ML20235S082
| ML20235S082 | |
| Person / Time | |
|---|---|
| Site: | LaSalle  |
| Issue date: | 02/24/1989 |
| From: | Johnson I COMMONWEALTH EDISON CO. |
| To: | Murley T NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 5532K, NUDOCS 8903060086 | |
| Download: ML20235S082 (26) | |
Text
,
Comm:nwalth Edis n Z. W One First National Plaza. Chicago, Illinois V
Address Reply to: Post OTfice Box 767 Chicago, Illinois 60690 0767 February 24, 1989 Mr. T.
E. Murley U.S. Nuclear Regulatory Commission AT'IN :
Document Control Desk Washington, DC 20555
Subject:
Quad cities Station Units 1 and 2
" Response to Observations Identified In Executive Summary to Emergency Operating Procedures (EOP) Inspection -
NRC IR 50-254/88-200 and 50-265/88-200" IMC Docket Nos. 50-254 and 50-265 i
Reference Letter from G.M. Holahan to Cordell Reed dated December 5, 1988 transmitting IR 50-254/88-200 and 50-265/88-200
Dear Mr. Murley:
The above referenced letter transmitted to Commonwealth Edison, the results of a July 18-29, 1988 inspection conducted by the NRC's Office of Nuclear Reactor Regulation (NRR) of activities associated with the Quad Cities Emergency Operating Procedures (EOPs). The letter requested Commonwealth Edison to provide responses to the observation summarized in the Executive Summary to the Inspection Report within sixty (60) days of the receipt of the letter. The responses to these concerns can be found in Attachment A to this letter.
A two (2) week extension was verbally requested and granted by Mr. T.
Ross, Quad Cities Licensing Project Manager (NRR).
Also, included in our response as. Attachment B is Quad Cities Station Procedure QAP 1100-13, Revision 1 entitled " Control of Emergency Operating Procedures". This document was developed following the EOP inspection and should facilitate the review of our response to the concerns noted in the inspection report.
8903060086 890224 PDR ADOCK 05000373 Q
T.E. Murley February 24, 1989 As noted in the above reference, Quad Cities Station provided a preliminary response to the inspection findings at the conclusion of the July 29, 1988 Exit Meeting.
He are now formally transmitting a copy of the
]
proposed actions which were presented at the Exit, as Attachment C.
The narrative summary included in Attachment A also describes the status of the applicable items.
1 Please direct any questions you may have regarding this mattor to this office.
Very truly yours, t
./lAf f N
I.
M. Joh n
Nuclear Licensing Administrator l
1m Attachments At Commonwealth Edison's Response to Concerns Relating to Emergency Operating Procedures B:
Station Procedure QAP 1100-13, Revision 1 entitled " Control of Emergency Operating Procedures".
C:
Proposed Actions Presented at July 29, 1988 Exit Meeting cc A.D.
Davis - NRC Regional Administrator T.E.
Ross - Project Manager, NRR Senior Resident Inspector - Quad Cities 5532K
l 4
1 1
ATIACIMENT_A I
CQMtiQUNEALTH EDISON'S RESPDHEE TO COMEKENS RELAIlliG_IQ 1
l EMERGENCY _DPERATING PRDCEDERES (EQE11 l
l HARRATIYE._SU14 MARY A proposed schedule of corrective actions was presented at the EOP inspection exit meeting held on July 29, 1988 at Quad Cities Station (See Attachment C for more detailed information).
Corrective actions based on these proposals have been in progress.
Additionally, these corrective actions have been reviewed in light of concerns raised in the Executive Summary of the subject Inspection Report.
i l
A general overview of progress made since the July inspection follows and is provided as an update to the " Proposed Actions" presented at the exit meeting.
In August of 1988, Quad Cities Station approved an Administrative Procedure (QAP 1100-13, Control of Emergency Operating Procedures) to control the EOP development and maintenance process.
It was developed in accordance I
with the guidance provided in NUREG-0899 and addresses the Icsues raised in the August 29, 1988 proposed Action Plan.
This procedure has been utilized as the station revises its QGAs to Revision 4.
QAP 1100-13 is provided as a reference to aid in the Review 4 of this response (Attachment B).
{
The latest r,evision to the QGAs is scheduled to be implemented on April 10, 1989.
The calculations developed for Revision 4 have been reviewed and revised. This review included an independent check and approval by the station Operating Department.
The Plant Specific Technical Guide (PSTG) was prepared using the
)
updated calculations and guidance from the Revision 4 Emergency Operating Guidelines (EPG). Concerns which were raised during the NRC inspection are being addressed and any technical deviations from the EPG are being formally justified.
The Plant Specific Writer's Guide (PSWG) was rewritten and now provides the guidance required to adequately implement the QGAs in the flowchart format. The initial PSNG was developed by the station during November, 1988 and is in the process of being finalized at this time.
Both the PSTG and PSWG have been used to develop our draft QGA procedures and are being maintained and updated with information obtained from the verification and validation program.
i
,. The verification and validation program that is being used on the draft procedures includes:
1.
Control Room and Plant Walkdown 2.
Tabletop Demonstration of the Procedures / Exercises 3.
Simulator Demonstration of the Procedures / Exercises These three phases will result in a thoroughly reviewed and tested procedure and the process will continue with an ongoing program for soliciting feedback even after the procedures have been implemented.
Throughout the procedure development process, an effort has been made to include reviews by individuals from various discipling and varying experience levels.
Representatives involved in the review, include 1.
Control Room Operators; and 2.
Shift Supervisors; and 3.
Operating Department Management; and 4.
Computer Technicians; and 5.
Degreed fiuman Engineering Personnel; and 6.
Training Personnel; and 7.
General Electric Consultants.
At the conclusion of the development of the QGAs, a training program will be initiated and completed prior to the implementation of the procedures.
All license holders will attend a two-day session which will be developed to cover the full range of the QGAs. These procedures will be implemented following the two (2) day training.
Immediately following this session of training, the annual simulator crew training is scheduled to begin.
Subsequent to the EOP implementation, Quad Cities Station will begin its annual simulator training. The simulator training will include training on the revised QGA's.
Contract proposal specifications are being prepared to award a contract for the station's upgrade to EOP, revision 4.
This will include many enhancements to our procedures as Commonwealth Edison is attempting to develop a uniform approach to EOPs within our three BWR stations.
All Performance Issues listed in the " Proposed Actions Plan" for immediate response have been completed.
The remaining portion of this response contains each item of concern noted in the EOP inspection report Executive Summary and the station response to the concern.
L
. COECEEH:
(1)a.
The_deyglopment of the_ Emergency Operating Procedures _lEOPs) was not adeguate_lA_thatl The_lisensee did aqt_deyelop a revised _Elant_Epeslu n_Inshnical Guide I ESIGl._and_ElanL Spaniu s_Rr i t e r ' s _ Guide _iESW_R)_pIls r_t9_the dAYRlopDLEnt_And_ implementation _of significant revisions to the EOPs in_accordance with the guidelines of NUREG 0899.
RESPONSE
The PSTG and PSWG have been rewritten in accordance with QAP 1100-13 (page 3 of QAP 1100-13).
After their development, the draft QGA procedure was developed and is in the process of verification and validation.
Page 4 of the QAP states that "The proposed modifications shall be made to the QGA's in accordance with the approved PSTG and writer's guide" to prevent any future deviation from this methodology.
CONCERN:
(1)b.
The_licensae_Lailed..to_deYalop_and_ implement an_ adequate _YRIllination and_Xalidation_pIngtem for the EOPs.
The verificalinn and validation PI Og Lam _pe r f o rmed_did_no t p r og r ammatisally_ addle S S the_nesassaII attr.ibutes_and_.Eas_periqrmed in an infoIJnal manner which severely limitad_the effectlyeness of the effort.
RESPONSE
A formal verification and validation is being performed on the April 1989 revision of the QGA's.
It is being performed in accordance with QAP 1100-13 as described on page 4.
CONCERH:
(1)c.
The _ lice n s ee_had_nnt _pInrided_t tain ing_opprop ri a te_t9_th e_ssspe_af EQE_leylslens_Qn_a_ timely _.hanis to th d igensad_gpgratgIat
RESPONSE
In accordance with QAP 1100-13, page 6, appropriate training will be dictated by the QGA committee and the onsite review will verify that training has been completed prior to implementation of the procedure.
CRMCERN:
The_ maintenance of the_EDEs_and_ESIGa_waa_nol_adeguate in thatl.
(2)a.
Th e_llcen s en_did..nq Lapprnpr_l e te l y__spntra l_a nd_ma int ai n_the_ES_TEs._And Rupp21 ting ca1eu1atinns_up-tp-datg_as a design _hg3_in_dp.cymentt
i l
RESPONSE
Calculations are controlled as described in OAP 1100-13, page 2.
The PSTG is controlled as described on page 3.
The PSTG and calculations are reviewed and approved and are retained and tracked as plant records.
CONCERH:
(2)b.
The_litenseS_31Lngt_c9ntIQ1__the reylginna_oLthe EOPs in accol_ dance
. lib administrative procedures for di.s_tLibution.
w i
RESPONSE
QAP 1100 -5 (Temporary Procedures and Temporary Changes to Permanent Procedures) was revised to clearly assign to the originator the responsibility of distributing QAP 1100-T14 (Temporary Procedure j
Change Notice Sheets) to specific manual holders.
QAP 1100-T6 (Temporary Change to Permanent Procedure Request / Temporary Procedure Request) was revised to require originator to sign off verifying that " notice sheets have been prepared for existing procedures and will be distributed to the appropriate manual holders".
CDNCERN:
(2)c.
The_llcensee_proxirled_insuf_ficiant_persnnnel_ tees #rce.s to malnta_in the_techninal and human _ engine _eLing_ basis of the EOEg1
RESPONSE
An EOP Coordinator has been assigned and functions in conjunction with a multidiscipline EOP Committee to coordinate matters concerning the EOPs.
Human engineering matters are being handled by CECO human engineering personnel.
CONCERN:
The-_11CRAspe_pLQYidfd_1D3dequate management oversight of tite _EQE deEe19pment._ program _in_thatt (2)d.1.
Ear i of i c_cudi t s_qL the_EQE_d elel opment_ ping (Dm_we r e n o t p erf_p ImeA__by the_ Quality _Aasurance Depar_tmenti
RESPONSE
As previously addressed in the response to the Notice of Violation issued in Dresden Inspection Reports 50-237/88012; 50-249/88014, and the failure to audit the Emergency Operating Procedures prior to June 1988 was an oversight. Quality Assurance missed the recommen-dation in NUREG 0899 for Quality Assurance overview of the EOP Program and had independently concluded that the involvement of the NRC licensed Senior Reactor Operators within Quality Assurance in the implementation, training, and simulator use of the EOPs offered adequate coverage.
l
- When notified of NRC concerns in this area at Dresden in June 1988, Quality Assurance took aggressive action to address the issueoat all the Commonwealth Edison Nuclear Stations.
At Quad-Cities Station, research into the Emergency Operating Procedure development process j
l began immediately. The Quality Assurance Audit Schedule was revised on July 1, 1988, to include an Audit of the EOP Program.
A l
comprehensive Audit of the EOP Program was conducted July 11-15, J
1988.
Audit team personnel included a technical advisor, with significant experience in the EOP development process, and NRC licensed Quality Assurance personnel from both Quad-Cities and I
Dresden Stations.
)
l The results of the Quality Assurance Audit (QAA 04-88-52) were discussed with members of the NRC Emergency Operating Procedures Team during their inspection. The Quality Assurance Audit identified many of the sane concerns brought out in the NRC Inspection Report.
Quality Assurance is monitoring the upgrade of the Emergency Operating Procedures Program via follow-up of this Audit.
To ensure continued coverage of this area, the 1989 Quality Assurance Audit and Surveillance Schedules for all Commonwealth Edison Stations contain requirements to assess the Emergency Operating Procedures Program.
CONCERN:
(2)d.2.
Co rte ctlyg_antl0 US_LQI_ AiLininntiRR_ in_thR_E_QP__dRVRlopm2AL_ pLQg ram wate not impigmented following the licensee's revjew of Information l
Nating 86-6.4_henange_an_inade_quate evaluation was RefformeIL_In l
Addit 1QR2 the licensee's utilization of other_information notices was queglianable due to the lack of managRmant review.
RESPONSE
l Information Notices from 1981 - 1987 have been reviewed to determine adequacy. The review was to determine if the initial response was 4
adequate, inadequate or not applicable.
I The Information Notices from 1978 - 1981 with responses that were deemed to be inadequate will again be reviewed and responded to following development of an action plan.
Information Notices from 1978 - 1981 are still being reviewed for adequacy.
Similarly, those responses whleh are considered to be l
Inadequate will be responded to again. This adequacy review is scheduled to be completed by May 31, 1989.
. Recent changes in the method of review of this type of operating experience (OPEX) has resulted in a significant increase in management review.
Information Notices and other forms of OPEX information are initially screened by Regulatory Assurance l
personnel.
Following this screening, the information is reviewed by cognizant station personnel and a response is formulated. This I
response is then reviewed by the appropriate department head and upper station management. When the response is approved, any items that need tracking to ensure completion are entered into a computer tracking system to ensure timely resolution.
CONCERN:
(2)d.3.
CDtrect1ye aetions for 1.abRliDg defieienc1eE_,._identifled_hy_pf_tmis_ua UBC__inspentionE uwere ibDdagunle_hacDune_Rnaning_lEbeliug_effQLtA werR_ Rat _gvaluated_pglo r to the_ implement 311pn of the correctlyg actinnat
RESPONSE
Commonwealth Edison Human Engineering personnel have been contacted to address the issue of labeling.
Guidelines resulting from human factors input will be incorporated into QAP 300-17, Control Room Labeling and Color Coding by March 30, 1989.
The changes will be implemented in accordance with this procedure.
CONCERN:
The technical basjs of the EOPs was deficient in that (3)a.
The_llcensge_.did not pInyJ_de a methqd_ Lor _capihustille_ gag __CQatI.Dl_in the.lQER_ hec.aune_the_bydingen_Aontig1_plsvisions of the Prliaaty Cont ainme nt_ Con t rn1_g ui delinna_w ere_not_.l ncsIp o ra t ed.
In_additiont I
the_licenaee did not ptcyide a justification for this significant day 1011DAt l
l
RESPONSE
1 A Ilydrogen Control procedure has been developed and is being incorporated into the April 1989 revision of the QUAs.
CONCERN (3)b.
Th e_ license e_ alt er ed_t h e_DM RQQ_Imarg eAcy_ Etos educe _. Guideline s_.LEEG1 login_LgE_ Reactor Pressure vessel _.(.BPV) flooding _because installed pI1FLDIL_cDntD1DRle n t_ggle r l e ve l I n strur!!cnt atig g_w a s_Rqt_Aya ll ab l e2 l
Tha_llce n se e_did_nat_e flectlyaly_utili z e_pl a nt_spe_c il ic_eg uipme u t_t o PIsyide_an_alteI.na_Le_matb2d_af level indication _end_did_nnt_ pray.ide_a suILislent_teshninal_iuattficatlon (s.t_this_ significant _tachnical deviationi
-7 _
i RESPOtiSE :
The technical justification for this technical deviation will be revised and upgraded by April 10, 1989.
Additionally, a modification is being pursued at Quad Cities Station which would install primary containment water level indication to accomplish our full QGA upgrade to revision 4 of the EOPs.
CQtiCERN:
(3)c.
The_licensen_.incnrtently calculated _the_p11 mary _ containment praas. urn limlt_anistessu r e_suppres sisn_pressarn_ limit _b e.cauae_a nan conservatlys._acEymptinn for the_P.tessure_batiE_SI__tha r
calculations _.was_ utilize.d.
In additio_n,_the_linensen had based all th e_Aa l_c ula tlans_u p9 n_a_ pIRyl o u s revis1gn_qLthe_EEGs.1
RESPONSE
The Primary Containment Pressure Limit and the Pressure Suppression Pressure Limit have been recalculated to reficct more conservative values for the April 1989 revision of the QGAs. The calculations were performed using Revision 3 calculations due to the absence of revision 4's calculations.
CQtiQCEN:
(3)d.
The_llaensee_did_not_reyla.e_the calnnlatiens_qLthe_ESTG following plant _Inadificat.isna_which_affected_the_ basis _of the_ calculations Ent_ example,__the_calnulatinns__ Lor the cold and hat _s.hutdow2_baten weights _were_no Lreyised_f9112 wing _modifisat19na_t2_the ltandby hiquid_Cantrol (SLCLaystentantihe_calsvlatinn_for_.the_flox st agnat i o.n_NA t el_l eYf l._(_ESWkkwa s_Da t r e v i s e d f o l l owing _a modification _in_the_macles1_Cuel design,.
RESPONSE
Calculations for the SLC shutdown weights were revised to reflect the modification to the SLC system and the FSWL limit was revised to reflect the modification of the nuclear fuel design. These were revised in accordance with QAP 1100-13.
This procedure also describes on page 1, the method in place to review the impact of plant modifications on QGA procedures.
CDt4CERN:
(3)e.
The_llcansne_de_viateLftsnLthe_ingir_01_the BWRO.G_EEGa_during_their process.sf incorporating _ESIGs_into_flowshattl0Es.i_.JpAcifinally1 the_lngic_pLthe BWRQG_EP9E_w_ith_ Inspect to thg_ requirements _fgr_a re a cto1._s c Lanu__t he_. reg ni teme nt s for c o ntIn1_q LRPV_in j erLi on ;_a n d_t h e methodology _f91_pIlmary_ containment _yenting_were incorporated _into the._EQEs incorrentlya i
j
. RESPONSE:
QGA 100-1, 500-7-2 and OOP 1600-13 have been upgraded for the l
April 10, 1989, procedure implementation.
To prevent recurrence of this problem, deviations from the EPG require technical justification and committee review prior to approval as described in QAP 1100-13, (page 5).
Functional accuracy of these deviations are also checked during the verification and validation process.
CRILCEBli:
TechniscaLius.t111catinnlar significant_ changes to the EPGs was not provided.
For examplei l
(3)f.1.
Ihe_,11censge_dirl_no_t flainia1R_the_ LOP _cR0 tee __in_the._fS.TG.
A_s _a rasytt1_1be Justificatlan_for subsequenkshange.s__to__the_Aunes_.was nat_ayAllablei
RESPONSE
QAP 1100-13, page 3, directs the preparation of technical justifications for any changes made to the QGA curves. The curves are being maintained with the PSTG and this requirement will be incorporated into a revision of QAP 1100-13 by May 3, 1989.
CONCERN:
(3)f.2.
The_licensge_inenIpnIAted additional steps into the EOPs which wer_e not_.in_the_fEIGL__As_a_lesaltt__ thele _ changes represented deXintinns IIom_the_EPG loalc which were not justified1
RESPONSE
l l
Deviations from the EPG require technical justification and committee review prior to approval as described in QAP 1100-13, page S.
Changes to the procedure are incorporated by first reviewing the PSTG for required changes as described in QAP 1100-13, page 3.
CONCERN:
(3)f.3.
Thelicemsee_deleief _ applicable _indeclinn_sub. systems __f;_om__1311RQG_EPS Co n t i ng e nc y...P_ race dura _ Nm_LwithonLterh nisaLj u atif icatio n
RESPONSE
The Fire System has been added to the list of injection systems for the April 1989 revision of the QGAs.
CONCERN:
(3)f.4.
The_lis e n s.eA_41.d._nat_p tqYide_.Etonitoling _ fAr_s.es Dada ry_co nt a i nm en t r a d iatinn_l e_tels_in_alLate_at_te gni ting _sitannneLance_at_d ur i n g _e n acnidentt
RESPONSE
Technical justification will be provided for areas which are not equipped with radiation monitoring by April 10, 1989.
. CONCERN:
IheJIMman_IBat9J.a_En91DRDIing guidance of the EQEa_yas deficient in
_tllaLL (4)a.
The_ESW_G_ p ray.i dad _.imade qualR_9 uldan te_Ca nce r n ing._t h e _.1In pl eJn_e n tatinn oC_the_PSTG_into_1he_ERP__flownhart_fortnal_And_the__ESt!G was not ut1111ed for the_deynippment of the EOPs.
l
RESPONSE
The PSWG was revised and now includes directions for the implementation of the PSTG into flowchart format.
This guidance is being used to develop the April 1989 revision of the-QGAs.
COUCERN:
(4)b.
Th e_in sp e ction_le am_id en tif i ed_numeI_qu a_RXDmple n_QI_I na de qu S LS implefn.Antation of the PSMG_because the_.llsenaee had not effectlygly impl.emented a verification and validation pI_qqr.am.
RESPONSE
The verification and validation process is being used, in accordance with QAP 1100-13, to verify compliance with the PSWG.
CDUCERU Ihe_pIRCed1EAl_ade.quacy_Qf-_thelOER_ was definient in thall.
(5)a.
The li_qsnaee_did_not revise the_QPEI_atinnal_pISCRduIe_. Cot _CnntalDaent e
Sprby__.CDntrR1_and__the__nalnulational_hasis of the EOPs after the_spl.ny Ilqw___llal_tS_Ngr e reviaed by the vend 2IA
RESPONSE
The operational procedure and calculational basis for the containment spray control are being revised to reflect the vendor information.
These revisions will be complete by April 10, 1989.
C9MCERN The._li nens an_di d_not_pI nv_ide_ade. quat e_ pros e du r eJi_Cor_ssmp letop e ratsI antions_naneaanty._for_thn_arcompliabmant of the_EE.Gru__f.9I_exampl_g1.
(5)b.1.
EIqCedure_did_ Dot _pIRy.ide. for the alter.pate control rod InteI11gn technique _ of hydraulic contIp1 rod venting.
RESPONSE
A procedure is being developed to accomplish alternate control rod insertlon via venting of the control rod drive hydraulle control unit. This procedure will be developed by April 10, 1987.
CONCERN (5)b.2.
SaveIAl_pronedures_lDChad_specifis_infarpation neCesanty_ fordhe CDIJ.eSt_PRIf91mance of the opera. tor tankai
o
. RESPONSE:
The verification and validation process described in OAP 1100-13, page 4, is being used to identify procedural weakness and prevent this situation from occurring in the future.
CDUCERH:
(5)c.
The._ligensee_. implemented _an ineffective methg4qls.gy for alarming _and MQnitoring_the EOP entry conditions which allowed an_entIy conditign
.tD_.hE_m1SH9_d1
RESPONSE
The alarm setpoints for area high temperature have been changed to coincide with the OGA entry conditions.
CONCERN 1
(5)d.
Thft.lic e n ses _impleme n ted_.an_ine fie c t i v e_m et had_.19_ ens u rn__th a t_ap a cial LOQlE_RECensary_fo r the perform.ance of the_EDes_auda pet.ator_ai_ds pnated on plant instr _umentation and control panels reagined available and_were aecurale_and_up _to _date_,.
RESPONSE
A surveillance procedure is being developed to control and maintain special tools and operator aids that are required for QGA use.
This will be developed by April 10, 1989.
CDMCE.BM SSVeIA1._E_lgnififDAt_dellaiencias were noted during_1he EOP accident ECengrios. Thage include.d1 (6)a.
Ibe_licenaRR_did_A01_ maintain._an_Bdaquate_QYRIy_lew.__of_ thn_ control Inom_activiti.es_and_as a result _ Aid _ont._implemmat_all_the requi194 4
actions _91_the_ IDEA _in_the_ time required benanse the operntata_had di.I Ci culty_interpr e ti ng_And_ implementing _the_.EQP s. The_inspention team _noncluded_thAt_1bia_defiriency_ was_the__ result _nf_synily compinx PI9CeduteaupsnL_Lendability of the EOPs, and_ingdagnate operatg1 LLainings.
RESPONSE
Following the QGA audit, all operating crews were observed during l
execution of the OGA procedures at the simulator facility. The crews were observed by the Assistant Superintendent of Operating, the Production Training Center and the Regional NRC Inspectors.
This overview of EOP execution demonstrated acceptable EOP usage and adequate EOP training.
Possible problems with complex procedures and poor readability are being guarded against due to the verification l
and validation process being used for the April 1989 revision.
I
_ 11 -
CONCERTI (6)b.
The_ licensee _did_noLimplement_the_. directed AC.tisna_01_the_EDEs_wlth respert_to_inw_.ptmasnLe_ venting nf_the_PIlmary__conta11 ment _and_the i
e!!!eIg e D Cy_dEPI e S AMEl 3 atign_of_the r e a c t 01_ greEEMI e_ye 33 eL(rey ) due to misinteIpIttation of th.e EOPs and a lack of confldgnge of the 11CRRs ed_.DP ela t9 FE_in_t he_s flef tiSe D eE SJ1._t he_ PIlmAIy_ROAtAinm e nt j
_YRDting_pfsredure. 'The inEPEft19n_t_ tam _CanClyfed that these j
di f11Culti es_w e rn _th e _ te smit _si_ina d eq uata_eng ine.e ring _eralu a t19n _e nd l
OpatatoI_ training._on_the_baslE af._the_P11 mary contalrn.enLyent_ path and the emergency depressurination procedure.
RESPONSE
The containment venting procedure has been revised to account for the failure of the standby gas treatment (SBGT) train that is in service during high pressure containment venting. A technical evaluation has been conducted which verified the ability of the containment vent valves to close at high containment pressures.
The firm that conducted this evaluation has been contacted to also address the ability of these valves to open under these conditions.
Classroom training on containment venting will be complete by April 10, 1989.
C0tiCEElis (7)
The_11Censge_ Aid _nqLPIRYlde_an_effectlye_.AethRd for PIeNenting PLl!!)ALy_ Containment _PERSEMI.e_inCle0SeS_heCSMER_An Adegklate RDgineRLing evaluation of thg_ygnLpath was 42LEeIIDImed_Snd P E931 E10 D E _we r e_nQ.t_PLQy_ide d f o r venting _the._.primaIy._C9 nt a inmen t under all accident scenarlnE2
RESPONSE
A technical evaluation has been conducted which verified the ability of the containment vent valves to close at high containment pressures. The firm that conducted this evaluation han been
)
contacted to also address the ability of these valves to open under these conditions. Manual operation of containment vent valves is i
being researched by the station Operations Department and the results
)
of this research will be used to address this issue.
Development of written guidance is expected by August 1, 1989.
l l
Attachment B l
l l
QAP 1100-13 l
Revision 1 l
CONTROL OF EMERGENCY August 1988 l
OPERATING PROCEDURES l
l A.
EUREQSE The purpose of this procedure is to describe the method to control and l
revise the Quad-Cities Emergency Operating Procedures (OGA). This procedure will provide a program that assures proper review and verification of the procedures prior to change.
l B.
EEEERENCES 1.
NUREG-0899, Guidelines for the Preparation of Emergency Operating Procedures.
C.
ERQEEDilEE I
1.
Plant design changes shall be reviewed for their impact on the l
QGAs.
In order to accomplish this review, the following list I
contains the items that need to be reviewed. This review needs to be performed soon enough to allow time to implement the changes to the QGAs prior to implementation of the change.
In cases where training requirements are substantial, this time needs to be at least three to four months.
a.
Plant modifications shall be reviewed for their effect on the QGAs.
This shall include effects on the operation and performance of equipment used in the QGAs and effects on input parameters for the calculations.
This review may be performed by a qualified QGA reviewer.
l l
b.
Instrument setpoint changes shall be reviewed for effects on QGAs and the calculations.
This review may be performed by a qualified QGA reviewer.
c.
Tech Spec changes shall be reviewed for effects on QGAs and the calculations. When a Tech Spec change is subm1Lted, the effect of the proposed change shall be evaluated and the evaluation submitted to the QGA staff for reference.
Coordinating implementation of the procedure changes and the Tech Spec changes shall be done by the Tech Staff Supervisor.
1 l
l d.
Changes to control room instrumentation or controls not performed under a modification shall be reviewed for effects on QGAs.
The review shall assure that the scales and labels i
of controls and instruments remains consistent with that contained in the QGAs.
Implementation of the changes needs to be coordinated'with the changes in the procedures.
(
e.
Changes to procedures referenced in the OGAs shall be reviewed for their effect on the QGAs.
All procedure changes to procedures referenced by the QGAs shall be routed to the QGA committee for review.
If the changes require changes to the QGAs, the implementation of all the changes should be coordinated. - - _ _ _ - - - _ - _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l
QAP 1100-13 Revision 1 f.
Reload licensing submittals shall be reviewed for changes to the QGAs and calculations. The fuel contract specifies that GE will perform a review and update of QGA parameters effected by the reload. The results of this review shall be evaluated. This review should be coordinated with the review of the reload Tech Spec change to identify all changes to the QGAs which need to be completed prior to unit start-up.
g.
Changes or suggestions made by plant personnel should be reviewed for potential changes to the QGAs.
Comments made by operating staff should be documented and evaluated.
Comments and suggestions from classroom training shall be gathered by the training department and given to the QGA committee.
h.
Evaluations from simulator training and certifications should be reviewed for changes to the QGAs which might improve operator performance.
These shall be written up by simulator personnel or transferred from review of the training documentation by training personnel and given to the QGA committee.
1.
Comments, suggestions, findings and observations from QA audits of the QGAs shall be evaluated and appropriate changes shall be made to the QGAs.
Response commitment dates shall reflect the necessary requirements for adequate validation, verification, and training.
2.
The calculations required to support the QGAs shall be maintained and controlled to prevent unapproved changes.
a.
The method for controlling the QGA calculations is outlined as follows:
(1)
The calculations need to be controlled to prevent unauthorized changes.
After review and approval, the calculations shall contain a current revision date and number and previous revisions shall be identified as superseded and retained.
If a complete new set of calculations are performed due to changes in the generic owners group calculations, the new calculations shall start with a new rev number of 1.
The old calculations shall be identified as superseded and retained.
(2)
Each calculation shall have a review cover sheet showing the current revision, date, and authorization for use, b.
Review required prior to changing calculations.
(1)
The calculations shall be independently verified after they are completed.
Input parameters that have not i
changed from t.he previous calculation do not need to be l
reviewed.
All other input parameters shall be verified j
as correct and the calculations shall be verified.
If I
the calculation is a new calculation, all input l
parameters shall be verified. The source of the input data shall be identified with the input parameters.
l l
I QAP 1100-13 Revision.1 l
(2)
The calculation shall be on-site reviewed and approved for i
use in the procedures. The review will be documented on a-cover sheet that is kept with the calculations.
(3)
After approval, the calculations shall be placed in a l
controlled file. The superseded calculation shall be retained with an explanation of why it was replaced.
(4)
The procedures and the Plant Specific Technical Guide (PSTG) shall be reviewed.for changes required by the.new calculation, and appropriate procedure changes shall be initiated.
)
I 3.
The following steps provide the actions necessary to prepare changes j
to the OGAs.
j a.
Preparing changes to the procedures.
(1)
When reviews have identified changes that are required or desired to the OGAs, the following reviews need to be performed.
(a)
The PSTG shall be reviewed for changes that may be required.
(b)
If changes to the PSTG are required, the modified PSTG shall be reviewed against the Emergency Procedure Guidelines (EPG).
If any deviations were created by the change, a technical justification l
shall be prepared documenting why the deviation was j
made. The PSTG and the deviation document shall be I
tracked with a revision number and date.
(c)
The modified PSTG and any technical justifications shall be on-site reviewed. The reviewed copy shall be maintained on file. The previous revision shall be retained as a plant record.
(d)
The writer's guide shall be reviewed for any changes that would be needed to accommodate the proposed changes. Any changes to the writers guide shall be reviewed against NUREG-0899 for compliance with the requirements in that document.. Any differences that arise between the writers guide and NUREG-0899 shall be documented.
(e)
If the writers guide has been modified, the revised writers guide shall be on-site reviewed. This review shall include a review for addressing " human factors" concerns. The writers guide shall be tracked with a revision nwnber and date.
The approved writers guide shall be retained on. file and the superseded revision shall be retained for plant records. -
QAP 1100-13 Revision 1 (2)'
The proposed modifications shall be made to the QGAs in accordance with the approved PSTG and writers guide.
The changes that are made will be incorporated into draft revision copies of the procedures. These copies shall be clearly marked as draft copies not approved for use.
b.
Verification of the draft procedures shall include the following itemst (1)
The draft procedures shall be reviewed against the PSTG to verify that the procedures accurately follow the PSTG.
Any differences between the PSTG and QGAs shall be rectified by revising the draft procedures or revising the PSTG.
(2)
The draft procedures shall be reviewed against the writers guide for adherence with the methods and controls specified in the writers guide. Any discrepancies shall be rectified by changing'the draft procedures or revising the writers guide.
(3)
The procedures shall be walked down by licensed personnel to assure that the changes will work and accurately reflect the plant equipment. The results of these walkdowns shall be documented. Any discrepancies noted shall be justified or incorporated into the draft procedures.
If changes are made to the procedures, the previous steps in this section~shall be repeated.
(4)
A table top exercise shall be conducted to simulate actual use of the procedures to assure that they will perform as expected. The results of'this exercise shall be documented.
Any discrepancies noted shall be justified or incorporated into the procedures.
If changes are made to the procedures, the previous steps in this section shall be repeated, c.
A multi-disciplined on-site review shall be established to review all of the documentation associated with the change.
The committee shall document its review and provide feedback on the proposed changes. Any changes that are required to the procedures shall be validated again.
Changes to the PSTG and writers guide shall be reviewed as described above. The committee shall prepare a complete safety evaluation for the change in the 50.59 format.
)
(1)
The review shall contain operating and technical personnel.
(2)
Other disciplines shall be included on the review as appropriate.
(3)
The review shall contain personnel quallfled to review the changes for " human factors". _ _ _ _ _ _ _ _ _ -
QAP 1100-13 Revision 1 l
(c)
Review the procedure for adherence to the technical calculations.
(d)
Review'the verification and validation documentation for the change to assure that adequate validation was performed and the procedures have been checked properly.
l (e)
Review the changes to assure that " human f actors" concerns have been addressed and the procedures are usable by operators.
1 (f)
Revise the safety evaluation to reflect any changes since its preparation.
f.
Training requirements for the change.
(1)
The QGA committee shall determine the training l
requirements for the changes. The reasons for the decision on training requirements shall be documented.
l This training may include any or all of the following l
(a)
Written training in the form of " required reading".
(b)
Classroom training.
(c)
Plant Walkdown training.
l (d)
Simulator training.
l (2)
When the training requirements have been determined, the training department shall schedule the training and l
arrange to have the training completed.
I l
I' (3)
Any required training materials shall be prepared. This may be done by the QGA committee or the training department.
4 l
(4)
The training shall be documented when it is completed.
l This documentation shall be retained in the training l
records system.
)
l g.
Final review and implementation.
l (1)
The on-site review shall verify that all training required has been completed.
l (2)
The on-site review shall determine if any changes were i
required as a result of feedback during training.
If changes were required, the committee shall determine I
where in the change cycle these changes need to be incorporated.
I I
-e-
QAP 1100-13 Revision 1 (3)
The on-site review shall sign the procedure change cover sheet to authorize the procedure for use.
(4)
The Station Manager will approve the use of the procedures.
(5)
The procedures will be distributed and controlled in accordance with the station procedure program.
4.
Making temporary changes to the QGAs.
I a.
If a temporary change is required to a QGA, that change must be reviewed by a qualified reviewer for the following:
(1)
Does the change affect any QGA calculations.
(2)
Does the change deviate from the PSTG.
(3)
Will the change require verification.
(4)
What training will be required prior to the change.
b.
If any of the first three are true, then the QGA can't be changed by a temporary procedure, c.
If the first three are not true, and the only training required is written " required reading", then the change may be made as follows:
(1)
Prepare the change as any temporary procedure is prepared.
(2)
Prepare the " required reading" training package on the change.
(3)
Obtain approval for the temporary change and make copies in accordance with QAP 1100-5, Temporary Procedure and Temporary Changes to Permanent Procedures.
(4)
Inform the on shift licensed personnel of the change and the training package.
Assure that the training is documented.
(5)
For subsequent shifts, the SCRE will be responsible for training all on shift licensed personnel on the change as soon in the shift as possible.
(final) _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
QAP 1100-13 Revision 1 l
d.
Validation of the procedures.
(1)
A review of the changes shall be made and documented to determine if the changes require simulator validation of the procedures. The review documentation shall include as a miriimum a description of the changes that were made and the effects of these changes on the use of the l
procedures. All reasoning for the decision not to l
conduct a validation shall be carefully documented to provide an auditable explanation of the decision.
(2)
If simulator validation is required:
(a)
Scenarios shall be prepared to test the changes made to the QGAs.
The scenarios shall be developed with the assistance of the training department.
The training departemnt will make arrangements for obtaining simulator time.
Personnel for performing the validation shall be scheduled with the assistance from the operating department.
(b)
The validation shall be performed. The validation team shall include personnel required to operate as well as personnel to evaluate performance.
As a minimmn, three licensed individuals are required for operating the simulator in addition to evaluators. The results of the validation shall be documented.
(c)
The documented results of the validation shall be evaluated and any discrepancies shall be l
justified.
If the procedures are modified as a l
result of the validation, all the previous steps I
of the verification shall be performed again.
A decision shall be made and documented as to whether the validation needs to be repeated following the chenges.
e.
Final review of the proposed changes by the review committee.
1 (1)
The On-Site Review Committee shall perform a final review of the proposed changes, including the results of the validation.
(2)
The on-site review shall document the following in its final reviews (a)
Review the procedures for compliance with the EPG, PSTG, and any technical justifications.
(b)
Review the procedures for adherence with the writers guide.
k/bcAmedG PROPOSED ACTIONS e Programmatic Issues e Imediate EstablishIntegratedE0PProgram i
DevelopmentandMaintenancetoInclude:
i CalculationControl PTG Writer'sGuide Verification MultiDisciplineReview Validation Training i
ChangeControl CalculationControl i
i NRCConcern(DWPress) 1471Hl04632 l
l PROPOSED ACTIONS e Programmatic Issues (Continued) s Short Term e
CalculationControl ReviewandReviseCalcs.
1 IndependentCheck Approval e
PTG Revision l
DuetoRevisedCalcs.
Include NRC Coments/ Concerns Provide Technical Justification for Deviation I
fromEPG RewriteWriter'sGuide s
GenerateDraftQGAusingNewE0PControlProgram i
i Verification MultiDisciplineReview i
1471Hl04632 O
PROPOSED ACTIONS e Programmatic Issues (Continued)
Validation (Simulator) e Training e
BasedonMagnitudeofChanges e
ImplementWithinOneWeekofTrainingCompletion e
ImplementationLongTerm e
ReviewRev.4forProgramEnhancement s
E0PStaffingConsiderations e
1471Hl04632
PROPOSED ACTIONS e
PerformanceIssues e
Imediate ReinforceControlRoomResponsibilities i
SE+E0P SCRE+BigPicture ReinforceConductofOperations(Procedure i
Adherence)
Clarify 00PonVenting i
PlaceKeepingMethod i
1 UseofMarkers GE Review of Past Evaluations for Programmatic i
Issues l
l 147W04632 1
PROPOSED ACTIONS e Performance Issues (Continued) i ShortTerm SimulatorRequalEvaluations 5CrewsBeginning8-2-88 e
(IncludesObservedCrew)
Asst. Supt.Oper.toEvaluateallCrews e
OfferNRCIndependentOverview e
PTCOverviewandReportonEffectiveness i
l.ongTerm e
i NewSimulator(SiteSpecific) i 1471Hl0463l 1
E0P TRAINING ExistingProgram 1.
Classroom Lecture 1-1/2 Days 2.
Simulator 8 Days 3.
GE Established Scenario With Station Guidance 4.
SimulatorExam IndependentGroup, Write, Administrate,andEvaluate 5.
Accredited Program 6.
NRC Exams in 1987 1471Hl0463l
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