View source for NUREG-0889, SER Conditionally Supporting Response to Procedures Generation Package

{{Adams
| number = ML20138G654
| issue date = 10/18/1985
| title = SER Conditionally Supporting Response to Procedures Generation Package
| author name = 
| author affiliation = NRC
| addressee name = 
| addressee affiliation = 
| docket = 05000373, 05000374
| license number = 
| contact person = 
| case reference number = RTR-NUREG-0737, RTR-NUREG-0889, RTR-NUREG-0899, RTR-NUREG-737, RTR-NUREG-889, RTR-NUREG-899, TASK-1.C.1, TASK-1.C.9, TASK-TM
| document report number = GL-82-33, GL-83-05, GL-83-5, NUDOCS 8510250574
| package number = ML20138G620
| document type = SAFETY EVALUATION REPORT--LICENSING &amp; RELATED ISSUES, TEXT-SAFETY REPORT
| page count = 7
}}

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ENCLOSURE 1 SAFETY EVALUATION REPORT PROCEDURES GENERATION PACKAGE LASALLE COUNTY STATION UNITS 1 AND 2
: 1. INTRODUCTION Following the Three Mile Island (TMI) accident, the Office of Nuclear
  ,              Reactor Regulation developed the TMI " Action Plan" (NUREG-0660 and NUREG-0737), which required licensees of operating reactors to reanalyze transients and accidents and upgrade emergency operating procedures
      ,          (E0Ps) (TMI Item I.C.1). The action plan also required the NRC staff to develop a long-tenn plan that integrated and expanded efforts in the writing, reviewing, and monitoring of plant procedures (Item I.C.9).
NUREG-0899, " Guidelines for the Preparation of Emergency Operating Procedures," represents the staff's long-term program for upgrading E0Ps, and describes the use of Procedures Generation Pa::kage (PGP) to prepare E0Ps. Submittal of the PGP was made a requirement by Generic Letter 82-33, " Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability." The generic letter requires each licensee to submit to the NRC a PGP to include:
(1) Plant-Specific Technical Guidelines (ii) Writer's Guide (iii) A description of the program to be used for the
,                               validation of E0Ps (iv) A description of the training program for the upgraded E0Ps.
This report describes the review of Comonwealth Edison Company's response to Generic Letter E2-33 related to development and implementation of E0Ps for LaSalle 1 and 2. Our review was conducted to determine the adequacy of the licensee's program for preparing and implementing E0Ps. Criteria for the review of PGPs were not included in the Standard Review Plan (SRP). This review was, therefore, based on NUREG-0899, the reference document for the E0P upgrade portion of Generic 0510250574 851018 PDR  ADOCK 05000373 F                     PM

Letter 82-33. Review criteria based on this guidance has now been developed and included in SRP Section 13.5.2, Rev. 1, issued July 1985.
Section 2 of this SER briefly discusses the five parts of the licensee submittal. There are some items in Section 2 of this SER that the NRC staff feels would further enhance the E0Ps. These issues were not
      -                 completely addressed by the licensee in its revision to the plant-specific technical guidelines; however, in the context of the overall excellence of the program developed by the licensee, these issues are of miner significance.
: 2. EVALUATION AND FINDINGS The licensee submitted its PGP in a {{letter dated|date=September 26, 1984|text=letter dated September 26, 1984}}, from J. M. Marshall to H. R. Denton. The PGP contained the following five i
parts of the LaSalle General Abnormal (LGA) Symptom-Based Emergency Procedures:
                        --  LaSalle County Station Emergency Procedure Guideline Technical Guidelines, Including Attachment A 1
Writer's Guide
                        --  Validation Description l
Verification Description
                        --  Training Description The NRC staff conducted a review of the LaSalle PGP, and detailed its findings in a Draft SER which was forwarded to the licensee by a {{letter dated|date=April 1, 1985|text=letter dated April 1,1985}}, from A. Schwencer to D. L. Farrar. The Draft SER contained a number of open items. The licensee addressed these items in I                       a revised PGP (submitted by letter from H. L. Massin to H. R. Denton.
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i dated June 28,1985), and in its letter of August 20, 1985, from Mr. Massin to Mr. Denton. The results of the NRC staff rev'iew of the LaSalle PGP, including the response to the open items and the revisica to the PGP, are described in the following subsections.
A. Plant-Specific Technical Guidelines (P-STGs)
The P-STGs were reviewed to determine if they provided acceptable
      -                methods to meet the objectives of NUREG-0889. The licensee briefly described a method wherein they will use generic Emergency Procedure Guidelines (EPGs) and, with appropriate changes, develop E0Ps for LaSalle 1 and 2.
TheBoilingWaterReactorOwnersGroup(BWROG)EPGs, Revision 3, 4
dated December 8,1982, was approved by the NRC staff in a {{letter dated|date=November 23, 1983|text=letter dated November 23, 1983}}, from D. Crutchfield to T. Dente of the BWROG.
The licensee's P-SIGs were generated from Revision 3I of the EPGs.
Each deviation from Revision 3 of the EPGs is identified by a letter in the margin of the P-STGs. Attachment A to the P-STGs describes the deviations and provides an explanation for each one. The staff's review was performed by conducting a step-by-step comparison of the P-STGs with the NRC-approved BWROG EPGs, Revision 3. In addition, the staff reviewed each deviation including the justification for each deviation.
4 Revision 3 to the EPGs is generic to GE-BWR 1 through 6 designs in that it addresses all major systems which may be used to respond to an emergency. Because no specific plant includes all of the systems 1

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in these guidelines, the guidelines were made applicable to LaSalle by deleting statements which address systems not installed at the
        .           LaSalle plant. Several open items in the Draft SER were resolved by editnrial changes to the PGP. Because the licensee's P-STGs are mostly consistent with the generic guidelines, the deviations from the EPGs provide acceptable means for mitigating the consequenos of accidents and transients, and the relative significance of the items
      -             remaining to be addressed is small, the staff finds the licensee's P-STGs acceptable. Following is a discussion of the remaining items which are numbered as they were in the draft SER:
Item A.3 The LaSalle 1 and 2 E0Ps are based on the BWR0G EPGs which are contained in NE00-24934, Revision 3. The staff safety evaluation of the EPGs dated February 4,1983 (Generic Letter 83-05) identified two areas of the guidelines as requiring more work. Specifi; ally, the overly conservative limits iri the determination of drywell spray flow rate needed to be reduced and emergency venting pressure needed to be determined. The licensee's response to the staff's concerns in these areas is presented in a {{letter dated|date=June 28, 1985|text=letter dated June 28, 1985}}, t
With regard to drywell spray, the licensee has provided a plant-unique calculation for determination of the safe region for the operator to initiate drywell spray. Based on the licensee's f
j                   calculations which show that, after the spray cools the containment l                   to the spray temperature, the containment negative design pressure is
!                   not exceeded, the LaSalle plant-unique calculation satisfies the i
staff requirement stated in Generic Letter 83-05 and is acceptable.
Item A.4 The staff has reviewed the material provided by the licensee as justification 'or the selection of 60 psig (1.3 x design) as the Primary Containment Pressure Limit for venting of the LaSalle
                                      ~

m-e-      %
5-containment. We agree that the approach taken by the licensee addresses the requirement in the SER for the generic BWR EPGs for defining a venting pressure, and we find the licensee's proposed venting strategy (using one 26-inch vent path) acceptable on an interim basis. However, for the longer term, we request that the licensee address the following areas:
: a.              Limitation of offsite radioactive releases, such as by consideration of fission product retention during venting and the use of sequenced vent paths.
: b.              Consideration of depressurization rate during venting to limit suppression pool flashing and hydrodynamic loads.
: c.              The licensee's best-estimate basis for the purge valve (and other valves in the sequenced paths) operability limit.
: d.              The licensea should consider the effect of containment venting on ductwork failure (if used as a pathway), and the consequence of subjecting equipment near the failed duct to the steam / radiation environment.
Item A.6 The licensee, in its letter from H. L. Massin to H. R. Denton dated August 20, 1985, indicated that the process for using the EPGs and background information to identify control room operator tasks and information and control needs will be described in the Detailed Control Room Design Review (DCRDR) Progrem Plan. The staff's review of that process will be described in its evaluation report of the
!                  DCRDR Program Plan.
With satisfactory resolution of the above items, the licensee's P-STGs will provide an adequate technical basis for developings LGAs.
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B. Writer's Guide The writer's guide was reviewed to determine if it provided acceptable methods for accomplishing the objectives stated in NUREG-0899. The licensee stated that the purpose of the writer's
;                                 guide is to provide administrative and technical guidance on the preparation of the LGAs. The writer's guide provides instructions for writing LGAs, including format, instructior.al steps, mechanics of style, flow charts, symbols, graphs, place-keeping aids, logic terms, and examples. The writer's guide states each LGA shall provide the basic purpose for the procedure, list 'the entry conditions, and in the body of the procedure, contingent operator actions based on interpretation of parameters and conditions. Based on the information provided in the revised writer's guide and the information provided in the licensee's {{letter dated|date=August 20, 1985|text=August 20, 1985 letter}}, on the l
i control room operator tasks, the NRC staff finds that the LaSalle writer's guide provides adequate direction for translating the technical guidelines into LGAs that meet the stated objectives of the LaSalle writer's guide, and adequately address the objectives of NUREG-0899.
Validation / Verification C.
The. description of the licensee's validation / verification (V/V)
;                                 programs were reviewed to determine if they acceptably address the objectives stated in NUREG-0899. The objective of the validation program is to ensure that a trained operating crew can manage
!                                 emergency events using the LGAs. The verification program described in the PGP has two objectives: that the actions specified in the LGAs are technically correct and accurately reflect the technical guidelines.
i Because they provide acceptable methods for accomplishing the j                                 objectives of NUREG-0899, the staff finds the licensee's V/V descriptions, as modified in the {{letter dated|date=June 28, 1985|text=June 28, 1985 letter}} from H. L. Massin to H. R. Denton, acceptable, i

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_7-D. Training Program The licensee's description of the operators' training program on the revised LGAs was reviewed to determine if it acceptably addressed the objectives stated in NUREG-0899. The training program as described in the PGP consists of the following two parts: (1) classroom training sessions and (2) practical training on the plant-specific simulator using nonnal shift operating crews. Written and performance evaluations will be made. The training plan, as presented in the revised PGP as clarified by the licensee's {{letter dated|date=August 20, 1985|text=August 20, 1985 letter}}, adequately addresses the objectives of NUREG-0899, and should result in appropriate training for the operators on the upgraded LGAs.
: 3. CONCLUSIONS The PGP submitted by Comonwealth Edison Company for LaSalle 1 and 2 meets the requirements of Generic Letter 82-33 (Supplement 1 to NUREG-0737),andprovidesacceptablemethodsformeetingtheobjectives of NUREG-0899. The PGP presents a program that should enhance the safety of operating the LaSalle units, and provides a sound program and basis for objectively incorporating any future modifications to the LGAs. The NRC staff, therefore, has concluded there is reasonable assurance that LGAs developed and implemented in accordance with the licensee's progran I
will provide adequate guidance in an effective and useable fonn to allow control room personnel to effectively mitigate the consequences of a broad range of transient sand accidents. This completes the requirements for TMI Action Plan Item I.C.1 for LaSalle 1 and 2. Future changes to the PGP should be made in accordance with 10 CFR 50.59. The three items identified in Section 2 of this SER should be addressed by the licensee as described.
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