ML20093A474
| ML20093A474 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/22/1984 |
| From: | NEBRASKA PUBLIC POWER DISTRICT |
| To: | |
| Shared Package | |
| ML20093A467 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 PROC-840622, NUDOCS 8407100546 | |
| Download: ML20093A474 (17) | |
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, PROCEDURES GENERATION PACKAGE
. June 22, 1984 ,
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COOPER NUCLEAR STATION NEBRASKA-PUBLIC POWER DISTRICT h
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43 i c3 4-TABLE OF CONTENTS J
Sectit.i 4 Page I Introduction 1 6
II; '
P;. tnt-Specific Technical Guidelines 2 III .. Writ. 's Guide for E0Ps- _6 ,,
IV E0PlV'tification e Program 8 ,
V E0P Validction Program 10 +
VI- E0P Training trogram 12
' Attachments Attachment 1- 15
( Guideline ~for Preparat un of Operating Procedures, Cooper Nuclear Station, h m 0, April 25,~1984.-
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' I.- INTRODUCTION .
The purpose'of this Procedures Generation Package (PGP) is to describe t the emergency operating procedure - (EOPs) development at Cooper Nuclear Station (CNS) . This document was developed in response to Supplement 1 :
to NUREG-073), Item 7.2b, page 15. ,
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II. PLANT-SPECIFIC TECHNICAL GUIDELINES GENERAL The following program describes the program for converting the General Electric (GE) Boiling Water Reactor Owner's Group (BWROG) E=ergency Procedure Guidelines (EPGs) for GE-BWR 1 through 6 designs into E0Ps for CNS.
The GE/BWROG LPG, Revision 31 (dated March 1984) was used for development ,
of the initial CNS E0Ps. Revision 3I includes improvements by the BWROG Emergency Procedures Committee to Revision 3 (approved by the NRC) which will appear in Revision 4, due fo~ NRC review at the end of 1984.
Differences between Revisions 3 and 31 and their technical justification are documented separately.
When subsequent revisions to the EPGs are approved for implementation by the U.S.' Nuclear Regulatory Commission, the revised information will be incorporated into the E0Ps using the established revision, review and approval process.
PROGRAM DESCRIPTION The following plant-specific technical and source information was used in generation of the CNS E0Ps:
o GE/BWROG EPG, Revision 3I dated March 1984 o USAR o Technical Specifications o Existing E0Ps o As-built plant drawings o Equipment manuals
.o Emergency Operating Procedtires Writing Guideline (INP0 82-017) e Guidelines for the Preparation of Emergency Operating Procedures (NUREG-0899)
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f The E0Ps were developed by- following the EPGs step-by-step adding plant-specific information, details and nomenclature as required. The EPGs are generic-to GE-BWR 1 through 6 designs in that they address all major systems which may be used to respond to an emergency. Because no .
specific plant includes all of the systems in these guidelines, the guidelines are applied to individual plants by deleting statements which are not applicable or by substituting equivalent systems where appropriate. For example, since CNS does not have HPCS, IC or SPMS- -
systems, ; these were deleted. Likewise, CNS has a Mark I primary containment design and all actions applicable to Mark II and III primary containment designs were deleted. Additionally, the EPGs contain in some cases a general category of system which is bracketed, (i.e., [0ther steam driven equipment]) or a bracketed list of' systems, dependent on
,. plant design, that potenti 11y could be used for a given action. The EPG Appendices provide the' direction necessary to apply the bracketed information to the plant-specific E0Ps. Where a list of systems appropriate for a given accion was identified, the corresponding CNS systems were incorporated into the E0Ps. In other cases whera the best q
choice of systems was suggested, these were evaluated and the one or two e most appropriate for'CNS were used. Since the technical basis for the EPGs are generic to GE-BWR 1 through 6 designs using the implementation criteria described above, this method for developing the CNS E0Ps is
-technically justified.
As part of the Verification Program, agreement between the GE/BWROG EPG and CNS EPG is documented along with the basis for any changes on a form !
similar to Figure 1. Likewise, agreement between the CNS EPG and E0Ps is !
documented using a similar form. !
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J FIGURE l-Page of STEP DOCUMENTATION i
Draft Document:
i Source Document:
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DEVIATION DRAFT SOURCE FROM SOURCE STEP STEP BASIS FOR DEVlATION YES NO ,
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Brackets ( - ] within the EPGs enclose plant unique setpoints, design limits, pump shutoff pressures, etc. Parentheses ( ) within brackets -
indicate the source for the bracketed variable. The bracketed values were obtained for the CNS E0Ps in the following manner. Some of the plant unique setpoints are obtained from the CNS technical and source information summarized previously such as the Technical Specifications.
Some of the action levels and curves are calculated values based on EPG, Appendix C, " Calculational Procedures". A list of the plant specific data required for these . calculations and the source of this data was generated as part of the E0P documentation.
A walk-through of the E0Ps was made through the CNS control room 'to confirm that:
o Instrumentation was available to implement the actions in the E0Ps o The action levels were within the range of the installed instrumentation o The action levels could be read on the installed instrumentation o The action level units were in agreement with the installed instrumentation o The nomenclature in the E0Ps were in agreement with installed nomenclature on the control room panels "
Discrepancies were corrected in the E0Ps.
'III. WRITER'S GUIDE FOR E0Ps GENERAL The. Writer's Guide provides detailed instructions on how to prepare E0Ps using sound writing principles. Its recommendations address all aspecth of. writing procedures from a human factors standpoint. Compliance with the CNS Writer's Guide helps ensure all E0Ps are complete, accurate, and readable to control room personnel. This also ensures conformity of format and style for future revisions to the procedures, s
. DOCUMENT DESCRIPTION
- .The CNS Writer's ~ Guide consists of technical and adminictrative information which is us2d to generate concise and precise instructions with a uniform text arrangement.
~ General and specific guidance for preparation of the E0Ps is addressed in the Writer's Guide as follcws:
o Procedure designation and numbering o Procedure organization and format o ' Procedure preparation and content o Mechanics of style o Typing format o Reproduction o Binding
I The Writer's Guide will be revised as necessary, based on training
- feedback, operating experience, and the results of the verification / validation programs.- The CNS E0P Writer's Guide is based on:
o Emergency Operating Procedures Writing Guidelina (INP0 82-017),
developed by the Emergency Operating Procedures Implementation Assistance (EOPIA) Review Group and published by INPO o Guidelines for the Preparation of Emergency Operating Procedures (NUREG-0899)
The CNS Writer's Guide is presented in Attachment 1.
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i IV. E0P VERIFICATION PROGRAM GENERAL E0P verification is the evaluation performed to confirm the written correctness of tne procedure and to ensure that applicable generic and plant-specific technical information has been incorporated properly.
This evaluation also chec'ks that the human factors aspects presented in the E0P Writer's-Guide have been applied. The verification program is based 'on the industry document Emergency Operating Procedures Verification Guidel'ine (INPO 83-004), developed by'the E0 PIA Review Group and published by INPO. .
PROGRAM DESCRIPTION The E0P Verification Program encompasses the efforts necessary to support a comparative evaluation of E0P to source documentation. In developing a process to fulfill this objective the following elements were included:,
o Plant-specific calculations used in the upgraded E0Ps are verified by an independent engineering organization o A Human Factors Engineer conducts a review of the 0Ps and the E0P Writer's Guide o Agreement between the E0Ps and the EPG is documented along with the basis for any changes o Control roc 1 walk-throughs of the E0Ps are performed to confirm:
- a. E0P nomenclature agrees with equipment nameplate, and
- b. Actions levels can be read on ins:alled instrumentation s
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I o An NPPD Licensing and/or Quality Assurance review of the E0P
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o- Each upgraded EOP is submitted for formal review in accordance i- with the established CNS procedures Satihfactory completion of the CNS Verification Procedure for Emergency Operating Procedures will provide a record of activities during the program process. Discrepancies found during the evaluation will also be documented along with the resolution for each discrepancy.
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V. E0P VALIDATION PROGRAM GENERAL E0P validation is the evaluation performed to determine that the actions specified in the procedure can be performed by the operator to manage emergency conditions effectively. The methodology for E0P validation utilizes presently available methods at CNS while recognizing and
. allowing for future improvements. The E0P validation will evaluate the operator's ability to manage emergency conditions using the E0Ps. It ,
will validate those parts of the E0Ps not covered by an technical validation of generic technical guidelines. The program is based on the industry document Emergency Operating Procedures Validation Guideline (INPO 83-006), developed by the E0 PIA Review Group and published by INP0.
PROGRAM DESCRIPTION In developing the E0P validation program, several methods of validation were considered:
o Generic simulator sessions o Control room walk-throughs o Desk top reviews o Seminars / workshops L
Although each of the methods will yield useful information bout the E0Ps, it is believed that control room walk-throughs and sessions on a generic simulator will best establish the accuracy of the E0Ps and demonstrate that the procedures will effectively mitigate transients and accidents.
.The program will be implemented by a team comprised of:
o CNS personnel o A General Electric Company advisor o A Human Factors consultant-1 The team will select and develop scenarios which best exercise each E0P.
In selecting the scenarios, emphasis will be placed on human engineering factors as well as technical adequacy. The scenarios will be developed to guide the operator through anticipated procedure steps so that the evaluation criteria can be addressed. The team will note expected versus actual responses to E0P actions in order to identify potential problems with the E0Ps. They will evaluate operator feedback and provide disposition to procedural discrepancies. It is recognized that some problems may require revision to the E0Ps. In such cases, the validating team.will determine the extent to which the revised E0P must again be verified / validated. Completion of the CNS Validation Procedure for Emergency Operating Procedures will fully document the above process.
E0P validation will be performed prior to the Training Program discussed in Section VI.
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V1. E0P TRAINING PROGRAM
-GENERAL The EOP training program is designed to support implementation of the EOPs. The training is closely tied to the verification and validation of the E0Ps to ensure a supportive program. The underlying goals are to enable the operator to:
o Understand the structure and te:hnict.1 bases of the EOPs o Develop a working knowledge _of the E0Ps o Use the E0Ps under adverse operational conditions This training program will also point out any problems with the new emergency procedures enabling revision and refinement before they are fully implemented in the plant. The following descriptian outlines the approach used to train licensed oper .: ors on the EGPs and to ensu-- the operators are informed and knowledgeable of future changes to the E0"s.
PROGRAM DESCRIPTION The initial _ training effort consists of classroom instruction, control rocm walk-throughs and simulator exercises. In the classroom sessions lectures will be presented which are based on the BWR Emergency Procedure Guidelinea Appendix B, " Detailed Discussion of Cautions and Operator Actions". These are specifically tailored to the CNS plant and will include the following information:
o Logic behind E0P development o The E0Ps themselves o Application of E0Ps under multiple failure scenarios Control room walk-throughs will provide practical e xperience with the E0Ps. During this method of training, the team app >oach to using E0Ps will be stressed.
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This walk-through training will concentrate on:
o Operator responsibilities o Information flow
.o Interactions of the operators in the control roam
' Operators will be referred to control room panel indications and controls in specific emergency scenarios which simulate varying degrees of plant degradation.
Training on the E0Ps will be conducted usi g scenarios on a control room simulator. Scenarios will be developed to utilize a generic simulator.
Training will be conducted with all operators performing their .4ormal control room functions. Emphasis will be placed on leadership roles and divisions of responsibilities among the control room staff as applied to the E0Ps. To further promote the operator's understanding in the various aspects of the E0Ps, team communications and procedural usage techniques will be reinforced during post scenario critique and discussion sessions.
In addition, the plant training and operations staff will participate in
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the development and execution of refresher training. The training staff will develop the scenarios, observe and evaluate the walk-throughs, and critiquc the results. All licensed operators will undergo control room walk-taroughs using the E0Ps during refresher training. The walk-throughs will be conducted either in the control room or a simulator. Realistic. scenarios will be developed to ensure that the critical aspects of the E0Ps are exercised. The scenarios will be varied sufficiently to ensure the operators do not develop a set pattern of responses to incidents but are able to respond to the symptoms as they develop. Further training needs will be determined from the performance of the operators.
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As the.EOPs undergo-revision, training on minor procedure revisions will be' conducted through a program of required readings (self-taught),
preshift briefings or lectures in the requalification program. Training on major. revisions will be conducted by the use of classroom instruction and walk-throughs in the control room or on a-simulator. If operational considerations do not allow control room walk-through s an a simulator is not available, training on - major revisions will be conducted during classroom instruction.
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e o- O ATTACHMENT 1
, t COOPER NUCLEAR STATION ,
GUIDELINE FOR PREPARATION OF EMERGENCY OPERATING PROCEDURES I < p 6
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