on scenarios to be conducted for training. Control room walk-throughs are addressed in the response to question 3 below.

3. Subsection 6.4.2 (page 7 of 9) stateo that walk-throughs for or simulator exercises will be used in training. Since the J. M. Farley Nuclear Plant has a plant-specific simulator, the operators should be trained on the simulator except for those areas where the simulator is significantly different from the control room. Those areas should be covered by control room walk-throughs.

APCo Response:

Currently, as stated above, operators are trained on the simulator. Control room walk-throughs are not conducted because the simulator is not significantly different from the control room.

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