ML20092H491

Forwards Response to 840511 Request for Addl Info Re 840531 Generation Package for Emergency Procedures

ML20092H491
Person / Time
Site:	Prairie Island
Issue date:	06/18/1984
From:	Musolf D NORTHERN STATES POWER CO.
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8406260137
Download: ML20092H491 (5)

Text

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Northem States Power Company 414 Nicollet Malt Minneapolis. Minnesota 55401 Telephone (612) 330-5500 June 18, 1984 Director Office of Nuclear Reactor Regulation U S Nuclear Regulatory Commission Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLAhT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Information Related to Procedures Generation Packace In a letter dated May 11, 1984 f rom Mr James R Miller, Chief, Operating Reactors Branch #3, Division of Licensing, USNRC we were requested to provide additional informatian in five areas related to our by 31, 1984 generation package for emergency procedures. The purpose of this letter is to provide the requested information.

Attachment (1) is a copy of the information requested by the NRC Staf f.

Attachment (2) contains our responses prepared by the Prairie Island Nuclear Technical Services group.

Please contact us if you require additional information related to this issue.

D s : D k-,

David Musolf Manager - Nuclear Support Servics DMM/ dab c: Regional Administrator - III, NRC NRR Project Manager, NRC Resident Inspector, NRC G Charnoff Attachments 8406260137 840618 PDR ADOCK 05000282 L F PDR I

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Director of NRR, USNRC June 18, 1984 Attachment (11 REQUEST FOR ADDITIONAL INFORMATION PRAIRIE ISLAND NUCLEAR GENERATING PLANT . UNIT NOS.1 AND 2 The staff is reviewing the Procedures Generation Package (PGP) for Prairie Island Unit Nos. I and 2 submitted by letter from David Musolf to the  ;

Director of the Office of Nuclear Reactor Regulation dated May 31, 1983. We nave determined that additional information is needed to conduct a detailed review of the Plant-Specific Technical Guidelines and Validation / Verification portions of the PGP. The staff is currently conducting a detailed review of the two remaining portions of the PGP, the plant-specific writer's guide and the training program. So that we may continue our review of the Plant-Specific Technical Guidelines and the Validation / Verification Program, the following information should be provided as a revision to the PGP.

1. A description of the process used to determine the applicability of the actions specified in the generic technical guidelines to your plant.

This should be a detailed description of the engineering evaluation or analysis, to the specific operator task level, that was performed to '

modify the generic guidelines and apply them to Prairie Island Unit Nos.

I and 2.

2. If the process described in item 1 identifies any safety significant deviations from, or additions to the generic technical guidelines (because of different plant equipment operating characteristics or design), the PGP should: (1) describe the evaluation performed to determine the safety significance of the deviations, (2) identify the safety significant deviations or additions, and (3) provide the technical justification (i.e., engineering evaluation or analysis, as appropriate) for the plant-specific apprcach.

3. Describe the process for using the generic guidelines and' background documentation to identify the characteristics of needed instrumentation and controls. For the information of this type that is not available from the ERG and background documentation, describe the process to be used to generate this information (e.g., from transient and accident analyses) to derive instrumentation and control characteristics. This process can be described in either the PGP or Detailed Control Room Design Review Program Plan with appropriate cross-referencing.

4 For potentially safety-significant plant-specific deviations from the ERG l instrumentation and controls, provide in the PGP 'a list of the deviations ,

and their justification. These shculo be submitted in the plant-specific l

technical guideline portion of the PGP, along with other technical '

deviations.

5. Provide a description of the methods that Northern States Power Ccepany will use to validate / verify emergency operating procedures developed by this program.

The information is needed to provide assurance that a sound basis, and a formal, documented process are used for making current and future modifications to emergency operating procedures.

r Director of NRR, USNRC June 18, 1984 Attachment (2)

1. To determine the applicability of actions specified in the generic technical guidelines to Prairie Island, a comparison was performed between the reference plant, used for develop-ment of the generic guidelines, and Prairie Island.

The reference plant is described in the Uestinghouse Emer-gency Response Guideline (ERG) background information. It describes each of 25 separate plant systems to the extent necessary to provide technical guidance on the operation of plant system in response to an emergency transient but not '

in a detail which exceeds that specifically identified in the ERGS. Each of these system descriptions was then compared to Prairie Island and a list of differences was obtained. Review of this list indicates no safety signifi-cant differences exist between Prairie Island and the reference plant.

The method used to generate procedures from the generic guidelines, involved review of the guidelines, supporting background information, existing plant emergency, abnormal, and normal operating procedures and other plant reference material as necessary (Technical Specifications, FSAR, Flow and Logic Diagrams). The ERGS are generally speci-fic in what operator tasks are required to perform a ,

required step. In .some areas the ERGS require that plant specific means or setpoints be entered. These were re-searched by reviewing existing procedures, system draw-ings or discussions with operators and system engineers.

Appropriate tasks were written and entered into the pro-cedure. Consolidation of certain ERG steps were done to assist in operator performance of the tasks. For example, three steps are used in the ERCS to assure auxiliary feedwater flow: 1. Verify AFW pumps running, 2. Verify AEW flow, and 3. Verify AFW valve alignment. These were consolidated into one step dealing with AFW flow. Set-points are another area which required input into the ERGS to create plant specific Emergency Procedures. These were researched through review of plant documentation and a setpoint document was created for use in procedure devel-opment to insure consistent and accurate application of the setpoint information.

2. As described in item 1 above, no safety significant devia-tions to the generic guidelines were identified.

3. The process of using the generic guidelines and background documentation to identify the characteristics of needed instrumentation and controls will be described in our De-tailed Control Room Design Review Summary Report. Our approach to performing Systems Review and Task Analysis was described in the program plan submitted in June, 1983 and audited during the control room design review NRC in-progress audit performed in March,1984. Unless further clarification is received from the NRC, we plan on meeting the intent of the NRC memorandum summarizing the meeting held with the Westinghouse Owners Grcup Procedure Sub-committee and NRC staff representatives on March 29, 1984.

(NRC memorandum dated April 5, 1984 from H. Brent Clayton to Dennis L. Ziemann).

4. No safety significant plant-specific deviations from the ERG instrumentation and controls have been identified.

Further work is being done, by the Control Room Design Review Program, in this area consistent with the intent of the NRC memorandum summarizing the meeting held with the Westinghouse Owners Group Procedure Subcommittee and NRC staff representatives on March 29, 1984 (NRC memorandum dated April 5, 1984 from H. Brent Clayton to Dennis L.

Ziemann). ,

5. The plant specific procedures have undergone several valida-tions/ verification processes.

1) Table-top validation / verification of the procedures during operator requalification training session which consisted of each shift compliment (control room reactor operators, senior reactor operator, and shift supervisor) reviewing each procedure and providing comments. Procedures were reviewed for readability, completeness, accuracy, and technical content.

2) Use of the procedures by licensed operators and licensed engineers during simulator training in the 1983 operator requalification program.

3) Comparative evaluation to ensure that consistency was maintained between the procedures and the background documents.

4) Human Factor assessment utilizing an interdisciplinary team with engineering, operations, and human factors expertise performing walk / talk-through of the procedure at a full scale control board mockup. This assessment included component availability and arrangement and mover,ent patterns. As a further compliment to the above validation / verification processes, the procedures are now being exercised on the plant-specific simulator during the 1984 licensed operator and licensed engineer requalification program. Recommended changes will be processed in accordance with our normal plant adminis-trative control directive for procedure control. In addition the procedure will undergo a detailed human engineering review during the control room design re-view. The review will study:

o Arrangement of related controls and dfsplays o Traffic patterns o Component availability o Component labell;ag o Direct feedback verification of control position o Procedural sequence validity o Component suitability o Procedure-label consistency o Communication requirements -

o Manpower A set of Human Engineering Deficiencies will be devel-oped and evaluated in accordance with our Detail'ed Control Room Design Review Plan.

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