ML20215H585
| ML20215H585 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 04/10/1987 |
| From: | Warembourg D PUBLIC SERVICE CO. OF COLORADO |
| To: | Calvo J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM), Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20215H588 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 P-87145, TAC-44304, NUDOCS 8704200432 | |
| Download: ML20215H585 (18) | |
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Company of Colorado 16805 WCR 19 1/2, Platteville, Colorado 80651 April 10,1987 Fort St. Vrain Unit No. 1 P-87145 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
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ATTN: Mr. Jose A. Calvo
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Director, Project Directorate IV Docket No. 50-267 SilBJECT:
Fort St. Vrain Procedure Generation Package Summary Report Evaluation
REFERENCES:
1)
NRC Letter, Heitner to c
Williams, Dated 11/13/86 (G-86602)
- 2) PSC Letter, Warembourg to Berkow, Dated 3/6/87 (P-87095)
Dear Mr. Calvo:
The purpose of this letter is to provide you with Public Service Company's response to the " Draft Safety Evaluation for Fort St. Vrain Nuclear Generating Station Procedures Generation Package" in accordance with the requirements of Reference 1 and the extended schedule of Refercnre 2.
I This response addresses each item contained in the Safety Evaluation and provides a disposition in the form of a revision to or a basis for not revising the Procedures Generation Package.
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8704200432 870410 PDR ADOCK 05000267 P
PDR S,
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P-87145 April 10,- 1987
.,.-s If you have any qtestions, please contact M. H. Holmes at (303) 480-6960.
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Very truly yours,
<0 /7 1Ymd D. W. Warembour Manager, Nuclear 3
Engineering Division DWW:DJG/asa 3
.g Attachment CC: Regional Administrator, Region IV Attention: Mr. J. E. Gagliardo, Chief Reactor Projects 8 ranch 4
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Mr. R. E. Farrell Senior Resident Inspector 6
Fort St. Vrain 1
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s-Public Service Company's Response to the Nuclear Regulatory Commission's DRAFT SAFETY EVALUATION RELATING TO THE PROCEDURES GENERATION PACKAGE On October 30, 1985, Public Service Company (PSC) submitted its Procedure Generation Package (PGP) as required by NUREG-0737.
This PGP contained the following sections:
Program Description Verification and Validation Program a
Training Program a
Guideline for the Preparation of Emergency Procedures On November 17, 1986, PSC received a " Draft Safety Evaluation by the office of Nuclear Reactor Regulation Relating to the Procedures Generation Package".
This evaluation included both comments and suggested changes to the Procedures Generation Package.
The purpose of this document is to address each item contained in the
" Draft Safety Evaluation".
The format of this document will list, by corresponding numerical reference, each item addressed in the evaluation, followed by PSC's response.
This submittal includes a revised PGP with the following four (4) attachments:
1.
Guidelines for Preparation of Emergency Procedures, SOAP-2 (Writer's Guide) 2.
E0P Verification Worksheet 3.
E0P Verification / Resolution Record 4.
Evaluation Criteria Checklist NOTE:
Changes to the PGP and Writer's Guide are denoted by vertical lines along the left-hand margin.
A copy of PSC's " Program Plan for the Integrated Validation of NUREG-0737 Initiatives" is included for reference purposes.
Evaluation Item A1 1
"Specifically, it is necessary to relate the task analysis activity to the development of the full complement of E0Ps implemented as a result of the upgrade.
In addition, if any events are identified that reqcire new E0Ps (beyond those already approved),
as indicated in Section 2.3.2 on page 6 of the PGP, PSC should submit, for staff review the...."
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PSC's Response The selection of specific Emergency Procedures for task analysis cand included in PSC's Detailed Control Room Design 1
Review (DCRDR) Summary Report! was based on an analysis of the structure of PSC's existing Procedure Set.
This was accomplished by identifying the Critical Safety Functions (CSFs) and the symptoms of challenges to those CSFs.
The Emergency Procedure Set is thus defined as the Procedure Set required to maintain these CSFs.
(A single procedure may contain as many sections as are required to exhaust the resources available for maintenance of a CSF.)
The result was a relatively small set of procedures for which flow charts were developed.
These flow charts provided the basis for the walk-through talk-through phase of the task analysis and also provided the basis for the informational needs analysis.
These same flow charts and
" informational needs" documents will provide the basis for the symptom-based procedure set.
The event-oriented procedures will be developed from the existing emergency procedure set.
Identifying an " event" will, in all probability, not require a new symptom-oriented procedure, unless that
" event" requires that a new CSF be defined. The identification of an " event" requiring an " event-based emergency procedure" would result in the definition of a technical basis, and the 4
submittal of that technical basis for staff review and approval.
A task analysis will be conducted to determine the content, scope, and structure of the new procedure.
Evaluation Item A2 "The PGP should also describe the methods to be used as a part of this checking process, who should perform the
' check', and how the results are to be documented and used.
This ' check' should include all parts of the procedures."
PSC's Response The " Verification and Validation Program" section has been retitled and reformatted to reflect the mechanics of the Emergency Procedure Verification activity. The Validation section now references PSC's more comprehensive plan.
(See General Comment To Evaluation Section C.)
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d General Comment to Evaluation Section B
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Certain of these comments contain suggested additions to the Writer's Guide portion of the PGP, which appear to be outside the j
scope of a Writer's Guide.
Specifically, these items are of an administrative nature and are currently addressed as such.
A reference section has been added to the PGP which lists these documents.
Evaluation Item B1
"...it is important that the Writer's Guide address conditional or logic statements, explain how they are
- written, and include examples of those to use, and those to avoid."
PSC's Response PSC Procedure G-2 " Fort St. Vrain Procedure System", Section 3.6.7, contains a recommended "If/Then" format for PSC procedures.
In addition, Appendix B of NUREG-0899 has been excerpted, modified to include plant specific examples, and is included in the revised Writer's Guide as Appendix 2.
Evaluation Item 92 "The Writer's Guide should be revised to specify some type of placekeeping aid."
PSC's Response The value of a plackeeping aid is recognized and several types (and/or methods) are being evaluated.
This evaluation process includes consideration of control room lay-down areas, user preferences, effectivity, and implementation.
The actual implementation of the selected placekeeping method will be included in PSC's Operator Aids Implementation Change Notice #1900.
Since the Writer's Guide is a guide for procedure writing and not a controlling document for procedure use, including criteria for the selection and use of a placekeeping aid would not be appropriate.
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Evaluation Item 83a "EOPs should be structured so that they can be executed by the minimum shift staff, and the minimum control room staffing required by the Technical Specifications."
PSC's Response The above stated guide has been included in the Writer's Guide as Section 3.2.18.
Evaluation Item B3b
" Instructions for structuring the E0Ps should be consistent with the roles and responsibilities of the operators."
PSC's Response Current separation of operator responsibilities within the control room is by division of physical areas (control boards).
Each operator member of the minimum shift staff (as required by the Technical Specifications) is qualified to perform the operations required for any particular control station.
Control functions are unique to specific control boards (a
particular task is accomplished at only one location) and each procedure step includes the physical location of a control or indication.
(See Section 3.7 of the Writer's Guide.)
In summary, an operator assigned to a particular area has the responsibility of performing all procedure steps associated with that assigned location.
Evaluation Item B3c
" Action steps should be structured so as to minimize physical conflicts between personnel while carrying out procedural steps."
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PSC's Response Separation of operator responsibilities within the control room by physical areas precludes major physical conflicts.
This fact will be verified during validation activities.
The Validation Program Plan specifically maps operator activity during E0P walk-throughs (see " Program Plan for Integrated Validation of NUREG-0737 Initiatives",
Section 3.2.2).
Any major physical conflicts between operators identified in the walk-through phase will be addressed in the " correction phase" of the Integrated Validation (see Section 4.0).
Evaluation Item B3d
" Action steps should be structured tc avoid unintentional duplication of tasks."
PSC's Response The above statement has been added to the Writer's Guide as Section 3.2.19.
Evaluation Items 84a, b, c, & d "The Writer's Guide should, therefore, address the format of the following types of action step:
a.
Steps that are used to verify whether the objective of a task or sequence of actions has been achieved.
b.
Steps for which a number of alternative actions are equally acceptable.
c.
Steps of a continuous or periodic nature, d.
Steps performed concurrently with other steps."
PSC's Response Specific steps formatting guidelines contained in NUREG-0899 were excerpted and included in the Writer's Guide as restructured Sec' ion 3.11.
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Evaluation Item B5 "The Writer's Guide should address availability and accessibility of the E0Ps, and the techniques used to distinguish them from other plant procedures. See NUREG-0899, Subsections 6.1.2 and 6.1.4, for additional guidance."
PSC's Response Specific space has been allocated and identified by procedure type within the immediate operating area for the l
storage of procedures.
Procedures which address emergency type situations are contained in RED binders and marked on the exposed edge as to the type of procedure, in accordance with established practices.
Non-emergency type procedures are contained in BLUE binders.
Distribution (quantity, location, etc.) of all controlled documents is spelled out in PSC's Document Distribution Handbook.
Due to the nature of each task, Emergency Procedure Generation and Emergency Procedure Use are assigned to different areas of responsibili ty.
Since the Writer's Guide is not the controlling document for procedure di stribution, specifying these housekeeping tasks within this document would not be appropriate.
Evaluation Item B6
" Criteria regarding the quality of E0P copies should be included in the Writer's Guide.
See NUREG-0899, Subsection j
6.2.2, for additional guidance."
1 PSC's Response Performance expectations (and requirements) exist within the various departments having the responsibility for the production and distribution of procedures.
Document reproduction employees also receive training relative to the quality of document copies.
High resolution printers are utilized for printing the original copies of all documents.
Duplication equipment is routinely monitored and maintained for quality reproduction.
Periodic checks are made of Control Room Procedures and other documents as part of Fort St.
Vrain's Quality t
Assurance (QA) audit program.
Legibility is verified as part of these audits.
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Existing methods are sufficient to ensure legible copies of procedures.
Since the Writer's Guide is a guide for procedure writing and not a controlling document for procedure production, including criteria for the quality of E0P copies in the Writer's Guide would not be appropriate.
Evaluation Item B7 "The Writer's Guide should specify the content and format of the reference phrase and the criteria to be used to determine when information or steps of a reference are to be included in an E0P rather than referenced."
PSC's Response Section 3.11.6 has been added to the Writer's Guide to provide guidance for specifying the content and format of a reference phrase.
Section 3.2.15 has been expanded to include criteria which defines the conditions under which reference steps may be used.
Evaluation Item B8 "The Writer's Guide should require each E0P to have a cover page. This page should specifically identify the E0P, its revision number and date, number of pages, provide a place for review and approval signatures, and indicate the facility to which the E0P applies."
PSC's Response Level I,
Administrative Procedure G-2,
" Fort St. Vrain Procedures Systems",
Section 3.4, Page 11 of 78, specifically addresses the above concern. A more specific reference to Progedure G-2 has been included in the Writer's Guide under Sect Sn 3.10.4.
Evaluation Item 89 "The Writer's Guide should include information on how pages I
of an E0P are to be formatted (i.e., line spacing, margins, tabs, etc.), or where in other plant documentation this type of information may be found."
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PSC's Response Administrative Procedure G-2 contains a Procedure Format section (Section 3.6).
Due to the fact that the new Emergency Procedures are to be in a two (2) column format, the Writer's Guide (SOAP-2) has been revised to specifically address the emergency procedure format.
Evaluation Item B10 "Each page of an E0P should contain identifying information.
This information should include a brief title, procedure
- number, revision number /date, and number of pages in the E0P.
The Writer's Guide should describe how this information is to be written, and where it should be located."
PSC's Response Administrative Procedure G-2, Section 3.4.4, specifically addresses page numbering, revision, and pagination of the procedures.
The Writer's Guide (SOAP-2) addresses the relationship between E0P titles and alpha-numeric designations.
The E0P cover sheet and each additional page will show a procedure title and the applicable alpha-numeric designation.
(See example included as Appendix 3 of the
" Guidelines for Preparation of Emergency Procedures".)
Evaluation Item B11 "The Writer's Guide discusses the basic divisions of an E0P (Section 4.1 on pages 9-11 of 18), but should also describe how subheadings are to be written and located.
Further, it should state how pages and action steps are to be numbered."
PSC';, Response Section 3.10.5 has been added to the Writer's Guide to provide guidance for the use of subheadings.
Section 3.10.7 has been added to the Writer's Guide providing guidance for numbering instruction steps.
Page numbers are discussed in PSC's response to Evaluation Item B10.
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a Evaluation Item B12 "The Writer's Guide should describe the approach used for emphasizing words or phrases in the E0Ps.
-The emphasis techniques can include capitalization, underlining, bold type, etc."
PSC's Response The use of word or statement emphasis shall be limited to the, applications and techniques discussed in the following sections of the Writer's Guide:
1.
3.2.20 and Appendix 2 - Logical statements Referencing specific engraved names 2.
3.7.3 3.
3.10.5 - Heading and subheading format 4.
3.12.3 - Caution and note formats 5.
3.7.1
- Emphasis of switch or control position l
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General Comment to Evaluation Section C The PGP as submitted provided a section entitled " Verification and Validation Program" however, this section was actually a partial summary of the Verification and Validation Program applicable to the Emergency Procedure effort. While there is no outstanding regulatory requirement for a formalized Verification and Validation program. PSC has a comprehensive program plan.
This
" Program Plan for the Integrated Validation of NUREG-0737 Initiatives" was not included in the PGP submittal due to the fact that NUREG-0737, Supplement 1, 7.2.biii, required only "a description of the program for validation of E0Ps".
A copy of this Program Plan is being provided with this submittal for reference purposes.
It should also be noted that the validation activities relative to the Emergency Procedure effort is an element of the Integrated Validation effort.
(The Integrated Validation is not an element of the procedure effort).
Evaluation Item C1 "The types of personnel involved in the Verification and Validation process are identified in the PGP.
In addition, the PGP should also state the intended roles and responsibilities for these individuals."
PSC's Response The roles and responsibilities for personnel involved in the validation process are identified in the " Program Plan for the Integrated Validation of NUREG-0737 Initiatives",
Section 3.1.2, and in Attachment A to that plan.
Specific roles and responsibilities required of the personnel involved in the verification process will be assigned by the j
team leader as required to support the activities.
In general, the " team" concept will utilize the expertise represented by different disciplines in a collective manner to accomplish the stated objective.
5 Evaluation Item C2 "To ensure verification and validation of all E0Ps, the program description should include an indication that the full complement of E0Ps will be reviewed and exercised to their fullest extent..."
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PSC's Response A new Section, 3.1.1, has been added to the PGP specifying that each procedure is subject to verification activities.
Section 3.2.1 of the " Program Plan for the Integrated Validation of NUREG-0737 Initiatives" addresses the development of validation scenarios.
Section 3.4.2 1
summarizes the evaluation criteria for this validation.
Evaluation Item C3 "The validation program should be expanded to include a description of the criteria that will be used to select the scenarios to be developed on the basis of what is needed to validate the E0Ps, and should ensure that multiple and consequential failures are included."
PSC's Response l
Scenario development (or selection) cv teria is provided in Section 3.2.1 of the " Program Plan for the Integrated Validation of NUREG-0737 Initiatives".
Evaluation Item C4 "The PGP should indicate that feadback from the control room mockup walk-throughs will be used to ensure the accuracy, readability, usability, and completeness of the E0Ps."
PSC's Response i
Section 3.4,
" Assessment", of the " Program Plan for the Integrated Validation of NUREG-0737 Initiatives", defines the acceptance criteria and method (s) for applying that criteria in determining the acceptability of the E0Ps.
Section 4.0 describes the " correction phase".
Evaluation Item C5 i
"The Verification and Validation Program should include the criteria or methods that will be used for determining the need to verify and validate any changes in the E0Ps, resulting from either the results of a previous Verification j
and Validation Program or from subsequent E0P revisions."
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PSC's Response Section 4.3.6 of the " Integrated Validation of NUREG-0737 Initiatives", includes " Additional Requirements" relative to reverification and/or revalidation of procedures changes as a result of deviations and/or discrepancies.
Fort St.
Vrain will implement an administrative procedure that will require all subsequent E0P changes to be evaluated by a review group, Emergency Operating Procedure Review Group (E0PRG). The E0PRG shall:
a.
Ensure that the purpose of the proposed change is defined and that a procedure change is required.
b.
Evaluate the potential value and use of any 4
procedure addition, deletion or change.
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Review the proposed change for impact on operator work load during emergency operations, d.
Ensure that all available options or g
4 alternatives have been fully assessed.
e.
Verify that the change activity includes consideration of established human factor principles.
i In addition, the E0PRG shall determine the extent of verification and validation activities necessary to ensero that the proposed changes conform to the requirements as described by the Emergency Procedures Generation Package (PGD).
Evaluation Item C6 "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 control room mockup walk-throughs with the minimum control room staff size required by the FSV Technical Specifications."
i PSC's Response Section 3.1.2 of the " Program Plan for the Integrated Validation of NUREG-0737 Initiatives" specifies two (2) i control room operators for validation walk-throughs.
Fort St.
Vrain Technical Specifications require two (2) operators.
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J Evaluation Item C7 "The PGP should also state how this
' check' is to be accomplished, which documents or forms are to be filled out to record the results of the ' check', and the procedure for revising E0Ps in accordance with the results."
"...and examples of the documents or forms should be included in the PGP."
PSC's Response The PGP (Section 3.1) has been revised to address the structure of the verification activity and the methodology to be used.
Procedure revisions required as a result of validation are addressed in Sections 4.3.2 and 4.3.3 of the
" Program Plan for the Integrated Validation of NUREG-0737 Initiatives".
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General Comment to Evaluation Section D Although the PGP states that control room / mockup walk-throughs will be used for operator training, the training program description should be expanded to address the following items 4
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" Discuss the extent that operators will be trained on the i
E0Ps.
The PGP should indicate that all E0Ps will be walked through to the fullest extent possible by all operators."
PSC's Response i
PGP Sections 4.2.1 and 4.2.2 as written, discusses in j
significant qualitative detail, the " extent that operators will be trained on the E0Ps". A more quantitative statement i
has been added in Section 4.1 to indicate that all licensed operators will walk-through all procedures.
Evaluation Item Olb "Since there is no simulator to dynamically exercise the
- E0Ps, the control room / mockup walk-throughs should be j
accomplished in the most realistic manner possible.
The i
i approach that will be used should be detailed in the PGP."
i PSC's Response The method for conducting training walk-throughs has been i
added to the PGP, Section 4.2.2.
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Evaluation Item 01_c i
" Indicate that, during the walk-throughs for team training, i
i minimum control room staffing will be used."
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i PSC's Response j
The third sentence of PGP Section 4.2.2 has been revised to
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indicate the use of minimum control room staffing, j
j Evaluation Item Old f
" Indicate the use of a wide variety of scenarios, including 4
,I those involving multiple and consequential
- failures, to i
fully train the operators on the E0Ps during the walk-i.
throughs".
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PSC's Response The primary goal of the Fort St. Vrain E0P's is the restoration and/or maintenance of.the plant CSFs.
Specifically, Fort St. Vrain E0P's shall provide contingency action steps to every E0P instruction step to the fullest extent of the plant control system design.
The procedures, therefore, shall be capable of mitigating the challenges to CSF's for any licensed-based scenarios.
Since operators shall be exercised through all possible E0P paths, the operators will receive full training through a variety of credible accident scenarios.
Evaluation Item 02 "The PGP should briefly describe the process by which FSV plans to deal with any discrepancies discovered in the E0Ps during the implementation of the training program.
PSC's Response E0P changes resulting from Verification and Validation activities will be handled in accordance with Section 4.3 of the " Program Plan for the Integrated Validation of NUREG-0737 Initiatives".
Training within the procedures will be conducted only on an
" approved' procedure set.
Any discrepancies discovered during training will be handled in accordance with Administrative Procedure G-3, Section 4.4.
Evaluation Item 03 "The PGP should be revised to provide more detail on these sessions. At a minimum, these (pre-shift) sessions should include walk-throughs of the revisions."
PSC's Response A paragraph has been added under Section 4.2.4 of the PGP which addresses the above comment, t
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Evaluation Item 04 "The PGP should include a commitment to train all operators on all E0Ps prior to their implementation in the control room."
PSC's Response A paragraph has been added under Section 4.1 of the PGP which specifically addresses the above comment.
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