Response to Portion of NRC Request for Additional Information … · 2012-11-21 · MFN 06-444 Page...

GE Energy

David H. HindsManager. ESBWR

PO Box 780 M/C L60Wilmington, NC 28402-0780USA

T 910 675 6363F 910 362 [email protected]

MFN 06-444 Docket No. 52-010

November 18, 2006

U.S. Nuclear Regulatory CommissionDocument Control DeskWashington, D.C. 20555-0001

Subject: Response to Portion of NRC Request for Additional InformationLetter No. 74 Related to ESBWR Design Certification Application -ESBWR Human Factors Engineering NEDO-33274 Rev. 0,Procedures Development Implementation Plan - RAI Numbers 18.9-1through 18.9-10

Enclosure 1 contains GE's response to the subject NRC RAIs transmitted via theReference 1 letter.

If you have any questions about the information provided here, please let me know.

Sincerely,

David H. HindsManager, ESBWR

Oo&ffGeneral Electric Company

MFN 06-444 of 2

Reference:1. MIFN 06-383, Letter from U.S. Nuclear Regulatory Commission to David Hinds,

Request for Additional Information Letter No. 74 Related to ESB WR DesignCertification Application, October 11, 2006

Enclosures:1. MFN 06-444 - Response to Portion of NRC Request for Additional Information

Letter No. 74 Related to ESBWR Design Certification Application -ESBWRHuman Factors Engineering NEDO-33274 Rev. 0, Procedures DevelopmentImplementation Plan - RAI Numbers 18.9-1 through 18.9-10

cc: AE Cubbage USNRC (with enclosures)GB StrambackGE/San Jose (with enclosures)eDRF 0000-0059-9163

Enclosure 1

MFN 06-444

Response to Portion of NRC Request for

Additional Information Letter No. 74

Related to ESBWR Design Certification Application

Human Factors Engineering

NEDO-33274 Rev. 0, Procedures Development ImplementationPlan

RAI Numbers 18.9-1 through 18.9-10

MFN 06-444 Page 2 of 14Enclosure 1

NRC RAI 18.9-1

A. Ch. 18, App. A, of DCD states that the ESBWR emergency procedure guidelines(EPG)/severe accident guidelines (SAG) were derived from Rev. 2 of the BWROGEmergency Procedure and Severe Accident Guidelines. Section 3.1.1 of NEDO-332 74 states that ESBWR adapted EOPs from previous ABWR designs. Section 3.3also mentions adapted procedures from 'previous ABWR procedures." Also, the useof the Rev. 2 of the BWROG EPGs to develop the first version of the ESBWR EPGsis not shown in Figure 2 of NEDO-33274 nor is it discussed in the text of NEDO-33274. Please clarify.

B. Section 3.1.1 of NEDO-33274 states that the "..ESBWR EOPs are the result ofapplying ... OERs [Operational Experience Review] to modify previousprocedures..." Which OERs are referred to here? Are they available for NRCreview?

C. Section 3.1.2 states that "The EPGs, contained in Appendix 18A of the Chapter 18of the DCD, provide a basis for human factors evaluations of emergencyoperations. "However, Figure 2 shows the HFE evaluations on the right side of theFigure as being applied to the EOPs rather than the EPGs. Please clarify.

D. The last two sentences of Section 3.1.2 mention EOPs and procedures. It appearsthat it should be EPGs. Please, clarify.

E. Section 3.2.1.6 states that "... emergency procedures displays are continuouslyupdated. "Please clarify "continuously ".

F. Section 3.3.3 discusses an error tracking system, but it is not clear if this system isto be used or not, or how the decision will be made as to its use. Please clarify.

G. Section 4.4 discusses alarm response procedures for dedicated fixed-position alarmtiles. Since the HSI Design Plan, NEDO-33268, notes that only selected importantalarms are fixed-position on the Wide Display Panel (WDP). Please clarify whetherall alarms will have ARPs or just the subset that are fixed position.

H. Figure 1 ofNEDO-33274 has a block labeled "Emergency Procedure and ResponseGuidelines" but the term "Response Guidelines" has not been used in the text. Also,the phrase "All HSIs conform to HFE Guidelines" is under both "HSI Task SupportVerification" and "HFE Design Verification" of Figure 1, and HFE guidelines aretypically not relevant to task support verification. Also, Procedure Development isapparently missing from Figure 1. And, the input of PRA/HRA and Task Analysis toprocedures is not shown. Please clarify Figure 1.


GE Response A

A. The DCD Tier 2, Chapter 18, Appendix A, EPGs/SAGs were derived from theBWROG EPGs/SAGs Rev. 2. The DCD Chapter 18, Appendix B, documents thedifferences between the generic ESBWR EPG/SAGs and the BWROG EPGs/SAGsRev. 2. NEDO-33274 Figure 2 will be updated to reflect that the BWROGEPG/SAG Rev. 2 is an input in the HFE Program during HSI procedure design andtext will be added in the NEDO description regarding EPG/SAG Rev. 2 use in theProcedure Development Implementation Plan.

Also, the second sentence of section 3.1.1 of NEDO-33274, where it states, "Asdescribed in Chapter 18 of the DCD, the ESBWR procedure development processadapted EOPs from previous ABWR designs" will be deleted.

In addition, section 3.3, first paragraph, 4 th sentence of NEDO-33274 will berevised to read, "They are adapted to the ESBWR using engineering evaluation andanalysis to support the adequacy of each ESBWR deviation from previous BWRand ABWR procedures".

B. The initial ESBWR EPGs in DCD Tier 2 Chapter 18 were developed based onprevious experience on BWR, ABWR Plant Specific EPGs as well as the BWROwner's Group EPGs. Operational Experience Reviews (OERs) of previous BWRand ABWR EPGs and Emergency Procedures are based on potential ESBWRcustomers in-use plant procedure transmittals and use of a GE sub-contractedemergency procedure designer that has designed or assisted in the design of variousBWR product lines including using common EOP flow chart templates as a startingpoint, with refinements based on plant specific design features, licensed operatorfeed back, procedure validations, and NRC operator licensed exam results.Additionally, potential ESBWR owners with existing units, will provide theiroperational experience with their own procedure designs. The ESBWR EOPs willbe derived from the generic ESBWR EPGs with HFE inputs based on the HFEProcedures Development Implementation Plan. For clarification, in NEDO-33274Rev. 0, section 3.1.1, the paragraph's second and third sentences will be revised toread:

"As described in Chapter 18 of the DCD, the ESBWR proceduredevelopment process will adapt EOPs from previous BWR and ABWRdesigns. The initial ESBWR EOPs will be the result of applying thegeneric ESBWR EPGs considering the unique ESBWR design featuresand operational experience reviews (OERs) of previous BWR and ABWRemergency procedures, to modify the previous procedures as needed toaddress system and component differences from the BWR and ABWR."

C. The Emergency Procedure Guidelines (EPGs) evolve into Emergency OperatingProcedures (EOPs), procedures that are used by the plant operations personnel. It iscorrect that the right side of Figure 2 should show the EOPs for the HFEevaluations.


D. In this case, the usage should refer to EPGs as the EPGs are compared to theBWROG EPGs. The Task Analysis is for EPGs as the EPGs direct tasks that areperformed in the plant Emergency Operating Procedures and support procedures.

E. Section 3.2.1.6 paraphrases the Utility Requirements Document, Chapter 10,Instrumentation, Control, and Man Machine Interface System, section 3.4.2.2.2where it states that the power plant parameters and status presented as part of theprocedure displays shall be continuously updated, in regards to practices forelectronically displayed procedures. At this stage of the ESBWR design, theEmergency Procedures displays may be flow chart or logic format and the plantparameters and statuses presented are used either directly or in support of the plantEmergency Procedures, such as dynamic limit curves, which display the safe andunsafe zone of plant operation, and the plant trends in those zones.

F. The error tracking system will exist and will be the HFE Issue Tracking System.Section 3.3.3 third paragraph, last sentence, is referring to an example trackingsystem, regarding simulator tests of an early BWR tracking system as discussed inthe second sentence of the same paragraph.

G. The dedicated fixed-position alarms tiles are associated with system levelannunciator alarms. The alarm response procedures will address all system levelannunciator alarms.

H. The text, "Emergency Procedure and Response Guidelines" is associated with thesame text used in NUREG 0711 Rev. 2, Figure 7.1. The text box of Figure 1 ofNEDO-33274 will be revised to read, "Emergency Procedure Guidelines" as thereis no discussion of Emergency Response Guidelines in the document.

In Figure 1 of NEDO-33274, remove the text "All HSI conform to HFEGuidelines" under header HSI Task Support Verification column will be removed.

In Figure 1 of NEDO-33274, the figure will be revised to add the text, "ProcedureDevelopment" in the appropriate location as well as revise the figure to showPRA/HRA and Task Analysis as input to procedure development.

DCD/LTR Impact

No DCD changes will be made in response to this RAI.

LTR NEDO-33274 Rev. 0 will be revised as described above.


NRC RAI 18.9-2

A. DCD Chapter 13.5 and this plan discuss the scope of the procedure program for theESBWR. Ch. 13.5 commits to ANS 3.2 (no revision provided). However, it does notcommit to RG 1.33 (which endorses ANSI/ANS 3.2 but also provides additionalguidance). The most current version of ANSI/ANS 3.2 is 1994 (Reaffirmed 1999).Please address.

B. DCD Section 13.5.3.4 lists procedures to be covered by the Procedure DevelopmentPlan. These are all addressed in NEDO-33274 except for Radiation Control,Calibration, and Inspection procedures. Please address.

GE Response

A. DCD Tier 2 Chapter 13 will be revised to show commitment to Regulatory Guide1.33 Revision 2, February 1978 as well as ANSIIANS-3.2 1994: R1999(R=Reaffirmed), Administrative Controls and Quality Assurance for theOperational Phase of Nuclear Power Plants.

B. NEDO-33274 will be revised to address procedures for Radiation Control,Calibration, and Inspection as identified in DCD Tier 2, Section 13.5.3.4.

DCD/LTR Impact

DCD Tier # 2, Section 13.5.3.4 will be revised as noted in the attached markup inRevision 3.

Sections 1.2, 3, and 4 ofLTR NEDO-33274 Rev. 0, will be revised as described above.


NRC RAI 18.9-3

A. Section 1.2, Scope of NEDO-33274, in Item L.a, appears to limit the scope of theplan to "..representative procedures for important tasks.." This plan should apply toall procedures within the categories described. Please, clarify.

B. Section 4 of NEDO-33274, "Integrated Operating Procedures Included in Scope ofPlan" does not include maintenance procedures. Please add, orjustify why they arenot included.

C. Section 4.2 "System Operating Procedures" applies SOPs to systems important tosafety. This should be clarified to include those BWR systems in RG 1.33 plusanalogous ESBWR systems. Please clarify.

GE Response

A. The discussion of selection of representative procedures will be revised. The text ofsection 1.2, Scope of NEDO-33274, in item L.a will be revised to read, " Identifyimportant procedural tasks from the areas of abnormal conditions, accidentresponse, normal operation, test and surveillance;"

B. Maintenance and modification procedures that require operator actions to be takenin the main control room or remote shutdown station shall be included asappropriate. Add to section 4 of NEDO-33274, first paragraph, third sentence,"...Maintenance Procedures for performing maintenance,.

C. The statement, "... important to safety", is verbatim from SRP 13.5.2.1, procedureclassification, system procedures. Only those BWR systems in Reg. Guide 1.33applicable to the ESBWR, as well as the specific ESBWR systems, would beaddressed in this HFE Procedure Development Plan.

DCD/LTR Impact




NRC RAI 18.9-4

Section 3.2 limits the use of the Procedure Writers Guide to Normal OperatingProcedures and Emergency Procedures. According to the acceptance criterion ofNUREG-0711, the Writers Guide should apply to all procedures within the scope ofNEDO-332 74, which would also include maintenance procedures. Please clarify whetherthe appropriate items in Section 3.2 and Section 4 also apply to maintenance procedures.

GE Response

All plant procedures will be based on a Procedure Writers Guide(s), be they NormalOperating and Emergency Procedures, as well as Maintenance procedures.

Section 3.2, of NEDO-33274, first paragraph, last sentence C will be revised to read:

"The normal plant operating and emergency procedures developed bydesigners and procedure writers, as well as maintenance procedures, areenhanced during the application of the ESBWR HFE program plan byfollowing procedure development steps:"

Section 3.2.1 of NEDO-33274 will be revised to read:

"Develop a Writers Guide for the ESBWR that establish the process fordeveloping technical procedures that are complete, accurate, consistent, andeasy to follow. The Writers Guide will contain objective criteria such thatprocedures developed in accordance with it are consistent in organization,style, and content. The guide will be used for all procedures within the scopeof this element."

DCD/LTR Impact


LTR NEDO-3 3274, Rev. 0 will be revised as described above.


NRC RAI 18.9-5

A. Section 1.2.2, Emergency procedures, discusses the content of ARPs, but does notinclude setpoints as an item to be included. This section should refer to all of theguidance in NUREG-0700, Rev. 2, Section 4.5, which includes setpoints. Pleaseaddress.

B. Section 3.2.1.7 states that procedures displayed in the HSI conform to industry andregulatory guidelines regarding HFE principles for computer displayed controlsand procedures. This should refer specifically to NUREG-0700, Rev. 2 (pluserrata), Section 8. Also, please specify which industry guidelines.

C. The commitment to ANSI/ANS 3.2 should be clarified to apply to the latest versionof ANS 3.2, which is currently 1994 (Reaffirmed 1999). -

GE Response

A. The Alarm Response Procedures are understood to associate the alarmed conditionwith the instrument setpoint. For clarification, section 1.2.2 first paragraph, lastsentence will be revised to read, "..., (2) the source of the signal and it's alarmsetpoint, (3) any immediate actions that occurs automatically, (4) the immediateoperator action, and (5) any long-range actions. The Alarm Response procedureswill comply with section 4.5 of Ref. 2.1.8, NUREG-0700 Rev. 2."

B. For clarity section 3.2.1.7 of NEDO-33274, will be revised to read, "Normal plantoperating and emergency procedures displayed in the HSI will conform to section 8of NUREG-0700 Rev. 2 (plus errata), regarding HFE principles for computerdisplayed controls and procedures."

The industry and regulatory guidelines regarding HFE principles for computerdisplayed controls and procedures include Refs. 2.3.5 NUREG/CR-6634:Computer-Based Procedure Systems: Technical Basis and Human Factors (2000,BNL) and several EPRI reports on Hybrid Control Room Modernization Planningand Human Factors Guidance Application Support.

C. Reference 2.2.1 will be corrected to ANSI/ANS-3.2 1994: Reaffirmed 1999.

DCD/LTR Impact




NRC RAI 18.9-6

A. Section 3.3.3, ESBWR Incorporation of As-Built Procedures, states that identifiedissues are incorporated into procedures if risk important. While the use of riskinsights is important and encouraged, it is not necessary nor does not appearappropriate here. Identified procedure enhancements should all be incorporatedwithout a risk screening. Please explain the rationale for using risk screening toincorporate information into procedures.

B. Section 4 states that selected samples of normal plant operating and emergencyprocedures are validated using a talk/walk through. Please, clarify why only"samples" are validated using talk/walk through, i.e., how are the remainingprocedures validated.

C. The Section 3 lead-in material states that HSI Task Support Verification applies tonormal operating procedures and that HFE Design Verification applies toemergency procedures. Per NUREG-0711 both of these activities should apply toHSIs that are contained in both normal and emergency procedures. Also, does thisstatement refer to HSIs, computer-based procedures, or both?

GE Response

A. Section 3.3.3 of NEDO-33274, last paragraph, last sentence, pertains to issues fromthe operational training program and that if risk important issue are identified in theHFEITS, any proposed changes to the procedures or HSI are evaluated. Howeverfor clarity section 3.3.3 of NEDO-33274, last paragraph, last sentence will berevised to read, "Each issue undergoes the same type of analysis and if riskimportant or otherwise a procedure enhancement, proposed changes in theprocedures or HSI will be evaluated and incorporated if appropriate."

B. All normal operating procedures are to be validated. For clarity, section 4 ofNEDO-33274, second paragraph, last sentence will be revised to read, "All normalplant operating and emergency procedures will be validated through simulatortesting where applicable, or through talk/walk through."

C. The premise of the HFE Procedures Development Plan was a top down approachstarting first with the EPGs/EOPs, followed by the Normal Plant OperatingProcedures. Section 3, fifth paragraph, numbered items 1, 2, and 3 are revised tohave numbered items 1 and 2 reversed in order. The initial HFE DesignVerification would be for the emergency procedures, followed by HSI Task SupportVerification of normal plant operating procedures, then Integrated System DesignValidation of all normal plant operating and emergency procedures.

DCD/LTR Impact


MFN 06-444Enclosure 1


Page 10 of 14


NRC RAI 18.9-7

A. Section 3.1 states that the types of electronic procedures displays range from fullyinteractive to viewable pdffiles. Other sections of the document and the DCD seemto imply that interactive CBPs will be used. Please clarify.

B. Section 4.6 states that "Computer support for using the EOPs is considered duringthe design development." Also, Items 6 through 10 used the words "if adapted"forCBPs. DCD Tier 2, Revision 1, Section 18.9 seems to state that this decision hasalready been made to use CBPs for the EOPs. DCD Tier 2,Section 18.9 alsoprovides six characteristics/requirements of the CBP system that is only qualifiedwith the possibility of simulation revealing deficiencies and the possible need for adifferent implementation in some of these requirements. Please clarify.

GE Response

A. The types of electronic procedure displays as described in section 3.1 ofNEDO-33274 will remain the same, fully interactive to viewable display procedurefiles, in some cases, to be determined during the HSI procedure evaluation. It isdesirable that all procedures will be computer based. However, the ability to printthe procedures from a pdf archive file will also be provided in addition to theinteractive CBPs.

B. For clarity, section 4.6 of NEDO-33274, Items 6 through 10, the text, "If adapted,"will be removed. Also newly issued DCD Tier 2 Chapter 18 Rev. 2, section 18.9has been revised. There are now 9 bulleted requirements for procedures presentedelectronically and the text, "unless simulation reveals deficiencies and a need fordifferent implementation requirements", has been removed and the paragraphrevised in its entirety.

DCD/LTR Impact


LTR NEDO-3 3274 Rev. 0 will be revised as described above.


NRC RAI 18.9-8

NEDO-33274 states in Section 4.6 that "Sufficient laydown space is provided for hardcopies of EOPs, other procedures and other documents required by the operators duringaccident management and the performance of their regular duties. However, it is notclear if this applies to the main control room only or if it also applies to the remoteshutdown facility and appropriate local control stations. Please clarify. Also, while theloss of CBPs is noted in Operational Conditional Sampling in the V & V Plan, in item4.3.1.4.1. 1.b, it should be addressed in the Procedure Development Plan.

GE Response

The main control room will have a lay down space for hard copies of EOPs and otherprocedures or documents required by the operators during accident management and theperformance of their regular duties. The remote shutdown panel area and local controlstations do not have dedicated lay down areas for plant procedures, but empty area roomspace is available for temporary procedure carts, work tables, or other devices forprocedure use.

Section 4.3.1.4.1.1.b of NEDO-33276, HFE Validation and Verification ImplementationPlan, HSI failures, lists loss of processing and/or display capabilities for computer-basedprocedures. The original intent was to have back-up hard copies of all plant proceduresfor such a scenario when the computer based procedures were not available. The use ofhard-copy paper procedures are discussed in section 3.1 of NEDO-33274.

DCD/LTR Impact


No changes to the subject LTR will be made in response to this RAI.


NRC RAI 18.9-9

Section 3.2.2 ofNEDO-33274 discusses the determination of the minimum inventory. Thediscussion in NEDO-332 74 should be updated based on the response to RAI 18.7-7.

GE Response

The response to RAI 18.7-7 commits to revise section 5.2, second paragraph ofNEDO-33267, HFE HRA Implementation Plan, to reference Table 19.2-3, Risk Insightsand Assumptions in Tier 2 Chapter 19 Rev. 1, September 2006. ESBWR DCD Tier 2Chapter 19 Revision 1, September 2006, will be added to reference section 2.1 ofNEDO-33274 for consistency.

DCD/LTR Impact


LTR NEDO-33274, Rev. 0 will be revised as described above.


NRC RAI 18.9-10

Section 3.2.3 of NEDO-33274 notes that SPDS will not necessarily be in the TSC andEOF. The discussion in NEDO-33274 should be updated based on the response to RAI18.7-5.

GE Response

RAI 18.7-5 does not address SPDS, however for clarity section 3.2.3, third paragraph,last sentence of NEDO-33274 will be revised to read, "The ESBWR HSI does notprovide a separate SPDS, but rather, the principal functions of the SPDS, as required byNUREG-0737, Supplement 1, is integrated into the HSI design."

DCD/LTR Impact


LTR NEDO-33274, Rev. 0 will be revised as described above.

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