IR 05000261/1995017
| ML14181A713 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/26/1995 |
| From: | Kellogg P, Mellen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181A712 | List: |
| References | |
| 50-261-95-17, NUDOCS 9507120032 | |
| Download: ML14181A713 (14) | |
Text
pR REoU UNITED STATES o
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 Report No.:
50-261/95-17 Licensee: Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License No.:
DPR-23 Facility Name: H. B. Robinson Steam Electric Plant Unit 2 Inspection Conduct : June 5-9, 1995 Inspector:
L 110575 Date gned Accompanying Personn 1:
P. M. Steiner C. J. Moore, PSHA, In Approved by: K ello ief Da e S gned Op ationa ogerams cton Operations Branch Division of Reactor Safety SUMMARY Scope:
- This special, announced inspection was conducted in the area of Emergency Operating Procedures (EOP).
Its purpose was to verify that the licensee's EOP and EOP support procedures were technically accurate; that their specified actions could be meaningfully accomplished using existing equipment, controls, and instrumentation; and that the available procedures had the usability necessary to provide the operator with effective operating tools. The inspection evaluated the adequacy of the licensee's EOPs and EOP support procedures, conformance of these procedures to the Westinghouse Owners'
Group Emergency Response Guidelines, and conformance of these procedures to the approved writer's guides. The inspection included a review of corrective actions for previously identified deficiencie Results:
In the areas inspected, violations or deviations were not identifie The inspectors concluded that the licensee had adequately followed-up on previously identified EOP and Abnormal Operating Procedure (AOP) items. The documentation was complete and nearly always contained the appropriate resolution of the comments. The team concluded that the licensee's EOP and AOP verification and validation was effective. The overall assessment was that the EOPs, AOPs, and associated support procedures were adequat PDR ADOCK 05000261 G
PDR Enclosure
REPORT DETAILS 1. Persons contacted Licensee employees
- S. Hinnant, Vice President - Robinson
- S. Billings, Regulatory Affairs
- D. Crook, Regulatory Affairs A. Garrow, Acting Manager -
Licensing G. Johnson, Nuclear Assessment Section
- R. Krich, Manager -
Regulatory Affairs
- E. Martin, Manager -
Document Services
- B. Meyer, Manager Operations
- B. Moyer, Manager - Nuclear Assessment
- T. Nutale, Manager Operations Training
- V. Smith, Emergency Operating Procedure Writer
- B. Stover, Manager Operations Procedures
- D. Young, Plant General Manager Other licensee employees contacted included engineers, technicians, operators and office personne NRC Personnel
- W. Orders, Senior Resident Inspector
- C. Ogle, Resident Inspector
- T. Peebles, Operations Branch Chief
- Attended exit interview on June 9, 199 A list of acronyms and abbreviations used in this report is contained in the Attachmen.
Follow-up on Corrective Actions for Violations (92702) (Closed) Violation 50-261/94-07-01, "Quality Assurance Program Deficiencies." The 1994 NRC inspection team identified a violation of 10 CFR 50, Appendix B, Criterion II, "Quality Assurance Program."
Specifically, the Quality Assurance Organization failed to provide control over activities affecting the quality of the identified structures, systems, and components in that in 1989, the results of an NRC inspection of EOPs, identified that the EOPs, EOP support procedures, and EOP program were deficient. Despite the results of this inspection, the Quality Assurance Organization failed to audit the area, nor was any licensee action taken to assure that these areas were inspected by Quality Assurance and the necessary corrective actions implemente The only documented Quality Assurance action in this area was a field note which identified problems with EOP setpoints but failed to ensure corrective actions and was deleted from permanent plant records after 12 month Enclosure
Report Details
The inspectors reviewed the corrective actions for this violation and found that subsequent to the 1994 NRC inspection, the licensee's Quality Assurance Organizations had performed several reviews of the EOP/AOP To ensure that the Quality Assurance Organizations inspection/audit findings will be appropriately dispositioned, the inspectors reviewed the NAD inspection/audit and documentation methodology change The inspectors reviewed SUPT-01, "Control of NAD Generated Records,"
Revision The inspectors reviewed the requirement for record retention and found that Attachment 1, provided detailed requirements for the retention of QA Audit and NAD Assessment records. SUPT-01 did not have provisions for the dispositioning of field note SUPT-03, "Data Management," Revision 0, Section 1.0, required that observation data greater than 12 months old be purged from the current observation database each month and that "No Hard Copies are to be Maintained of Purged Data."
This purging of data was a contributing factor which led to the NAD-identified EOP setpoint problem which was not appropriately dispositione This did not solve the previously identified problem; it removes the records so the problem cannot be identified agai The inspectors then reviewed NUA-NGGC-1510,
"Nuclear Assessment Process," Revision 0, which had an effective date of May 30, 199 NUA-NGGC-1510 has increased the record retention to two years and includes the EOPs and AOPs on the Audit schedul Additionally, PLP-026, "Corrective Action Management,"
Revision 22, requires weaknesses to be documente The threshold for items to be included in this documentation is not directly state The inspectors were informed that the threshold was set by plant managemen The inspectors noted that the current threshold is such that the comments generated in the field notes would now be included in the corrective actions progra Finally, the inspectors reviewed R-SP-94-10, "Emergency and Abnormal Operating Procedure Upgrade Project Assessment," and RNAD 95-074,
"EOP/AOP Verification."
These provided objective evidence that the EOPs and AOPs were reviewed, and the comments were appropriately dispositione The inspectors concluded that the licensee had completed appropriate corrective actions for this violation. This violation is close (Closed) Violation 50-261/94-07-02, "Instructions, Procedures, and Drawing Errors."
The 1994 NRC inspection team identified a violation of 10 CFR 50, Appendix B, Criterion V, "Instructions, Procedures, and Drawings."
Specifically, during simulator scenarios, steps in the site-specific EOPs were not accomplished in accordance with the approved mitigation strateg For example, Enclosure
Report Details
during the SGTR with a MSLB scenario, all the MSIVs were closed before entering the diagnostic portion of the EOP This resulted in loss of the primary heat removal system and potentially uncontrolled, unmonitored releases through the MSL PORV Also, during the SBO, the EDGs were allowed to run without adequate cooling for an extended period of time, even though both the high coolant temperature and the high lube oil alarms for EDG 'B' were lit. If the mitigation strategy of EPP-1 had been followed, EDG 'B'
would have been shutdown substantially sooner. Deviation from the EOP network step sequences was an accepted plant practice and allowed by OMM-022, "Emergency Operating Procedures User's Guide."
A second example was that the extensive use of cross references in procedures resulted in procedures, that could not be performed as writte All prerequisites in referenced procedures were often not applicable and if prerequisites were met, in some cases, it would have resulted in incorrect equipment configurations or unacceptable delays in the accident mitigation strategy performanc A third example was that 20 safety-related power supplies that were used in EOP and Reactor Protection System instrument loops were of a different type and a lower voltage rating than the power supply depicted on the drawings and used by the setpoint vendor These included Pressurizer Pressure, Pressurizer Level, and Steam Generator Level power supplie A fourth example was that EPP-1 used 10 percent CST level as the setpoint for switching to alternative supply, while the Station Blackout Coping report required 34 percent CST leve The inspectors reviewed the corrective actions for all of the examples of this violation and found that adequate corrective actions had been taken. The inspectors also noted some cases where some procedural enhancements may be desirabl The inspectors reviewed the corrective actions pertaining to performing steps out of sequence and determined that they were adequat The licensee policy was appropriately modified to require more strict adherence to step sequences, the appropriate policy document pertaining to procedure use was modified (OMM-022), and a night order was promptly issued to ensure operators were informed about the change. The licensee undertook these actions in a timely manner and also only after first taking appropriate actions to ensure that the change in policy would not have unanticipated negative effect The inspectors reviewed documentation pertaining to corrective actions taken with respect to the example about cross reference The inspectors also discussed this topic with licensee personnel, performed desk top reviews of procedures, and examined the effects Enclosure
Report Details
of cross references within procedures through walkdowns in the plan The inspectors found that considerable improvements had been made with respect to this issu The inspectors did note a few cases where additional improvements could be made in some procedure Additionally, the inspectors concluded that it would be valuable to provide a more detailed, written guidance to procedure writers on this topi For example, the guidance in Section 5.10.8, OMM-41, "Transitions," could be expanded to more fully address the need to minimize cross references. Examples of identified concerns include the following:
The inspectors noted that some cross references in procedures were not formatted consistently with the guidance in OMM-04 For example, OMM-41 specified the use of the terms "Go To,"
"Use," and "Using," when directing transitions in procedure The inspectors found that other terms were used in procedures to direct transitions such as the following:
IAW AOP-013, Steps 5 and 11 Refer To AOP-022, Section A, Step 10; AOP-014, Step 9 Perform AOP-022, Section C, Step 4 Implement AOP-023, Step 7 Check AOP-026, Step 42 The inspectors concluded that there remain some cases where procedures in the EOP network could be substantially improved by eliminating unnecessary transitions to procedures outside of the EOP networ For example, Step 17 in AOP-017 directs operators to perform a task "Using OP-402."
The only information needed to perform the step in EOP-17 was a small portion of text describing a few valve manipulations and that this text could be effectively incorporated directly into EOP-017 rather than being reference The inspectors concluded the items noted above were characterized as minor procedural enhancement The assessment is that the substantial improvements have been made with respect to the cross referencing concerns previously identified, and the corrective actions taken are adequat The inspectors reviewed documentation pertaining to corrective actions addressing discrepancies between plant equipment and instrument drawings. The inspectors also discussed this item with licensee personne The inspectors concluded that the corrective actions were adequate. The information documented how the licensee had determined that a discrepancy occurred as a result of the Enclosure
Report Details
facility equipment being correct while vender-supplied drawings were in error. This conclusion appeared to have been reached through a reasonable analysis and to have been well supported. The licensee also documented that walkdowns had been performed to determine the correct "as build" information and that the drawings have been revised to reflect the information obtained through these walkdown It appeared that a reasonable and systematic process was used for prioritizing tasks such as this on The inspectors determined the minimum operating value of 10 percent CST level used in EPP-1 was correc The document RNP-I/INST-1015,
"Analysis of Condensate Storage Tank Level Alarm Setpoints,"
demonstrated that the SDAFW pump could operate down to a CST level of 10 percent. However, it could not be restarted without venting if it is stopped after the level drops below 34 percent. This was clearly stated in a caution prior to step 26 of EPP-1, Revision 1 The inspectors concluded that the licensee had completed appropriate corrective actions for this violation. This violation is close (Closed) Violation 50-261/94-07-03, "Document Control Deficiencies."
The 1994 NRC inspection team identified a violation of 10 CFR 50, Appendix B, Criterion VI,
"Document Control."
Specifically, the licensee failed to establish control over the issuance of procedures which prescribed activities affecting quality, in that controlled copies of AOP-004,
"Control Room Inaccessibility,"
PEP-104,
"Emergency Control - Site Area Emergency," APP-048 "Main Control Room HVAC System Panel," OST-010, "Power Range Calorimetric During Power Operation Daily,"
and OST-551,
"Turbine Valve & Trip Functional Test," were either of the wrong revision or were missing pages. These copies included the Emergency Onsite Facility copie The condition of the copies made the procedures unusabl The inspectors reviewed the corrective actions for this violation and found them to be adequat The licensee has generated procedure RMS-106, "Internal Audit of Controlled Documents," which defines a program to ensure all controlled documents are audited on a routine basi An audit was conducted to identify out of date revisions and unusable copies of controlled documents. Also, a corporate letter was generated which identified management expectations of individuals who use and maintain controlled document A program is in progress to reduce the number of controlled documents on sit The inspectors performed a random audit of recent revisions to AOPs and found no discrepancie The inspectors concluded that the licensee had completed appropriate corrective actions for this violation. This violation is close Enclosure
Report Details 6 (Closed)
50-261/94-07-04, "Corrective Action Deficiencies."
The 1994 NRC inspection team identified a violation of 10 CFR 50, Appendix B, Criterion XVI,
"Corrective Action."
Specifically, setpoints provided by a contractor have not been validated by the licensee as being correct but were incorporated in the EOPs, and numerous weaknesses in the EOPs, EOP program, and EOP support procedures that were identified in a previous NRC inspection (NRC Inspection Report N /89-16)
have not yet been resolve These weaknesses include (1) needed equipment for some required actions is not prestaged, mentioned in the procedures, or always easily available, (2) the plant verification and validation process continues to be inadequate, (3) no process has been established to ensure that changes to equipment or other procedures that affect the EOPs and EOP support procedures are identified and result in the necessary procedure revisions, (4) no requirement for in-plant walkthroughs of procedures has been incorporated into the governing EOP program documents, (5) staffing for all disciplines who must perform actions in the EOPs and support procedures (e.g.,
I&C, chemistry) is not provided round the clock, and (6) independent job performance aids for AOs who must perform multiple local actions have not been developed for actions other than a few in the dedicated shutdown procedure The inspectors reviewed the corrective actions for this violation and found:
(1) Prestaging of equipment and local operator aids were addressed as part of the in-plant walkdowns performed by the A Equipment has been prestaged and location aid labels have been added where appropriat (2) The licensee performed an extensive revision of the verification and validation procedure; OMM 043 has been revised to include more detail in the checkoff list The inspector reviewed Revision 5 of OMM 043 and noted that extensive changes had been mad (3) Changes to the procedures are accomplished through the normal change proces The originator has the responsibility for ensuring that affected procedures are revised. The licensee has incorporated the EOPs in the ISYS program where a computer search finds portions of the affected procedure (4) The V&V process requires a walkdown of the procedure by all the affected organization A new procedure requires verification for all disciplines affected by the revision. A walkdown was done for all actions required in the plan Enclosure
Report Details
(5) A review of personnel requirements for round the clock coverage was initiated from the existing EOPs, Dedicated Shutdown Procedures, and AOP During the review, maintenance personnel were staffed for 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> coverage beginning April 30, 199 The review was completed on May 6, 1994, and it was determined that coverage was not require (6) Location aid labels have been added where necessar The inspectors concluded that the licensee had completed appropriate corrective actions for this violation. This violation is close.
Follow-up on Previously Identified Items (92701) The 1994 NRC inspection team identified that setpoint values were generated by a vendor from information provided to them by the licensee in 1990, but were not reviewed by the licensee before being incorporated into the EOP The inspectors reviewed the corrective actions for this and found the licensee had included vendor generated setpoints into their calculation databas The inspectors verified that the calculations were appropriately maintained and updated as necessar The 1994 NRC inspection team identified that cautions in the EOPs and support procedures frequently lacked a description of the potential hazard to equipment or personnel as required by the WG Both notes and cautions were written containing action steps or conditional steps, also contrary to the W The inspectors reviewed the corrective actions for this and found that they were adequate, while also noting that additional improvements could be made. The inspectors reviewed the role and presentation of cautions and notes in procedures through desktop reviews and in-plant walkthroughs of procedure The inspectors found that substantial improvements had been made, but that a few problems such as those identified in the 1994 inspection still existe Examples of problematic cautions and notes include the following:
The caution prior to Step 23 in AOP-014 (presented in other places also), which warns operators that Steps 23 and 24 need to be completed within five minutes, does not state the potential consequences of failing to heed the caution. Based on the results of operator interviews, the inspectors concluded that including that information in the caution would have provided useful informatio Enclosure
Report Details
The first caution prior to Step 23 in AOP-020 (presented elsewhere as well)
states in part,
"..
.
Personnel in Containment should be warned.
.
. " The inspectors concluded that the caution was presenting instructions that would more appropriately be presented as a procedure step in order to ensure that the action instructions are not overlooke The inspectors considered these isolated example The overall program of cautions and notes were adequat The 1994 NRC inspection team identified some technical concerns in the EOPs and EOP support procedures. These included AOP-17, EPP-1, Path-1, and AOP-1 The inspectors reviewed these procedures and found that the current revisions either included the NRC findings or were left as is with an adequate justification from the license The 1994 NRC inspection team was concerned about the legibility of metal tags used to label equipment outside of the control roo The inspectors walked down several EOPs and AOPs and found the equipment labels to be satisfactory with exception of one instance in EPP-27, Step 18,
"Loss of DC Bus 'B'."
The new labels for breakers on 480V BUS 5 were not installed at the time of the procedure walkdow In.one case, a label had been hand written below the installed breaker labe This label was incorrect. Next to the hand written label, the word "wrong" was hand writte Also, the 480V BUS 5 breaker lacked an obvious OPEN/CLOSE indication. A green metal bar protrudes through a glass bubble when the breaker is open and a red bar protrudes when the breaker is shut. No where on the breaker does it identify that this is the OPEN/CLOSE indicatio The licensee added this breaker to their corrective actions progra The inspectors considered this an isolated example. The inspectors concluded the overall plant labeling and nomenclature was adequat The 1994 NRC inspection team walkthroughs of the procedures identified numerous cases where manpower and tool requirements for performing actions outside of the control room were not specifie Few problems of this nature were identified, and those that were identified, were minor relative to those identified in the 1994 inspectio For example, in AOP-014, Step 22, operators are instructed to "Obtain Sufficient Hose From The Stock Room To Run Hose From The Charging Pump To The Storm Drain In The Turbine Building Outside The CCW Pump Room Door."
The inspectors concluded that the minimum length of hose needed to perform this task should be determined and specified in the procedure. As another example, a weakness was identified in the staging of essential tools and Enclosure
Report Details
equipment for AOP-004, which are staged in the Fire Equipment Buildin One of the radios dedicated for the use in this procedure was found to function only marginall The inspectors considered these isolated example The overall specification of manpower and tool requirements for performing actions outside of the control room was adequat The 1994 NRC inspection team identified that logic statements were frequently not used in accordance with the WG requirements for the presentation of decision criteria or were used in ways that could potentially lead to operator erro The inspectors reviewed the presentation of decision criteria and use of logic terms in procedures through desktop reviews of procedures and during in-plant walkthroughs of procedure The inspectors found that substantial improvements had been made but that some problems such as those identified in the 1994 inspection, still existed as wel Examples of problematic steps include the following:
In AOP-024, Step 23, the term "until" is used to convey logical relationships upon which actions are contingen Some logic statements are long and confusin Further, standard formatting conventions that help ensure that logic statements are as easy to read and understand as possible are not adhered t For example, the logic statement in AOP-024 is long and confusing and contains conjunctions that are formatted as logic terms. The logic statement in Step 31 of AOP-020 is very problematic. The step is very long--2 pages with the page break occurring between the Logic term "OR" and the text that follows i The step also contains logic statements that are highly embedded (e.g., Step 31.e. in the RNO column consists of a "When--Then--Or" statement that is within an "If--Then" that is within another "If..
.
Then" statemen The inspectors considered these isolated example The overall presentation of decision criteria and use of logic terms in procedures was adequat.
Verification and Validation The 1994 NRC inspection team identified weaknesses in the licensees validation process. To assess corrective actions in the verification and validation process, the inspectors (1) interviewed personnel knowledgeable of the current verification and validation processes, (2) evaluated records of procedures reviews, and (3) reviewed verification and validation guidance and requirements (OMM-043, Revision 5).
Additionally, Enclosure
Report Details
findings from table-top reviews of procedures and plant walkdowns of procedures provided were considered indicators of verification and validation program performance. Although these sources of information were not as useful for evaluating changes in performance as other methods might have been (e.g.,
observing another simulator validation) the inspectors did conclude the information examined evidenced improvements in verification and validation methods and procedure A number of the weaknesses identified in the 1994 report have been addresse Examples include the following:
Two of the 1994 findings indicated that revised portions of procedures were not always validate First, cross references, including entry conditions, to and from the procedure were not performed so that potential effects of the revisions on the procedures were not evaluate Second, not all portions of procedure revisions were validated (e.g.,
actions in the RNO column).
The inspectors found indications that improvements had been made which addressed the concerns described in the paragraph abov Facility personnel stated that during verification and validation activities performed as part of the recent EOP upgrade, the need to consider all possible paths through procedures was recognize Table-top reviews included tracking the implications of a change through all contingency actions and alternative "paths" through procedural actions created by cross references from the procedure steps being reviewe During scenario validations, multiple scenarios were used to ensure validation of at least most contingency actions (the interviewee stated that in some cases, if it was particular burdensome to capture every contingency step in a procedure, the process might have used several scenarios to capture most possibilities and then a few steps omitted from the scenarios would be walked down separately).
Validation checklist requirements (from checklists provided in OMM-043), provide additional assurance that all steps in a procedure validation will be included in the validatio Two 1994 findings dealt with concerns about how steps were read and repeated back during validation. First, the process failed to note that the SRO did not read aloud about half of the procedure steps verbatim, but rather paraphrased the content of the step and failed to recognize the additional mental workload associated with having to translate steps in this fashion. Second, the process failed to note that the licensee practice of RO repeat-backs of procedure steps could not be implemented for Steps 3 and 45 because they are too long and comple The team observed that the RO did not attempt to repeat back these steps. The inspectors found indications that Enclosure
Report Details
improvements had been made that addressed the concerns described in the paragraph abov Personnel interviewed stated that current practices include reading steps verbatim. Also, verbatim reading is required in validations by OMM-4 The 1994 NRC inspection team also identified examples of procedural deficiencies that were not found through the licensees verification and validation process prior to approval and implementatio As documented in discussions of findings above, deficiencies in procedures were also identified during the 1995 inspectio However, overall the procedures showed marked improvements; the inspectors concluded that improvements in the validation and verification practices were an important contributing factor to the positive change.
Action on Previous Inspection Items (92701) (Closed)
IFI 50-261/94-300-01,
"Identification, availability and instructions for breaker operating tools."
This item concerned information regarding the OPEN/CLOSE buttons on the breaker cabinet fac The inspectors verified that operator aids describing the function of the OPEN/CLOSE buttons was installe (Closed) IFI 50-261/94-300-02, "EOP and AOP procedure deficiencies."
This item concerns deficiencies in two procedure (1) FRP-H.1, "Response to Loss of Secondary Heat Sink," Revision 8, added a new step (8) to provide a method to clear the Feedwater Isolation Signal while trying to establish a feed pat This step de-energizes safeguards logi There is a caution prior to this step which states that SI must be manually initiated. However, the caution does not mention the fact that Phase B will not automatically initiate if neede The inspectors reviewed the procedure and determined that it is adequate for the conditions it addresses. Securing power to safeguards will only prevent automatic initiating of Phase B and Containment Spray; it does not disable manual initiation of spray or individual operation of Phase B valves. Also, it does not disable the annunciators associated with the conditions that would initiate these function With the provided caution and operator training on responding to annunciators, operators will be able to manually initiate spray and Phase (2) AOP-14,
"Component Cooling Water System Malfunction,"
Revision 5, had inconsistencies on guidanc Section A, Step 32, gives detailed guidance on how to rotate operation of the charging pumps to prevent losing flo Section C, Step 9, directs the same task but does not give the detailed guidanc Enclosure
Report Details
The inspectors reviewed and walked down Revision 9 of the AOP and determined that the same method is now used to determine the rotation of the charging pump (Closed) VIO 50-261/95-08-01,
"Inadequate AOP-014 Attachment 1."
The item concerned AOP-14 attachment 1 revision 6. The procedure logic did not describe a systematic method of installing cooling to multiple charging pump configuration Also, Step 19a used an incorrect valve identifier for valve CC-862 The procedure incorrectly called for valve CC-862D to be identified vice CC-862 The inspectors walked down Revision 9 of the AOP and found the logic in the procedure allowed for correct installation of cooling to multiple charging pump Also Revision 9 uses the correct valve identifier for CC-862.
Exit Interview The inspection scope and findings were summarized on June 9, 1995, with those persons indicated in paragraph The NRC described the areas inspected and discussed in detail the inspection findings listed belo No proprietary material is contained in this repor No dissenting
comments were received from the license Item Number Status Description and Reference VIO 50-261/94-07-01 Closed Quality Assurance Program Deficiencies (Paragraph 2.a)
VIO 50-261/94-07-02 Closed Instructions, Procedures and Drawings Errors (Paragraph 2.b)
VIO 50-261/94-07-03 Closed Document Control Deficiencies (Paragraph 2.c)
VIO 50-261/94-07-04 Closed Corrective Action Deficiencies (Paragraph 2.d)
IFI 50-261/94-300-01 Closed Identification, availability and instructions for breaker operating tools (Paragraph 5.a)
IFI 50-261/94-300-02 Closed
[OP and AOP procedure deficiencies (Paragraph 5.b)
VIO 50-261/95-08-01 Closed Inadequate AOP-014 Attachment I
(Paragraph 5.c)
Encosure
ACRONYMS AO Auxiliary Operator A0P Abnormal Operating Procedure APP Annunciator Panel Procedure CCW Component Cooling Water CST Condensate Storage Tank EDG Emergency Diesel Generator EOP Emergency Operating Procedure EPP End Path Procedure FRP Functional Recovery Procedure IFI Inspector Follow-up Item MSIV Main Steamline Isolation Valve MSL Main Steamline MSLB Main Steamline Break NAD Nuclear Assessment Department NRC Nuclear Regulatory Commission OMM Operations Management Manual OP Operating Procedure PORV Power Operated Relief Valve RC Reactor Coolant RNO Response Not Obtained RO Reactor Operator SGTR Steam Generator Tube Rupture SI Safety Injection SBO Station Blackout SDAFW Steam Driven Auxiliary Feedwater SRO Senior Reactor Operator VIO Violation V&V Verification and Validation WG Writer's Guide Enclosure, Attachment