IR 05000266/1989019

Insp Repts 50-266/89-19 & 50-301/89-18 on 890619-30. Violation Noted.Major Areas Inspected:Emergency Operating Procedures

ML20248D208
Person / Time
Site:	Point Beach
Issue date:	08/03/1989
From:	Hasse R, Hopkins J, Phillips M, Vanderniet C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20248D196	List: IR 05000266/1989019 ML20248D191
References
50-266-89-19, 50-301-89-18, NUDOCS 8908100290
Download: ML20248D208 (34)

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U. S. NUCLEAP, REGULATORY COMMISSION

REGION III

F ,, ort's No. 50-266/89019(DRS); 50-301/89018(DRS)

Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Licensee: Wisconsin Electric Power Company 231 West Michigan Avenue - Room 308 Milwaukee, WI 53201 Facility Name: Point Beach Nuclear Plant, Units 1 and 2 2nspection At: Two Rivers, Wisconsin Inspection Conducted: June 19-30, 1989 Inspectors: $~^ DO Team Leader Date

)J. dHopkins I)<p 4 f " 9- TY

$, Date C. V r iet [

Date J. Sears, Consultant (COMAX)

. a amore, Co 'u tant (SAIC)

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Approved By:' Monte P.'Phillips, Chief '

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Operational Programs Section Date Inspection Summary Inspection on June 19-30, 1989 (Reports No. 50-266/89019(DRS); 50-301/89018(DRS))

Areas Inspected: Special announced safety inspection to verify that the Point Beach Emergency Operating Procedures (EOPs) were technically correct and usable. The inspection was conducted in accordance with TI 2515/92 (SIMS No. HF 4.1).

Results: One violation was identified (failure to provide adequate control of G Ps - Paragraph 2.c(1)(a); however, no Notice of Violation was issued since the licensee had identified the issue and was taking corrective actio "

8908100290 890804 PDR ADOCK 05000266 ,

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DETAILS 1. Persons Contacted Wisconsin Electric Power Company J. Zach, Manager, PBNP

• R. Lyduck, Superintendent, Technical Services

• T. Staskal, Operations Engineer A. Krieser, General Superintendent, Quality Engineering E. Mercier, Nuclear Engineer

• G. Maxfield, General Superintendent, Operations

• J. Knorr, Regulatory Engineer

• F. Flentje, Administrative Specialist, Regulatory Services Other licensee personnel were contacted / interviewed during the inspectio !

• Denotes those attending the exit interview on June 30, 198 . Emergency Operating Procedures Background Emergency Operating Procedures (EOPs) have undergone significant changes due to the 1979 accident at the Three Mile Island (TMI)

facilit ihe post-TM1 procedures are symptom-oriented rather than event-oriented. Symptom-oriented E0Ps provide the operator guidance on how to verify the adequacy of critical safety functions and how to restore and maintain these functions when they are degrade Symptom-oriented E0Ps are written in a manner that the operator need not diagnose an event to maintain the plant in a safe shutdown condition for all accidents that are within the scope of the E0P The purpose of this inspection was to verify that the Point Beach E0Ps are technically correct; prepared in accordance with the writer's guide; that their specified actions can be accomplished using existing equipment, controls, and instrumentation; and that the available procedures have the usability necessary to provide the operator with an effective operating too Inspection Methodology The inspection consisted of a desk top review of 22 Optimal Recovery Procedures and 18 Function Restoration Procedures. an in-plant walkdown of local actions specified in 11 Recovery Procedures and one Abnormal Procedure; exercising five scenarios on the plant simulator which used 12 procedures; and a human factors review of the procedures, plant walkdowns, and simulator exercises. In addition, 9 users and developers of the E0Ps were interviewe A detailed listing of these activities is given in Appendix _ =___ ___-

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c. Inspection Results The following paragraphs provide a general discussion of the;results of the inspection. Detailed observations and concerns are given in Appendix (1) Desktop Review The desktop review consisted of a detailed comparison of the E0Ps to the owners group (WOG), Emergency Response Guidelines (ERGS). Where deviations from the ERGS occurred, the documented justification for these deviations was reviewe Also, a large sample of setpoints used in the E0Ps was compared to the plant specific setpoint document. The backgrouad portion of the ERGS was referenced extensively to . assure the Point Beach E0Ps were consistent with the accident mitigation strategy developed by the W0 The inspectors concluded that the Point Beach E0Ps were adequate to mitigate accidents within the scope of the ERG Several areas of concern were identified as discussed in the following paragraphs:

(a) E0P Control The basis documents for E0Ps consist of the owners group guidelines (ERGS), the plant specific deviation documentation (which provides the basis for deviation from the ERGS), and the plant specific setpoint documen The E0Ps are written in conformance with a writers guide which specifies procedure format and other conventions of presentation. The E0Ps are then reviewed through a verification and validation (V&V) process to assure that they are technically correct, will accomplish the intended purpose, can be performed as written, and have been

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prepared in accordance with the writers guid The inspectors reviewed the E0P control program at Point Beach and determined that it was not fully adequate in that:

• The setpoint document and the deviation documentation were not covered by the plant documentation control program (the ERGS are controlled by the owners group).

• There was no formally implemented V&V program to assure the continued adequacy of the E0Ps (see Paragraph 2.c.(5) for a discussion of the V&V effort of the original issue of the E0Ps).

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These deficiencies were also identified during a licensee audit conducted from June 5 through June 8, 198 Several concerns identified during this inspection could be attributed to this lack of formal E0P control:

• Presentation was not consistent in terms of abbreviations, location information, and equipment identificatio * Deviation documentation was not consistent in that a deviation in one procedure might be documented but an identical deviation in another procedure would not be documente * Setpoints used in the E0Ps were not always consistent with the setpoint document. For example, the setpoint document specifies that the reactor coolant pung in loop B be started in preference to that in loop A when pressurizer spray is desire The E0Ps state no preferenc * There was an obvious error in one setpoint calculation in the setpoint documen * The complete basis for the cooldown curve in CSP-P.1,

" Response to Inadequate Core Cooling," was not provided in the setpoint document or the deviation documentatio Other examples identified by the licensee's internal audit included:

• Five new or revised setpoints were not included in the setpoint documen * 10 CFR 50.59 evaluations were not being consistently performed for E0P revision While none of these examples represented a significant safety concern, the potential did exist for significant safety issues to go undetected. This failure to provide control of the E0Ps and their basis documents consistent with the control exercised over their original generation and their importance to safety is considered a violation of 10 CFR 50, Appendix B, Criterion VI, " Document Control." Since the licensee had identitied the problem and was implementing corrective actions, no Notice of Violation will be issued pursuant to 10 CFR Part 2, Appendix C, Section V.A. Completion of the corrective action will be tracked under Open Item (50-266/89019-01; 50-301/89018-01) as detailed in Appendix I

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(b) Reliance on Operator Training and Knowledge During the review of the E0Ps the inspectors noted a very heavy reliance on operator training and knowledge. For example:

• Actions that must be performed locally are not typically identified as such in the E0Ps. The operator is expected to know what can be done in the control room and what must be done locall * Locations of equipment that must be operated locally are rarely give * Equipment identification is rarely complete (i.e.,

f unctional title and equipment number).

• Lack of reference to operations procedures or presentation of detail for some evaluation such as establishing letdown or aligning AF * Detail presented in the equivalent ERG step is frequently omitted, such as specifying " narrow range" when referring to steam generator level and specifying plant specific conditions for starting an RC The operator is expected to know thi Discussions with licensee personnel responsible for E0P preparation indicated that this reliance on operator knowledge was due to a large extent to operator comments received during their review of the original E0Ps. The inspectors were concerned that while the high level of operator knowledge was confirmed during procedure walkthroughs, too much weight was put on this " assumed knowledge" factor relative to considerations of operator behavior during high stress conditions, the need to accommodate the

"least competent operator," and gaps in operator knowledge. The licensee agreed to reassess this issue through the continuing V&V progra (c) Step Sequencing The licensee deviated extensively from the step sequencing presented in the ERG The revised sequencing of immediate action steps was based primarily on control board layout and the desire to maintain a smooth flow of action across the board rather than jumping from one side of the board to the othe This revised sequencing was generally justified and considered an enhancement. No violation of the mandatory I

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step sequencing presented in the ERG background document i

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was identifie The reason for revised sequencing of other steps was not always documented nor clear. While the ERGS do permit revision of step sequencing within priority classes, the logic for the step sequencing used in the E0Ps should be identified. (See Paragraph 6 of this report for an additional concern in this area identified subsequent to this inspection).

(2) Containment Sump Recirculation Switchover

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At Point Beach the switchover of the suction source for injection flow from the RWST to the containment sump (as described in E0P-1.3) requires local manual operator actio The time required to complete this action had been conservatively estimated at 7.5 minutes.

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With bot.h injection trains operating, this evolution was accomplished on one train while the other train continued injection using the RWST as its suction source. Thus, there was always injection flow. With one injection train inoperable (single failure), injection flow would be interrupted for 7.5 minutes during suction source switchover for the operable trai Earlier analyses indicated that it would take 10-13 minutes for the core to become uncovered with no injection during a large break LOCA. Thus, injection would be re established before core uncovery occurred. Subsequent analyses indicated core uncovery could occur in 1.5-3.0 minutes and the loss of injection flow for 7.5 minutes was no longer acceptabl Further background on this issue is presented in LER 89-004 (Docket No. 50-266).

The inspectors reviewed the licensees actions relative to this issue to determine if it had been adequatcly resolved. As a temporary measure, a Night Orcier had been issued alerting the operators to maintain injection flow during the switchover even if om train was inoperable. This was to be accomplished by maintaining high head SI flow using the high head pump taking suction from the RWST while the low head (RHR) SI pump suction I was being aligned to the containment sump. A permanent procedure (E0P-1.4) to accomplish this switchover was in draft and undergoing licensee review. The inspectors concluded that these actions adequately addressed the issu During the inspector's review of this issue, another issue was identified. During a licensee audit conducted in July 1988 it was determined that the high head SI discharge valves MOV-866A and MOV-866B (Trains A and B respectively) would be in a high radiation environment during a design basis accident. These valves are not environmentally qualified nor included in the

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.s inservice testing program. These valves are normally open; however, E0P-1.3 requires these valves to be closed during the process of determining if low head SI can be used. If adequate low head SI cannot be established, valves MOV-866A and 8 must be reopene Since these valves are not environmentally qualified, operability in the worst case scenario cannot be assured. The evaluation performed as a result of the audit finding concluded that it was not necessary to close MOV-866A and B when assessing ,

low head SI flow and it would be best to leave these valves in

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the open position. E0P-1.3 has not been revised to reflect this conclusion. The completion of this action and issuance of E0P-1.4 will be tracked as Open item (50-266/89019-02; 50-301/89018-02).

(3) E0P Walkthroughs Walkthroughs of selected E0Ps were conducted with licensed and non-licensed operators who would normally perform these task Particular emphasis was given to local actions in the plan The objective of these walkthroughs was to determine if these actions could be performed in a timely manner with a minimum potential for erro The inspectors identified a number of concerns during these walkthrough These are included in Appendix B. One generic concern was the lack of location information for local actions as addressed in Paragraph 2.c(1)(b). Also, there were several procedures that required entry into potentially high radiation areas to perform local actions. The E0Ps eo noi,31ert the operator to the fact that this situation may exist nor provide direction if the condition does exist. The licensee should address this concer (4) Simulator Exercises:

Five scenarios were conducted on a non plant specific simulator (Kewaunee). These scenarios were conducted during two sessions utilizing two operating crew Each crew consisted of a Duty Shift Superintendent (DSS), Duty Operating Supervisor (DOS),

two Control Operators (CO) acting as Reactor Operator and Balance of Plant Operator, and a Duty Technical Advisor (DTA). This crew size meets the minimum PBNP Technical Specification requirement A total of 12 Emergency Operating Procedures (EOP), as identified in Appendix A, were exercised during these scenarios. One of the five scenarios was conducted during both sessions due to its !

complex transitions through the E0Ps. This allowed the inspection team to observe two independent crew's transitions through the E0P L _ _ __ _- _

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In general, the specified actions detailed the selected E0Ps are technically correct, can be accomplished using the existing equipment, controls and instrumentation, and provide the operators with an effective operating tool. The procedures led the operators through the transition points without much confusion. However, both operating crews appeared hesitant and confused during the execution of E0P-3 and ECA-3.1 when confronted with one faulted Steam Generator (SG) and one ruptured SG (i.e., a SG with a tube rupture).

During the scenario, the faulted SG had been isolated per E0P-2 and then the ruptured SG was identified and isolated per Steps 2 and 3, E0P-3. From this point E0P-3 prepares the plant for a cooldown which is initiated at Step 16. The plant cooldown is initiated using the intact SG, if available. With no intact SG available (none was), the faulted SG should be used (by continuing with E0P-3) or the ruptured SG should be used per ECA-3.1. Both crews hesitated when deciding which SG to use to cooldown the RCS. This delayed the cooldown and depressurization of the RCS. According to the Westinghouse Optimal Recovery Guidelines, timely operator intervention is necessary to limit the radiological releases and prevent SG overfil No direct procedural guidance is given in selecting a SG for cooldown in the PBNP E0Ps or in the Westinghouse ERGS. The Westinghouse Emergency Response Guidelines-Low Pressure Version (ERG-LP), Revision 1, Background documents, discuss several factors which must be considered when choosing between the faulted and ruptured SGs for plant cooldown. In order for the operating crews to make an informed and timely decision when choosing the between the two SGs,.the E0Ps need to imlude additional information about the possible adverse consequences of each choice and any additional actions required based on that choice. Note that this concern is not solely restricted to PBNP and is being forwarded to the Westinghouse Owners Group (WOG) for additional revie While performing E0P-1.3, in a separate scenario, the operating crew identified a possible procedural enhancement. The first CAUTION of Step 10 instructs the operator to transition to ECA-1.1 if at any time it is apparent that Containment Sump Recirculation can not be established or maintained. However, steps prior to the CAUTION statement begin to realign various components for Containment Sump Recirculation. The operating crew suggested that the CAUTION be placed at the beginning of E0P-1.3 to prevent delaying entry into ECA-1.1. This possible enhancement was previously identified by the PBNP Training Department.

, (5) E0P Verification and Validation (V&V)

The inspectors reviewed the V&V Program to determine if the following six objectives had been addressed:

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• That E0Ps are technically correct, i.e., they accurately reflect the technical guidelines.

L l * That E0Ps are written correctly, i.e., they accurately l reflect the plant-specific writer's guide.

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• That E0Ps are usable, i.e., they can be understood and followed without confusion, delays, errors, etc.

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• That there is a correspondence between the procedures and l

the control room / plant hardware, i.e., controls / equipment /

indications that are referenced, are available, . . . use the same designation, use the same units of measurement, and operated, as specified in the procedure * That the language and level of information presentation in the E0Ps are compatible with the minimum number, qualifications, training, and experience of the operating staf * That there is a high level of assurance that the procedures will work, i.e., the procedures guide the operator in mitigating transients and accident The evaluation was based on review of V&V program documentation, discussions vith the E0P program manager and staff, and review of the E0Ps themselves. The E0P review included desk-top comparison to technical guidelines and the PBNP Writers' Guide, walk-throughs of a sample of E0Ps, and a simulator exercises in which two different operating shift teams performed a sample of E0Ps in the context of emergency scenario The team concluded that the V&V processes used for the initial set of plant-specific, symptom-based E0Ps, based on Revision 1 of the Westinghouse Owners Group generic Emergency Response Guidelines, were adequat While the initial V&V program was adequate, the licensee did not require similar processes to be applied to E0P revision It was noted that an informal process in place however to ensure consistent application and to ensure the continuing high quality of the E0Ps the licensee should consider formally implementing a continuity V&V progra (a) V&V Program Description Verification. The E0P verification process was defined by a procedure in the PBNP Procedures Generation Package (PGP), Attachment 3.1, dated February 21, 1984. This procedure, with some revisions, was issued as a controlled plant procedure, P11.17, Revision 0, March 25, 198 Verification was performed over the

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period from May 1984 through June 1985. Thus it was performed mostly under the guidance given in PGP l Attachment 3.1. Comparison of this document to P11.17. Revision 0, indicated that no changes were made that might be expected to affect the consistency of verification activitie Orly one change was made that was judged by the Inspection Team to be negative:

removal of the set of criteria pertaining to procedure referencing and branching from the Evaluation Criteria Checklist. This is an important verification issue that should not be omitte . Validatio The E0P validation objectives stated in the PBNP Procedures Generation package are (1) to ensure the usability of the E0Ps, i.e., that they

" provide sufficient infortnation that is understandable to the operator"; and (2) to ensure the operation correctness of the E0Ps, i.e., that they "are compatible with plant responses, plant hardware, and the shift manpower."

An E0P validation procedure was included in the PG However, different validation processes were actually used, as summarized beic".

• Evaluation er several dredt E0Ps based on performance by PBNP personnel at the Zion simulator (March through April 1983).

• Desk-top review by members of the Plant Manager's h Supervisory Staff with the purpose of judgiri9 the technical adequacy of the procedures (performeo during the course of procedure development, with a final review during May and June 1985, just before the new E0Ps were implemented in July 1985).

• Observation of operator training on the new E0Ps prior to their implementation. This training involved all shift teams and was conducted at the Kewaunee simulator. Approximately 80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br /> of observation were conducted by a member of the E0P upgra& i ugram team, assisted by simulator instrucicrs ana, for part of the effort, by contractor personnel. Observer comments were recorded and operators were asked for their comments, questions, and suggestions about the E0Ps. These comments were evaluated and used to make changes in the E0P * Scenario based validation exercises conducted in a full-scale photomosaic mockup of the Point Beach control room. Fourteen scenarios were used. The scenarios were reviewed and found to

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exercise all of the E0P The scenaries were not limited to single failure event The.

L scenarios were performed by control room personnel, approximating real tirie performance, { 1 and were videotaped. After each scenario, the operators were interviewed and their comments recorded. The vidaotapes and operator comments ,

were then analyzed to identify problems in the ,

performance of the E0Ps. This effort was conducted by the contractor for the PBNP Detailed Control Roam Design Revicw (DCRDR). The contractor team provided human factors engineering !

1pertise as well as operations and training '

expertis The validaticn portion of PBNP's E0P program was not documented as carefully as the verification portio The validation procedure defined in the Procedures Genere. tion Package was not followe Nevertheless, based on the information provided by the licensee about the validation activities, on review of a sample of the documentation, and on review of the E0Ps themselves, the E0P Inspection Team concluded that the licensee did conduct an extensive validation effort adequate to meet the intent of NUREG-0737 4 Supplerent 1, and the guidance in NUREG-089 (b) Conclusions

• The verification and validation processes used to prepare the initial set of symptom-based E0Ps were adequat * The licensee should consider formally establishing cor.tinu:ng processes for E0P verification and validation, consistent with the applicable regulatory guidance, to be used when E0Ps are revised or new E0Ps are writte This should be done in a controlled procedure that specifies when and how E0P verification and validation shall be conducte * E0P verification should address the accuracy of instructions to branch within a procedure and transition or refer to other procedure P11.17, Revision 0 omitted criteria for this topi * The continuing validation process should include ,

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simulator validation. The validation procedure in the PBNP Procedures Generation Package did not address simulator validation, although simulator validation was part of the progra E

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• The current requirements for writing, revising, reviewing and approving E0Ps are contained in three i

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different procedures: PBNP 4.19 (" Emergency Operating Procedures Writers' Guide"), PBNP 4.21

~(" Composition, and Revision Review Guidelines for Operating Pror.edures"), and PBNP2.1.1, NNSR, (" Classification, Review & Approval of Proceduret,").

These procedures should be reviewed for consistency and ease of use, and to ensure that requirements wil(

not be overlooked. For example, PBNP 4.21 does not mention the requirement to determine whether a new precedure or revision requires a 10 CFR 50.59 revie (6) Walkthrough of AOP-10A, Revision 8 A walkdown was conducted of A0P-10A, Revision 8, " Control Room ,

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Inaccessibility." This -Abnormal Operating Procedare provides guidance for the local control of equipment for scfe shutdown-in the even the Control Room mast be evacuated. Although this procedure is not classified as an Emergency Operating Procedure, it is critical to plant safet In the judgment of the Inspection Team, this A0P in particular should be subjected to the same rigorous development and mainter,ance processes as the E0Ps. Since the inspectors had numerous ceaents on this procedure, a detailed discussion is preser. ed below:

(a) General Comments The procedure does not provide enough guidance on how step responsibilities are to be dividei between the individual unit operators. Regarding immediate actions in the control room, Unit 1 and Unit 2 share two panels (C0-1 and C0-3). There are also certain items of common equipmen There were two wal'kdown teams, one for each unit, each assisted by a Control Operator. One of the operators indicated that he would perform Steps 5.1-5.11 only for his unit. The other operator indicated that he would perform the steps for both units when a step involved a shared ,

pune Step 5.12 requires the performance of local manual immediate actions according to three checklists, one assigned to the Duty Shift Superintendent, one to Operator 1, and one to Operator 2. In the Operator 1 Checklist, it is made clear that the actions are to be performed for both units (The DSS and Operator 2 checklists were separately wasked down by different Inspection Team members). However, in the Subsequent Actions section of the procedure (Section 6.0), it is not inade clear that the actions are to be performed for both units for example:

immediate actions in the control rr.m. It was also unclear who was responsible to perform the various subsequent action _ - - _ _ _ _ - _ _

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I-The licensee shold clarify the division of responsibilities for performing A0P-10 (b) Immediate Actions in the Control Room (Steps 5.1-5.11) --

General Comments There was inconsistency in the completeness of component identification. In most cases, a name designator is given that includes system and type of equipment, and a component number is given. In some cases though, only a component number is given with an incomplete name designator (e.g., Steps 5.2, 5.3, and 5.6a). In other cases, only a name designator is give No delay or confusion in the identification of controls was observed during this walkdow However, the licensee should review the completeness and consistency of component identification in A0P-10 There was inconsistency of terminology between the procedure and panel labels (e.g., A0P Step 5.6a seys "LDGS c atrol to

'VCT'" whereas the control is labeled " GAS STRIPPER DIVERT VLV." Also, the procedure directs the operators to " shut" valves, whereas the valve control positions are labeled

"0 PEN" and " CLOSED"; this is a consistent discrepancy. No cor, fusion or delay in component identification was observed; however, inconsistency of terminology between panel labels and procedures is not a good practice and could be a source of confusion. The licensee stated that the control room panels will be relabeled to resolve discrepancies identified during the Detailed Control Room Design Revie When this is done, procedure terminology shouln be compared to the new labeling specifications to ensure consistenc (c) Immediate Actions in the Control Room -- Specific

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HrpComments

• Step 5.1: There is no guidance about how fast to ramp power dow * Step 5.5: The instruction is ta place main feed valves in manual and shut. There are two feed valves and two bypass valves to be shut. The valve numbers are identified, but it would be preferable to provide name descriptors as wel * Step 5.7e: The instruction is to pull out (lock out)

CCW pump P11 Pump 11P would normally be running but, if not, 11A should not be locked ou The procedure should direct the operator to verify one pump running and lock out the other pum __ _

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• Step .5.7f: A typographical error was note The 2 pump identifier is P27, nit P37,

• Step S.'79: See comment about step 5.7 One !

condensate pump should be runnin ;

• Step 5.7h: The operator indicated that there is a preferred pump. If so, this should be clarifie (d) Local' Manual Action ($ection 5, Step 5.12, Operator 1

Checklist)

General Comments

• Accessibility: All equipment to be operated is easily accessible with one exception; the bearing cooling valve requires use of a ladder. A dedicated ladder is provided in the are * Environmental conditions: Operator 1 is not required i to enter any area susceptible to high radiation or

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contamination. Emergency lighting is provided in all areas where checkli;t tasks are performed. A flashlight is provided in the ready pack kept in each unit for use should A0P-10A be require I

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• Feasibility of performance with minimum shift staffing:

Each individual task can be performed by one perso Operator 1 was able to complete all required lineup tasks and get to his assigned local operating station (SG level control) in a short tim !

• Equipment locations: The procedure does not give equipment location information except for Building ;

Elevation or Roo No problems in locating equipment '

were identified during the walkthrough. The tasks in the Operator 1 Checklist do not require the operator to travel extensive distances or change elevations frequentl * Component identification: Old labels are embossed metal plates and are difficult to read. New labels are large tags with black engraving on white plastic plates. The new labels are excellent. The changeover ;

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was in progress but incorrplete. The components involved in AOP-10A are 6 s0 marked with red paint for quick identificatio i

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(e) Comments on Specific Checklist Items l

• PAB E1.26 (A0P p. 7)

l The requirement is to isolate instrument air to containment, for both unit The air supply valve are specified to be closed. However, two additional valves should be opened and caps removed to depressurize the instrument air headers. The procedure does not mention those component * AF Room (A0P p. 7)

The checklist task is to activate these instruments by transferring power supply to " local." The source range monitor power supply controls have two positions !

- " normal" and " backup." The Inspection Team was informed that the normal power supply is a separate supply provided for these in plant instruments. The backup supply is a second level of assurance of power to the NIS source range instruments at these local 4 panels. During the walkthrough, the assisting I operator did not know this, and also found the discrepancy between the switch position label and the procedure term (" backup" versus " local") confusin If it is desired to power these instruments off their backep supply in the even of a remote shutdown, the checklist time should be changed from " local" to .

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• Feed Pump Suction Pressure The operator is instructed to transfer feed pump suction from the CST to service water & n suction pressure decreases to 7.0 psig. The procedure says

" shut CST supply"; the panel labeling of the controls is incomplete and inconsistent with the procedure wording. This was not a problem for the assisting operator, but it is not good practic (f) Subsequent Actions (procedure Section 6.0) General Comments The steps in'this section of the procedure are performed by different people. For example, Steps 6.4 and 6.6 are performed by Operator 1, Step 6.5 is performed by Operator 2, and Step 6.7 is performed by Auxiliary Operators coordinated by the Duty Operating Superviso There is no indication of the division of responsib!1ities. This might be confusino since, in the preceding section of the procedure, individual

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responsibilities were grouped into separate checklists. More important, Section 6 does not consistently make it clear when a step must be performed for botn units (for example, Steps 6.4- and Step 6.8).

Because of Appendix R requirements, the local shutdown instrumentation panels are in a different cubicle than the controls required to manage steam generator level. Also, the Unit 1 and Unit 2 controls are in differeat cubicles. Therefore, Operator 1 has to go back and forth'among three area The licensee should make sure that it is feasible for one person to control steam generator feed for both units given the location of the con.ponenu involve . Specific Step Comments Step 6.6, CAUTION:

The wording of the Caution is complex and difficult to follow. It is a logic statement that is not properly writte !

The limiting value for rate of feed stated in the i

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Caution cannot be read precisely on the available instrumen Other comments on this procedure are included in Appendix ;

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d. Human Factors Evaluation A human factors evaluation of the E0Ps was conducted to ensure that the E0Ps: (1) are consistent with the Procedure Writer's Guide, (2) could be physically performed; and (3) could be correctly performed by the staff. The human factors evaluation consisted of .a desk-top review of selected E0Ps, E0P walkdowns in both plant and control room, observation of simulator exercises, and interviews of selected users, developers, and trainers of the Point Beach E0P (1) DESKTOP REVIEW A desktop reviev. to address human factors issues was conducted using a sample of procedures from the PBNP emergency operating procedure (EOP) se The procedures were evaluated for consistency with PBNP 4.19, Revision 7, " Emergency Operating Procedures Writers' Guide."

Criteria from NUREG-0899 and NUREG-1358 were also applie ,

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The procedures were found to be, for the most part,' written and formatted clearly and in accordance with the provisions of the Writers' Guide. Some departures from and weaknesses of the Writer's Guide are summarized in the following paragraph (a) Page Identification and Nurr. bering (Writers' Guide Section* 3.3, 5.11.3, and 6.8)

The Writers' Guide gives incomplete guidance about the identification and numbering of figures and appendice The Guide states'(Section 5.11.3) that all figures will appear at the end of the procedure. It does not state whether they will be numbered as part of the main body of the procedure or separately. Generally, figures have been numbered as part of the main body of the procedur The fi0ures in E0P-0.2 do not have page numbers. The Writers' Guide should state the practice in regard to page numbers of figures, and appendices and all procedures should conform to the stated practic (b) Procedure Organization (Writers' Guide Sections 4.1, 5.11.3, and 5.11.4)

lhe licensee should review the Writers' Guide for completeness in providing guidance for procedure organization. The guidance provided on this topic is presently divided among three sect-ions, which makes it more difficult to us Section 4.1 should list all potential elements of procedures within the E0P set, In~dicating n their required order and indicating whether each element is required or optional. Potential elements should include figures, tables, checklists, appendices, foldouts, and any other items that may be relevant. Without this type of guidance, the organization of emergency procedures could

'become inconsistent in the futur i (c) Format of Instructional Steps -(Writers' Guide Section 4.3)

The procedures reviewed were found to be consistent with the Writers' Guide provisions regardirg the format of instructional steps. However, the Writers' Guide provides incomplete guidance on this topic. This has resulted in format inconsistencies as discussed belo The Writers' Guide states (Section 4.3) that letter designation of substeps indicates that the steps are listed in the desired order of performance, whereas substeps preceded by dashes indicate that the order of performance is not important. However, the Inspection Team was informed by the users thci. dashes preceding a list of substeps indicate that all of the substeps do not necessarily have to be performe !

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Assuming that the E0P users' interpretation of the intended meaning of alpha / numeric designators versus dashes is correct, a number of instances of incorrect usage were found in the E0P set:

• E0P-0, Steps 32 and 33 (In these examples, substep "a" says to "Use all of the following" (emphasis supplied). This instruction is followed by a list of conditions preceded by dashes. The

"?.11" in substep "a" seems to contradict the meaning cf the dashes.)

• E0P-0.3, Step 9

• E0P-1.2, Step 26

• E0P-2, Step 4

• ECA-2.1, Step 34 This issue should be addrened in the revision cycle in progress to update the plant-specific procedure set to the Westinghouse ERG, Revision 1A. If the use of dashes is not clearly defined and ;nsistently applied, control room personnel could become confused and omit necessary substeps in responding to an en. agency. The Writers' Guide should clearly state the significance of alpha / numeric substep designators versus dashe The E0P set should be reviewed to make sure that the intended convention is consistently applie (d) Use of Cautions and Notes (Writers' Guide Section 5.5)

NUREG-0899 states that some form of emphasis should be used to attract attention to cautions. The PBNP Writers'

Guide does not explicitly require this, but, caution statements in the E0P's show the use of asterisks, e.g.:

"* CAUTION * 00 NOT TERMINATE ALL FEEDWATER FLOW . . ."

Currently there is no highlighting of cautions in the procedures themselve PBNP intends to provide for this as a feature of their new word processing system for production of procedures. The update of the plant-specific procedures to ERG Revision IA will be produced on the new syste Section 5.5 of the PBNP Writers' Guide states that cautions and notes should not contain operator actions. However, some cautions and notes in the procedure set do contain operator actions, for example:

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• E0P-0, note preceding Step 8:

IF INDICATED SI FLOWS ARE NOT APPROXIMATELY EQUAL, TREN NOTIFY DSS / DOS AND USFVISUAL VERIFICATION R THER THAN INSTRUMENTATION PRIOR TO ISOLATING A FAULTED SI PAT j This note contains several present or potential action step * E0P-0.3, note preceding Step 3:

SATURATED CONDITIONS IN THE PRESSURIZER SHOULD BE ESTABLISHED BEFORE TRYING TO DECREASE PRESSURIZER !

LEVE This appears to be a required verification ste * E0P-1.2, caution preceding Step 5:

MAINTAIN C00LDOW RATE < 100 F IN RCS COLD LEGS

• E0P-1.3, second caution preceding Step 7:

MAINTAIN RHR PUMP FLOW 2200 GP TOTAL "A" RHR PUMP FLOW EQUALS FI-925 PLUS FI-626 TOTAL "B" RHR PUMP FLOW EQUALS FI-928 PLUS FI-924 This note contains an action step plus a note. The action step is redundant; it is covered by a Step 7h ano Step 8 The instrumentation used to determine total flew should be included in Steps 7h and Step 8h as applicabl The Writers' Guide states that " procedure transitions can be included in a. note when absolutely necessary." It implies that transition instructions cannot be provided in cautions. This is done, however, in the E0P set, where l transitions instructions are found more frequently in cautions than in notes. Examples are listed below:

• E0P-0.3, first caution preceding Step * E0P-1.2, caution preceding Step * E0P-1.3, first caution preceding Step 1 * ECA-2.1, first and second cautions preceding Step Transitions are step PBNP has treated transitions as cautions when the transition requirement depends on some condition that may or may not occur, and whose occurrence

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w is'not d'ependent on'any.particular step in the procedur .'.

It was the judgment of the Inspection. Team that this is i. .

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~ one way to treat this situation. The Writers Guide Section 5.5 should'be revised to clarify the guidance'

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on. transition instructions.in cautions / notes, and make it .

consistent with;the.exieting practice,-which was concluded to be acceptabl There are also instances.in'the E0P.. set when conditiona iaction steps are' included as cautions. While this ma be acceptable, as~ discussed above, the practice should be minimized because it requires the operators to hold .

parameter monitoring requirements.in working memory while proceeding with other tasks. If there are too many; cautions-and notes to keep in mind throughout a long series.of steps or an entire procedure, working memory may be overloade Possible ways to minimize this potential problem include:

• . Treat the condition instruction as an action. step /RNO and repeat it as ne'cessar * Treat the conditional instruction as a caution if this is judged to be p' referable to making it a step, and repeat the caution as-appropriate during the course of the procedur * Expand the information provided on the foldout page to include some or all of the conditional requirements now presented as cautions and print the foldout page on the backs of the procedure pages so that it will face each page.of procedure steps. If, during the course of the procedure steps, an item of information on the fold-out page is no longer needed, it should be delete Operations personnel thougnt that it might be helpful to b print the foldout page information facing each page of steps in any case, even if no additional conditional requirements are added to i (e) References and Branching to Other Procedures or Steps (Writers' Guide Section 5.8)

The procedures were found to conform to the Writers' Guide in inis area. However, PBNP has minimized referencing

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operating procedures used to supplement the E0P in us Apparently, decisions have been made as to when a specific reference is needed and when the operators may be expected to know that they should, or may need to, refer to an ,

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operating procedure. PBNP personnel explained that

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references have been minimized because of the difficulty 20 l

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p; of. ensuring that references remain correct when referenced procedures are changed; however,. referencing of relevant

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procedures is the-only way to ensure that~the_ effects on E0P steps of other procedure changes'can be checke The licensee should consider identifying all' procedure that should be consulted in the performance.of an E0P step in the.E0P by~name.and numbe (f) Component Identification (Writers Guide Section 5.9)

The Writers' Guide states that equipment, ' controls,.' and displays will be identified in the E0P ~ set in " operator language," and that the terms used may not always match

. panel labeling. During the E0P inspection,-considerable inconsistency was observed. .This was not considered.to be a problem by.the Operations personnel who were interviewed, and-it was not observed to'cause confusion during walkthroughs. Procedure and panel label. terminology should be consistent'so as to not require the operator to compensate for inconsistent use of terminolog The.recent Detailed Control Room Design Review, identified control room labeling as an area needing improvement. The licensee indicated that a change' package to redo the control' room labeling was in progress (Relabeling of equipment in the plant is in progress). The inspection team believes that the redesign of'the control room labeling based on a standard list of-terms, abbreviations, acronyms, and conventions-for component / equipment numbers, approved by Operations, would be. advantageous. The standardized list could they be used in the development l and revision of procedures. When the control room l relabeling is implemented, steps should be taken to ensure consistency between the new labels and the E0P set as well es all other optrating pmcedure Pumps, breakers, and valves should be identified by number as well as ' descriptive nam Equipment numbers i are frequently omitted in the FBNP E0P set. Based on the l

walkthroughs conducted during the inspection, it appears that the present operators do not have difficulty with the component identification information given in the E0P se However, the PBNP operators as a group are very experience It may be easier over the long term to follow a practica of L ;dentifying components by both descriptive name and nuruber l than to make the judgments of when this is needed and when

! it is not needed by operators with varying amounts of b plant-specific experienc !

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(2) Interviews Interviews were conducted with Point Beach Operations, Operations Engineering, and Training personnel to obtain information about E0P responsibilities and training, to obtain a user assessment of the usability and effectiveness of the E0Ps, and to identify any concerns related to the E0Ps. Nine personnel were interviewed:

• One Duty Shift Superintendent (Senior Reactor Operator license, the highest Operations supervisor on shift).

• Two Duty Operations Supervisors (Senior Reactor Operator license, the control room supervisor).

• Two Control Operators (Reactor Operator license, the control room panel operator).

• Two Auxiliary Operators (not licensed, responsible for local panel and equipment operation in the plant).

• One Training Department representative (formerly an Auxiliary Operator and a Control Operator at Point Beach; Reactor Operator license).

• One Operations Engineering representative with responsibility for E0P management (Senior Reactor Operator license).

In addition, assessments were obtained from discussions with other Point Beach personnel during other inspection activitie In general, these personnel reported confidence in the E0P They were unanimously of the opinion that in the case of an event, the E0PS will work effectively to bring the plant to safe and stable conditions. They also were unanimously of the opinion that the new, symptom-based E0Ps are significantly better than the previous E0Ps. They reported that this opinion represents a significant change from skepticism which prevailed '

before they gained experience with the synptom-based E0P Point Beach personnel did not identify any concerns which they considered major problems. They did identify some areas in which they thought improvements might be made, as discussed :

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below:

(a) Staffing Levels The minimum shift complement, per the Point Beach Technical Specifications, is an eight person tea !

The shift team consists of one Duty Shif t Superintendent (DSS), responsible for both units; one Duty Operations

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Supervisor (DOS), responsible for both units; two Control Operators (CO), one assigned to each unit; and four Auxiliary Operaters (AO). There is:also a Duty Technical Advisor (DTA). The DTA provides engineering expertise and is not req'.. ired to have an operator licens Most of the interviewees felt that this minimum staffing could be very lean under certain conditions, in particular,

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if there were.an accident affecting both units. The Duty Operations Supervisor would be E0P reader / manager for.both units simultaneously. The Shift Superintendent would probably be involved in implementing the Emergency Pla A0 task requirements could also be difficult to cove For example, if there were a loss of all AC. power, two A0s would be needed to operate the atmospheric steam dump The third fully qualified A0 would have to cover all the other in plant tasks. The eighth man can assist, but cannot work alone. Additional staff could be called in,.

but there would be a time dela (b) Training The Control Room personnel felt that more simulator training time would be beneficial. They commented that this may not be possible until the PBNP simulator is operational, but would like to have more simulator time as sooi as possibl It was commented that the limited time on the Kewaunee simulator l is very evaluation oriented. Some operators feel that more time is needed purely in a training mode, when they can stop,

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ask questions, and receive redirection and explanations from the simulator instructors. This concern has been brought to the attention of the Training Department and steps have been taken to designate time strictly for training, separate from the evaluation required at the conclusion of simulator trainin (c) E0P Content and Clarity No major concerns aoout E0P content and clarity were state Several people mentioned the instructional steps that require verification that a condition does not exist - e.g., verify "no steam generator completely depressurized." Given the logic for using the dual-column procedure format, this kind of negative wording cen be confusing. Instructions of this kind were taken from the generic Emergency Response Guidelines and personnel responsible for E0P development said that they could not come up with acceptable alternative wording. The operators who ,

participated in interviews said that statements of this kind '

are not a significant problem nos that they are familiar with the E0P The use of negatives has been brought to the attention of the Westinghouse Owners Grou l

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One interviewee suggested that it would be helpful to make sur that all relevant Operating Instructions (0Is) are referenced by alphanumeric designator and nam One interviewee commented that locally operated equipment is not always identified as such in the E0Ps and suggested that this should be done consistently, in particular for valves requiring local operation. The Inspection Team found concerns about the identification of local equipment in other activities .

during the inspectio '

Control Room personnel commented that transitions may be missed. j None of the personne1' interviewed considered transitions a significant problem. They felt that th.e design of the E0P set, ,

the E0P training, and the quality of Control Room teamwork and communications minimize the likelihood of a missed transition or an incorrect transition and make it possible to recover quickly. Some interviewees thought that printing the foldout page so that it faces each page of instructional steps might facilitate transition This issue was examined by the Inspection Team in otaer activities and is addressed in the findings and recommendations from the desk-top revie l (3) Simulator Exercises The Inspection Team observed simulator exercises to evaluate the usability and effectiveness of the E0Ps in the context of real-time, integrated team response to emergency operating conditions. The simulator exercises were conducted at the Kewaunee Nuclear Power Plant simulator facility, which has the g capability to model Point Beach plant responses and where Point j Beach Operations personnel currently receive simulator trainin '

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Five emergency response scenarios were defined for the purposes of the E0P inspection. These scenarios went beyond design-basis, single-failure events to provide a rigorous test of E0P effectiveness under complex condition The scenarios

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required the use of six procedures in the E0P series, six in

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the ECA series, and two in the CSP serie Use of the Status Trees was also require .

In General, it was found that the staffing level was adequate (for Control Room tasks), the roles and responsibilities of the crew were clearly defined, a team approach was utilized, L communications were effective, and the operators were able to perform their assigned tasks. Peacekeeping, branching within i'

a procedure, and transitioning to other procedures were accomplished for the most part without difficult A few specific problems occurred which indicated needs for procedure improvement:

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• Scenario 1 - Main Steam Line Break Inside Containment ("A" Steam Generator) AND Steam Generator Tube ("B" Steam Generator)  ;

i Confusion was observed about which steam generator should be

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used to cool down since one was ruptured and'one was faulte There was enough hesitation that the faulted. steam generator, which may be used according to the ERG strategy, was nearly dry so the_only choice was to use the ruptured generato The operators were reluctant to do this because it would result in a release to the atmosphere. It was concluded that clearer guidance needs to be given in E0P-3 to use a faulted generator or ruptured generator if there is no intact steam generato Both crews that participated in the simulator exercises had a l problem with this decision and the terminology and guidance on this issue in E0P-3. The procedure steps in which confusion was evident were: the caution preceding Step 3; Step 7; and Step 16; It is not until Step 16b that explicit guidance is given to use the faulted or the ruptured steam generator. By the time Step 16 was reached, as mentioned above, the faulted steam generator was dr It-also appeared that there is a problem in the wording of Step 16 in E0P 1. The present wording is directly from the ER However, if one steam generator is blown down and at containment pressure and pressure in the other is stable or increasing, the appropriate path in the procedure may not be clea * Scenario 3 - Anticipated Transient Without Scram AND a a Steam Generator lub Leak ("B" Steam Generator)

Neither crew showed any difficulty in responding to this sce # o. There was one short hesitation related to Steps 20 and 22 of E0P-3. Instrument air was not available in this scenario and no PORV wac available to depressurize the RCS. The procedure directs the operators to go to ECA-3.3, "SGTR Without i Pressurized Pressure Control," under these circumstance However, the Point Beach auxiliary spray system has a relief line feature that forces the auxiliary spray valve to open if normal charging is isolated and the charging pumps are operatin This is not mentioned in E0P-3, Step 2 One crew momentarily thought that they could not use auxiliary spray. They quickly recalled the relief line feature, but it may be desirable to refer to this plant-specific option in the E0 * Scenario 5 - Loss of Coolant Accident AND Containment Sump Recirculation Cannot Be Established No difficulties in performing this scenario were observe ,

However, a question was raised about E0P The first i caution preceding step 10 directs the operators to go to i

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l ECA-1.1 if at any time it becomes apparent that containment sump l recirculation cannot be established or maintained. However, i the operators will be in E0P 1.3 for a considerable length of :

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time before reaching Step 10 because, per Step 6 RNO, Steps 7 -

10 cannot be performed until RWST level goes below 28% (low level alarm setpoint). In a real event, this could take 30 to 40 minute In the simulator, the time lag was reduced. The crews recognized that they would not be able to establish containment samp recirculation well before they reached Step 10 but had to wait. In a real event, the wait would be longe It was suggested that the caution preceding Step 10 of E0P should be moved up to precede Step 5. Another suggestion was to make the content of this caution part of the RNO for Step . Training and Qualification Effectiveness The inspectors performed no formal review of the licensee's training program for E0P Conclusions on training and qualification effectiveness were based on interviews with the operators, discussions and observations during procedure walkthroughs, observations during the simulator exercise, and technical discussions with those personnel responsible for E0P preparatio The inspectors concluded that the qualification level'of the Point Beach personnel was hig Conclusions on the effectiveness of classroom training program drawn from this observation had to be tempered by the fact that the experience level for these personnel was also very high. The licensee should remain alert to this fact, especially in light of the heavy reliance placed on operator training and knowledge (see Paragraph 2.c.(1).(b)). The loss of highly experienced personnel through retirement or other turnover could have impact on the qualification leve . Quality Verification Effectiveness The inspectors reviewed licensee audits and surveillance covering E0Ps. Only three audits and one surveillance had been performed since the inception of the symptom based E0P The first audit addressing E0Ps was conducted in September 1984. The emphasis in this audit was design control; however, some effort was expended on engineering input to the E0Ps. Findings relative to E0Ps from this audit were programmatic and were resolve The second formal QA oversight effort was a surveillance performed during a simulator training session conducted in November 1987. Meaningful observations were made during this surveillance and a re resolve The first in-depth assessment of the E0Ps was made during a vertical slice audit of the RHR system conducted in August 1988. Significant findings from this audit included the containment sump switchover problem (see Paragraph 2.c.(2)), the lack of environmental qualification of the high head SI discharge valves (see also Paragraph 2.c.(2)), and the general lack of control over input to the E0Ps (see Paragraph 2.c.(1)).

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The only' audit focusing exclusively on the E0Ps was conducted in June 1989 just' prior to this NRC inspection. The findings of this audit are discussed in Paragraph 2 c.(1).

The inspectors concluded that the early quality oversight effort was inadequate to assure good control of the E0Ps. This was due at least in part to the lack of focus of oversight activities on the E0Ps. When focus was placed in this area, the oversight effort was effective in identifying the problems and showed good technical dept . Open Items Open-items are matters which have been discussed with the licensee which will be reviewed further by the inspectors or which involve some actions on the part of the NRC or licensee or both. The open items disclosed during this inspection are detailed in Appendix B and referenced throughout the body of the repor . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on June 30, 1989. The inspectors summarized the purpose, scope, and findings of the inspection and the likely informational content of the inspection report. The licensee acknowledged this information and did not identify any proprietary informatio Subsequent to the conclusion of this inspection, an additional concern was identified. Due to resequencing of immediate action steps in E0P-0 from the sequence provided in the ERGS, a potential appeared to exist for exiting E0P-0 at step 11 to CSP-H.1. If RCS pressure is less than SG Pressure (LOCA), CSP-H.1 transitions to.EOP- In this case, the operator would-not return to E0P-0 to complete the immediate action steps, including verification of containment isolatio This concern was discussed with the licensee via telephone on July 26, 1989. Resolution of this issue will be tracked as an Open Item (50-266/89019-03; 50-301/89018-03).

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y APPENDIX A Description of Inspection Activities .j Emergency Operating Procedures (1)

'(3) E0P-0 Reactor Trip or Safety Injection i (2)(3) E0P-1 Loss of Reactor or Secondary Coolant (2)(3) E0P-2 Faulted Steam Generator Isolation (2)(3) E0P-3 Steam Generator Tube Rupture (3) E0P- Rediagnosis (3) E0P- Reactor Trip Response E0P- Natural Circulation Cooldown E0P- Natural Circulation Cooldown with Steam Void in Vessel (with RVLIS)

E0P- SI Termination E0P- Post LOCA Cooldown and Depressurization (2)(3) E0P- Transfer to Containment Sump Recirculation (2)(3) E0P- Post-SGTR Cooldown Using feedwater (2) E0P- Post-SGTR cooldown Using Blowdown [ '

E0P- Post-SGTR Cooldown Using Steam Dump (2) ECA- Loss of All AC Power (3) ECA- Loss of All AC Power Recovery Without SI Required ,

(3) .ECA- Loss of All AC Power With SI Required !

(2)(3) ECA- Loss of Containment Sump Recirculation ECA LOCA Outside Containment (2) ECA- Uncontrolled Depressurization of All Steam Generators ,

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(2) ECA- SGTR With Loss of Reactor Coolant-Subcooled Recovery Desired (3) ECA- SGTR With Loss of Reactor Coolant-Saturated Recovery Desired (3) ECA- SGTR Without Pressurized Pressure Control

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(2) CSP- Response to Nuclear Power Generation /ATWS (3) CSP- Response to Loss of Core Shutdown CSP- Respcnse to Inadequate Core Coeling l CSP- Response to Degraded Core Cooling l CSP- Response to Saturated Core Cooling i (3) CSP- Response to Loss of Secondary Heat Sink CSP- Response to Steam Generator Overpressure CSP- Response to Steam Generator High Level L CSP- Response to Loss of Normal Steam l Release Capabilities CSP- Response to Steam Generator Low Level

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CSP- Response to Imminent Pressurized l Thermal Shock Condition i CSP- Response to Anticipated Pressurized Thermal Shock Condition CSP- Response to High Containment Pressure CSP- Response to Containment Flooding CSP- . Response to High Containment Radiation Level CSP- Response to High Pressurizer Level CSP- Response to Low Pressurizer Level CSP- Response to Voids in Reactor Vessel Off-Normal Procedures (1)

(2) A0P-10A Control Room Inaccessibility (1) All procedures were reviewed during the desktop review described in Paragraph 2.c.(1).

(2) These procedures were walked down as described in Paragraph 2.c.(3).

(3) These procedures were exercised during the simulator scenarios described in Paragraph 2.c.(4).

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s APPENDIX B Detailed Findings and Comments From i

The E0P Inspection at Point Beach This appendix presents a detailed statement of the Open Items identified during this inspection and a listing of comments which the licensee agreed to review and take appropriate action where warranted. No response is required on the comment . Open Item (50-266/89019-01; 50-31/89018-01) - E0P Control) i Place the setpoint document in the plant document control syste Assure all setpoints are included and accurat Implement a formal continuing verification and validation progra ) Place the documentation of significant deviations from the ERGS into a document control syste . Open Item (50-266/89019-02; 50-301/89018_02-Containment Sump Recirculation Issue procedure addressing switchover to containment sump i recirculation with one injection train inoperabl Resolve environmental qualification issue for valves MOV-866A and . DetailedCommentsontheE03 The following comments do not generally include those generic comments included in the body of the report. In cases where a comment applies to a step appearing in more than one procedure, it is noted as generi E0P- * Step 11 RNO - No preference is stated for which RCP to start.

l This is not consistent with the setpoint document. (generic). E0P-0.2 i

• No deviation has been documented for deleting step 10 of the ER E0P- * Step 4 - The caution on cooldown rate preceding this step should have been an action step as in the ER i l

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• Step 12d RN0 - The E0P states " increase charging flow" in an attempt to stabilize RCS pressure rather than the use of pressurizer spray as specified in the ERG; however, charging flow was maximized in step 11 ) l

• Step 24 - The caution preceding this step states "If fuel damage is suspected . . ." No guidance is provided on what conditions might indicate fuel damag E0P-2

• Step 1 - The deletion of the action to close or " confirm closed" the bypass valves does not appear justified on the basis that they are closed during 100% power operation. (generic)

• Step 5 (ERG Step 6) - The deletion of ERG step 6c does not appear appropriate since it is a transitional ste * Step 5 RNO (ERG Step 6 RN0c) - Moving the ERG substep 6 RN0c to a high level utep makes the transitional nature of this step unclea * Step 4 - A list of all of the valves needed to isolate blowdown should be includt . E0P-3

• Step 3.d RNO - The equivalent ERG step specifies isolating the turbine driven auxiliary feedpump from a ruptured SG if a motor driven auxiliary feedpump is running. The E0P deleted the reference to a running motor driven auxiliary feedpump withoutdocumentedjustificatio * Step 4.a RNO - No deviation was written for deviating from the equivalent ERG ste * Step 18 - The caution preceding this step implies the core exit temperature should be at the specified temperature rather than below the specified temperature.

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• Step 18 RNO - The ERG step requirement of ". . .to less than

250 psi above the pressure of the intact steam generator used for cooldown" has been omitted without justificatio * Step 3 RNO b.1 - This step fails to alert the operator that he may have to enter a high radiation area. Also, the specified local actions are at two different locations with no location information give (generic)

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% E0P- * Step 3 - This step requires depressurization below 1000 psig to isolate the accumulators. It should contain a caution not to depressurize to the accumulator setpoint pressure and inadvertently inject the accumulators. (generic) ECA- * Step 19 - The alternate water supplies should be liste (generic)

• Step 18 - References to operating instructions should be given for venting generator hydrogen, deenergizing unloaded inverters, and establishing battery chargers. (generic) ECA- * Step 8 - No plant specific means are provided for establishing RCP thermal barrier cooling as required by the ERGS. (generic) ECA- * Step 18b - The steam generator pressure quoted for assuring accumulator injection is in error due to a calculation error in the setpoint document (setpoint H.7). (generic) ECA- * Caution No.1 Preceding Step 1 - This caution should have remained as a step since it directs operator actions if RWST level reaches less than 60%.

• Caution No.1 Preceding Step 2 - This caution should have remained a step since it directs operator action based on CST level. (generic) ECA- * Step 15 RN0B - This substep directs operators to release steam from a steam generator by any other method. No guidance is given on other methods available. The only means the operators could think of is manual lifting of the code safety valve Guidance should be provide (generic) CSP- * Symptoms - The deviation documented in the deviation document makes no sens ,

• Step 6 - Same comment as abov l

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I e CSP-I.3 l-l

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• Step 13 - This step depressurizes the RCS to permit blocking SI initiation. A caution is needed to assure pressure is not reduced to the SI initiation pressure. (generic)

• Step 19 - The way this step is written it appears that the procedure could be exited with vent valves 50V-575 A or '

50V-575 B left ope CSP- l l

• Step 12 - The equivalent ERG step aligns the SI system to the RWS CSP-P.1 aligns the SI system to the BAST. The intent ;

of this step has been changed with no deviation document being ;

writte * Figure 1 - The complete basis for this curve (Post-Soak Cooldown Limit) is not given in the setpoint documen A0P-10A

• GENERAL: The procedure does not consider the possibility of the high radiation barriers being up. This procedure has several valves that are to be operated which are located in possible high rad areas. If the high rad barrier gates are up what should the operator do'? No direction is give !

• Gi.NERAL: Procedure is inconsistent regarding the use of titles and equipment number * GENERAL: Procedure does not differentiate the immediate actions of the unit 1 and unit 2 control room operator * GENERAL: Marking of electrical breakers is not consistently accomplished, as is done with valve * Step 5.1 - No specific type of ramp rate is mentioned. Fastest being the manual rapid ramp down which should be preferre * Step 5.5 - Step does not mention bypass valves although the valve ,iumbers are give * Step 5.6.b - Substep provides no contingency for this specific pump being inoperabl * Step 5.6.d - Valve title is not given as is done with the other valves in this ste * PAB, El. 8' - 3D and 40 control power breakers are not clearly marked inside the panel _ -- -

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e Valves 2CV-384A and ICV-384A are located in separate pipeway These pipeways should be specifically identified in the procedur * Second PAB, El. 8' - 1 and 2P2B cross-conn breakers are not correctly identified on the procedure, they should each be preceded by the letter "B." <

• MCC B33 uses the word " strip" when referring to the position of 1

"open." In the context of the use of the words and the directions in the steps the word "open" appears to be most suitabl * Step 6.0 - Several of the actions in this section of the procedure intend actions to be taken for both units' equipment, however, the equipment is mentioned in a singular nature rather than a more appropriate plural natur * Step 6.0 - This section also does not specify who is to be performing the listed steps even though certain individuals will already be in the areas to perform the action * Step 6.9.1 - Locations should be included in this list of plant equipmen * Step 6.9.2 - balve is mislabeled in the procedure, should be

"overboards" not " returns."

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