RBG-17137, Forwards Addl Info Re Generic Ltr 82-33, Suppl 1 to NUREG- 0737 - Requirements for Emergency Response Capability. Info Suppls Emergency Operating Procedures Generation Package Submitted 830831

Forwards Addl Info Re Generic Ltr 82-33, Suppl 1 to NUREG- 0737 - Requirements for Emergency Response Capability. Info Suppls Emergency Operating Procedures Generation Package Submitted 830831

ML20087D695
Person / Time
Site:	River Bend
Issue date:	02/27/1984
From:	Booker J GULF STATES UTILITIES CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20087D698	List: ML20087D700 RBG-17137, Forwards Addl Info Re Generic Ltr 82-33, Suppl 1 to NUREG- 0737 - Requirements for Emergency Response Capability. Info Suppls Emergency Operating Procedures Generation Package Submitted 830831
References
RTR-NUREG-0737, RTR-NUREG-737 GL-82-33, RBG-17137, NUDOCS 8403130486
Download: ML20087D695 (4)

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AREA CODE 409 836-6631 February 27, 1984 RBG- 17137 File Code G9.5, G9.8.6.2 G9.33.4 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Suclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Denton:

River Bend Station Units 1 & 2 Docket Nos. 50-458/50-459 In response to the NRC's letter dated January 18, 1984, (A. Schwencer to W. J. Cahill) requesting additional information concerning Generic Letter 82-33, " Supplement 1 to NUREG-0737 -

Requirements for Emergency Response-Capability", Gulf States Utilities Company (GSU) has prepared the attached supplement to its Emergency 0perating Procedures Generation Package submittal, dated August 31, 1983 from J. E. Booker to D. G. Eisenhut.

Sincerely, e

J. E. Booker Manager-Engineering Nuclear Fuels & Licensing River Bend Nuclear Group

/R K/je Attachments

, , g 0403130486 840227 PDR ADOCK 05000458 p PDR

y Attachment 1 1 of 3 s

1. .A. GSU is a member of the Boiling Water Reactor (BWR) Owner's

" Group Emergency Procedures Committee-(EPC). The BWR Owner's Group EPC has been responsible for the development and documentation of the generic-BWR Owner's Group Emergency Procedure Guidelines (EPG generic technical guidelines). The EPC consisted of representatives from General Electric and experienced personnel from utilities owning BWRs. During-

-development of the EPG's, GSU's EPC representative has provided input to the EPC regarding River Bend Station's (RBS) specific design and operation considerations. In Generic Letter 83-05,

" Safety Evaluation of ' Emergency Procedure Guidelines, Revision 2', NEDO-24934, June 1982," the Nuclear Regulatory Commisssion determined the EPG's to be acceptable for implementation.

The EPGs were reviewed by the appropriate analysts from GE who were cognizant of licensing basis assumptions employed in cempleting the design basis analysis. In addition, an engineering evaluation of the EPGs is being performed by GSU and will be documented.

The operator. reviewing the EPGs for applicability to RBS will have held a reactor operator license. The operator currently evaluating the applicability of the guidelines to RBS is an individual who has been licensed on three BWRs (including a BWR-6) and has written a number of system operating, general operating and abnormal operating procedures for RBS.

The EPGs require inclusion'of plant specific information in several places. This plant specific information is being developed and reviewed by the RBS Architect / Engineer (A/E),

Stone & Webster.

The process which was used by the BWR Owner's Group to develop the EPGs has assured that the EPGs have been reviewed by design engineers and plant technical engineers acquainted with the plant's capabilities,-systems and equipment. These reviews have assured to the maximum extent possible that nc conflicts exist between the EPGs and the licensing basis accident analysis.

B. RBS will prepare a written explanation for each EPG step not included and/or for each EPG step that has been modified to agree with the specific RBS configuration.

The completed Emergency Operating Procedures (EOPs), with the referenced EPGs and written explanations for EPG exceptions will be forwarded to General Electric Company for technical review.' This review will be completed at least 90 days prior to fuel load.

Comments from this review will be resolved, in writing and the E0P's will be revised as necessary.

, J'

Attachment 1 (cont'd.) 2 of 3

2. The RBS Detailed Control Room Design Review (DCRDR) Program Plan, submitted to the NRC in January 1984, provides a description of the following activities:

a) The process for identifying the information and centrol needs cf the operators b) The process used to ensure the availability and adequacy of the instrumentation and controls to meet the identified needs.

A summary of the information stated in that document is indicated below.

Task Analysis The INPO NUTAC DCRDR Task Analysis Guideline will be used as a reference for the task analysis. Operator tasks will be analyzed for selected operating scenarios . usin,; the symptom-oriented E0Ps and documented on task analysis forms in the following manner:

a) Discrete steps in the E0P's will be identified in the order of performance.

b) A brief description of the operator's tasks per procedural step will be recorded.

c) Instrumentation and/or controls that the operator requires will be identified per procedural step to either: (1) initiate, maintain, or remove from service a system, (2) confirm that an appropriate system response has or has not occurred, i.e., feedback, or (3) make a decision regarding plant or system status.

Verification of Task Performance Capabilities The availability of instrumentation and controls (I&C) that the operator requires will be verified by comparing the task analysis I&C requirements information to the actual main control room. The presence or absence of the required instrumentation and controls will be noted on the task analysis form. Any absences will be treated as Human Engineering Discrepancies (HED's) and will be assessed during the DCRDR process. _

An example of the process used to determine the adequacy of the instrumentation and controls that the operator requires is as follows:

If a meter utilized in a particular E0P step exists in the main control room, that particular meter will be examined by the DCRDR review team to determine whether or not it has the appropriate range and scaling to support the operator in the corresponding E0P step. If the range and scaling is appropriate, it will be noted as such on the task analysis form. If the meter range or scaling is not appropriate, it will be noted on the task analysis form and will become an HED.

J

Attachment 1 (cont'd.) 3 of 3 With regard to specific items in the Authors Guide:

A. The procedure format provides a place to " check off" steps as they are done.

B. The Control Room Operating Foreman will assume the positions of E0P Director / Coordinator. He will evaluate and determine whether the objectives of a step or a sequence of actions has been achieved. He will use his technical knowledge and operator aids, such as GE/ERIS, to make this determination.

C. The Author's Guide provides a control and use section to address sequencing requirements.

D. Equally acceptabic steps are addressed in the two column format end by " branching" both of which are explained in the Author's Guide.

E. Concurrent steps are specified in the E9P's, as required to assure mitigation of mechanistically possible conditions.

F. Reference 2.1 (AD.'1 0003) is attached for your information (Attachment 2). Reference 2.2 (OSP 3007) will be provided for your information upon final approval.

G. When the procedures are issued, the main control room copy will be tabulated to provide easy operator access.

3&4. The RBS E0P Verification and Validation Program Procedure (OSP-0008) will be provided for your information upon final approval. All E0P's will be verified and validated in accordance with this procedure.

5. With regards to the E0P Training Program:

a. The simulator has the capability of " introducing" approximately 150 different casualties. These casualties will be organized into scenarios that will exercise each E0P during the initial Operator Simulator Training Program.

b. The RBS fuel load date is April, 1985. RBS's initial E0P's are the symptom based procedures which meet the intent of NUREG-0737. Operators will be trained on these symptom based procedures.

c. The operator's understanding and use of the E0Ps will be evaluated and documented during the initial simulator training program as well as requalification training.