ML20236N337
| ML20236N337 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 11/10/1987 |
| From: | Fay C WISCONSIN ELECTRIC POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20236N340 | List: |
| References | |
| CON-NRC-87-109 TAC-44329, TAC-44330, VPNPD-87-482, NUDOCS 8711160120 | |
| Download: ML20236N337 (16) | |
Text
i 3
f I
1 3
WISCONSIN CtflC F3WER COMPANY 231 W. MICHIGAN, P.o. BOX 2046, MILW AUKEE, WI 53201 (414)221 2345 VPNPD-87-482 NRC-87-109 i
)
November 10,-1987 U. S. NUCLEAR REGULATORY COMMISSION Document Control Desk Washington, D.
C.
20555 Gentlemen:
DOCKETS 50-266 AND 50-301 EMERGENCY OPERATING PROCEDURES GENERATION PACKAGE (TAC'S 44329 AND 44330)
POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 By letter dated June 1, 1984, we submitted to you our Emergency Operating Procedures Generation Package (PGP), which described the process by which we planned to adopt and implement an upgraded set of Emergency Operating Procedures (EOP's) for Point Beach Nuclear Plant, based on the Westinghouse Owners' Group Emergency Response Guidelines (WOG ERG's), Revision 1.
In a letter dated May 5, 1987, you provided us with a Draft Safety Evaluation on car PGP.-
In this Safety Evaluation, you identified a number of concerns and' requested that we amend our PGP or provide justification for not making changes as appropriate.
You also requested an updated PGP. to this letter is a detailed response to each concern expressed in the Draft Safety Evaluation.
Each item
-number corresponds with the respective item number in the Draft Safety Evaluation.
Changes identified in this attachment will be made'as soon as practicable.
Attachments 2 through 4 consist of our Emergency Operating Procedures Writers Guide, Verification Procedure, and Training
. Course outline, respectively.
These documents plus the Point Beach Nuclear Plant Control Room Design Review Program Plan, Revision 1, submitted on March 31, 1987, which describes and provides procedures for EOP validation, make up our updated PGP.
f egugggg gugp
>\\,
=
y
- G n
M
.I; t 4r 1
~-
j J
-NRC Docume'nt Control Desk-November'10, 1987 s
Page 21 Also provided for your information in. Attachments 5'and.6~are a'n[ example EOP.and_a Critical' Safety Function Status _ Tree as implemented _at Point Beach.-
We;believe our EOP; generation process.is well controlled and'
. documented,Lresulting-in an improved and cohesive set of EOP's' q
'for Point. Beach Nuclear Plant.
We also believe that we haveL met the-intent of NUREG: G737, Supplement'1,.and NUREG 0899 with-Lthis process.
We hope'that our response to the specific comments'in your Draft Safety Evaluation and'our updated PGP adequately address your concerns.
Should you have any further. questions or require' additional "information to bring your, evaluation'to a satisfactory conclusion, please_' contact-us.
Very truly yours, h
C. W.j ay-Vice President Nuclear Power.
' Attachments 1
1 i
i
L j
'Page 1 i.
h; ATTACHMENT 1 I
l RESPONSE TO NRC PGP SER DATED 05-05-87
'l l
Plant-Specific Technical Guidelines Item 2.A.1 I
Plant specific E0P information which deviates from or adds to the generic technical J
guidelines, along with supporting information, is documented in our Deviation Documents. The E0P Verification Procedure requires a check for documentation of deviations between the ERGS and E0Ps.
. Writer's Guide Item 2.B.1.a
.In the. writer's guide the term." action" refers to operator manipulations or
. assessment of plant' equipment and conditions. Examples are repositioning of j
a control switch or reading an indication. We discourage the placement of these types of operator actions in potes.
We do not consider operator movement through the procedures via transitions and branching to be " actions" in themselves thus notes and cautions which-direct the operator to move through the procedures are acceptable. This-is censistent with the WOG - ERGS which include transitions in notes and cautions when necessary.
[
The writer's guide section 5.5 states that procedure transitions can be included in notes and cautions when necessary.
g Items 2 B.1.b & d I
In order to distinguish the caution from'the note the word caution will have an asterisk on either side.
Example:
- CAUTION *-
Also to distinguish the caution from the note, and to eliminate some capitali-zation, the statement behind the note will not be in full capitals. The word note will remain in-full capitals.
Example: NOTE:
)
Example:
- CAUTION
- THIS IS A CAUTION.
l NOTE: This is a note.
I Appropriate revisions will be made to section 7.7 of the writer's guide.
I
~4 l
J
l Page 2 Item 2.B.1.c The present version of the writer's guide, Revision 5, dated June 7, 1985, section 5.5 first paragraph, last line states, " Cautions or notes that apply to the entire procedure are placed at the beginning of the procedure; those_that apply to a portion of a procedure are placed immediately before the procedural steps to which they apply."
It is our intent that via this instruction, cautions and notes pertaining to a
~
particular step will be wholly contained on a single page, and be placed immediately before the applicable step, on the same page as the step (s) to which
-they. apply, whenever possible.
In keeping with the practice of keeping information short and concise, none of the cautions and notes are long enough to require more than a few lines.
1 The writer's guide will be changed to explicitly state that 1) cautions and notes will be wholly contained on a single page and 2) cautions and notes which apply to a single step or group of steps will be placed directly before the steps to which they apply including, whenever possible, placement on the page where the step begins; and 3) a page break between a caution or note and the applicable high level step is not desirable.
Item'2.B.2.a The writer's guide _will be rewritten as follows to address the use of and and or
^
in the same logic statement.
The useaof and and or within the same action shall be avoided. When and and or are used, an explicit form shall be used as shown in this example:
Example:
IF both condition A and condition B occur, THEN go to step 5.3.6.
)
1 EE l
l IF both condition A and condition C occur, THEN go to step 5.3.6.
I I
Item 2.B.2.b e
The writer's guide does not presently define the word "not" used as a logic term.
Instructions for the use of not will be added to the writer's guide in the follow-ing manner; "al) statements, other than logic statements, which use not shall be I
the opposite of the input statement used."
l l
Item 2.B.2.c
)
l IF, THEN, and WHFN are the only capitalized logic statements because this form
)
provides a clear understanding to the operators; the separation of the two parts of the logic statement is very obvious.
Confusion is reduced by not making every other word capital. The other logic terms (i.e., and, or) are underlined j
to show there is a difference between a logic statement and a regular I
conjunction, 1
l l
l
g, Page 3 I
Item 2.B.2.d i
It'is not possible for E0P users to mistake the conjunctions "and" and "or" for
)
l
' the logic terms "and" and "or".
If the words "and" or "or" are in the antecedent, j
then it is a logic term.
If the words "and" or "or" are in the consequent or other statement, the words are conjunctions. This usage is not confusing to the
-operator.
Item 2.B.2.e The embedded logic has been removed from the example E0P.
Further, to prevent the use of embedded logic, the following section will be added to the writer's
' guide.
Actions which are embedded as in the following example, will be avoided because the action 1) may be overlooked and not be performed, 2) it is difficult to verify the performance of each action step when a checkoff or sign-off is used, and 3) it can be confused with a logic statement.
Example: Verify all SI accumulators are isolated, THEN, cooldown pressurizer with auxiliary spray.
Item 2.B.3.a Limits'should'be expressed quantitatively except for those occasions when specific values and parameters cannot be applied.
1 An example of a non-quantitative limit is the use of a limit curve. The use of a curve as an example will be included in the writer's guide. The specific wording of section 5.1.5 will remain as is.
l
-i Item 2.B.3.b Section 5.3 of the writer's guide states that a' contingency action, if it exists, is included unless it degrades from the appropriate actions. We will
.s revise the paragraph as follows:
Contingency actions, if they exist, which.do not degrade performance will be specified for each circumstance in which the expected results or actions might not be-achieved. Contingency action which could degrade performance are those which are.1) overly difficult to accomplish or 2) provide minimal benefit when compared with leaving the expected condition unsatisfied. Typical contingency actions are directions to override automatic centrols and to initiate manually actions normally initiated automatically.
Item 2.B.3.c References to "the user" will be removed from sections 5.4.7 and 5.4.8 of the writer's guide.
i 5
?
Page.4 g..
7 tem 2.B.3.d Insertion of a new heading labeled " Attachments" and descriptions of acceptable attachments as follows will be added to the writer's guide.
j
.A.
Appendices i
1.
Appendices shall contain information of a narrative type.
2.
Appendices should be typed and have a letter designation.
Example: APPENDIX "A" 3.
The text of the appendix should be in block form with headings underlined (see example in E0P, Attachment 5).
B.
Figures Figures shall contain information best displayed in a graphical or j
pictorial format. Rules regarding figures will be amended as detailed
)
in response to-items 2.B.3.f and 2.B.3.g below.
Item 2.B.3.e-Table 2 will be expanded to include all abbreviations, acronyms, and symbols encountered in the E0Ps.
Item 2.B.3.f The writer's guide states figures should be "of sufficient size." There is no I
characteristic size of figures to be used because the content of the figure determines the size. The following statements will be inserted into the writer's i
guide:
1.
Figures shall be set in the middle of page.
2.
Figures shall have'an underlined title capitalized in the pitch and type style of the procedure.
3.
Each figure shall be wholly contained on a single page.
4.
Size shall be surficient enough to be seen by a user, at normal I
reading distance, without the aid of an instrument (i.e., magnifying
(
glass).
j l
Item 2.B.3.g f
The writer's guide section 7.5.7 will be revised to state, " Items in figures which need to be clearly identified will be labeled. The labeling within the figures l
should be of a proportion which allows reading from a normal distance."
Item 2.B.4.a i
s l
= _, _ _ - - -
f I
I 1
q
.Page'S
.g
.j 5) k!O
.a
,.s l '
1' 7 N }i JIn'oEder.to fulfill the; re'quirement for '.' Instructional content" of the writer's
'4 iguide,jthe following~ statement.will.be added.
s
-^9
- j
, L _*.
\\
/ Sentences which: require the operator to act or make an observation shall be'
. written ' as' a' directive'.
~
A:
, Item'2iB.4.b
-The-writer's guidefwill be exp'anded'to' include'a description of the delineation
'ofJimmediate-operator actions in the following manner.
it
, Delineation of immediate ope ator action will be by a note at the beginning of
.the procedure which states:
a
- " NOTE:. Steps (number through_ number) are immediate actions steps."
i o
<l JIn addition, the step' number of immediate. action steps will be enclosed-
'in'a circle.
I
- Item'2.B;4.c
- +,
.In theLcompleted EOPs, the useJof boxed steps is explained in a nota at the beginning'of'all procedures which contain such steps. This note explains that-x
~
the/ steps outlined by a box are1only completed if a loss of offsite AC has.
occurred. This appropriately designates the boxes used in the E0Ps; We will denote this in the-writer's guide as follows:
'When'a' step'in a procedure requires us-to act:in a case of loss of'offsite AC,-
these will be [noted at the beginning of the procedure ~with the'- following:
(NOTE: The steps outlined with boxes tare only to be done if a loss of offsite' AC has. occurred.
. Item 2.B.4.d u
q The'following statements shall be added to'tihe. writer's guide.
L t
l'.
. Steps which are intended to. verify a specific action shall include the.
j
' word ~ verify 1
~
2.
- S'teps of continuous or periodic concern / applicability are identified in the E0P background documents.
l 3.
Steps may be performed concurrently with other steps unless otherwise-
- j identified.
]
.l
- 4.
Alternative,-equally acceptable. actions for steps shall be identified y
using an' appropriate,' defined symbol.
[
5.
Steps'which do not state specific actions should be considered as b
- diagnostic in a general' sense.
j 1
11 l
_j l
+ +
2 --
-_=-:___--:___---__--_-____. __- ____---___--_-__________-_____.____-_--_.---:-~
N Paga.6 s
^
3
-4
' I tem - 2. B. 5 '. a
- The writer's. guide sta'tes that referencing should be minimized. Branching I
Eshould also be minimized. The'following addition ~to the writer's guide will be
.made.
l
lTo) minimize potential operator confusion branching will be used when the
~
operation is.to leave one procedure or step and'use another procedure or step.
LTheL use of branching shall be minimized."
l
'-K l
' Item'2.B.5.b In order to' conform to the earlier statements in the writer's guide, the words "go'to";will_not.be. capitalized. This phrase is not one of the three logic.
statements,' ifs WHEN,-THEN.
Capitalization of "go to" would cause it to be 7 ncorrectly interpreted as a logic statement thereby causing confusion.
"Go to" i
statements are emphasized by insuring they are a high-level step when included in the' Action / Expected Response: column of the E0Ps.
It was observed during simuletor exercises.that this was sufficient. emphasis for these steps.
Item 2.B.5.c Formatting:a reference td a step;in another procedure (i.e., Go to E0P-1) has i
- been-addressed in the latest writer's guide revision section 5.8.
, Item 2.B.5 d i he= word " transferring" will be replaced with'the word " branching" in order to n
T 3z be consistent with other sections of the writer's guide.
j 1
EItem 2.B.5.e 1
Clearl. defined separators and/or_ tabs between each respective E0P, CSP, andlECA
-)
ifor_ easy _ identification are used'at PBNP but were'not' mentioned in the writer's 0
-guide.
.A short description of the; applicable E0P,LCSP, tor ECA marker will be cplaced with the numberingLsystem.
Item 2.B.6 i
-Place-keeping systems are not described in'the writer's guide. The writer's
]
' guide provides. instructions for the procedure writer.
Place-keeping is for the j
. operator. 'Every. operator has his own way of keeping track in the procedures.
l
. Colored shoestrings are available for page. and' procedure. place-keeping if the operator chooses to use them.
j
~
'1 i
Item 2.B.7 4
The adoption of an approach to associate common terms directly with the panel C
l engravings is being accomplished as part of the control room design review lprojecti, Any changes required as a result of this review will be incorporated
?into the Writer's Guide and E0Ps as appropriate.
)
i
h Page.7-L Item 2.B.8.a.,b.,c.,d.,e.
These steps describe the use of the E0P procedures. Use of procedures'is addressed l
elsewhere in our E0P program including the verification and validation,'which in-J
-sure the minimum number of operators on hand can efficiently and effectively use j
the E0Ps to mitigate the consequences of an accident.
Item 2.B.9.a l
The procedure designators were changed in the latest revision of the writer's guide. The problem with the ES procedure designator no longer exists.
Item 2.B.9.b A section will be added to the writer's guide to include status trees as follows:
)
Each status tree is derived from the Westinghouse Owners group status trees j
and will be identified with the designator ST followed by a sequential number.
i Formatting shall be explained in the writer 8c guide as follows:
critical safety function status trees will be presented in the block version. The trees are represented horizontally along the page. Color
. coding and line pattern coding shall be used from each branch point to its I
terminus. All text'shall be at least as legible (type size and spacing) as the instruction steps in the guidelines. Each status tree shall have a l
designator block identical to that used in the standard guideline format.
An example status tree is included.
(See attachment'2) j
'l Item 2.B.9.c 1.
The cover page specifically identifies the EOP.
a 2.
The revision number and date are included in the title page title l
block.
l 3.
The page number but not the total pages is provided in the j
procedure. The total pages number is not given in order to 0
-facilitate the process of changing the procedure. The intent of f
stating the number of pages is met by placing " continued" on the i
bottom of all pages except the last page which is labeled "End".
{
i 4.
.A place for review and approval is not provided for each procedure.
l This is accomplished through the administrative review and approval process governed by PBNP 2.1.1 " Classification, Review and Approval j
of Procedures".
l 5.
Indicating the unit and facility applicability is not necessary i
because the EOP, ECA, and CSP procedures are identified to apply j
to Point Beach Nuclear Plant and they apply to both units.
These methods of procedure and page classification is consistent with Point Beach
[
Nuclear Plant Administrative Procedures.
\\_
Page 8 h*
Item 2.B.9.d 3
Writer's guide section 3.3 is consistent with present practice at PBNP for the
~ identification of procedure pages. The Verification Procedure was revised to be consistent with this practice.
~
t Item 2.B.9.e l
An addition to the writer's guide will state, "Each action step shall be wholly contained on a page when step content allows.
If step' content exceeds allowable page space,.the step will be conspicuously identified indicating the continuation."
Item 2.B.9.f Examples will be added to the writer's guide to show formatting style of a foldout page, a figure, a table, and a status tree.
i Item 2.B.9.g 4
i In the area of general typing instructions the following addition will be made.
" Type style is courier with pitch set of 12."
Item 2.B.9.h l
The writer's guide will be changed to address a consistent form of measurement l
for margins.
]
' Item 2.B.9.i The writer's guide will be' changed to, "There will be one blank line between subsets in the action or contingency action columns. Additional blank lines may be'~used when necessary to maintain' alignment of the action and contingency action."
l Item'2.B.10.a 4
)
Whenever possible complete sentences are used. There'are cases when sentence fragments function best in the format used for E0Ps. The ERGS use sentence i
fragments when they are appropriate. No change will be made to the writer's j
guide.
Item 2.B.10.b The word " parenthesis" has replaced the word " brackets" in section 5.8.
Item 2.B.10.c The use of brackets is explained in the latest revision of the writer's guide section 6.3.1 (attachment 2).
Item 2.B.10.d The recommended words in the writer's guide are commonly accepted words used in
'the day to day operations at Point Beach Nuclear Plant.
Further explanation is j
not considered to be needed.
i l
l
'l j
w:
s n
PageL9' 3
l 5
l Item 2.B.10.e t
A parenthesis can denote equipment location. The addition of~" equipment location" to the list in section 6.3.4 of the writer's guide in accordance with 5.9.4 of the same guide will be accomplished.
J l
Item 2.B.10.f The addition of symbols > and <, greater than and less than, along with defini-tions,.will be added to Table 2 of the writer's guide.
d Item 2.B.11
- j
' k Necessary revisions to the EOPs' are identified by the administratively controlled a
. processes by which modifications, technical specification changes, and procedures are reviewed and approved. In addition, procedures are periodically reviewed to insure they are up to date. Revisions that are identified during these processes X
.are made in a timely manner.
. Item 2.B.12.
i We do not believe that-it is riecessary to address the quality of reproduction in the Writer's Guide.
It is standard practice with all procedures to insure copy quality approaches that of the original.
Item 2.B.13 I
Availability / accessibility of procedures is addressed by Point Beach Nuclear Plant Administrative Policy.
. Verification and Validation Program
-Item 2.C.1 I
l Providing the assurance of a high level of probability that the PBNP E0Ps will work was an inherent overall objective'of all of the integrated NUREG-0737, supplement 1,' activities at Point Beach for improving our emergency response i
capability. These activities included implementation of upgraded E0Ps, the
. j addition of a Safety Assessment System (SAS), the upgrading of post-accident 1
monitoring equipment for Regulatory Guide 1.97, the addition of emergency support facilities, and finally the Control Room Design Review (CRDR).
The NRC (in a memo from N. B. Clayton'to D. L. Ziemann, dated April 5, 1984) has recognized that system functions, operator tasks, and operator information i
requirements were analyzed at a generic level when the Westinghouse owners' Group j
(WOG), in accordance with NUREG-0737, Item I.C.1, performed a reanalysis of transients and accidents (many beyond the plant design bases) and prepared a set
(
}
of generic Emergency Response Guidelines (ERGS). The ERGS,'in turn, were vali-
]
dated via simula'or exercises on the callaway simulator (Revision 0 ERGS) and on i
the Seabrook simulator (Revision 1 ERGS). Subsequently, operator tasks were f
further reviewed and instrumentation and control requirements were assessed in l
the development of the PBNP-specific E0Ps, which are based on the Revision 1 WOG ERGS. The upgraded Point Beach E0Ps underwent extensive verification by both
.___mmi__m__
_2
Page 10
,,L, 1
l 4
l the Point Beach Manager's Supervisory Staff and an independent verification team l
and an initial validation on the Kewaunee simulator prior to implementation.
,A final validation of the implemented Point Beach NOPs was incorporated into our CRDR by conducting accident scenario walkthroughs on a full-scale photographic mockup of the Point Beach control boards (Wisconsin Electric has not yet installed a plant-specific simulator). The validation procedure (Appendix H of the CRDR Program Plan, submitted March 31, 1987) states that " validation determines if the actions specified in the E0Ps can be performed by the operator to manage the emergency condition successfully. The validation process will evaluate the aWlity of E0Ps to guide operators in mitigating transients and accidents."
Therefore, we believe that all of the activities discussed above provide a high level of assurance that the control room, the licensed operating crews, the E0Ps, and the supporting emergency response facilities will work together to mitigate postulated transients and accidents at Point Beach and that this objective is well documented.
Item 2.C.2 The verification of the upgraded EOPs, as described in the attached Emergency Operating Procedures Verification Procedure Point Beach Nuclear Plant, Units 1 and 2,. Procedure No. Pll.17 dated March 25, 1985, as well as review by the Point Beach Manager's Supervisory Staff was performed in detail on all of the E0Ps including Emergency Contingency Actions (ECAs), and Critical Safety Procedures (CSPs). The initial validation of the EOPs on the Kewaunee simulator prior to their implementation exercised all of the E0Ps and ECAs except E0P-3.2, Post-Steam d
Generator Tube Rupture Cooldown Using Blowdown. However, E0P-3.1 and 3.3, regarding post-SGTR cooldown using feedwater and steam dump, respectively, were exercised and are similar to E0P-3.2.
In addition, at least one CSP in each function restoration category was exercised. The remaining CSPs are similar enough to those that s ere exercised to provide an adequate validation.
The final validation of the implemented E0Ps was integrated with the validation
]
of control room functions conducted as part of the PBNP CRDR. The CRDR and E0P validation was conducted by performing walkthroughs of emergency scenarios on the l
PBNP control room photographic mockup using licensed operating crews as described ir Appendix H of the PBNP CRDR Program Plan, Revision 1, Procedure s ard Forms for Validating Control Room Functions and Emergency Operating Procedures (ECPs). The i
number of emergency scenarios was expanded from approximately five for validation of control room functions alone, to fourteen (14) scenarios to ensure that all E0Ps
,l (i.e., E0Ps, ECAs, and CSP 3) were exercised.
In addition, any residual steps j
missed in the emergency scenarios due to branching to other procedures were walked
)
through individually. Therefore, we believe that all of the PBNP E0Ps have been adequately exercised.
l Item 2.C.3 A plant-specific simulator is not yet installed at Point Beach. The initial E0P validation was conducted by exercising the draf t upgraded E0Ps on the Kewaunee simulator prior to implementation. The Kewaunee Nuclear Plant is a two-loop Westinghouse PWR similar in design to Point Beach, but with a different control board layout. The development, verification, and the Point Beach Manager's Supervisory Staff review and approval of the Point Beach E0Ps included checks to l
l
l Page 11 ensure that the Foint Beach - specific E0Ps were consistent with the Point Beach control' boards, Instruments, and controls. The final validation of the imple-met.ted E0Ps was conducted as part of the PBNP CRDR using licensed operating crews to walkthrough emergency scena m s on the photographic. mockup of the Point Beach 1
control boards. This final va.!!ation of both control room functions and E0Ps
'is described in Appendix H of the PENP CRDR Frogram Plan, Revision 1, Procedures and Forms for Validating Control Room Functions and Emergency Operating Procedures (EOPs). Associated procedures for Conducting the Systems Functions Review and Task Analysis (SFRTA), Conducting Control Room Inventory, and Verifying Instru-mentation are described in Appendices E, F, and G, respectively, a.
Appendix H of the CRDR Program Plan, Revision 1, describes the criteria used to select emergency scenarios run on the PBNP photographic mockup during the final E0P validation. The full exercise of all E0P steps required fourteen scenarios plus analysis of residual steps The scenarios included the initial plant conditions, action sequences, and expected outcomes for hypothetical plant emergencies and were planned to include a unique set of paths through the E0Ps in order to exercise as much of the procedures as possible. The WOG Task Flow Charts and the list of PBNP safety-and non-
' safety-related systems were used by subject matter experts in operations and human factors engineering to define a sat of scenarios that adequately sampled various emergency conditions and the plant systems used in those conditions.
Selected scenarios included single failures (e.g., reactor trip without SI and large break LOCA), sequential failures (e.g., loss of all AC pc,wer with SBLOCA and steam generator tube rupture with a LOCA), and concurrent failures (e.g., secondary break inside containment with loss of spray capability and uncontrolled depressurization of both steam generators).
b.
All E0P procedural steps (including notes and cautions) that were not validated on the photographic mockup during one of the fourteen scenarios, I
were walked thrcugh individually on the mockup. These residual steps were
]
tracked using task analysis worksheets (TAWS) from the SFRTA,. which were 1
reassembled into sequences representing each scenario. This ensured that I
no E0P steps were missed, j
Item 2.C.4 The Point Beach Technical Specification 15.6.2 and Table 15.6.2-2 delineates the minimum control room staffing during conditions when fuel is in either reactor.
The Operating Point Beach Nuclear Plant Administrative Control Policies and Procedures Manual (QA Volume 1), Section PBNP 4.3, Operation's Personnel Assign-l ments and Scheduling, and Section PBNP 4.2.2, Operating Supervisor requires a l
licensed reactor operator be assigned to the control board of each fueled unit l
and a licensed operating supervisor or shift superintendent be available in the l
control room. During the validation exercises on the photographic mockup, one licensed operating supervisor and one licensed control operator were used to I
I.
walk through emergency scenarios applicable to a single unit.
For scenarios applicable to both units simultaneously (e.g., loss of all AC power), a second l
licensed operator was added to the operating crew to " man" the second unit.
l Therefore, the validation crew sizes and qualifications were consistent with minimum allowed control room staffing levels.
{
Y Page 12 9
It'em 21C.5-l J
, Verification of instruments and controls;that weresidentified-.during the' System j
/ Function-Review and Task Analysis (SFRTA) was accomplished during the'PBNP Control
. Room ~ Design-Review-(CRDR)'. -These tasks are described in the PBNP CRDR Program Plan,. Revision 1, previously submitted to the NRC on March' 31, 1987. -Specific l
- procedures used in the SFRTA', Control Room Inventory, and Verification of Instru-1 mentation are <iocumented'in Appendices E, F, and G, respectively, of the Program
" Plan.
l LItem 2.C.6' During the E0P writing, verification and validation process safety-significant
{
. steps were not specifically identified. However, the verification, review and
~ approval process was sufficient to-identify and correct;possible problems. prior' to: implementation. 'During the. verification process described in the verifiestion
- procedurel(attachment 3) each step of the E0Ps was' compared to.the' generic WOG-ERGS and all deviations including additions and deletions were identified.
l These deviations:and justifications are documented in the Deviation Document.
-i Item 2.C.7.
1
. Changes:to E0Ps are initially prepared and reviewed in accor. dance with PBNP 4.21.
PBNP-4.21 explicitly documents the review process via an.EOP Procedure Change j
. checklist.. The purpose of PBNP 4.21 is to ensure that E0P changes are prepared j
-and reviewed in-a manner consistent with preparation and review of the initial' E0Ps.
q Additionally, prior to any change being implemented, the change must be-reviewed i
3.-in.accordance with PBNP 2.1.1, " Classification, Review, and Approval of-Procedures." This is the same procedure which was followed during the ibitial E0P' implementation.
3 i
{
Item 2.C.8 Because our' reference documents include the.FSAR and current EOPs, any unit l
~
differences would be identified-and would be treated in accordance with the veri-a
! fication.and validation procedures relative to the'WOG-ERGS.
In addition, the l
validation. scenarios walked through on the PBNP photographic mockup were distri-buted between Unit 1 and Unit 2 emergencies to ensure the E0Ps vere validated for both units.
]
Training Program f
Item 2.D.l.a i
Training on E0Ps has been structured such that the operators are stepped through j
the'EOPs from the NUREG 0737 requirements, the Westinghouse Owner's Group generic l
ERG and finally the E0Ps for Point Beach Nuclear Plant. Through this process il F
the operator develops the knowledge as to how the E0Ps are structured and the basis for the methods for transient and accident identification and mitigation
.i through the use of the EOPs. This training includes instruction on each E0P, j
-ECA and CSP.
l 1
e s
I' u n__. _ _ ___ _ __
t
- 7 Ls Page 13 L
~
q p
,s Item 2.D.1.b' i
In addition to the training described in 2.D.1.a, the' function and operation of l
L systems in mitigating transients and accidents,is covered during operator training on individual systems and integrated operations. This training insures the l
operator understands'the use of the necessary systems and demonstrates the ability to use these systems as required by the E0Ps.
Item 2.D.1.c 1
, Understanding the technical content of procedures,-including the E0Ps, is an under-lying objective of the operator training program. The program follows a logical progression from the physical fundamentals through system design, operation and I
finally integrated system and plant response. This, with a knowledge of E0P structure and objectives, insures the operators know and understand the overall ob4ctives of each procedure Given the procedures the operator also demonstrates ha ability to properly use the E0Ps using the full-scale control rocm photographic mockup, the control room and simulator exercises as appropriate.
Item 2.D.1.d As discussed in item 2.D 1.c above the operator must demonstrate the ability to effectively use the E0Ps. The operators also receive instruction and demonstrate l
the ability to effectively function as part of a team during training on inte-grated plant operations.
1 Item 2.D.2 1
As part of the INPO a w editation process, the operator training program was
]
evaluated to ensun that the mode of training best fit the stated objectives.
3 i
operator clas ucom training is continually reinforced through the use of walk-throughs of normal and emergency operation scenarios and simulator exercises.
l Item 2.D.3.a As stated in the description of the E0P training course in our Control Operator Training Program, each emergency operating procedure and critical safety pro-l cedure is taught and demonstrated on the simulator.
Because the Kewaunee Nuclear Plant Simulator is used at present for this demonstration and it has a control board layout different from that at PBNP, walkthroughs on a full-scale mockup of the PBNP control boards are performed to reinforce the use of these E0Ps at PBNP. When a PBNP specific simulator is available, all training will be performed on the simulator.
Item'2.D.3.b As discussed in item 2.D.2.c above, the training on E0Ps and integrated plant operations addresses the role of the operator functioning as a member of a team in utilizing the E0Ps.to diagnose and effectively mitigate the possible effects cf abnormal and emergency conditions.
I
_ _ _ _ _ _. _ _ _ _ _ _ _. _ -_ _ ______ _ _ w
Page 14
+
ls i
Item 2.D.3.c
.)
1 l
The training 'on E0Ps ' includes use of the simulator and procedure walkthroughe j
~
f for a number of scenarios which include multiple failures. These scenarios i
adequately espose the' operator to the use of the E0Ps under numerous and a variety of conditions.
I Item 2.D.4
.I i
As determined by the Superintendent - Operations who is responsible for procedure changes, if the change is.significant, formal training will be conducted.
Prior
{
to this training being performed a training needs analysis is conducted to deter-mine' what the initial and contint ed training needs are.
If this needs analysis determines that the revised procedure be reviewed by the operators and training held prior < to implementation, this is so noted and the appropriate actions taken.
When the new E0Ps were developed, all operators received formal training in the classroom and'3imulator prior to implementation.
-Item.2.D.5 Program level exam'. nations are administered after each significant portion of the initial operator N aining program.
A simulator examination is administered to 4
each trainee upon completion of the E0P portion of the training program.
continuing training for the operators includes an evaluation and critique which utilizes written exams and the simulator.
i i
4 I
l 1
'. ~
o
'l
________________________-__-____--_D