ML20215H595

Procedures Generation Package:Public Svc Co of Colorado Fort St Vrain Nuclear Generating Station

ML20215H595
Person / Time
Site:	Fort Saint Vrain
Issue date:	04/10/1987
From:	PUBLIC SERVICE CO. OF COLORADO
To:
Shared Package
ML20215H588	List: ML20215H585 ML20215H595 ML20215H603 ML20215H610
References
PROC-870410, NUDOCS 8704200438
Download: ML20215H595 (12)

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PROCEDURES GENERATION PACKAGE PUBLIC SERVICE COMPANY OF COLORADO FORT ST. VRAIN NUCLEAR GENERATING STATION 8704200438 870410 PDR ADOCK 05000267 P

PDR

4 TABLE OF CONTENTS Section Title Page 1.0 I N T RO DU C T I O N.............................................. 2 1.1 Purpose..............................................2 1.2 Scope.................................................2 1.3 Organization.................

....................... 2 2.0 PROGRAM DESCRIPTION.................................

2 2.1 General.........................................

.... 2 2.2 Structure of Emergency Operations.....................

3 2.3 Mechanics of Writing Procedures.......................

3 l 3.0 VERIFICATION AND VALIDATION.................................

5 1

3.1 Verification Activities..............

6 l

3.2 Validation Activities.........................

....... 8 l 4.0 TRAINING PR0 GRAM........................

9 l

4.1 General Requirements...................

.............. 9 l

4.2 Program Description.................................. 9 l

4.3 Training Evaluation................................. 11 l

4.4 Training Program Changes............

................. 12 l

5.0 REFERENCES

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1.0 INTRODUCTION

1.1 PURPOSE The purpose of this Procedures Generation Package (FGP) is to describe the development of emergency procedures at Public Service Company's Fort St. Vrain Nuclear Generating Station.

The Fort St. Vrain nuclear plant is a High-Temperature Gas-Cooled Reactor (HTGR) located near Platteville. Colorado.

1.2 SCOPE This document was developed in response to Supplement 1 to NUREG-0737, Item 7.2b, page 15.

1.3. ORGANIZATION This document consists of the following parts:

Introductien Program Description Verification and Validation Program Training Program I

References Attachments:

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1. Guidelines For Preparation of Emergency l

Procedures (SOAP-2) l

2. E0P Verification Worksheet l

3. E0P Verification / Resolution Record l

4. Evaluation Criteria Checklist 2.0 PROGRAMOj,50R!cT!0N 2.1 GENERAL in conjunction with other activities related to NUREG-e 1

0737, Supplement 1, most notably the Control Room Design i

Review (CRDR) and Safety Parameter Display System (SPDS),

Public Scrvice Company (PSC) is in the process of defining Critical Safety Functions (CSFs) and rewriting certain i

plant procedures.

This document pertains to the methodology for generating a particular subset of plant procedures that deals with emergency operations and monitoring and restoration of CSFs. These procedures are 4

l part of a much more comprehensive set of operational, maintenance, and administrative procedures at Fort St.

i Vrain.

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1 2.2 STRUCTURE OF EMERGENCY OPERATIONS Emergency plant operation at Fort St.

Vrain will be conducted using a parallel path approach. On one path are event-oriented emergency procedures. On the parallel path are symptom-oriented CSF restoration procedures.

A symptom-oriented diagnostic procedure, invoked when i

certain transient conditions, such as reactor scram, occur, determines which path is initially used by control room operators.

The diagnostic procedure will instruct operators to take certain immediate actions.

It will then direct the operators to verify that the symptoms indicating normal CSFs are present.

If the CSFs are i

normal, the diagnostic procedure will direct the systematic identification of the precipitating event and indicate which event-specific procedure should be used.

4 If CSFs are threatened, the operators will be instructed to use the appropriate symptom-oriented CSF restoration procedure.

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The event-oriented emergency procedures will be used when a particular precipitating event can be unambiguously identified using the diagnostic procedure.

While an event-oriented procedure is being conducted, one i

individual in the control room will be responsible for monitoring the status of all Fort St.

Vrain CSFs.

The SPOS will be used as the primary monitoring tool, but CSF monitoring procedures will also be provided.

If any CSF is lost, or is in imminent danger of being lost, the event-oriented procedure will be abandoned and one, or more, CSF restoration procedure (s) will be immediately invoked and will dictate further operator actions.

This parallel path approach takes advantage of the best characteristics of both event-and symptom-oriented procedures.

2.3 MECHANICS OF WRITING PROCEDURES Since generic guidelines do not exist for HTGR, the mechanics of the generation of a new emergency procedures t

set will be somewhat different than those used by light i

water plants, but will accomplish the same objectives.

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2.3.1 Preparation Because Fort St. Vrain is a unique type of plant, there are no owner's group emergency procedure guidelines from which to generate plant-specific procedures.

There is, however, an existing l

approved set of Emergency Operating Procedures l

(E0Ps) implemented at Fort St. Vrain.

During the CRDR task analysis, it was noted that many procedures in the existing E0P set do not, in

fact, relate to " emergencies", but to abnormal situations that can be (and are) dealt with on a fairly routine-basis (e.g.,

single circulator trip).

To meet the CRDR task analysis requirements, a basis for a new set of procedures, dealing strictly with symptom-oriented CSF monitoring and restoration was developed and analyzed in the Fort St. Vrain Control Room mock-up.

Subsequent to the CRDR, PSC has undertaken to restructure their old emergency procedures set into -those that are truly " emergency" procedures and those that really deal with abnormal operational events.

In preparation for rewriting the E0Ps for the present effort, a set of existing procedures dealing with emergency events will be defined. Also, a complete set of CSF Monitoring and Restoration Procedures will be defined - based i

on the analysis done for SPOS development and for the CRDR.

From that point, the methodology described in the remainder of this PGP will be used to generate the new procedures, 2.3.2 Writing New procedures A procedures writing team will convert those procedures that have been retained through the selection process into the format defined by the Emergency Procedure Writer's Guide to be described in section 2.3.3.

One new procedure will be generated for each event represented in the retained procedure set.

Since the existing procedure set has already been approved by the Nuclear Regulatory Commission (NRC), no new analysis will be required to convert to the new procedure format.

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N If any events are identified during the selection process that are deemed important enough to l

require procedural

guidance, then additional l

procedures will be writter..

l If additional events are identified that require l

new E0Ps, a technical basis will be established l

and submitted for NRC Staff Review.

In addition, I

a Task Analysis will be completed to ensure that l

the information and controls required to carry out l

the procedures are available in the control room.

The CSF Monitoring and Restoration Procedures will be formatted in accordance with the Writer's Guide.

The CSF Monitoring Procedure will be adapted from the algorithms used in the SPDS to define the status of individual CSFs. The flow charts and task analyses that were produced by the CRDR will be used in the development of the CSF Restoration Procedures. A check will be performed on the CSF Restoration Procedures to make certain they are appropriate and complete.

2.3.3 Writer's Guide A guide for writing Fort St. Vrain emergency and CSF procedures has been developed from the following references:

" Emergency Operating Procedures Writing Guideline" (INPO-82-017)

" FORT ST. VRAIN PROCEDURE SYSTEM, Procedure G-2".

This guide is entitled " Guidelines For Preparation of Emergency Procedures",

and includes detailed requirements for procedure format, organi:ation, level of detail, content, and style.

This guide is included in this PGP as Attachment 1.

l 3.0 VERIFICATION AND VALIDATION l

The E0P Verification and E0P Validation Programs arv I

interdependent, however separate in that the E0P Verification is l

considered to exist at the component level and the Validation of l

E0Ps is part of the Integrated Validation effort.

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l 3.1 VERIFICATION ACTIVITIES l

This section describes the E0P Verification Program for l

evaluating the E0Ps for written correctness and technical l

accuracy.

The evaluation of useability and operational I

correctness is addressed in the " Program Plan for the l

Integrated Validation of NUREG-0737 Initiatives".

This l

division of the evaluation for these four (4) l characteristics is based on the type of evaluation to be l

used.

The E0P Verification Program encompasses the l

efforts necessary to support a comparative evaluation of l

each E0P to the source documents, whereas the E0P l

Validation Program encompasses tne efforts necessary to I

support a performance evaluation of t*e FOPS.

l A verification team will be established before (or during) l the procedures writing effort.

The verifica+. ton team will l

include one or more of the individuals cr the procedure I

writing team, a human factors specialist, and at least one l

licensed control room operator who did not participate in l

the procedures writing effort.

l The verification activity will utilize the team concept in l

conjunction with visual inspections of the control room.

I One member will be designated as the team leader and this l

designee may assign specific duties to individual members.

l 3.1.1 Obj ec t _i_ve l

The objective of the verification activity is to I

ensure the written and technical corre:tness of I

the emergency procedures.

Verification will I

consist of a series of static checks to ensure i

that the following conditions are met:

Each procedure is technically correct, i.e.,

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it accurately reflects either the existing l

procedure or a flowchart developed for a l

particular CSF.

Each procedure is written correctly according l

l to the Writer's Guide.

The language and level of information l

I presented are compatible with the l

Qualifications,

training, and experience of I

the range of individuals on the operating l

staff.

(The validation of this condition is l

part of the Integrated Validation Program.)

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0 The information and control requirements l

l embodied in each procedure are available from l

the displays and controls in the Fort St.

l Vrain Control Room.

l 3.1.2 P_r_ogram Structure l

The verification activity consists of the l

following four (4) phases:

PREPARATION:

Preparation includes developing l

l (or determining) the criteria needed to l

parform the comparative evaluation between l

the E0Ps and their applicable source l

documents, determining how to apply the l

developed evaluation criteria, designating l

the personnel to perform the comparative l

evaluation, and scheduling the assessment.

ASSESSMENT:

Assessment generally includes I

l the performance of the comparative evaluation i

between designated source documents and the l

E0Ps using the evaluation criteria to l

identify any discrepancies between them.

l This assessment shall be conducted by the l

following steps:

l Make a general review of the E0P using the l

" PROCEDURE GENERAL" portion of the evaluation l

criteria checklist ( Attachment 4) and source l

documents.

l

- Indicate on Form #1 of the E0P Verification l

Worksheet (Attachment 2) that the evaluation l

was performed, either by checking the l

acceptable column or by designating the l

appropriate discrepancy sheet for any l

discrepancies identified.

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- Make a step-by-step review of the E0P using l

the step, caution, note-specific portion of l

the evaluation criteria ( Attachment 4) and l

source documents.

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Indicate for each step on Form #2 of the l

l E0P Validation Forms (Attachment 2) that the l

comparative evaluation was performed, either l

by checking the acceptable column or by l

designating the appropriate discrepancy sheet l

for any discrepancies identified.

RESOLUTION:

Resolution includes the l

l determination of the appropriate solution for l

any discrepancy and the incorporation of the l

solutions into the E0Ps.

l The E0P Verification Worksheets (and l

resolutions) will be returned to the l

procedure writer for rewriting or otherwise l

correcting the procedure or applicable l

section.

00CUMENTATION:

The results of the

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verification activity shall be recoroed using the following forms:

l E0P Verification Worksheet (Sample included l

as Attachment 2) l E0P Verification / Resolution Record (Sample l

included as Attachment 3) l All records shall be retained in accordance with l

Quality Procedure Q-17, " Quality Records".

I 3.2 VALIDATION ACTIVITIES l

The validation of all changes to the Fort St. Vrain l

Control Room and E0Ps is to be accomplished through an l

Integrated Validation effort as described by the " Program l

Plan for the Integrated Validation of NUREG-0737 l

Initiatives".

I 3.2.1 Objective l

Validation objectives as applicable to the E0Ps I

are defined in Section 2.2.1 of the " Program Plan l

for the Integrated Validation of NUREG-0737 l

Initiatives".

l 3.2.2 Methodology l

The methodology to be utilized in conducting the l

Integrated Validattor. activity is defined in l

Section 3.0 of the " Program Plan for the l

Integrated Validation of NUREG-0737 Initiatives".

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a-v 4.0 TRAINING PROGRAM 4.1 GENERAL REQUIREMENTS l

Subsequent to the completion of the Integrated Validation l

activities and prior to implementation of ~the E0Ps into l

the control room, all operators scheduled for control room l

operating assignments will receive training on the full l

complement of E0Ps.

A training segment will be developed that deals specifically with emergency plant operation. This course segment will be made a part of the Reactor Operator Training Program, the Senior Reactor Operator Training Program and the Licensed Operator Requalification Program.

l (NOTE:

PSC presently has a course segment which addresses I

the existing set of emergency procedures.

This same l

course segment will be revised to address the new E0P set

-l structure and use.)

l The requalification training sessions conducted after the l

start of E0P generation will include segments to introduce j

the concepts of CSF monitoring and restoration.

4.2 PROGRAM DESCRIPTION Training for both licensed operators and license candidates will consist of classroom instruction and control room / mock-up walk-throughs.

Implementation of training will be conducted in the following manner:

4.2.1 Classroom instruction sessions for the Reactor-Operator Training Program and the Senior Reactor Operator Training Program will be conducted to introduce operators to the concepts of CSFs and the emergency procedures.

Procedures will be presented during classroom l

sessions to enable the operator to understand the l

structure of the E0Ps, to understand the parallel l

path approach to emergency operation, to obtain a l

working knowledge of the technical content of the l

E0Ps, to understand the technical basis of the l

E0Ps, and to understand the responsibilities of l

the operators in executing the E0Ps.

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4.2.2 Control room / mock-up walk-throughs for the Reactor Operator Training Program and the Senior Reactor Operator Training Program will be conducted to familiarize the operator with the particular displays and controls to be used when performing emergency tasks.

The walk-throughs will enable the operator to be exposed to the EOPs.in an operational setting and will provide the opportunity for the operator to demonstrate the use of the emergency procedures.

l The walk-throughs will be performed by the minimum l

cperating staff as required by the Technical l

Specification.

Each participant will be assigned l

the role of a particular shift position while l

performing emergency procedure walk-throughs.

l Walk-through sessions shall exercise all possible l

procedure paths to assure that each operator is l

familiar with the full extent of the procedure.

The operator's training in the use of each l

procedure in the control room / mock-up setting will 4

be documented using Job Performance Measures in accordance with the Fort St.

Vrain Training Management Procedures.

l Training walk-throughs will be performed in the l

following manner:

The minimum operating staff (as required by l

l Technical Specification) shall assume their l

normal operating positions and duties.

This

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may include routine CSF monitoring.

The trainer shall iniciate (via the SPDS l

l simulator) or verb &lly present the initiating l

symptom or event.

The operating staff shall assess the

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i postulated challenging event or symptom of l

such event and perform (simulate performance) l all procedure steps and contingency actions l

required under actual conditions to place the l

plant is a safe condition and assure public l

safety.

Changing plant conditions may be l

described to the operating staff in order to l

dynamically simulate plant onfigurations.

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Y 4.2.3 After all licensed operators have received initial training on the emergency procedures, they will receive a course segment related to emergency operation during requalification training.

This course segment will consist of a condensed version of the classroom portion of initial training.

Additionally, the classroom segment for requalification will include:

training on new E0Ps, descriptions of any significant transients or accidents (since the previous requalification class) that have required the use of emergency procedures and solicitation of feetoack from operators concerning their use of the emergency procedures.

The requalification training segment will also include walk-throughs in the control room / mock-up similar to those conducted for initial training.

4.2.4 Training on minor emergency operating procedure revisions is conducted through required reading using material derived from the plant Operational Information Assessment Group. Training for major revisions to the E0Ps will be conducted as pre-shift sessions or as operations seminars.

l Pre-shift sessions or operations seminars are i

special informational sessions convened for the l

purpose of providing operator briefings and l

training relative to recent changes in procedures, l

materials and/or policies.

l Pre-shift sessions or operations seminars convened l

for the purpose of training operators on major E0P l

revisions will include walk-throughs of the l

procedure changes with the minimum operating staff I

as required by the Technical Specifications.

4.3 TRAINING EVALUATION l

4.3.1 Evaluation of the effectiveness of the training l

sessions will be accomplished by the Fort St.

Vrain training staff.

The training staff will determine whether the objectives of the training program have been met by using a combination of written tests and the satisfactory completion of the Job Performance Measures associated with the emergency procedures.

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3 A minimum grade of 80% on the written test and a satisfactory on the Job Performance Measures will be required for successful course segment completion.

4.4 TRAINING PROGRAM CHANGES 4.4.1 Incorporation of changes to training materials which relate to the emergency procedures and operator feedback will' be accomplished using the Training Development process outlined in the Fort St. Vrain Training Management Procedures.

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5.0 REFERENCES

l 5.1 Administrative Procedure G-2, "FSV PROCEDURE SYSTEMS",

l Fort St.

Vrain Nuclear Generating Station, Issue 21, l

January 27, 1987.

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5.2 INP0 82-017, " Emergency Operating Procedures Writing l

l Guideline", July, 1982.

l 5.3 Quality Procedure, Q-17,

" QUALITY RECORDS",

Issue 10, l

January 30, 1987 l

5.4

" Guidelines for Preparation of Emergency Procedures",

l SOAP-2, (Attachment 1) l 5.5

" Program Plan for the Integrated Validation of NUREG-0737 l

Initiatives" l

5.6 NUREG-0737, Supplement 1,

" Clarification of TMI Action l

Plan Requirements".

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