ML20246D439
| ML20246D439 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/18/1989 |
| From: | Danni Smith PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| RTR-NUREG-1358 CCN-89-14132, NUDOCS 8908280087 | |
| Download: ML20246D439 (5) | |
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PHILADELPIIIA ELECTRIC COMPANY
. PEACil IK)TTOM A10MIC POWER STATION =
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R. D.1, Ika 208 Delta, l' pennsylvania 17314 m
rixn norrts-rus rowen onacantmx F17) 456-7014
' D. M. Srnitti l
Vice President
. August 18, 1989 Docket Nos. 50-277 50-278 U. S. Nuclear Regulatory Commission ATTN:' Document Control Desk y'
Washington, D. C.
20555
Subject:
Peach Bottom Atomic Power Station (PBAPS) Response To NRC Integrated Assessment Team Inspection (IATI) Report
.(50/277/89-81,50/278/89-81) Dated April 6, 1989-
Dear Sir:
In the subject response, paragraph 2.4.4, the Philadelphia Electric
' Company committed ~to provide a schedule for the revision of the PBAPS Emergency Operating Procedures (E0P's) by May 31, 1989.
In my subsequent letter, dated May 24, 1989, we changed the May.31 date based on the issuance of'NUREG 1358 " Lessons Learned From the Special Inspection Program for. Emergency Operating Procedure Conducted March-October'1988" and the scheduled NRC/NUMARC Workshop.
After evaluating the effect of NUREG 1358, we have updated our E0P Revision Schedule and are now submitting it as an attachment-to this letter. We have also enclosed some explanation of the elements of the schedule.
I trust this will satisfy our commitment.
If there are further questions, please do not hesitate to contact me.
Sincerely.
Attachments (2) cc:
R. A. Burricelli, Public Service Electric & Gas T. M. Gerusky, Commonwealth of Pennsylvania T. P. Johnson, USNRC Senior Resident Inspector T. E. Magette, State of Maryland W. 7. Russell, Administrator, Region I, USNRC fg '
H. C. Schwemm. Atlantic Electric f
J. Urban, Delmarva Power j
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jq To:1 U. S. Nuclear Regulatory Commission ge' 1
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PBAPS E0P UPGRADE TO REVISION 4 0F THE BWROG EPG'S NGAP Presently, the administrative controls for PBAPS E0P's-(TRIP's), as well as the Plant-Specific Writer's Guide (P-SWG) are included in Administrative Procedure A-94.
Philadelphia. Electric Company is implementing Nuclear
' Group Administrative Procedures'(NGAP's), which are procedures that direct activities performed by more than one organizational component of the Nuclear Group. Since PECo's Limerick facility follows an almost identical process for its E0P's as does Pcach Bottom, it was decided to create a common administrative control procedure at the NGAP level. This procedure directs the process by which revisions to E0P's may be made. The Writer's Guide information has been removed, and shall be developed as a separate document..
.P-SWG The Plant-Specific Writer's Guide is also being developed as a common document for both Limerick and Peach Bottom. The revised P-SWG will include guidance provided in the recently issued NUREG 5228, " Techniques for Preparing Flowchart-format Emergency Operating Procedures".
i
-APPENDIX C CALCULATIONS Appendix C of the EPG's provides the guidance for performing calculations required for determining values / curves utilized in the E0P's. These calculations have been completed by Stone and Webster, and are being reviewed by PECo.
l PSTG The Plant-Specific Technical Guidelines (PSTG) developed from the EPG's has not been a controlled document at PBAPS. As part of the upgrade to L
Revision 4 of the EPG's, the PSTG is being revised, as well as being incorporated into the site Document Control process.
To:
U.' S. Nuclear Regulatory Commission
~ Pag 3 2 PSTG APPENDIX A Appendix A to the PSTG, titled "EPG-PSTG Development", specifies where PBAPS' PSTG differs from the EPG's and provides the justification for such-differences.
PSTG APPENDIX B Appendix B to the PSTG, titled "PSTG-TRIP Procedure Development", describes the development of the TRIP's from the PSTG. This document, coupled with Appendix A, will provide a detailed explanation on how the TRIP's were developed from the EPG's.
V&V UPGRADE The Verification and Validation process (V&V) is being improved and incorporated as an NGAP Guideline.
T-100 DRAFTS The T-100 Series TRIP's are flowchart format procedures based on the EPG's.
T-200 DRAFTS The T-200 Series TRIP's are prose format satellite procedures of the T-100 Series.
TRAINING Operations personnel will be trained on the revised TRIP's prior to final review by the Plant Operations Review Committee (PORC). This will provide an opportunity for licensed Operations personnel to review and suggest revisions prior to final approval.
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YAttachment)2L REQUIRED REVISION:
Following.0perator training, some. revisions to the: procedure may be-required based'on.0perator comments.
a FINAL PORC
' Tlie:Pla'nt' 0perations Review Committee will review the. revised TRIP's', as well'as the V&V process. PORC will then recommend approval or further
_ revisions. :.
PRESTAGE~
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Performance of the T-200 Series procedures may require equipment, tools or-
- labels to' facilitate their performance. Such material will be'prestaged in
- the plant at appropriate locations.
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