IR 05000275/1989024
| ML16342B636 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/28/1989 |
| From: | Miller L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341F504 | List: |
| References | |
| 50-275-89-24, 50-323-89-24, NUDOCS 9001180128 | |
| Download: ML16342B636 (58) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
Report Nos:
50-275/89-24 and 50-323/89-24 Docket Nos:
50-275 and 50-323 License Nos:
FacHity Name:
Inspection at:
Pacific Gas and Electric Company 77 Beale Street, Room 1451 San Francisco, Cali fornia 94106 Diablo Canyon i/nits 1 and
Diablo canyon Site, San Luis Obispo County, California Inspection Conducted:
November 27, 1989 through December 8, 1989 Inspectors:
G. Johnston, Operator Licensing Examiner P. Morrill, Operator Licensing Examiner K. Johnston, Resident Inspector, Diabl,o Canyon Consultants:
A. Sutthoff, SAIC Inc.
J.
Sears, COMEX Inc.
Approved By:
LF er r,
~e
,
pera sons Se tion I> z&S'
e gne
~Summar:
Inspection from November 27 through December 8, 1989 (Report Nos.
50-275/89-24, and 50-323/89-24)
Areas Ins ected:
A special team inspection of the Licensee Emergency peratsng rocedures in accordance with Temporary Instruction TI 2515/92.
Results of Ins ection:
Areas of Stren th Observed Durin the EOP Ins ection The EOP program is recognized by the facility staff and management to be a vitally important program.
This has lead to extensive support for the program from management.
The facility has committed to using a multidisciplinary review process for the EOPs. The'facility has a system of Local Action Checklists for the EOPs which are demonstrably useful tools for the operators.
900l180i28 S<r1228 PDR ADOCK 0 00027
Si nificant Issues:
The facility guide is incomplete or unrestrictive in a number of areas.
The verification and validation program appears to require additional thoroughness.
The plant lighting in some areas is poor and not conducive for proper operation.
The licensee's training of the plant operators may not have provided sufficient time during the last requalification cycle for training on Functional Recovery Procedures or for Emergency Contingency Actions procedures.
The licensee may potentially undermine the credibility of the equality Assurance program by blanket deferrals of action due dates for Action Requests generated from audits of plant activities.
Summar of Violations:
There were no violations identified within the scope of this inspection.
Deviations:
There were no deviations identified within the scope of this inspectio REPORT DETAILS NRC-Ins ectors
"G. Johnston, Team Leader, LIcensing Examiner
"P. Morrill, Licensing Examiner
"K. Johnston, Resident Inspector, Diablo Canyon
"A. Sutthoff, Human Factors Specialist, SAIC Inc.
- J. Sears, Reactor Systems Specialist, COMEN Inc.
"L. Miller, Chief, Operations Section
"P. Narbut, Senior Resident Inspector, Diablo Canyon Persons Contacted
"J.
Townsend, Pl.ant Manager
"R. Flohaug,.guality Assurance, guality Services Supervisor
- D. Taggart, Director,.guality Support
- D. Miklush, Assistant Plant Manager, Operations Services
- S. Fridley, Operations Manager
"R. Fisher, Senior Power Production Engineer
"T. Martin, Training Manager
"M. Kelly, Regulatory Compliance Engineer
- M. Barkhoff, Acting gC Manager
- J. Blakley, Nuclear Safety and Regulatory Affairs
"D. Helete, Nuclear Generation Engineer
"C. Leach, Ops/Eng Training Supervisor (Acting)
J.
Melsch, Operations Training Supervisor J. Becerra, Senior Training Instructor R. Jett, Simulator Supervisor R. Ortega, Power Production Engineer
~ Denotes those attending Exit meeting December 8, 1989.
Members of operating crews, training personnel, and auxiliary operators were interviewed during the course of this inspection.
Procedure Reviews A review of the Diablo Canyon Power Plant (DCPP)
EOPs and EOP program documents was conducted, applying the criteria in Temporary Instruction 2515/92, Revision 1, the requirements of Supplement 1 to NUREG-0737,
"Requirement for Emergency Response Capability," the guidelines in NUREG-0899, "Guidelines for the Preparation of Emergency Operating Procedures,"
and the findings of NUREG-1358,
"Lessons Learned From the Special Inspection Program for Emergency Operating Procedures Conducted March-October 1988."
The review consisted of a 'desktop review of the documents prior to the inspection, as well as procedure walkdowns, interviews, and observation of simulator exercises on site during the period November 27-December 8, 198 Writers Guide:
In order to develop procedures that clearly and consistently present information to operators in a way that will minimize error,; a complete and restrictive writer's guide is necessary.
A complete writer's guide addresses every aspect of the procedures, and a restrictive writer s guide defines the precise methods;and formats to be used when writing procedures; Writer's guides that are incomplete or nonrestrictive leave format decisions to the writer's judgment and preference.
Because individual writer's judgments vary', this will result in increasingly inconsistent and complex procedures over time that may increase, rather minimize, human error.
The DCPP writer's guide fails to address a number of important aspects of EOPs.
For example:
o The writer's guide fails to provide explicit criteria for the level of detail to be included in procedure steps.
o The writer,'s guide fails to define "transition."
o The writer's guide fails to define the "sentence format" that should be used for contingency instructions.
o The writer's guide fails to define the different structure and use of substeps as action steps versus expected responses.
As a result, these two forms are mixed, with the result that steps are more difficult to understand and perform.
o The writer's guide fails to define type size, style, and page format requirements for the procedures.
o The writer's guide does not address the use of symbols in the EOPs.
The writer's guide directions on a number of aspects of the EOPs is not sufficiently restrictive to result in consistent application 'of guidance.
For example:
o The writer's guide requirements for including system response time are subjective.
o The writer's guide directions for using common usage vocabulary are subjective.
The writer's guide directions for legibility of graphs, charts, tables, and figures, are subjective.
The writer's guide directions on appendices does not define clearly when a single column format is to be used, versus a dual-column format.
'he guidance provided in the writer's guide on the following items allows structure in the EOPs that may lead to confusion and error:
f 'L 1 ~
o The writer's guide allows the inclusion of actions in cautions and notes, and fails to restrict the length or complexity of these forms.
o The writer's guide includes acronyms,and abbreviations with multiple meanings.
o The writer's guide includes terms for which more than one acronyms or abbreviation is allowed.
o The writer's guide allows foldout pages that exceed one page.
Yerification and Validation:
Thorough verification and validation of EOPs is critical to ensure that the technical and format bases documents (that is, the plant-specific technical guidelines and the writer's guide)
have been applied; to ensure that the procedures correspond to plant nomenclature arid equipment; arid to ensure that the procedures are usable and can be performed.
A number of concerns were identified with the DCPP verification and validation program.
They are:
1)
The DGPP program for verification and validation includes.a checklist to ensure that the program is implemented properly.
However, the checklist contains a number of subjective criteria and will therefore not ensure adequate verification and validation.
For example:
o The checklist.asks if figures are
".adequate for readability" but provides no criteria for determining minimum acceptability.
o The checklist.asks if the "typical user" can locate equipment required by the procedure, but fails to describe the limits of this "typical user."
o The checklist asks if the procedure is formatted consistently with the writer's guide, but fails to provide the reviewer an outline of the requirements of the writer's guide.
Mithout such an aid, it is unlikely that all requirements of the writer's guide will be checked against 'the procedure.
2)
The OCPP EOPs contain-a number of indications that verification was inadequate.
For example, the procedures contain inconsistencies within single EOPs and across the entire EQP set.
In. addition, numerous deviations from the writer,',s guide are found in the EOPs!,
including those in areas that'have
.a strong connection to potential human error.
For example:
a.
Decision making during stressful situations like emergencies can be very difficult.
Therefore, it is particularly important thai decision or logic steps be clearly and consistently structured.'he DCPP writer's guide:addresses
.a number of the
g
b.
requirements for logic step structure.
However, the OCPP EOPs contain numerous examples of inconsistent, complex, and potentially confusing decision steps.
o The IF, THEN, UNTIL, OR logic structure is overly complex and deviates from writer's guide requirements (e.g.,
j E-,0.2, page 15; E-0.3, page 9).
o
~
Conditional steps are found embedded in expected responses in violation of writer s guide requirements (e.g., E-l.2, page 15).
o 'he term "unless" is improperly used to structure conditional steps (e.g., E-l.2, page 16).
o Conditional steps are found lacking the term "THEN" to introduce the contingent action, in contrast to writer'
guide directions (e.g., E-l. 1, page 17; page 18; page 19; E-0.2, page 12).
o The logic structure used in many entry conditions and foldout pages violate the requirements of the writer'
guide.
Noyement within and between procedures can be disruptive and confusing, and cause unnecessary delays and errors.
It is important that directions to operators for referencing other procedures be clear and consistent,and that references be minimized.
The DCPP EOPs contain many inconsistencies and deviations from Writer's guide requirements for transition steps.
For example:
o Numerous examples of transitions have been found using terminology that contrasts from that found in the writer'
guide
"per" (E-0. 1, page 12; E-l. 1, page 16)
"perform" (E-0.2, page 4; E-l.l,, page 21)
"preview" (E-l, page 12)
o The EOPs include a number of implicit references (e.g., E-0. 2, page 10).
Other inconsistencies and deviations from the writer's guide reflective of inadequate verification include:
o The transition to E-O, step 12, from E-O, step ll.b.
RNO, is incorrect, due to the OTSC dated 1/31/89 that divided E-0 step 12 into step 12.a and step 12.b.
Because OTSCs allow changes to the EOPs that may lead to errors, it is not recommended that temporary change systems be allowed in EOP program o The quality of reproduced graphs, charts, and figures is very poor (e.g'.,
Appendix h, worksheet 3; Appendix N; Appendix S).
o Periods are used with abbreviations and acronyms, in contrast to writer's guide directions (e.g., E-l. 1, page 3).
o Pl,urals of acronyms and abbreviations are handled inconsistently (e.g.,
S/G(s) vs.
SGs).
o Parentheses are used inconsistently, and in contrast to writer's guide directions.
Actions steps, references, and logic steps are found in parentheses throughout the DCPP EOPs.
o The writer's guide states that steps should be precise.
However, the EOPs contain steps that are vague and non-specific.
For example,
"Stop all but one or two RCPs, if desired (E-1.2, page 18)."
The inconsistencies and problems in DCPP steps may be generally explained by either a) variation due to inadequate writer's guide directions, or b) inadequate verification -against the writer s guide.
As noted above, these problems include some areas that are known to have a strong relationship to potential error.
3)
Cautions and Notes Cautions are intended to identify potential equipment damage or personnel injury.
Notes are intended to include supplemental information that can be useful to operators during performance of the EOPs.
Neither is intended to include action steps.
Inclusion of action steps in cautions and notes can lead to omission of the steps, due to operator expectation that actions will be included and numbered sequentially in action step format.
In addition, inclusion of actions in cautions and notes will lead to lengthy and sometimes complex statements, that operators will be likely to skip.
Clear and distinct formatting of cautions and notes, minimized use, and concise writing is important to ensure that operators will read and understand the important information they contain.
In addition, identification of the potential hazard in cautions can draw operator attention to the critical information and potentially reduce error.
DCPP EOPs contain numerous cautions that are overly complex, inconsistent, include actions, and fail to clearly identify the potential hazard.
Notes in the DCPP EOPs are overly complex and inconsistent; some cautions appears to be unnecessary, some notes appear to incl'ude cautionary information.
Operators stated in interviews that cautions and notes were often useless to them or overlooked.
In simulator exercises, operators were observed to skip over a number of the longer caution and notes.
In general, this area in the DGPP EOPs is considered to hold a potential for increasing, rather than minimizing, operator. error e le
Conclusion of Review of EOPs:
The review provided confirmation that in general the strategy and direction provided by the WOG ERGs are incorporated into the facility EOPs.
However, the procedures did show evidence of a lack of adequate verification and validation.
This determination was made by the Team on the basis of the number of apparent inconsistencies and variance in
'detail in the procedures.
A review of the verification and validation documentation revealed a distinct lack of human factors examination.
The documentation also does not indicate an effort to compare the procedures to the generic WOG Emergency Response Guidelines.
It does, however, show evidence of some review against the site specific ERG document.
The documentation further does not provide an indication of the scenarios used on the simulator for the validation exercises.
These omissions do not provide the NRC with evidence of a thorough review commensurate with the significance of the EOPs.
The licensee's effort to resolve these concerns should focus on providing a critical review process utilizing a multidisciplinary approach and a comprehensive writers guide.
Further, the licensee's verification and validation program should also provide a multidisciplinary process to ensure that all factors associated with the EOPs are addressed during the process.
Simulator Exercises The Team requested that the licensee provide two crews of operators to conduct simulator exercises on successive days.
The operations staff provided two crews that were available from the same operating shift.
The crews were instructed to perform during the scenarios as close to how they would in an actual event.
Four scenarios exercising
EOPs were conducted on the Diablo Canyon simulator to verify that the procedures provide the operator with an effective operating tool to place the plant in a safe shutdown condition for accidents and transients within the scope of the EOPs.
The scenarios were run with two different operating crews consisting of a Shift Foreman (SFN),
a Senior Control Operator (SCO),
a Control Operator (CO),
an Assistant Control Operator (ACO), and a Shift Technical Advisor (STA).
Both crews mentioned that the scenarios used in the EOP inspection were more complicated than those they ordinarily meet in their training.
The scenarios included a Loss of Qffsite Power combined with a Loss of Secondary Heat Sink, a Loss of Containment Sump Recirculation following a Design Basis LOCA, a Steam Line Break combined with a Steam Generator Tube Rupture, and an Anticipated Transient Without SCRAM combined with a Steam Generator Tube Rupture.
In the scenario which included a Steam Line Break and a
SGTR, at step
RNO of E-3,
"Steam Generator Tube Rupture," the transition should have been made to ECA-3. 1,
"Steam Generator Tube Rupture With Loss of Reactor Coolant - Subcooled Recovery Desired."
Miscommunication resulted in a transition to E-3. 1, "Post SGTR Cooldown using backfill, instead of ECA-3. 1.
The operating staff had not referred to the entry conditions on
the two EOPs.
Entry for ECA-3.1 is from step 14 of E-3, whereas entry for E-3.1 is from step 39 of E-3. E-3.1 does not include starting a Reactor Coolant Pump(RCP).
ECA-3. 1 does include startinj a RCP at step 16.
In the exercise the operators did start a
RCP in sprite of no such instruction in the EQP in,use.
Training should emphasize the need for precise communication
.and a check of entry conditions before entering the procedure.
The simulator exercises demonstrated that the EOP procedures are technically correct and can be accomplished by using the existing equipment, controls, and instrumentation.
Several areas for procedure enhancement are described below:
o Both steps 5b and 7b of E-l.3 state
"Cut in series contactor and Open 8982 (A)(B)"
The operators suggested the these two manipulations and the corresponding operations in the RNO columns be separated into two steps.
o The operators also suggested that step 2 of ECA-1. 1 which presently adds makeup to the Refueling Mater Storage Tank (RMST) from the spent fuel pool OR the CVCS system (Volume Control Tank) should be changed to AND in order to makeup from both sources simultaneously.
o ECA"1. 1 Appendix M, step 3d, directs subsequent actions if the Steam Generators in both loops 3 and 4 are intact.
The RNO column directs actions if the loop 4 Steam Generator is not intact.
The RNO column does not address actions if the Steam Generator in loop 3.is not intact.
o E-1, step 7c, directs that, if RCS pressure is increasing, RCS pressure should be stabilized with normal or auxiliary pressurizer spray.
In order to get spray, the procedure should be amplified to direct the prior aligning of normal charging.
It should be noted that two other scenarios prepared by the inspectors and proposed for use in the EOP inspection, a station blackout and a
Class V accident, but were not used.
The licensee has a new procedure for cross"tieing a Diesel Generator from one to supply vital bus power for the opposite unit.
This temporary procedure, TP T0-8911, was
.
reviewed and found to be adequate; however, the Diablo Simulator is not presently capable of simulating this cross-tie operation or a failure of same.
The proposed Class V accident, or interfacing LOCA, started with a failure of valves in the RCS -
RHR piping with the high pressure Reactor Coolant impinging on the low pressure RHR system and failing outside containment.
The inspectors were informed that this accident has never
~ A
been simulated on the Diablo simulator, and the operators have not been trained in responding to this specific accident.
Commentary from the two crews during the post scenario critiques indicate confidence on their part regarding their knowledge of the procedures on the whole.
However, the operators'omments indicated a lack of familiarity with the Emergency Contingency Action (ECA) and Functional Recovery (FR) procedures.
The comments indicated that the operators had not had extensive contact from training with the FR procedures.
The crew that experienced an error in transitioning to another procedure apparently was from a request by the Senior Control Operator to the Shift Foreman to pull a procedure out of the procedure rack.
The procedure that was required was ECA-3. 1, the Shift Foreman inadvertently pulled out procedure E-3. 1 "Post-SGTR Cooldown Using Backfill."
The reason the error was not detected by the operators was due to the fact that the two procedures essentially accomplish the same task in the early part of the procedure;and do not diverge significantly until later.
It would have become obvious that the procedure could not have been used any further at that point.
The Team Leader's analysis of the error indicates that the actions taken in the procedure would have been essentially the same in terms of getting the Reactor Coolant System (RCS) to a condition stable enough to proceed with a cooldown.
Eventually it would have become obvious that the actions in E-3. 1 would not suffice, because the RCS pressure would prevent a backfill from occurring.
From this the NRC Team Leader determined that the actions of the crew would not have jeopardized the plant.
The Team Leader questioned the Operations Training Supervisor about the training the operators receive in verification of the appropriate procedure on entry.
The Supervisor stated that it was not emphasized unless the operators had entered the wrong procedure during a simulator exercise.
The crew would then have received instruction on verifying that they were in the correct procedure during the critique that follows each exercise.
The Supervisor further stated that it was noi a practice to emphasize this during training. Earlier, during interviews, the Human Factors Specialist on the inspection Team received a comment from an operator that there have been problems with entering the wrong procedure and of failing to read Cautions or Notes prior to entering step 1 of a procedure.
It is apparent from these comments that the training the operators have received does not emphasize verification of the procedure
'rior to entry into the actions, nor does training emphasize the need to read the Cautions or Notes prior to step 1 in a procedure.
The NRC Team Leader concluded that the training the operators have received in procedure usage is not formalized, therefore, it may represent a source of potential error during the execution of EOPS.
It appears the licensee must provide some clear direction regarding procedure usage.
0 erator Trainin The observations of the Team members calls into question how thorough the training has been.
The observation provided in paragraph 4 above
illustrates the concern.
The operators provided comments that suggest that the amount of training received on the EOPs has been limited on the Emergency Contingency Actions and Functional Restoration Procedures.
A review of training records indicates that training for the majority of the Functional Restoration (FR) procedures has been in a classroom environment only, with very little time spent on the simulator with any of the FR procedures.
Further, the time spent with each of the ECA procedures is limited, although all of the ECAs are exercised on the simulator.
The lack of coverage on the FRs in particular is disconcerting because these procedures require a good understanding of the strategy of restoring functional operability to systems.
The total time spent in an average requalification cycle on the classroom reviews does not appear to be more than two to four hours over ihe two year cycle for all'of the FR procedures.
Considering the complexity of some of these procedures, this would appear to be minimal at best in terms of classroom contact with these procedures, let alone the very limited contact on the simulator.
An evaluation of the amount of training time required for the Operators by the Training staff appears to be strongly war ranted.
The NRC inspection team found the training the operations staff has received to be of high quality with the exception of amount of time spent on the lower tier EOPs, Emergency Contingency Actions and Functional Restoration procedures.
Licensee's Pro ram to Evaluate EOPs The facility does have an ongoing program to evaluate and review EOPs.
An effort is currently in place to more formally manage the EOP program, it does however appear to be in the early phases and is not y'et fully implemented.
The scope of the future effort to rewrite the EOPs includes a multidicsiplinary group for the review phase of the generation of the new procedures.
The effort, however, to produce the procedures is vested solely with the Senior Power Production Engineer assigned to the EOPs.
During the site visit the program was provided with additional staff support from the both the Training and Operations staffs after an inquiry by the NRC Team Leader about the adequacy of the resources committed to the program.
The milestone established for finishing the rewrite of the procedures, the end of the third cycle refueling outage for Unit 2, makes the effort of the Senior Power Production Engineer questionable
'regarding completion of the task in its entirety by the end of the outage.
This effort also has to include the completion of the required training for the operating crews, this would infer at least 6 weeks of effort prior to startup.
This does not appear to have been factored into the process.
Periodic audits have been conducted by the licensee's equality Assurance organization.
The results of those audits reveal substantially many of the same findings that this inspection revealed.
At the time this inspection was announced most of the Action Requests from the audit findings were overdue.
A change in the action due date for procedure
changes was made to coincide with the end of the Unit 2 third cycle refueling outage.
The decision appears to have been made shortly before the arrival of the inspection Team as evidenced by the recorded date when the change in the due date for the Action Requests of November 20, 1989.
The inference that the Team Leader has concluded from this action is that the licensee determined that the overdue Action Requests were indicative of a lack of prompt attention to the findings of the audits.
A significant concern arises from the blanket deferral of the action due dates for the Action Requests outstanding for the EOPs.
The reasoning of the Operations staff appears to be well founded that the complexity, and many interrelationships of the EQPs, requires that changes be made to all of the procedures at the same time.
Therefore, the decision to defer the due dates appears acceptable from the view of the NRC inspection team.
However, the NRC inspection team is concerned that this may send an inappropriate message to plant personnel.
Blanket deferrals such as this can infer that plant management does not share the concerns of the plant staff and undermines management's credibility.
The NRC inspection team concluded that the licensee's program for evaluating the EOPs in an ongoing program, when fully implemented, will provide assurance that the EOPs are maintained in a useable and efficient form for the use of the plant operators.
The licensee's internal audits of the EOPs indicated that the procedures have received close attention.
However, the licensee staff should avoid the use of blanket deferrals in resolving multiple findings associated with equality Assurance audits.
Plant Access Mabitabilit and Communications:
The team examined the habitability and access for the performance of local actions.
These local actions included the following:
o Local operation of the lOX Steam Dump valves.
o Procedure AP-9 "Loss of Instrument Air."
o Locally tripping the Turbine Driven Auxiliary Feedwater Pump.
o Locally close the breakers f'r the Pressurizer Power Operated Relief Valve.
o Local operation of 4KV safety related breakers.
o Aligning alternate Auxiliary Feedwater supplies to the Turbine Drive Auxiliary Feedwater pump.
o Local operations in the Post LOCA sample room.
o Local operations at the Boric Acid Storage Tanks.
o Locally operating the crosstie valve for Auxiliary Steam.
o Local operations at the Heater Drip Pump o Local Operation of the Hain Feedwater Pumps.
o Local operation of the Salt Mater Cooling system.
o Local operation of Busses
D and E.
In most instances access was adequate to the equipment with the following exceptions.
During a survey of the facility it was determined that the 115 foot elevation penetration area and the 100 foot penetration area in the Auxiliary Building present a particular problem as to lighting adequacy when the plant would experience a Loss of All AC power or a Loss of Offsite Power.
In the Loss of all AC Power situation the reliance on the DC lighting alone leaves these areas very dim.
Further, the lighting available in the 115 foot elevation when a Loss of all AC Power event has occurred makes it particularly hard to view equipment.
At the 100 foot elevation the areas where required lighting for Appendix R is installed the lighting is good around the local shutdown panel.
But, where the Appendix R lighting is not present the 1'ight levels are low, particularly around valves in the proximity of the containment wall.
During a survey of the lighting at the Component Cooling Mater Pumps on Unit 1 it was noted that when only DC lighting was on, CGM pump 1-2 had no light, while CCM pump 1-1 and 1-3 did.
In the Loss of all AC Power situation the reliance on the DC lighting alone leaves these areas very dim.
Further, the lighting available in the 115 foot elevation when a Loss of all AC Power event has occurred makes it particularly hard to view equipment.
Communications appear to be satisfactory with only some minor reservations.
The pl'ant phone system is extensive and provides coverage of most areas in the plant.
In particular it does cover the areas where emergency operations may have to be carried out locally.
On one occasion a phone, at the Unit Turbine Driven Auxiliary Feedwater Pump, was found to be out of service.
At commonly high noise areas the phones are equipped with receiver amplifiers and noise blanking microphones.
The plant radio system is not commonly use for routine in plant activities.
The reason for not using the radio system for routine activities has been the past history of the plant with'inadvertent Safety Injection actuations caused by Radio Frequency Interference with electronic circuitry.
The Operations Manager stated the radios would be issued if an emergency mandated, and is the policy whenever an emergency is declared.
The NRC inspection team concluded that the facility needs to continue to give the plant lighting problem 'a high priority.
Conversations with plant staff and management indicate it is receiving attention at the the present time.
The licensee should examine the tripping hazard potential in the facility, with particular emphasis on the many seismic support pads on the floors.
Communications for plant emergencies appears to be adequate, however, the facility should survey the equipment periodically to ensure that important locations have operating communications device. 'ocal Action Checklists The inspector discussed the local action checklists (LAC) with the EQP program leader.
The function of the LACs is to identify tools and equipment necessary to perform a local action required in an EOP and the environmental conditions which the action would have to be carried out
,under.
In the future, the LAC program is to establish, control of necessary tools and equipment such that it is ready in an"emergency situation.
Additionally, an appendix to the EOPs will include this information for each local action.
The program is relatively new and has not been completely implemented.
As such it is not possible to perform a complete review.
In general, the concept is a good one and when fully implemented as described should be a valuable tool.
In'eviewing the EOPs and their LACs the inspector did note the following weaknesses with completed LACs; o
Many LACs referred to other LACs which. reviewed the same local action.
However, in some cases the LAC referred to did not cover the same action or area.
(e.g.
ECA-O.O step.4, RNO)
o The LACs listed worst case expected radiation levels in the review.
In some cases doses were found to be extremely high.
It was not clear how realistic the high doses were.
If radiation levels expected for a given action would result in an operator receiving a
dose exceeding a regulatory dose limit for an emergency action, compensatory measures or alternative actions need to be available, o
A number of cases were found where required tools were not identified.
(e.g.
ECA-O.Q step 6a)
8.
~Ei M ti The inspection team met with representatives of the plant staff as denoted in paragraph 1 on December 8, 1989.
The team leader summarized the inspection findings with emphasis on Operator training and the resolution of the Action Requests.
The team leader pointed out to the facility staff that blanket deferrals of Action Requests could lead to the impression amongst the plant staff that the concerns raised in the Action Requests were not getting close attention.
Even if the decision to defer action was taken with prudence in mind, the impression left can be detrimental.
The concern conveyed about Operator training on Functional Recovery procedures and Emergency Contingency Actions focused primarily on the balance or ratio of training given to the Operators.
The team leader stressed that the training the Operators received may have been adequate, however, the time actually spent in training appears to be low on the face of the evidence.
The NRC Team Leader stated that the plant lighting appeared to be inadequate in some areas, particularly when Emergency Lighting was necessary.
The Plant Manager stated that a program is underway to
determine how to improve the lighting and emphasized that this effort has a high priority.
The overall program in place for the management of the EOPs appears to the team to be on track to producing an improved set of procedures.
The procedures in place now do not present a significant problem for the operators, and appear representative of the industry norm.
The NRC Team Leader noted that the facility appears to have recognized the EOP program to be a vitally important program.
This was evidenced by the commitment do a multidisciplinary approach to improving the procedures and the involvement of plant management in the process.
~
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/
~
V g
APPENDIX A Findin s of S ecific Concerns Associated with 1a o
an on s
E-1 Loss of Reactor or Secondar Coolant The first CAUTION appears out of place and would be appropriate as a
RNO or NOTE.
The second CAUTION is'not a CAUTION and, is really substep of step 1.
The continuous action steps need to be handled in a more effective manner to alert the operators and to specify duration of continuous action steps.
The CAUTION statement is really a continuous action and tells the operator to "Refer to" a procedure.'tep 6b:
Does not state how the operator is to verify that the Area Radiation Monitors are
"NORMAL".
There is no criteria available for"the operators in checking that radiation monitors are
"NORMAL". All that is really being checked by the operators is that the monitors are not in an alarm condition.
In addition, the
"NORMAL" reading,
"ALERT" setpoint, and
"ALARM" setpoint are not available at the RMs.
The operators are not trained to determine the ALERT or ALARM setpoints and would have to refer to various control room documents to obtain NORMAL readings.
This is a generic problem for all the places in the EOPs where operators must check readings on radiation monitors.
Step G.c RNO:
The operators check Containment Spray Pump Amps to determine if the pump is in operation, but there is no criteria for expected pump Amps.
This situation occurs when the EOPs require the operators to check for "flow" or "normal operation";
they routinely check for motor amps, but expected.
readings are not indicated on the control boards or in most EOPs.
The last sentence of 6.c RNO is a continuous action statement which is not identified as such.
Termination of containment spray does not include shutting 9001A/8 "Spray Discharge Valves" which were shut prior to spray initiation.
The system is not returned to its pre-actuation state.
Step 7a:
Checking subcooling requires use of the subcooling meter.
Most operators are not trained how to switch channels on this meter and rely upon its'eing set on the proper channel.
The CAUTION at the beginning of the procedure appears to be applicable here as a
NOTE or as a
RN Step 7c:
The operator is directed to use normal or auxiliary spray, but there is no guidance as to how this is accomplished.
For examp'le, consider all coolant pumps are off.
One must open NRHX valves (8107 8 8108) before ANY charging pump discharge for spray is available.
In addition, one must shut the loop normal changing valves (8146 8 8147) before alternate spray (through 8145 8 8148) will work (pressurizer steam bubble prevents spray flow).
To confuse matters more, opening the normal spray valves (455A 8 B) will also divert water from alternate spray to the loops.
Some of the EOPs have CAUTIONS or NOTES related to some of these concerns, but they are not repeated here and are not consistent.
The CAUTION regarding starting the RHR pumps is really a continuous action statement.
Step 9a2):
One is required to determine if RCS pressure is stable or decreasing.
The instruments to use are not specified.
The determination can be done by looking at the chart recorder (0 to 3000 PSI) which is not referenced in the procedure.
It is often completed by the operators looking at the
to 3000 or 0 to 600 PSI wide range pressure gauges.
At low RCS pressures the chart recorder may be hard to read accurately.
The recorder is needed again in substep 10.b.
Steps 12dl and 12d2:
These steps have "IF-THEN" statements in the left column which does not appear consistent with the writers'uide.
Also 12.d(2) states
"place a
second GCS/ASW Hx in service", this should be corrected to "CCW/ASW" Step 12e:
Tells the operator to energize R-32 and R-33.
The operators do not know how to energize R-32 and R-33.
Either the operators need to be trained or the persons who know how to energize R-32 should. be referenced in the procedure.
Step 12f3:
Tells the operator to check feed-pump turbines on the turning gear.
This cannot be done at the main control board and requires someone to check in the plant which is not stated in the EP.
RNO column contains reference to checking if ECCS flows are less than 200 GPM.
This low flow cannot be accurately read on the Unit 2 instruments.
This appears to be a generic problem with all unit two ECCS flow meter Step 15c RNO:
This step will disables the containment nitrogen system to depressurize an unisolable accumulator.
This places the containment nitrogen system out of service which will deplete the nitrogen back-up bottles early in an accident.
The step requires checking that main steam and blowdown radiation monitors are normal.
The normal readings or ranges are not stated in the EP 'or available at the instrument for the operators.
Steps 15d and 15e:
This step appears to stop the cooldown when intact S/G pressure is less than RCS pressure.
It appears appropriate to continue a cooldown at some rate until transferring to hot leg recirculation.
APPENDIX A BLACKOUT EMERGENCY LOADING OF VITAL BUSSES The sequence of loads to place on the vital busses is not specified.
The list in step 2 may be the appropriate sequence in which the vital busses are loaded manually, but this is not stated.
E-l. 1 SI Termination The second CAUTION statement regarding what to do if the subcooling monitor becomes inoperable seems misplaced and appears more appropriate as a
NOTE or RNO in step 11.
Step 3:
The substep to establish instrument air to containment does not include checking instrument air header pressure.
The unit two operator does not have any indication of air system pressure.
In addition there are no control room operating status lights or controls for "temporary" air compressors 0-5 and 0-6.
These two compressors were added at the end of 1983 when the original four air compressors did not have sufficient capacity.
Temporary A/C 0-5 and 0-6 have been in place since then and appear to have become permanent by default.
During the current inspection the only air compressors available were 0-5 and a third
"temporary" unit installed to the west of unit one turbine building.
Air compressors 0-1 through 0-4 have been tagged out since 9/20/89 to allow installation of new coolers and dryers and 0-6 was out of service due to an oil leak.
Temporary cooling ducting supported by ropes has been installed to cool A/C 0-5 (in October 1987)
and 0-6 in June 1989 since the installed cooling appears inadequate.
Facility personnel recently have been trying to finalize the system and have made progress in installing new coolers and dryers.
The licensee's management appears to have been unable or unwilling to correct known deficiencies or finalize the installed air system for several years.
Facility management should analyize the root cause of the delay in finalizing the air system and be alert that this type of situation does not reoccu 'i
Step 4a2 RNO:
This is a continuing action statement which is not emphasized and is open ended.
It is not clear how long one must control charging pump speed and HGV-142. If these items must be controlled from this point on in the procedure it should state this clearly.
When checking for SI flow it is very hard to read the Unit 2 flow at low flow rates.
Between 0 and 200 GPM it is nearly impossible to read the flows.
When stopping containment spray, the spray isolation valves (9001A 8 B)
are not shut.
Consequently, the containment spray system is not restored to its'riginal configuration.
Step 15a'7 turns",are specified, but the controller name is not stated.
Part b.
of the RNO column refers to "B-lA:VIIPart B, CVCS - MAKEUP CONTROL SYSTEM OPERATION - MANUAL OPERATION",
There is no Part B to this procedure.
E-1.3 Transfer to Cold Le Recirculation Step Step 5b RNO:
Has the operators opening valve 8982B "remotely" or "locally".
The terminology "remotely" is not in the writers'uide.
The term "locally" in the writers'uide indicates that this operation is done outside the-control room.
Since valve 8982B is inaccessible without opening up its'olted vault which may may violate the containment boundary, local operation of this valve appears to be a major operation which deserves more guidance as to what must be done and any time limitations.
7c:
The operator is directed to "locally open FCV-365" and to "verify flow locally at FI-88".
FCV-365 is an air operated valve with no means to open the valve at the valve itself (Short of cutting the air line to the valve).
The local operation must be described in adequate detail.
FI-88 is a local meter which indicates flow in "percent".
There is no acceptance criteria stated for adequate flow.
E-l. 4 Transfer to Hot Le Recirculation Step 8:
In substep e the operator is directed to "Verify ASW pp motor current is LESS THAN 54 AMPS".
This appears to be good practice but is not done during verifications of other operating equipment which do not include verification of pump AMPS as a specific substep.
To verify that
components are operating properly the operators do check motor current (when it is on the control boards),
but the expected motor current is not stated or indicated.
In the RNO column the operator is directed to throttle ASM-65 or 66 which are in, complete darkness in unit two.
Step 9:
In substep d through g the CCM valve tags are very hard to read.
Pump rooms, for pumps 1-2 and 2-2 do not have any emergency DC lighting.
Procedure E-3 Steam Generator Tube Ru ture Step 18:
Caution requires the operator to record a thermal cycle per STP-H-55 if Auxiliary Spray is used when Delta-T exceeds 320 Deg.
F.
Logging of such information is not a safety issue and should not consume operators time in the midst of a procedure designed to cope with a degraded plant.
This instruction should be placed at the end of the procedure when the plant is recovered.
Step 18b:
The step instructs the operator to open a
PRZR PORV until fulfillment of ANY of two conditions, one of which includes a choice of two different sub-steps.
The step as written is confusing; confusion may be lessened by changing ANY to ONE.
Step 20:
The sub-steps a, b, c, and d in the RNO column.
The MOG ERG says
"DO NOT STOP SI PUMPS" (capitalized for emphasis.)
Diablo Canyon has deleted this instruction with no justification in the Deviation document, It is important to remind the operators of this admonition especially since the caution in this step says
"ECCS must be terminated when termination criteria are satisfied,"
and consequently
"00 NOT STOP SI PUMPS" should be. placed at the beginning of each of the sub-steps in the RNO column.
Step 21b:
States
"Check any Cent.
Charging PP - running" and step 21e states
"Stop one of the two running Cent CHG PP;"
An operator may interpret this instruction to stop the running pump if only one were running.
The objective of MOG ERG is to keep one pump running and the language of the instruction should be changed to make it clea Step 36:
E-1.1 Step 24 and E-1.2 Step 20, all have the same action, to check RCP status of at least one running.
There is a lack of consistency in the writing of these steps.
E-l. 1 does not include the criteria for starting a
RCP, which is in the other two procedures.
E-3 includes criteria for reducing pump"heat in the action column, whereas E-1.2 includes such criteria in the RNO column.
E-3. 1 Post SGTR Gooldown Usin Backfill Appendix B:
The E-3 series of SGTR procedures, E-3, E-3. 1, E-3.2, and E-3.3 all include Appendix B, "Restart of Reactor Coolant Pump."
Appendix B is identical in the four procedures except that E-3. 1 Appendix B, Step 3, includes the question
'Does new range of indication (0-2500 psid) allow sufficient accuracy and readability for this task?"
This sentence should not be in an operators procedure, and is indicative of a less than comprehensive gA audit.
ECA 0.0 (Revision 2) Loss of All AC Power Step j.:
The Step Deviation Document (SDD) states that "Plant specific enhancements were added referring to local actions, and the use of various methods to recover last instrumentation in the RNO column."
The RNO column only states,
"Manually or locally trip reactor."
Ib makes no mention of instrumentation.
Step 2:
A LAC was not completed for the local turbine trip.
Step
RNO:
The LAC states,
"See EP E-0 step 14a RNO and OP D-l: IV for Local Action checklists."
The LAC for EP E-0 refers to the LAC for OP 0-19,
"Auxiliary Operator Actions following a Reactor Trip."
OP 0-19 does not address conditions near FCV-37, 38, and 95 or LCV-106, 107, 108, and 109.
OP D-1:IV, "Steam-Driven Auxiliary Feed Pump - Restart of Make Available After Overspeed Trip," likewise does not address the conditions at the above listed valves.
Issues which should have been addressed are the need for communications equipment, gloves to locally operate FCVs-37 and 38 which are in a high ambient heat area, and lightin ~
~
~
Step 5b RNO:
If the diesel generator will not start locally the operator is instructed to refer to OP J-6B "Diesel Generator - Hake Available."
However, the procedure is not available at the diesel generator and must be obtained from the control room.
Step Step 6a:
Although the LAC says no tools required, a speed wrench is necessary to open breaker cabinets and protective gloves are necessary to open the DC control power knife switches.
The majority of breaker cabinet bolts fit the speed wrench.
However, some bolts were found that did not.
During an emergency this could result in an unnecessary delay.
6c:
The ERG has the operator defeat the auto-start feature for the fan coolers placed along with other vital loads so that they can be loaded in a controlled manner following bus restoration.
The procedure does not do this and instead has the CFCU placed in low speed.
This is not addressed in the step deviation document.
If the CFCU automatically loads when the bus is energized, no CCW or ASW would start to supply the CFCU motor cooler.
The licensee's procedure background document reflected the ERG and listed the CFCUs as components which require their auto restart feature disable.
This finding was discussed with the licensee who agreed that it had been an oversight.
Step 8:
Emergency lighting for the local isolation of the RCP seals is poor.
This is of a concern since this step is only necessary on loss of AC power.
Step 9a The procedure closes LCY-8, hotwell fill from the condensate storage tank.
It does not address a need to verify the LCV-8 bypass valve closed.
Step Abbreviations differ between control room and procedures for the main steam and blowdown isolations and sample valve Step A cheater wrench may be needed to operate the lOX steam dump valves.
However, no cheater was found upon inspection of the tools at the auxiliary building control panel. All lOX steam dumps are reverse operating.
One of the auxiliary operators whom walked through this task with the inspector was not aware of this.
As such, local instruction or indication seems appropriate.
Step 14:
The terminology for the Main Turbine DC Bearing oil pumps and the feedwater DC oil pumps differ between the control room or local panel and the procedure.
Appendix X figure 1:
The Diesel Generator Load Limits Graph was marginally legible.
Appendix R Step 3b:
This has the operators throttle FCV-357 to establish RCP Seal cooling.
Valve FCY-357 is located in the 100 foot elevation Auxiliary Building Penetration area.
In establishing CCW flow to the RCP thermal barriers, communication between the Control Room and the Auxiliary Operator at FGV-357 is essential, as evidenced by Appendix R Step 3a(1) "Establish communications between the Control Room and the Operator..."
The phone in this area is about 40 feet from the valve.
The emergency lighting in the area of this valve is dim, and the area les numerous tripping hazards which are not clearly marked but are simply the same battleship grey as the floor.
ECA O.l (Revision 2) Loss of All AC Power Recover Without SI Re uired Step 14 Caution:
The 'caution statement required that a thermal cycle be recorded is the differential temperature between the auxiliary spray and the pressurizer is greater than 320 degrees F.
This seems unnecessary in the middle of an emergency procedure and would be more appropriate to include it in a post-trip recovery procedure.
Appendix N Step 14:
The step is unclear whether the operator to isolate the primary or secondary side of the transformers when opening supply breakers for non-vital 480V busse t
Appendix N Step 26a:
The step has an operator dispatched to the 500 KV switchyard to accomplish the step.
However, there is a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> watch at the 500 KV switch yard.
Therefore, it would seem appropriate, rather than dispatch another operator, to initiate communication.
EGA 0.3 Revision
Restore Vital 8us ECA 0.3 is not, a procedure discussed in the Mestinghouse ERG.
At Diablo Canyon, there are three vital busses for two trains of ECCS equipment were two busses are necessary for one full train of ECCS.
Step 3 of E-0 verifies all three vital 4KV energized.
The RNO has the operator refer to ECA 0.3 if two vital busses are energized and go to ECA 0.3 if only one bus is energized.
If no vital busses are energized, the operator goes to ECA 0.0, Loss of All AC Power.
The site EOP background document states that, "Ifat least one train cannot be restored quickly using ECA 0.3, the operator should transfer to ECA 0.0...."
This is not accomplished by EGA 0.3.
The final step of ECA 0.3 is to "Return to Procedure and Step In Effect."
There is only one entry condition:
step
of E-0.
A return to E"0 step 3 would send the operator back to ECA 0.3.
As a result, the operators could find themselves in a loop delaying them from taking actions described in ECA-O.O to isolate the RCS and verify AFM flow.
ECA-2.1 Uncontrolled Oe ressurization of a]1 Steam Generators Step 1:
The phrase
"Manually close valves." is in the RNO column which appears to be a typographical error.
Step 2:
The CAUTION is a continuous action statement which is not identified or limited.
Substep b has S/G level less than 50K with no adverse containment conditions specified.
Step 4:
In'the'-RNO"column'the operator is told to refer to OP D-l:V without any procedure title.
Step 5:
The CAUTION statement is a continuous action statemen ~
~
Step 6:
Substep b has the operators check for high radiation from the steamline radiation monitors without stating what constitutes normal or high readings.
Substep c tells the operators to check secondary radiation-normal, but does not state the monitors or any acceptance criteria.
ECA-3. 1 SGTR with Loss of Reactor Coolant - Subcooled Recover Desired Step 5c RNO:
The deviation document states that plant specific constraints on the use of containment spray during a LOCA were added, i.e.
two hours operation for iodine removal.
However, the procedure does not include any information on such a constraint.
Step 16a1 RNO:
States
"Stop all but one or two RCPs."
Such an instruction cannot help but be confusing.
Step 18d RNO:
The MOG ERG includes
"DON'7 STOP HIGH HEAD SI PUMP," in capital letters for emphasis.
Diablo Canyon has deleted this instruction, with no justification in the deviation document.
This sentence should be put back into the procedure.
Step 19a and 19c RNO:
The MQG ERG includes
"DO NOT ISOLATE BIT'n capital letters for emphasis.
Diablo Canyon has deleted this instruction with no justification provided in the deviation document.
ECA-3.2 SGTR with Loss of Reactor Coolant - Saturated Recover Desired Step 11d RNQ:
The MOG ERG includes
"DO NOT STOP CHARGING/SI PUMP" in capital letters for emphasis.
Diablo Canyon has deleted this instruction with no justification prdvided in the deviation documen Step 12d RNO:
The MOG ERG includes
"DDN'T STOP HIGH HEAD SI PUMP," in capital letters for emphasis.
Diablo Canyon has deleted this instruction, with no justification in the deviation document.
This sentence should be put back into the procedure.
ECA-3.3 SGTR Mithout Pressurizer Pressure Control Step Sa, Sb, Sc, Sd RNO:
The MOG ERG includes
"DO NOT STOP SI PUMPS" in capital letters for emphasis.
Diablo Canyon has deleted this instruction with no justification provided in the deviation document.
Step 9:
In substep d through g the CCM valve tags are very hard to read.
Pump rooms for pumps 1-2 and 2-2 do not have any emergency DC lighting.
FR-C. 1 Res onse to Inade uate Core Coolin Step
~
Substeps a, c, and e=require-. that the operators check for flow-grater-=-
than 200 GPM.
This low flow cannot be reliably read on the unit two flow instruments.
The next to the last substep a
RNO states the charging pump AMPS which is appropriate, but is not done for other similar verifications.
The last step of the substep a
RNO states
"Establish alternate injection (Recip Chg Pp, BIT bypass, normal charging)" but does not say how this must be done or what procedure should be used for reference.
Step
In substep a
RNO the operators are directed to check RVLIS level increasing, but they are not directed to the recorder on PANS 1/2 which is not consistent with the writers'uide.
Step 9:
Substep a directs the the hydrogen analyzer be checked to be in service, but does not say how to do this.
The operators do not know how to satisfy this substep without contacting Chem/Rad which is the RNO action.
In substeps c and d the phrase "in dry air" is used when referring to hydrogen concentration.
This nomenclature is not used on the applicable instruments and may cause confusio ~
~
Step 13:
In substep b
RNO the procedure will leave the nitrogen supply to the containment isolated and deplete the back-up nitrogen bottles.
The last part of the RNO states
"UNTIL Accumulator is depressurized and continue in this procedure."
This statement does not tell the operators what final alignment is desired for the system. It is not completely clear if the EP should be continued while depressurizing the accumulator or after depressurization.
Appendix F Establish Secondary Heat Sink Step Substep a does not include a check of the CST level chart recorder which woul'd provide back-up level indication and trend information.
FR-H. 1 Res onse to Loss of Secondar Heat Sink Step 5c:
The step includes 3 action sub-steps to establish Main Feedwater flow capability.
The RNO column opposite directs
"Go to Step 7 (Establish Feed Flow From COndensate System)."
However, sub-step c3 has its own RNO column which says "If no MFM path can be opened, then go to step 9"-
(Mhich checks the SG MR level and its RNO column returns to step 1).'f the operators cannot establish MFM flow, should he go to 'step 7 or step 9'l Steg 21d RNO:
The MOG ERG includes
"DO NOT STOP CHARGING/SI PUMP" in capital letters for emphasis.
Diablo Canyon has deleted this instruction with no justification provided in the deviation document.
Step 22d RNO:
The MOG ERG includes
"DON'T STOP HIGH HEAD SI PUMP," in capital letters for emphasis.
Diablo Canyon has deleted this instruction, with no justification in the deviation document.
This sentence should be put back into the procedur pi
FR-H.3 Res onse to Steam Generator Hi h Level Step 7:
"Check affected S/G radiation normal."
"Normal" is not defined.
The list of monitors in the action column should include the SJAE monitor, and the SlG Blowdown monitor.
FR-P. 1 Revision 3)
Res onse to Imminent Pressurized Thermal Shock Condition Step This step to isolate charging flow through the Boron Injection Tank (BIT)
follows the realignment of the normal charging flow paths in Step 10.
In step 10h, FCV-128 and HCY-142 are adjusted to maintain pressurizer level, regenerative heat exchanger outlet temperature and seal injection.
However, when the BIT is isolated FCV-128 and HCV-142 need to be readjusted to account for 'the loss of the flow path.
This is not addressed in the procedure.
Step 14c RNO:
If the SI accumulators do not close it becomes necessary to depressurize the accumulators by venting the nitrogen blanket.
The RNO closes a
containment nitrogen supply valve and opens a vent valve.
The procedure does not close the vent and reestablishes the containment nitrogen supply when the accumulator has depressurized.
This is not a conservative position since it isolates the backup nitrogen accumulators for the pressurizer PORYs and charging supply valves 8145, 8146, and 8147 (pressurizer auxiliary spray, normal charging, and alternate charging).
Additionally, the accumulators are separated from a containment vent by signal check valves.
Step 15a RNO:
This step is done if normal pressurizer spray is not available.
Normal spray is dependent on the availability of the loop 1 and 2 RCPs.
This, however is not made clear in the procedure.
Step 17:
The step states,
"Ensure makeup set for greater than RCS boron concentration of 2000 ppm (7 turns)." It does not state what needs
turns.
Step
RNO al):
In establishing excess letdown the step does not give guidance as to what is minimum charging flo Step
RNO a8):
In establishing excess letdown the step states,
"Open HCY-123 as necessary to maintain level and TI-122 LESS THAN 190 degrees F, excess ltdn temp."
At this step'n the procedure HCV-123 isolates the cold excess letdown heat exchanger from the hot RCS.
Operating Procedure 8-1A: IV, Excess Letdown -Place In Service, includes a caution statement to slowly perform the same step to prevent thermal shock to the excess letdown heat exchanger..
Step 23b 5):
The step refers the operators to maintain RCS pressure and temperature within the limits of Appendix S.
Appendix S, a graph of operational limits for pressurized thermal shock conditions was poorly reproduced in the control room.
Additionally, it is difficult to understand how to apply the graph to operating conditions.
This had been recognized by the licensee and a
new Appendix S drafted.
It will,be issued with the next generation of procedures.