ML20059H596

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Action Plan,Eop Task Force. Task Force to Restore EOP Process Documentation to Regulatory & Industry Stds,To Ensure Compliance W/Listed NUREGs
ML20059H596
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 01/14/1994
From: Fleming P
FLORIDA POWER CORP.
To:
Shared Package
ML20059H594 List:
References
RTR-NUREG-0800, RTR-NUREG-1358, RTR-NUREG-800, RTR-NUREG-CR-0899, RTR-NUREG-CR-1875, RTR-NUREG-CR-1977, RTR-NUREG-CR-1999, RTR-NUREG-CR-899 PROC-940114, NUDOCS 9401310022
Download: ML20059H596 (6)


Text

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yq Fk>rida gd Power ACTION PLAN DEPARTMEhrf/DVIDION CR 3 Operations NUCLEAR OPERATONS GOAL Emergency Operating Procedures (EOPs) Task Force PREPAND BY: D E APPFC D BY. DATE

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Paul V. Fleming Senior Nuclear Licensing Engineer f fg g g

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PROJECT DEFINmON (what is to be done?)

Restore EOP process documentation to regulatory and industry standards.

OBJECTIVE (Why will it be done?)

!!is imperative that actions be taken to reinforce the adequacy of the EOPs and restore process control documentation. Ensure applicable elements of the following regulatory guidance is complied with:

= NUREG/CRG99 Ouidelines for the Preparation of Emergency Operating Procedures a NUREG/CR-1875 Evaluation for Emergency Operating Procedures for Nuclear Power Plants

. NUREG/CR-1977 Guidelines for Preparing Emergency Procedures

  • NUREG/CR-1999 Human Engineering Guidelines for use in Preparing Emergency Operating Procedures for Nuclear Power Plants

. NUREG-1358 Lessons Learned form the Special Inspection Program for Emergency Operating Procedures (includes Tl 2515/92)

. NUREG-1358 S1 Lessons Learned form the Specialinspection Program for Emergency Operating Procedures (includes NRC Inspection Manual 42001)

. NUREG 600 Standard Review Plan 13.5.2: Operating and Maintenance Procedures.

. NUREG 800 Standard Review Plan 13 5 2 Appendix-A: Review Procedures for the Evaluation of Procedures Generation Packages.

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9401310022 940114 7 l PDR ADOCK 05000302 e )

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- . a ACTION PLAN'- Continued 1

. METHOD OF IMPLEMENTATION (How will it be done?)

e Assemble an interdisciplinary team to effect restoration.

Individuals have been selected from the following departments:

- Licensing [

c - Operations ,

L, . Training

- Quality Programs Engineering  ;

Using a team approach will provide independence and timely completion. .;

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. . Establish appropriato management to ensure the team functions in accordance with expectations. This is accomplished by using a -

2 Project Maneger (PM) reporting directly to the Operations Manager. Frequent status reports will be communicated to senior management and resident NRC inspectors. >

e Define management expectations of each team member in terms of accountabilities and responsibilities relating to EOP process ?l documentation, j SCHEDULE, WITH BENCHMARKS (when will it be done?)

e Assemble team to discuss milestones, responsibilities, accountabilities Snd logistics.1/24/94

. Update, Review and Approve the Deviation Document using revision 7 of the GTG: .

Update - 2/25,94  ;

. Review - 3/11/94 'E

. Approve - 3/25/94

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. ' Revise and approve EOP Writer's Guide (Al-402A): ,

Revise - 2/25,94 Approve - 3/4/94 -

= Revise and approve EOP Verification and Validation Plan: ,

Revise 2/25/94 l Approve - 3/4/94  !

e Revise Abnormal Procedures (APs) to correct valid deficiencies identified in IR 9316. lf Revise -2/18/94 ,

Approve 2/25/94 {

e Perform safety evaluations (50.59) on all existing EOPs and safety significant GTO deviations.

Deviations 3/11/94 AllEOPs - 3/25/94

= Perform verification on all EOPs:

Complete - 3/31/94 ' f

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-PageE- g b

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p ACTION PLAN - Continued e Perform validation as needed on EOPs:

r 1st run-Week of 4/4/94 2nd run - Week of 4/18/94 Complete 4/29/94

= Revise EOPs to correct valid deficiencies:

Revise 4/8/94 Approve - 4/15/94

. Perform end of task quality programs evaluation:

Complete - 5/6/94 RESPONSIBluTY (Who will do it?)

. The PM, a Senior Nuclear Licensing Engineer, is responsible for ensuring all elements of the restoration plan, as described below, are r completed:

- Operations will update the Plant Specific Technical Guideline (PSTG). This is 3ccomplished by developing a cross-step document comparing the Generic Technical Guideline (GTG) to FPC EOPS. Es ch safety significant deviation will be justified. The PM will be the first level of review. Engineering will provide a sNond level of review. The Operations Manger will provide approval. Establish the deviation document as quality and co',4 trolled.

- Quality Programs will revise the EOP Writer's Guide.

- The Training Department will revise the Verification and Validation Plan.

- Engineering wal review all safety significant GTG deviations.

The Training Department will manage verification and validation efforts with Operations support.

- Operations will revise EOPs to correct actual deficiencies.

Quality Programs will conduct an end of task evaluation.

PROGRAM COST (How much? What resources are required?)

With the exception of performing quality evaluations, all other activities ident:fied in this action plan will be accomplished using intradepartmental personnel and therefore should not result in additional expenses.

There may be a modest expense for the use of personnel (on loan from other utilities) outside the company to help perform quality evaluations.

RESULTS (How will results be measured 7)

Updating the GTG to EOP cross-step and deviation document provides the basis for evaluating EOPs. Ensuring all process documentation is accurate provides the necessary controls for future EOP revisions and evaluations. e IF NECESSARY, ATTACH SUPPORilNG DOCUMENTS Page 3

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i E0P TASK FORCE Proiect Management:

Paul Flemina (Licensing) reporting to G. H. Halnon, Operations Manager. ,

i Responsibilities and Accountabilities:  :

= Restore E0P support documentation to an acceptable status, reverify and revalidate all E0Ps, and produce new 50.59 evaluations on all E0Ps.

= Provide first level of review for all E0P deviations from the GTG.  ;

I a Provide a level of management that ensures all elements of this project l are accomplished in accordance with the established plan, which includes !

updating senior management.

Pro.iect Participants Ron Tvrie (Operations)

Responsibilities and Accountabilities:

= Develop cross-step document GTG to E0P and E0P to GTG.

= Develop deviation document using revision 7 of the GTG, a Ensure project manager review (concurrence) of deviations from GTG.

= Ensure Engineering review (concurrence) of safety significant deviations '

from GTG. l l

= Provide input to revising AI-402A (Writer's Guide for Emergency Operating Procedures) and AI-402C (EOP Verification & Validation Plan).

Joe Baumgardner (Quality Programs)

Responsibilities and Accountabilities:

a Review E0P development requirements.

  • Revise AI-402A (Writer's Guide for Emergency Operating Procedures).

= Coordinate and manage end of project QA evaluation.

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R. C. Zareck (Training)

Responsibilities and Accountabilities:

= Review E0P V&V requirements.

a Revise AI-402C (E0P Verification & Validation Plan).

R. D. deMontfort (Training)  ;

Responsibilities and Accountabilities:

= Coordinate and manage the verification and validation of all E0Ps. ,

= Ensure any problems encountered and documented during the V&V process are resolved.

R. Rawls (Operations)

Responsibilities and Accountabilities: ,

a Develop 50.59 for all E0Ps post verification and validation.

= Provide a technical review of safety significant deviations from the GTG.

= Provide a 50.59 type review for all safety significant deviations from the GTG.

M. Fitzgerald (Engineering) ,

Responsibilities and Accountabilities:

= Provide assistance for technical evaluations of safety significant deviations from the GTG.

= Provide qualified reviewers as needed to support any E0P revisions.

Operations Responsibilities and Accountabilities:

= Ross Bremer - SRO to aid in developing the E0P/GTG deviation document.

= E. Gallion - Provide and manage operators (R0 and SRO) to perform verification and validation of E0Ps. [ Coordinate with D. deMontfort] 4

D E0P Task Force Organization .

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B. J. Hickle Director, Nuclear. Plant Operations i

Greg Halnon Manager, Nuclear Plant Operations Paul Fleming Senior Licensing Engineer Project Manager Ron Tyrie Joe Baumgardner Ron Zareck Dave DeMontfort Mike Fitzgerald EOP Coordinator, SRO Quality Programs SRO~ Cert /Lic. Op Train SRO/Sim Trainer Engineering Writer's Guide EOP~V&V Plan -Manager Perf. Tech. Review'of QA Evaluation of V&V Act. Deviations Qualif. Review of Revisions Ross Bremer SRO Ricky Rawls SRO/STA Deviation Document Cross Step _ Document Writer's. Guide 50.59 Development

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