ML20236C256
| ML20236C256 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 07/14/1987 |
| From: | Hunsader S COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| 3320K, NUDOCS 8707290386 | |
| Download: ML20236C256 (6) | |
Text
_
- )
J/
~ Commonwealth Edloon -
e I
i Ons First NetiorrJ Plaza, Chicago, Illinois
- Address Riply to: Post Offica Box 76/
Chicago, Illinois 60690 0767. '
July 14, 1987
'Mr.' Thomas E. Murley, Director-Office of Nuclear Reactor Regulation U.S. Nu' lear Regulatory Commission c
Washington, DC. 20555
Subject:
- Byron Nuclear Station Units 1.and 2 Braidwood Nuclear Station Units 1 and 2 Emergency Operating Procedures NRC Docket Nos. 50-454/455 and 50-456/457 l
References (a): March 26, 1985 D.H. Smith letter to l
H.R. Denton (b):. September 19, 1986 P.C. LeBlond letter
')
to H.R. Denton
Dear Mr..Murley:
Reference (a) transmitted to the NRC the Byron and Braidwood Stations Procedures Generation Packages (PGP) used to " construct the Emergency.
Operating Procedures (EOP)" for each station. Subsequently, Attachment 2 in
)
reference (b) provided the response to a list of eleven (11) NRC concern areas
)
associated with the PGP review.
The purpose of this letter is to provide Commonwealth Edison's supplemental response for the ten (10) items committed to in reference (b).
These include Item numbers B.2.a,b,c,e; B.6.; B.7; B.10; B.11.a and B.13.b,c.
The response is included in Attachment A and it reiterates the NRC item with-the Edison response following.
)
4 Please address any questions concerning this matter to this office.
Very truly yours, q
l b
. C*
= =,
S. C. Hunsader Nuclear Licensing Administrator Attachment cc:
J. Stevens - NRR g
.;i Braidwood Resident Inspector
-j 8707290386 870714*
~
PDR ADOCK 05000454
.d )
3320K F
PDR;
.{
.i
U.S.N.R.C.
NUCLEAR REACTOR REGULATION
~87 JUL 27 A9 :17 l
1 e
-- 3 i
l ATTACHMENT A Item B.2.a criteria for the various instructions within the writer's guide need to be sufficiently explicit to assure common understanding by procedure writers. The writer's guide contains a number of statements in which several format options are available to procedure prr. parers. The guidance provided for formatting procedures should be revised in the following cases:
i a.
Section IV.B.4.c states that the " order of the symptoms is left to the discretion of the writer, as well as the choice to use strict ordering...or a loose ordering." The writer's guide should be revised to provide criteria for ordering of entry conditions or symptoms, and to designate the use of either numbers, letters, closed bullets or open bullets, pECo Response to B.2.a The writer's guide has been revised to require the use of "a loose ordering" of entry conditions or symptoms, and to designate the use of "open bullets" to indicate a choice of symptoms and " closed bullets" to I
indicate each symptom must be accomplished.
I l
Item B.2.b I
section IV.D.2.a indicates that figures and tables containea within the 1
text of a procedure may be titled in either of two ways, depending upon l
the writer's choice. This section should be revised to designate a single method for titling figures and tables contained within the text of a I
procedure.
CECO Response to B.2.b The guide has been revised so that figures and tables that are part of a procedure step are not labeled. A single method is provided for labeling i
figures and tables that are not integral parts of a procedure step.
l Item B.2.c Section IV.D.2.d should be supplemented with an example of how a table in a procedure should be formatted.
CECO Response to B.2.c Section IV.D.2.d has been supplemented with an example of how a table in a t
procedure should be formatted.
3320K
)j Item B.2.e Section VI.I indicates that equipment, controls and displays may be l
identified in any of several methods, depending on the discretion of the writer. THis section should be revised to designate a preferred method-for identifying equipment, controls and displays, and to provide guidance for its consistent use throughout the EOPs.
CECO Response to B.2.e This section has been revised to designate a preferred method for identifying equipment, controls and displays, and to provide guidance for its consistent use throughout the EOPs.
Item B.6.b_
In order to sufficiently emphasize GO To statements,Section VI.H.2 should instruct that the words GO TO be fully capitalized.
CECO Response to B.6.b In order to sufficiently emphasize "GO TO" statementsSection VI.H.2 requires the first letter of each word (the G and the T) to be capitalized. The "GO TO" statements are also required to be in bold faced print. Capitalizing the words "GO TO" would cause confusion since they directly preceed the capitalized procedure numbers. Therefore the complete Words "GO TO" will not be fully capitalized.
Item B.7 The correct use of punctuation can significantly increase the understandability of procedures.Section V.E discusses the use of hyphenation and gives examples of instances where words may be hyphenated to prevent confusion with other words, certain rules given in this section, 2.d.f, and 1, do not reflect standard English usage, do not appear to make these words less confusing, and should be avoided.
CECO Response to B.7 The rules of concern in Section 2.d. f, and 1, have been changed to reflect standard English usage.
-_________a
--3 i
1 d
Item B.10 Section VI.E.1.b states that, as a general rule, diagnostic instructions j
J shall not appear in high-level steps.
Consideration should be given to providing the same guidance regarding the use of operative instructions in high-level steps.
For example, an example given in Section VI.E.2.b has a high-level step " START AN RCp".
However, this is not an instruction to
)
start the pump per se, but a heading for the substeps to follow. The j
substeps may provide actions that are to be taken (e.g., start the associated lift pump) before the RCp is started. This situation would be avoided if Section VI.E.1.c stated that operative instructions shall not
{
appear in high-level steps.
CECO Response to B.10 Section VI.E.1.c states that operative instructions shall not appear in high-level steps.
Item B.11.a Notes and cautions provide operators with important supplemental information concerning specific steps in the EOps. The information provided in Section VI.G should be revised to address the f0llowing points:
a.
This section should provide an alternate emphasis technique for the distinction between cautions and notes. Cautions are currently to be distinguished from notes by the use of all capitals in the text. The use of all capitals makes text more difficult to read than mixed case and should be avoided. As an example of an alternate method, notes j
may be enclosed with straight lines instead of asterisks.
CECO Response to B.ll.a l
Cautions will use mixed case letters rather than all capitals. Caution will be surrounded by asterisks and notes by a solid line, in order to j
emphasize the distinction between cautions and notes, i
Item B.13.b Status trees provide important safety information to operators. Thus, it is critical that they be completely understandable. The guidance provided in Section VII.O for the preparation of the status trees should be expanded with regard to the following points:
a.
Because hand-drafted flow charts are more difficult to read than those produced by computer graphics or professional draftsman, this section should be expanded to include guidance for the size of letters and symbols to be used and criteria for readability.
_4_
CECO Response to B.13.b Section VII.0 has been expanded to include " guidance for the size of letters and symbols to be used and criteria for readability".
i
' Item B.13.c The entire text of the sample status tree presented in Figure 8 is capitalized. If all words are so capitalized, then capitalization cannot be used for emphasis; furthermore, text written in all capitals is more revised to state that capitalization in status trees will conform to the rules established for other EOPs.
CECO Response to B.13.c Section VII.G for the preparation of the status trees has been expanded.to require capitalization in status tree text to conform to the rules established for other EOPs.
i 3320K
_ _. - _. _ _ _ _. - - _ _. -