ML20238F559
| ML20238F559 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 09/04/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8709160223 | |
| Download: ML20238F559 (4) | |
Text
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3E DUKE POWEu GOMPANY.
P.O. BOX 33189 i
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' CHAMLOTTE. N.C. 28242 i:
,HALB. TUCKER TELernows room reeninast (704) 073-4531 wuuna roomnmow September 4, 1987 U. S. Nuclear Regulatory Commission Attentions-Document Control Desk
- Washington, D.-C.'20555-l Subjects. Catawba Nuclear Station i
l Docket Nos. 50-413'and'50-414 RII:LJW Deviation 413,414/87-13-01
Dear Sir:
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' Attached is our response' to' the subject; Deviation which concerns Emergency Oper;ating Procedures.
1 Vety truly.yours,
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/k [N.f Hal B. Tucker LTP/90/sbn Attachment xct LDr. J. Nelson Grace Regional Administrator
-U.' S. Nuclear Regulatory Commission
. Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia '30323
'Mr. P. K. Van Doorn NRC Resident Inspector Catawba Nuclear Station b
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PDR 7
RESPONSE TO DEVIATION 413-414/87-13-01 By letters dated February 28, 1983, and June 1, 1983 the licensee submitted the Emergency Procedures Generation Package (PGP) to address the requirements of Supplement 1 of NUREG-0737, Clarification of TMI Action Plan Requirements -
Requirements for Emergency Response Capabilities.
The commitments in these submittals include:
1.
A Writer's Guide for Emergency and Abnormal Procedures, Rev. 6, that provides instructions on writing Emergency Procedures and an Emergency Procedure verification program documented in PGP procedure, Verification Process for Emergancy Procedures, Rev. 1, which requires that the Emergency Procedures be reviewed for compliance with the Writer's Guide.
2.
An Emergency Procedure validation program documented in PGP procedure, Validation of Emergency Procedures, Rev.
1, which requires, among other commitments, the following:
a.
In Section 6.2.B, for the Step-by-Step Walk-Through, the commitment states, "If one or more steps fail to meet a criteria, the operator writes "NO" on the checklist blank and completes to document the discrepancy (ies)."
b.
In Section 6.2.C, for the Real-Time Walk-Through, the commitment states, "Both observers will identify problems the operators are having in performing the procedure using the Validation Observation Form (Attachment 4) as a guide to link performance syrptoms to evaluation criteria."
c.
In Section 7.0, Validation by Actual Performance, the commitment states, "As soon as possible after the use of an EP, the Shift Supervisor involved shall ensure that any problems encountered in using the EP are documented on Attachment 2 and forwarded to the OEDD.
If no problems were encountered, he should complete Attachment 2 with "NONE" under the discrepancy headings."
d.
In Section 8.0, Validation During Training, the commitment states, "After each training segment covering the EPs, Attachment 2 will be used by the senior training instructor to forward discrepancies to OEDD.
If no problems were discovered, he should complete Attachment 2 with "NONE" under the discrepancy heading."
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Contrary to the above, the licensee failed to fully implement the approved Writer's Guide requirements for logic j
statements, references to other procedures, action steps, emphasis techniques, punctuation, use of bullets, spacing
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and use of adverbs.
Specific examples of the deficiencies 4
in these areas are provided in paragraph 7.a of NRC Inspection Report 413, 414/87-13.
In addition, the licensee failed to document all discrepancies identified during the Step-by-Step Walk-Through on Attachment 2 as required by Section 6.2.B of the PGP validation procedure; failed to implement the observation form, Attachment 4, for linking performance symptoms to evaluation criteria as required by Section 6.2.C of the PGP validation procedure; and, failed j
to provide feedback on errors in Emergency Procedures as specified in Sections 7.0 and 8.0 of the PGP validation procedure.
j 1.
Corrective Actions regarding this dgviation:
Catawba Nuclear Station has always placed great emphasis on developing technically correct and usable procedures.
The lessons learned as a result of the PGP audit, especially the human factors review, will be incorporated into the EP/AP Writer's Guide and ultimately the procedures themselves.
Immediately after the NRC audit team left Catawba, actions were taken on the comments received from the inspectors.
A technical review has been performed of all setpoints in the procedures.
Additionally, many of the procedures have been retyped to minimize the use of emphasis techniques as well as to ensure the consistent usage of capitalization, underlining, and bolding.
To address the audit report comments, the following actions are planned or currently in progress:
1.
The Writer's Guide is being revised to address in detail the audit report recommendations.
A review of the Writer's Guide will be performed to ensure conformance to applicable industry guidelines including human factors and principles of presenting information.
The revised Writer's Guide will be submitted as a revision to the PGP by January 1988.
2.
The Emergency Procedures will be upgraded to be consistent with the revised Writer's Guide.
The appropriate levels of Verification and Validation will be performed by June 1988.
3.
All EOP's will be tested at the Catawba simulator to evaluate their usability.
A majority of the EOP's are e%pected to be tested by June 1988.
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. Operator Training will'be conducted'on the upgraded'EOP's prior to-their. implementation.- It is anticipated that the upgraded procedures will' i.
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'be' implemented by June'1, 1988.
2.
' Actions taken to avoid further deviations:
In addition:to the' corrective actions taken in Par $ll of thisTresponse, additional emphasis'will be placed on maintaining our procedures and increasing' operator.
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-. awareness.in the areas noted by the inspection.
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. 3.
'Date-when actions will be completed:
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The actions' indicated in Part:1 of this response will
'be completed by June 1, 1988.
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