NUREG-0660, Safety Evaluation Accepting Util 840301 & 870420 Responses to NUREG-0737,Item 1.C.1,except Where Noted in Section 2

Safety Evaluation Accepting Util 840301 & 870420 Responses to NUREG-0737,Item 1.C.1,except Where Noted in Section 2

ML20246D007
Person / Time
Site:	Davis Besse
Issue date:	05/03/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20246C985	List: NUREG-0660, Safety Evaluation Accepting Util 840301 & 870420 Responses to NUREG-0737,Item 1.C.1,except Where Noted in Section 2 NUREG-0899, Forwards Safety Evaluation Accepting Util 840301 & 870420 Responses to NUREG-0737,Item 1.C.1,w/exception of Items Noted in Section 2 of Rept,Re Procedures Generation Package, Per Generic Ltr 82-33,NUREG-0899 & NUREG-0800
References
RTR-NUREG-0660, RTR-NUREG-0737, RTR-NUREG-0800, RTR-NUREG-0899, RTR-NUREG-660, RTR-NUREG-737, RTR-NUREG-800, RTR-NUREG-899, TASK-1.C.1, TASK-TM GL-82-33, NUDOCS 8905100090
Download: ML20246D007 (7)

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_AFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION REGARDING THE PROCEDURES GENERATION PACKAGE FOR DAVIS-BESSE NUCLEAR POWER STATION, UNIT.1  ;

1 TOLEDO EDISON. COMPANY AND THE CLEVELA!4D ELECTRIC ILLUMINATING. COMPANY DOCKET NO. 50-346

1. INTRODUCTION The "TMI Action Plan" (NUREG-0660 and (1UREG-0737), required licensees of operat-ing reactors to reanal operating proceduresE0P's)(Item (yze transients 1.C.1).and accidents and to upgrade emergency.1he pl to develop a long-term plan that integrated and expanded efforts in the writing, reviewing, and monitoring of plant procedures (Item 1.C.9). NUREG-0899, " Guide-lines for the Preparation of Emergency Operating Procedures," describes the use of a " Procedures Generation Package" (PGP) to prepare E0P's. A PGP is required by Generic Letter 82-33 " Supplement 1 to NUREG-0737--Requirements for Emergency Response Capability. The generic letter requires each licensee to submit a PGP which includes:

(1) Plant-specific technichl guidelines (ii) A writers' guide

'I (iii) A description of the program to be used for the validation of E0P's (iv) A description of de training program for the upgraded E0P's.

ThisreportisthereviewoftheToledoEdison(TED)submittaldescribingthe development and implementation of E0P's for the Davis-Besse Nucivar Power Station, Unit 1(DB-1).

The review was conducted to determine the adequacy of the TED program for pre-paring, implementing, and maintaining upgraded E0P's for the DB-1. This review was based on NUREG-0800, Subsection 13.5.2, Standard Review Plan for the Review of Safety Aralysis Reports for Nuclear Power P16nts. Section 2 of this report briefly discusses the TED submittal, the NRC staff review, and the acceptability of the submittal. Section 3 contains the conclusions.

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The staff determined that the procedure generation program for the DB-1 has several items that must be satisfactorily addressed before the PGP is fully acceptable. TED should address these items in a revision to the PGP, or .

establish documented justification that revisions are not necessary. The revised PGP should not be submitted to NRC. However, concerns identified in ,

this evaluation may be followed up as part of the Region III inspection program. l The revision of the PGP, and subsequently of the E0P's, should not affect the i schedule for the use of the E0P's. The revision should be made in accordance l with the DB-1 administrative procedures and 10 CFR 50.59.  !

2. EVALUATION AND FINDINGS In a letter dated March 1, 1984 from Richard P. Crouse (TED) to Darrell G.

Eisenhut (NPC), TED submitted its revised PCP for the DB-1. The DB-1 PGP was reviewed by the NRC, and' a Draft Safety Evaluation Report. (DSER) identifying the NRC's findings was forwarded to TED on May 9, 1986. In another letter, dated April 20, 1987, fromDonaldC.Shelton(TED)tothe NRC Document Control Desk, TED submitted their response to the DSER. This response contained the following sections:

. Introduction Responses to Draft SER

- Enclosure 1: Davis-Besse Procedure Writers' Manual, Volume IV, Operations Procedures Guidelines Enclosure 2: Davis-Besse Emergency Procedure Verification and Validation Program The NRC staff review of the DB-1 PGP including the response to the SER items follows:

A. Plant-SpecificTechnicalGuidelines(P-STG)

The P-STG program description was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899.

The plant-specific technical guidelines detail the method for converting the B & W ATOG to DB-1 E0P's. TED identified the following source documents for use in generating E0P's for DB-1:

• ToledoEdison'sAbnormalTransientOperatorGuidelines(AT0G) l The SER on the Oconee Unit III AT0G The Davis-Besse Updated Safety Analysis Report (USAR)

• The existing Davis-Besse emergency procedures and system operating >

procedures

• The Davis-Besse as-built drawings l The Davis-Besse Procedure Writers' Guide '

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j-Based upon the staff's review of the TED response to the SER, the NRC staff finds that the DB-1 STG program should accomplish the objectives stated in NUREG-0899 and should provide adequate guidance for translating the ATOG into the DB-1 E0P's.

B. Writers' Guide The writers' guide was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899. The purpose of the writers' guide is to help develop and maintain procedures that are clear, consistent, and easy to use. The Davis-Besse writers' manual is divided into five volumes:

' Volume I - Administration and Emergency Planning Procedures Guidelines

' Volume II - Chemistry and Health Physics Procedures Guidelines

' Volume III - Maintenance Procedures Guidelines Volume IV - Operations Procedures Guidelines

• Volume V - Technical Procedures Guidelines Lach volume contains information on the content, format, and style of procedures. The staff. reviewed Volume IV and identified the following concerns:

(1) SER Item 2.2.1, Toledo Edison's response to this item states that instructions for recording revision dates are provided in Sections 1.4.3 and 2.3.3 of the revised writers' guide. The revised writers' guide does not contain a Section 1.4.3.

(2) SER Item 2.2.8: The validation and verification program is a means of checking the implementation of the instructions in the writers' guide. While the following items should be checked during validation and verification, they should also be included in the writers' guide to guide precedure writers:

a. Action steps should be structured to minimize the physical inter-ference of personnel in the control room,

b. Action steps should be structured to avoid unintentional duplica-tion of tasks.

c. Action steps should be structured to minimize the movement of personnel in the control room.

d. Action steps should be structured to be consistent with the roles and responsibilities of operators.

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e. Action steps should be structured to enable the control room super-visor to follow staff actions and monitor plant status.

f. Action steps should be structured to be executed by the minimum  !

control room staffing required by the Technical Specifications.

(3) SER Item 2.2.11: The writers' guide should address the following concerns:

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a. Section 3.2.3, page 3-7, states that the logic terms .IF, THEN, NOT AND, OR etc." should be used in conditional statements.

F additiBn,to these logic terms, this sect 1on should include j IF NOT ano WHEN as logic terms. The correct usage of each logic term should be discussed and examples of each should be provided.

b. Section 3.6.4, page 3-18, and Section 4.5.3, page 4-9, list ALL, BOTH, ONE, EITHER, NEITHER, NOT, and NOR, as words to use in Togic statements. The writers' guide shou F provide guidance on and examples of the use of these terms in logic statements.

c. Section 3.6.4, page 3-18, discusses the use of the word UNLESS in logic statements. When UNLESS is used as a logic term, the condition will t valve UNLESS...)ypically

. For this follow the reason, action the (e.g.,

writers' "Open guine should the be revised to indicate that UNLESS will not be used as a logic term.

d. Section 3.6.4, page 3-18, states that the conditional words IF and THEN should be capitalized and underlined; and Section 4.5.3, page T17, states that WHEN should be capitalized and underlined in logic statements. However, Section 3.3.2.b, page 3-10, and Section 14, Appendix D, page D-2, show conditionals where "if" and "when are not capitalized or underlined, and the actions specified are not introduced by THEN. These examples should be corrected.

e. Section 3.6.4, page 3-18, states that "1F should always be at the left margin (or leftmost tab, as applicable) of a lina." However, the corrected version of Example 1, Appendix A, page A-1, shows IF placed in the middle of the first line, after an instruction step. IF is also used without THEN. The writers' guide should be reviiid so that text and exaEpTis are consistent.

f. The example in Section 2.2 7, page D-6 (" Verify lube oil pressure is normal. THEN start pump ) combines two action steps into one by using THER ~ The writers' guide should states that THEN will not be used to run action steps together. The example in 5E Hion 2.2.7 should be corrected.

9 The writers' guide should discuss the inclusive and exclusive OR -

and provide examples of each.

h. The writers' guide should provide guidance and an example of acceptable usage of AND and OR in the same sentence.

With adequate resolution of the above items, the DB-1 writers' guide should accomplish the objectives stated in NUREG-0899 and should provide adequate guidance for translating the technical guidelines into E0P's that will be usable, accurate, complete, readable, convenient to use, and acceptable to control room operators.

Some revisions in the writers' guide introduced new human factors concerns.

The following comments address sections of the writers' guide that were added to the writers' guide since the previous revision was reviewed, or sections that were significantly modifieo.

(4) The discussion in the writers' guide of notes should be revised with regard to the following:

a. Sectiun 3.4.3.e, page 3-14, states that " note statements can be placed after a step, in rare circumstances, if such an order proves more logical ano necessary." Section 3.4.4.h, page 3-15, gives similar instructions. Operators should be aware of all information in a note before they perform the step to which the note applies.

Section 3.4.3.d and 3.4.3.e should be revised to indicate that notes will always be placed directly before the step or procedure to which they apply.

(5) The discussion of vocabular;r, syntax, and punctuation in the writers' guide should be revised to address the following:

a. Section 3.2, page 3-5 states that "only one action statement should be presented in a procedure step. This statement contradicts the I instructions given in Section 4.1.5, page 4-2. Section 4.1.5 should be revised to eliminate this contradiction.

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b. Section 4.2.3, page 4-5, states that synonyms should be avoided, and refers procedure writers to the constrained language list,

, Appendix C, pages C-1 to C-29. This list includes " common synonyms" I and states that "these synonyms may be used for clarity in certain cases"(pageC-5). These instructions are vague ano seem contra-dictory. Tha writers' guide should clarify instructions regarding the use of synonyms in E0P's.

l (6) The explanation of the word " verify" in the Constrained Language List, Appendix C, page C-28, states that "the use of ' verify' requires a step signoff"; hcwever, the writers' guide does not require these sign-offs for E0P's. The writers' guide should be revised to eliminate this inconsistency.

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C. Verification and Validation Program The description of the verification and validation program was reviewed to determiu if it described acceptable methods for accomplishing the objectives stated in NUREG-0899. The verification and validation program described in the PGP has the following objectives:

• to ensure that E0P's accurately reflect the source documents, to ensure that the level of information and detail in E0P's is consistent with the qualifications, training, and experience of the operating staff,

• to ensure that revisions to E0P's are written using the writers'

- guide

• to ensure that the E0P's are usable and compatible with plant responses, hardware, and shift staffing.

The staff identified no concerns.

The 08-1 verification and validation program should accomplish the objectives stated in NUREG-0899 and should provide assurance that the E0P's adequately incorporate the guidance of the writers' guide and the technical guidelines and will guide the operator in mitigating emergency conditions.

D. Training Program The description of the operator training program on the DB-1 upgraded E0P's was reviewed to determine if it described acceptable methods for accomplishing the objectives stated in NUREG-0899. The DB-1 training program described in the TED's response consisted of four phases, incluoing two sessions of classroom instruction, training on a simulator, are walkthroughs. The staff identified the following concerns:

1. The training program should include a description of the objectives of the program. This description should state that, at the con-clusion of training, trainees will meet the following objectives:

a. Trainees will understand the philosophy behind the E0P's. That ]

is, trainees will understand the structure and approach of )

E0P's to transient and accident mitigation, including control i of safety functions, accident evaluation and diagnosis, and the achievement of safe, stable, or shutdown conditions.

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b. Trainees will understand the mitigation strategy and technical ]

bases of the E0P's. That is, trainees will understand the function and use of plant systems, subsystems and components in mitigating transients and accidents.

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c. Trainees will have a working knowledge of the technical content of the E0P's. That is, trainees must understand and know how to perform each step in all E0P's to achieve E0P objectives.

d. Trainees will be capable of executing the E0P's (as individuals andteams)underoperationalconditions. That is, trainees must be able to carry out an E0P successfully during transients and accidents.

With adequate resolution of the above items, the DB-1 training program should accomplish the objectives stated in NUREG-0899 and should result in appropriate training for the DB-1 operators on the upgraded E0P's.

3. CONCLUSIONS The staff' concludes that, with the exceptions noted in Section 2 of this report, the PGP submitted by Toledo Edison for Davis-Besse Unit 1 adequately addresses the requirements stated in Generic Letter 82-33 (Supplement I to NUREG-0737) and provides acceptable methods for accor.plishing the objectives stated in NUREG-0899 in accordance with the guidance provided in the Standard Review Plan (NUREG-0800). The PGP should be revised to address the items described in Section 2. This revision need not be submitted to the NRC. For items that the licensee deems inappropriate for inclusion in its PGP, it should develop and maintain documented justification for subsequent review by NRR or Region III at some future date. Future changes to the PGP and E0P's should be made in accordance with 10 CFR 50.59.

Principal Contributor: Battelle Pacific Northwest Laboratories' and G. Lapinsky Date: May 3, 1989