IR 05000255/1989019
| ML18057A490 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 09/28/1990 |
| From: | Slade G CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9010040108 | |
| Download: ML18057A490 (8) | |
Text
- * consumers Power POWERINli MICHlliAN'S PROliRESS Palisades Nuclear Plant: 27780 Blue Star Memorial Highway, Covert, Ml 49043 September 28, 1990 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -GB Slade General Manager UPDATE TO EMERGENCY OPERATING PROCEDURES TEAM INSPECTION (89-019) STATUS OF NRC COMMENTS The NRC Emergency Operating Procedures (EOP) Inspection Team conducted a special safety inspection on July 24 through August 4, 1989 at the Palisades Plant. The results of the inspection were transmitted in your October 18, 1989 letter to D.P. Hoffman. In that letter, along with other requested actions, you requested that a written response be provided which included a description of our planned actions for resolving each of the specific items identified in Attachments II and III of your report including the dates by which those actions will be complete Our November 17, 1989 letter to the NRC stated that approximately 40 percent of the comments noted in Attachments II and III had been incorporated by revision into the EOPs. It also stated that the remainder of the items would be dispositioned and, as appropriate, included by revision into the EOPs by August 1, 1990. Some of these items were not completed by August 1, 1990. These items and the attached implementation schedule were discussed with the Resident Inspecto Approximately 90 percent of the comments in Attachments II and III, of your October 18, 1989 letter, have been evaluated and either included in the EOPs or determined not to require an EOP update. For the remaining, items we have determined that longer implementation schedule is required based on the scope of work involved. Gerald B Slade _ General Manager CC Administrator, Region III, USNRC NRC Resident Inspector-Palisades Attachment 9010040108 PDR ADOCK 05000255 Q PDC A CMS' ENERGY COMPANY 4o( /'II
- ** ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 UPDATE TO EMERGENCY OPERATING PROCEDURES TEAM INSPECTION (89-019) STATUS OF NRC COMMENTS Implementation Schedule September 28, 1990 6 Pages
.. * NRC Comment Attachment II UPDATE TO EMERGENCY OPERATING PROCEDURES TEAM INSPECTION (89-019) STATUS OF NRC COMMENTS -2. EOP 2.0, "Reactor Trip Recovery" Section 4.0 General Comment -Many of the steps in Section 4.0 are contingency actions. This procedure was ideally suited for two column format.(Page 2) CPCo Response We have hired a consultant to review our EOP procedure format and will evaluate for our purposes the two column format. We will complete the evaluation and if appropriate revise the EOPs by August 1, 1992. NRC Comment Attachment II -2. EOP 2.0, "Reactor Trip Recovery" Section 4.0 In Step 6, the statement
"(refer to EM-04-08)" implied that EM-04-08 provided instructions on how to emergency borate, in lieu of calculating the shutdown margins. EM-04-08 specified the RO (CO) as one of the persons with minimum skills to do the calculation During the walkdowns, the team found that the ROs were trained annually on doing this calculatio During the walkdown, some of the ROs interviewed stated that they could not reliably perform the calculatio More training is needed for the COs in performing the calculation or they should be removed from the list of people with the skill levels to perform the calculation The licensee's representative stated that they would evaluate this issue for possible change. (Page 3) CPCo Response Training on the shutdown margin calculation will be incorporated into requalification training process and training completed by February 28, 1991 . 1
- * NRC Comment Attachment II UPDATE TO EMERGENCY OPERATING . PROCEDURES TEAM INSPECTION (89-019) STATUS OF NRC COMMENTS -2. EOP 2.0, "Reactor Trip Recovery" Step 9 did not specify how the operators were to know that a spray with excessive delta-Thad occurre The licensee's representative stated that this was a training issue and they would evaluate the need for possible changes in the training on this point. (Page 3) -3. EOP 3.0, "Electrical Emergency Recovery" Operator Actions There was a difference of opinion among the operators interviewed as to what the term "operating" means in Attachment 1, Step 9.a. Some operators thought it meant that the diesel was simply running unloaded, while others thought that it meant that the diesel was loaded. The licensee agreed to evaluate the use of the term "operating". (Page 5) The inspector could find no definition of the term "throttle open" used in Steps 1.c and l.d of Attachment 13. The procedure did not specify how far open "throttle open" is. The licensee will evaluate the need to make the procedure clearer on this matter. (Page 6) Attachment II -4. EOP 4.0, "Loss of Coolant Accident Recovery" Step 25.d "checked" open M0-2087. The Writer's Guide indicated that "check" is to compare with a procedural requiremen During the walk down, the operator was unable to define check and could not find procedural authority to close a valve he knew had to be closed. The licensee agreed to add this to the training program. (Page 8) Step 73 used the word "check" as it was defined in the Writer's Guide. Since the operators had not received training in the guide, they were unaware of its meaning. The licensee agreed to incorporated this in EOP training. (Page 9) 2
- * Attachment II Section 4 UPDATE TO EMERGENCY OPERATING PROCEDURES TEAM INSPECTION
{89-019) STATUS OF NRC COMMENTS -8. EOP 8.0 "Loss of Forced Circulation Recovery" The meaning of the "refer to" in Step 45 was different from that in Step 47. This needed to be clarified at this point and throughout the procedure The licensee's representative stated that they will evaluate the need for revising the step and/or providing additional training on the meaning of the "refer to" statement. (Page 15) CPCo Response Training will be completed on EOP usage and definitions by August 1, 1991. NRC Comment Attachment II -6. EOP 6, "Excess Steam Demand Event" Step 26.b referred the operator to Attachment 5. Attachment 5 did not reflect the pump parameters of FSAR Table 6-2 for the LPSI pumps and Table 6-3 for the HPSI pumps. For example, Table 6-2 stated that the maximum pump flow was 4500 gpm for a two pump total of 9000 gpm. The appropriate chart to Attachment 7 did not go to 9000 gpm. Also, the installed flow meters would provide a total flow of only 8000 gpm. Similar comments were applicable to Table 6-3. The licensee agreed to evaluate this concern. (Page 12) -8. EOP 8 "Loss of Forced Circulation Recovery" Section 4.0 Acceptance criteria for degraded pump or a break in an injection line needs to be defined and addressed in Step 18.b. The licensee's representative stated that they will evaluate the possible need for resolving this issue. (Page 15) CPCo Response An evaluation of the affects of degraded pumps and line breaks on Safety Injection Flow is now underwa .. * UPDATE TO EMERGENCY OPERATING PROCEDURES TEAM INSPECTION (89-019) STATUS OF NRC COMMENTS The results will be incorporated into a revised attachment to the EOPs by February 28, 1991. NRC Comment Attachment II -2. EOP 2.0 "Reactor Trip Recovery" Attachment 4 Step l.g directed the operator to determine if CCW had been. interrupted for more than 10 minutes, but it did not indicate how the operator was to make this determinatio The licensee's representative stated that this was a training issue and would be evaluated to determine if the change was needed. (Page 4) CPCo Response The training on the determination of how long CCW has been isolated will be completed by February 28, 1991. NRC Comment Attachment III -1. Structure EOP 5.0 contained 40 contingency action steps and provided an example of how the procedures were heavily dominated by IF/THEN conditional statements. (Page 1) -4. Clarity of Instructional Steps EOP 4.0 was illustrative of the extensive use of continuous and nonsequential steps (17 and 54 respectively)
in* the Palisades EOPs. The designation of such steps did not always appear to be consisten Operators expressed differing opinions on when these steps should or could be performe Although sequential steps have marginal line for use in place keeping, no effective means existed to track unaccomplished
UPDATE TO EMERGENCY OPERATING PROCEDURES TEAM INSPECTION (89-019) STATUS OF NRC COMMENTS keeping, no effective means existed to track unaccomplished non sequential actions nor was there a single page display to use as a reminder of continuous action steps. (Page 3) -9. Operator Aids When questioned, there was a discrepancy among operators on how to use "non-sequential" steps. Some operators stated that these steps could be performed at any time, while others stated that the procedure must be completed up to that step before the step could be completed in a "non-sequential manner". Several operators were confused as to the difference between a "non-sequential" step and a "continuous" step. The licensee stated that "non-sequential" and "continuous" steps may be performed at any time. The licensee will evaluate the need for such a large number of "non-sequential" steps. (Page 6) CPCo Response The use of IF/THEN conditional statements, continuous and sequential steps, will be addressed by the Human Factors Review of our EOPs being completed by a contracto We will complete the evaluation and if appropriate revise the EOPs by August 1, 1992. NRC Comment Attachment III Human Factors Deficiencies-8. Vocabulary Operators differed in their interpretation of the statement "Verify qualified CETs" in COP 1.0, Step 6.c. The number of qualified CETs they would check varied from a few as one to as many as five, and some said they would printout all of the values. The location of the core matrix from which they were to be selected (some from center or near center, some from perimeter)
was also a source of confusion. (Page 5) Some operators interpreted the statement "Auxiliary feedwater flow available" as meaning that flow must be present to meet this condition, and some interpreted it as meaning that power to the auxiliary feed pump breaker was sufficient. (Page 5) 5 UPDATE TO EMERGENCY OPERATING
- PROCEDURES TEAM INSPECTION (89-019) STATUS OF NRC COMMENTS The "Warning" in EOP 3.0, Step 12, was not defined in the Writer's Guide; nor was it addressed
- in lesson plans for operator training. (Page 5) CPCo Response Training will be completed on EOP usage and definitions by August 1, 1991. 6