IR 05000302/1989010
| ML20245A727 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/07/1989 |
| From: | Kellogg P, Lawyer S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20245A724 | List: |
| References | |
| 50-302-89-10, NUDOCS 8906220137 | |
| Download: ML20245A727 (18) | |
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UNITED STATES ps ucoq'o.
NUCLEAR REGULATORY COMMISslON '
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REGION ll 101 MARIETTA STREET,N.W.
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. ATLANTA, GEORGI A 30323
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Report No.: 50-302/89-10 Licensee: Florida Power' Corporation 3201 34th Street, South
E St. Petersburg, FL 33733 Docket No.:
50-302 License No.: DPR-75
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Facility Name: Crystal' River 3
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Inspection Conducteo': May 15-19, 1989
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Inspector:
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'74124/89 fSand9 Lawyer,LeadInspector l
Date SignedL Team Members: Glen Salyers'
i Gordon Bryan Approved by:
/IM. b1.
Aw 7/9/9 -
' I P'. J. Kellogg, Chief..
& ate Signed '
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Operational Programs'Section Division of Reactor Safety
a SUMMARY j
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Scope: This routine, announced inspection involved the review of corrective
actions for previous findings in the areas of training and emergency operating
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procedures.
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Results: We have found that your pursuance of the resolution of our' original report comments has been thorough, technically responsible and in accordance with strict professional standards.
However,thereareareaswhichrequirefutherimprovement,Paragrah(4.a.3)
and (4.b.7). No violations or deviations were identified, f
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8906220137 890607 PDR ADOCK 05000302
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REPORT DETAILS j
1.
Persons Contacted Licensee Employees
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- A. Auner, Nuclear Training Controls Supervisor I
- D. deMontfort, Nuclear Training
- W. Bandhauer, Nuclear Operations Superintendent R. Fuller, Senior Nuclear Licensing Engineer
- B. Hickle, Manager, Nuclear Plant Operations and Maintenance L. Kelley, Manager, Nuclear Operations Training q
- P. McKee, Director Nuclear Plant Operation
- W. Marshall, Nuclear Operations Superintendent
- W. Rossfeld, Manager, Nuclear Compliance j
J. Smith, Nuclear License Operator Training Supervisor i
- K. Vogel, Nuclear Operations Engineer i
R. Widell, Director Nuclear Operations Site Support (
- M. Williams, Nuclear Regulatory Specialist
- K. R. Wilson, Manager, Nuclear Licensing Other licensee employees contacted included engineers, technicians, operators and office personnel.
NRC llepresentatives
- P. Holmes-Ray, Senior Resident Inspector - NRC
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- P. Kellogg, Chief, Operations Program, RII
- Attended exit interview on May 19, 1989.
A list of abbreviations used in this report is contained in Appendix B.
J 2.
Status of the GTG and the PSTG l
Currently, Crystal River uses the B&W Owner's Group E0P Technical Bases Document as the GTG and the sum of the plant specific TBD, the CR3 AT0G
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and various procedure generation packages as its PSTG. The team agrees l
with the selection of the TBD as a GTG but considers the existing PSTG l
deficient, primarily as a result of its poor definition. The licensee embarked upon a corrective action program on March 21, 1989.
I The licensee has committed to implement an upgraded consolidated PSTG.
This report will identify this issue as IFI 302/89-10-01.
3.
Closeout of inspector follow-up items, (92701)
a.
(Closed)IFI 302/87-42-01: Provide emergency feedwater availability
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information in the Control Room.
Important information on availability of emergency feedwater was not
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available to the operator in the Control Room. The licensee revised
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VP-580, Plant safety verification procedure, to include this
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information. The team concurred with this revision. This item is
closed.
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b.
(Closed) IFI 302/87-42-02: Revise AP-530, Natural' circulation to-clarify that the PORV may already be closed..
Step 3.10 required closing the PORV when in fact, under many situations the PORV would already be closed. The_ licensee changed the procedure such that the the PORV is verified closed. The team concurred with.this change to the procedure. This item is closed.
c.
(Closed) IFI 302/87-42-03: Revise AP-380, Engineered safeguards actuation, to clarify applicability of step '3.40.
I Reduction of RCPs to one at a point in the procedure in which there were no pumps running created a logic problem. The licensee revised
the procedure. The team concurred with the' revised procedure. This-item is closed.
d.
(Closed) IFI 302/88-09-01: Resolution of' place keeping deficiencies.
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i This inspector follow-up item identified that operator usage of-i several different place keeping _ methods such as fingers, pieces of i
paper and removal from the book of the procedures was. indicative of a place keeping deficiency.
In response to the identification of this deficiency, the licensee stated that they would ' place permanent book markers in the Control'
Room E0Ps.
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The team verified that the book markers are in the E0Ps and found that the corrective action was_ adequate. This item is closed.
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(0 pen)IFI 302/88-09-02; Licensee's implementation of an E0P cross-reference document.
The licensee did not have a document which cross re'ferenced each of the procedure locations in which a given operator action setpoint was located. The licensee has committed to' implement such a document-by June 30,1989. This item remains open.
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f.
(Closed) IFI 302/88-09-03: Correction'of technical deficiencies contained in the E0Ps as outlined in Appendix B.
This single IFI covered 8 pages of deficiencies containing
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approximately 60 separate items.
In response to the identification of this deficiency, the licensee
provided their intended corrective actions in two'. letters' dated
August 11 and August 29, 1988.
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t The team reviewed each of.these 60 Appendix-B deficiencies, the
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licensee's intended corrective actions and the revised procedures.
With.the single exception of the hot'well level modification which-is awaiting parts and has been documented under a new IFI, all of these deficiencies were corrected and the corrective actions were found to be acceptable. The team was positively influenced by the timeliness and quality of this effort.
This item is. closed, i
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(Closed) IFI 302/88-09-04:
Correction of human factors
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discrepancies contained in E0Ps as outlined in Appendix C.
This IFI consisted of three pages containing about 26 items of discrepancies. The licensee addressed 25 of these items to the l
satisfaction of the team.
In the remaining case, the item had not reached its due date. This item is closed.
h.
(Closed)IFI 302/88 09-05:
Correction of labeling discrepancies between E0Ps and panel indications as outlined in Appendix D.
l This inspector follow-up item identified 6 pages of nomenclature differences between the E0Ps and plant equipment.
l The licensee responded to each of the separate line items covered by l
this IFI.
The team has reviewed the licensee response and the associated corrective actions and found that the responses and corrections were
acceptable. This item is closed.
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(Closed)IFI 302/88-09-06: Licensee needs to upgrade the V&V
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program E0Ps contained a large number of discrepancies indicating a need for table top reviews and walkthroughs to upgrade the V&V program. The
'j licensee applied further V&V to each of the procedures that were revised as a result of inspection 88-09. This additional V&V provided adequate assurance to the team of the improvement in the E0Ps. This item is closed.
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(Closed) IFI 302/88-09-07: Licensee will review S0TA training and
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upgrade if necessary.
SOTA training was in need of review to provide assurance that the SOTA*S E0P functions were receiving proper emphasis during their training cycle. The licensee reviewed the training of the S0TAs and, while they found training to be adequate, they never-the-less incorporated several enhancements. The team concurred with the licensee's enhancements. This item is closed.
k.
(Closed)IFI 302/88-09-08: Licensee needs to formalize the program for ongoing evaluation of the E0Ps (paragraph'8).
This inspector follow-up item identified the formal program for continuing evaluation of the E0Ps as deficient.
Paragraph 8 of the inspection report indicated the licensee had committed to develop a formal evaluation program.
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After the inspection report was issued, during a telephone exchange, the licensee and one member of the NRC team agreed that no committment had been made.
For that reason, although the licensee's formal response defined the existent program and inferred that.it'
was adequate, it did not address the, subject of a committment.
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The 88-09 team'found that the entire ~ family of E0Ps'had been revised-d about 4 months before the inspection. Although several hundredl internally generated comments on the new procedures had been received:
.by the inspection date, the licensee chose to defer action.on most of these comments until'after the E0P inspection. The 88-09 team also noted that the ongoing program had not= been through a complete time cycle with respect to the new procedures.
No biennial. simulator review had been conducted; only 50% of the annual crew E0P simulator
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training time had been performed; only.25% of the annual required. reading-program had been completed; and none of the operating crews had completed requalification training on the new E0Ps.
For these reasons, the 89-10: team concluded that the licensee was correct and that the existing program for ongoing maintenance of the E0Ps was adequate.
.This item is closed.
1.
(0 pen) IFI 302/88-09-09: Revalidatictn of the E0Ps when the.. plant specific simulat'or is operational (paragraph 8).
This inspector follow-up item identified the necessity to revalidate the E0Ps when the plant specific simulator.becomes operational.
The licensee had committed to re-evaluate the E0Ps on the plant.
specific simulator within one year from the date the simulator becomes operational.
The simulator has not been installed in the new simulator building.
This item remains open.
4.
Inspection report 88-09 also noted areas considered-to be weak. These i
areas will be referenced by their respective Appendix numbers and discussed
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as follows:
a.
Appendix B l
1)
AP-360, Loss of decay heat removal a)
Step 3.2; This step did not establish containment i
integrity. The licensee revised the procedure appropriately.
b)
Step 3.3; There was-no list of RCS isolations in AP-360.
The licensee reviewed the option of listing the isolations-but determined they were too numerous to be appropriate.
t On review, the team concurred with this determination.
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c)
Step 3.4; OTSG cooling was listed too early in the procedure. The licensee revised the procedure to put this step after the step containing the spent fuel pool cooling option. The team concurred with this action.
d)
Step 3.4; The details section included both filling and venting the RCS. The licensee revised this step to remove venting the RCS.
The team concurred.
e)
Step 3.7; This step directed the closure of two valves l
that were probably already closed.
In addition, it did not assure that a flow path was available for the LPI pumps. The licensee chose to assure the two valves
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i The team concurred with this approach.
f)
Step 3.9; The caution preceding this step was improperly placed. The licensee revised the procedure. The team concurred with the licensee revision.
g)
Step 3.9; The intent of this step was not clear. The logic provided by the licensee in their answer to the inspection report clarified the intent.
Further clarification in the procedural step is not necessary in the opinion of the team.
h)
Step 3.10; There was no caution prior to step 3.10 warning operators of the possibility of LPI pump cavitation.
The licensee incorporated an appropriate caution. The team concurred with the procedure revision.
2)
AP-380, Engineered safeguards actuation a)
The procedure did not provide verification of proper DHR operation prior to entering piggy back operation and of proper containment sump level prior to switching DHR suctions. The licensee added a check for MVP cavitation and a verification of sump level. The team accepted this response.
b)
There was a conflict between steps 3.14 and 3.29.
The licensee clarified the intent of the steps. The l
licensee stated the steps are intended to accomplish different objectives, and are correct as written. The team concurs with the steps as clarified.
c)
Step 3.10 contained a negative statement and was not consistent with the Writer's Guide. The licensee reworded the statement.
The team concurs with this procedure chang a
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Step 3.16; This step did not use the high point vents i
as a backup to the PORV. The licensee agreed that it j
should and revised the procedure.
e)
Step 3.18; There was not a note prior to this step i
establishing the prefererice for using RCP-1B to
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maximize pressurizer spray. The licensee added an action substep which accomplished the intent of.the
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note. The team accepted this response.
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Step 3.20 and 3.24 did not address the possibility of the j
pressurizer vents being opened in step 3.14 and therefore
needing to be closed.
The licensee agreed, and changed the procedure. The team concurred with the licensee's procedure change.
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g)
Step 3.30; Sampling the containment sump was performed too late in the procedure. The licensee agreed and revised the procedure. The team concurred with the i
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licensee's procedure change.
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Steps 3.33 and 3.34 were reversed. The licensee agreed ar.d revised the procedure. The team concurred with the
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revision.
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Step 3.34; This step did not ensure that the high point vents were closed. The licensee changed the procedure.
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The team concurred with the change.
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Step 3.35; There was no provision to deal with the possibility of insufficient cooltig as a result of action taken in step 3.34. The license.e referenced B&W i
TBD Chapter IV Section B Step 2. A.5.2 as justification for relying on LPI flow contrary to the NRC-
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recommendation. The teain reviewed the licensee's supporting document and concurred with their analysis, k)
Step 3.36; There was no step to deal with a containment pressure increase following the termination of spray.
The licensee agreed. The licensee added a substep to the procedure. The team accepted the licensee response.
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Step 3.37; This step was unclear. The licensee agreed and
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changed the procedure. The team concured with the licensee's procedure change.
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Step 3,39; TMs step conta%ed conflicting information.
The conflict was due to the licensee's definition of HPI cooling.which the licensee has now clarified. The team concurred with the rewrite.
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3)
AP-450, Emergency feedwater actuation At the time of the E0P inspection, the wide range hot well level system had been inoperative for "a long time". An engineering evaluation concluded that the level transmitters were not suitable for vacuum service application. Although no E0P revision was necessary, a system design modification was issued.
The job is in progress, awaiting parts. The licensee has committed to restore the wide range hot well level systems to operation.
Resolution of this commitment will be identified as IFI 302/89-10-02.
4)
AP-513, Toxic gas a)
Step 2.2; Ventilation damper position labeling was incorrect and the operators were uncertain of the meaning of an associated blue status light.
The licensee revised the procedure and resolved the labeling and status light problems incident to enhancements stemming from the Control Room design review. The team found the licensee's corrective actfans were adequate.
b)
Step 3.9; The recirculation damper control potentiometer labeling was inadequate. The pot was relabeled to indicate no flow and full flow positions. The licensee's corrective actions were reviewed by the team and found adequate.
5)
AP-525, Continuous control rod motion Step '.8; Two technical specifications were incort 9ctly related to safety and regulating rod index imits. The procedure was revised to remove the errs.
The team reviewed the change and found is acceptable.
6)
AP-53C, Natural circulation Step 3.24; This step referenced an incorrect enclosure. The procedure was revised to provide the necessary information in an included table.
The revision resolved this problem.
7)
AP-580, Reactor trip a)
Step 2.3; This step neglected the option of boration using HPI aligned from the BWST. The procedure was revised to offer three mode dependent boration options; the option for use in mode 6 is HPI from the BWST at 2700 or more gpm. The team found the corrective actions adequately addressed
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this problem.
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b)
Step 2.11; This step' incorrectly directed closure of the letdown block orifice bypass valve.
The licensee revised the procedure to borate per procedure EP-140. The team found the revision to be adequate.
8)
AP-660, Turbine trip Step 2.3; There was no requirement to trip the reactor following MSIV closure. The licensee revised the procedure to ensure the turbine throttle and governor valves were closed and if not to trip the turbine locally, noting that this was a preferred alternative to MSIV closure and reactor trip. The team concluded this was acceptable.
9)
AP-990, Shutdown from outside the Control Room a)
Calibration stickers were missing on particular meters at the RSP. The licensee verified that the instruments were in calibration and then installed the missing stickers. This item was resolved satisfactorily.
b)
Both pressurizer level meters at the RSP were uncompensated; the procedure did not note-this nor were the instruments so labeled. To eliminate the possibility for confusion, the instruments were labeled as uncompensated level meters and the procedure level range was specified as uncompensated values, resolving the problem satisfactorily.
c)
Step 3.6; The requirement for the RSP operator to isolate letdown was impossible since valve control had not been shifted to the RSP. The procedure revision addressed the problem by directing local closure of MUV-49.
Since, at this l
point in the procedure, the Control Room is still operational, although at a reduced capability, the team concluded that this revision was preferable to a premature total shift of control to the RSP.
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d)
Step 3.21; For the case where letdown flow could not be established, the procedure did not specify the method by which make-up flow was to be decreased. The procedure has been revised to close MUV-27, the make-up block valve. The change I
was evaluated as satisfactory.
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10) EP-140, Emergency reactivity control a)
Step 3.5; During the walkthrough, the 88-09 team noted that some uncertainty existed concerning how to determine whether the RB was occupied; a prerequisite to sounding the RB evacuation alarm.
The licensee responded that existing 0P-417 required the operators to maintain a log of any persons in the RB during modes 1-4 and noted that the RB should be presumed to be occupied during modes 5 & 6.
Although the 89-10 team concluded that the evacuation alarm could be sounded without a prerequisite determination that the building was occupied, they acknowledged that the existing i
procedural requirements were also acceptable. To I
evaluate the probability of a wide spread training
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deficiency, the team conducted a table top i
walkthrough of the procedure with a randomly selected licensed operator; the results were satisfactory.
b)
Step 3.6; This step did not close all RCS connections except those associated with boration, if in process, and then reopen them selectively to determine the source of the dilution. The procedure was revised accordingly and evaluated as acceptable by the team.
l 11) EP-290, Inadequate core cooling a)
Steps 3.8 & 3.9; The 88-09 team noted that references to clad temperature were unnecessary since the ICC region was determined as a function of incore thermocouple temperature and RCS pressure. The licensee revised the procedure accordingly. The revision was found to be adequate.
b)
Step 3.14; The 88-09 team recommended that RCP start permissive conditions be listed to be
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consistent with other procedures. The licensee l
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not included in other E0Ps nor were they required.
The 89-10 team found that each of the pump start permissive circuit requirements have indication lamps adjacent to the pump switch and a normal pump start would not occur unless all of the associated series contacts in the closing coil circuit were closed.
Dump start prerequisites other than those associated with the closing circuit logic, e.g. subcouling margin, were included in the E0Ps. The 89-10 team concluded that no change to this step was required.
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Step 3.15; The proce' dure was missing an important-caution on the facing:page.. The procedure was revised to accomplish 'thisiintent although instead
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of carrying the caution on the facing page, the requirements were specified in the applicable j
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step detail column. The team considered'this alternative acceptable. -
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Step 3.17; The~ procedure incorrectly stated the operators should perform EM-308, a chemistry procedure. The licensee has revised the step to-require the operators to notify chemistry:to
. monitor RB H2 level referring to EM-308. ' The team found the revision acceptable.-
e)
Step 3.18; The 88-09' team recommended that the order of the guidance be modified since the best indication was the last one indicated in the. step.-
The licensee revised the order in which the
. alternatives were listed. This resolution was-considered ' satisfactory. :
~12) EP-390, Steam generator tube leakL a)
Noting that several steps in the procedure
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d required monitoring and maintaining parameters based'
upon plant conditions-contained in enclosures or tables, the team recommended that when a reference l
to those parameters was made, the table.or' enclosure be annotated within the step. 'The licensee has:
incorporated the recommendation in_the revised
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procedure.
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Step 3.7; This step did not. require.that MUV-24
be opened first to minimize thermal shock. The i
procedure was revised' appropriately..The team-i found the revision acceptable..
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c)
Step 3.19; The wording was confusing. The licensee
'l has clarified the procedure satisfactorily.
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d)
Step 3.19; The procedure required the operators to refer toienclosure 1 of AP-530, a single page.-
i The 88-09 team recommended that.that page be'added to EP-390 to' reduce the number of procedures in use concurrently. The licensee rejected the recommendation as contrary to policy concerning i.
concurrent procedure use vs replication of
.information. Although the recommendation has merit, the_89-10 team accepted the licensee's decision not'
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to adopt this recommendation.
e)
Step _ 3.36; Confusion existed concerning the 0STG steaming rate. The procedure.has been revise'd to specify steaming rate parameters. <The team:
found the revision acceptable.
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f)
Step 3.36; The procedure did not include a warning that the steam leak could cause: instrument errors.
A note has been added to the procedure to address
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this issue. The revision is acceptable.
13) VP-540, Runback verification procedure-a)
The procedure detail in step 1.3 referenced STS 3.3.1.1 which was not applicable. The licensee removed the reference from the procedure. The team accepted the procedural change.
b)
Step 2.2 reference to STS 3.3.1.1 was not clear.
The licensee disagreed with the item. As an alternate, the licensee clarified the information given in Computer Group 59 and the usage of SP-312.
The team reviewed the licensee response and concurred.
c)
Step 3.1; This step erroneously directed the l
i observation of radiation monitors instead of radiation monitor recorders. The licensee agreed and changed the procedure. The team concurred with the licensee's procedure change.
d)
Step 4.2; This step erroneously referred to AI-500 s tep 2.4.
The licensee agreed and changed the I
procedure by removing the reference to step 2.4.
The team acknowledged the procedure change.
14) VP-580, Plant safety verification procedure a)
The procedure lacked a specific termination or
exit criteria in the procedure. The licensee l
disagreed with the implied recommendation. The
_l licensee preferred to maintain termination of the VP as a management decision. The team reviewed the procedure and the licensee's position and agrees.
b)
Step 1.7; The use of the inequality sign and operatcr instructions for a STGR were inaccurate.
The lice. see agreed and changed the procedure.
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Step 2.8; The wording of the last bullet in the detail section was poor. The licensee changed the procedure. The team agreed with the
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licensee's procedure change.
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Step 2.11; This step did not specify frequency and duration of plotting temperature and pressure following loss of the three automatic plotting systems. The licensee argued that this is best lef t to management discretion. After the discussion with the licensee the team accepted their response.
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'e)
-Step 3.5; This_ step was.not properly a-S0TA function. The-licensee deleted the step from the procedure. The team agrees with the licensee's change.-
f)
Step 4.3; The hotwell level instrument read in inches and the E0P referenced feet. The-licensee changed the procedure to list both feet and inches. The. team concurs-with the licensee's procedure change.
g)
Page 9; The quality of the figure was poor. The. licensee changed the figure.
The team finds the new figure acceptable.
b.
Appendix C 1)
AP-380. Engineered safeguards actuation a)
Step 3.15; This step was not specific in its' references to-AP-530. The licnesee's revision removed the need for simultaneous use. The team concurs with the licensee.
b)
Step 3.19; This step was.poorly worded. The. licensee revised-'
this step. The team found the revised wording to clearly state the intent.
c)
Similar actions were not stated similarly. The licensee revised these steps as necessary The team concurred.with the revision.
d)
Step 3.21;_ This step was lacking in specificity. The step has J
been revised to show the exact table being referenced. The team agreed with the revision.
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2)
AP-450, Emergency feedwater actuation a)
Step 3.8; The step sequence was'.. incorrect. The' procedure has been revised.
The revision was acceptable.
b)
Step 3.12; An incorrect reference was listed. The procedure was revised. The revision was acceptable.
c)
. Step 3.14; This' step appeared to-contain two logically separate steps; a conflict with the Writer's Guide. The licensee's written response disagreed. The response was-
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reviewed and the_ item was discussed with the licensee's staff.
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The team concluded that the licensee was correct;'no. procedure I
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change was required.
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AP-460, Steam generator isolation actuation
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Step 3.6; This step appeared to contain two separate actions; an inconsistency with the Writer's Guide. -The licensee disagreed. The team reviewed-the problem and concurred that no change was required.
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b)
The 88-09 team noted that-the E0Ps' and the!RSP.used the tenn OTSG while the main'contro1~ boards used Steam Generator (STM GEN). The licensee disagreed with the team's concern. The-89-10 team concluded that both terms were readily recognized as-interchangeable'within the B&W segment of the industry and agreed with the licensee's decision -to not revise.the step.
c)
Step 3.19; A. valve location was incorrectly specified. The
. step was revised. The team found the revised step' acceptable..
d)
Step 3.27;- Feed rate was not. specified,; The. step was revised.
to provide feed rate control' parameter boundary information.
The revision was acceptable.
4)
AP-513, Toxic gas Step 3.12; The air. handling unit referred to in.this' step was inappropriately designated AH-35-FR rather than AH-32-FR..
The licensee revised the procedure.tolinclude the correct'-
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designation. The team concurred.
5)
AP-530, Natural circulation a)
The logic word was not capitalized and underlined when reproduced on the facing page. The licensee changed the procedure. The team concurred with the licensee procedure change, b)
Enclosure 1, 2,and-3 were of poor quality. The. licensee -
improved the quality of the enclosures. The team accepted the new enclosures.
'6)
AP-990, Shutdown from outside the control' room a)
An indicating lamp cover was missing and a'nother was incorrectly color coded. The' team inspected the RSP and found that both deficiencies had been corrected.
b)
Steam tables were not available at the RSP. The team verified that they were present at 'the RSP.
7)
AP-1076, Violent weather Four specific comments denoting omissions and errors were pointed out. The licensee. agreed and committed to revise the procedure by 6-30-89 into the format of an emergencyr plan procedure.-
Satisfaction of this commitment will be identified as IFI 302/89-10-03..
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8)
EP-290, Inadequate core cooling The caution prior to step 3.8 needed clarification. The licensee reworded the caution. The team concurs with the licensee's rewording.
9)
General comment resolution a)
The procedures contained labeling inconsistencies. These were listed in Appendix D and individually addressed by the licensee. The team's analysis of the licensee's response is addressed in paragraph 4.c b)
The concern was the number of copies of the EPs, APs and VPs in the Control Room.
The licensee placed an additional set of procedures in the Control Room. The team found the licensee's response to be adequate, c)
There were apparent inconsistencies in procedural steps.
The licensee reviewed the procedures for inconsistencies and made corrections where necessary. The team accepted the licensee's response.
d)
Some procedure references were inappropriately abstract indicating a need for the licensee to ieview the E0Ps to identify and eliminate these inadequacies. The licensee performed the review and made changes as necessary.
The team concurred with the action taken.
e)
Some graphs and figures were unclear. The licensee identified and corrected the discrepancies as appropriate. The team concurred with these corrections.
c.
Appendix D The procedures reviewed during inspection 88-09 contained a large number of labeling inconsistencies. The licensee considered each individually and either corrected the discrepancy, took an alternate course of action or explained why it should not be corrected. The team reviewed the licensee's response, both written and to the control board, and found the response acceptabl '
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5.
Exit Interview The inspection scope and findings were summarized on May 19, 1989, with-
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those persons indicated in paragraph 1.
The inspectors described the areas inspected and discussed in detail the inspection findings listed below. Although proprietary material was reviewed during this inspection, no proprietary material is contained in this report. No dissenting comments were received from the licensee.
Item Number Status Description / Reference Paragraph
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IFI 302/89-10-01 Open Develop upgraded consolidated PSTG (paragraph 2)
IFI 302/89-10-02 Open Restore hot well level system to operation (paragraph 4.a.3)
IFI 302/89-10-03 Open Revise AP-1075 by 6-30-89 (paragraph 4.b.7)
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i APPENDIX A l
l E0P LIST OF EMERGENCY OPERATING PROCEDURES AP-360 Loss of decay heat removal, Revision 2 AP-380 Engineered safeguards actuation, Revision 10
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i AP-450 Emergency feedwater actuation, Revision 11 AP-460 Steam generator isolation actuation, Revision 7 AP-513 Toxic gas, Revision 5 j
l AP-525 Continuous control rod motion, Revision 1 AP-530 Natural circulation, Revision 7 l
I AP-580 Reactor trip, Revision 10
AP-660 Turbine trip, Revision 6 AP-990 Shutdown from outside control room, Revision 3
AP-1076 Violent weather, Revision 10 I
EP-140 Emergency reactivity control, Revision 5 EP-290 Inadequate core cooling, Revision 7 EP-390 Steam generator tube leak, Revision 8 VP-540 Runback verification procedure, Revision 2
I VP-580 Plant safety verification procedure, Revision 9 l
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l APPENDIX B
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LIST OF ABBREVIATIONS
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l AP Abnormal procedure AT0G Abnormal transient operating guideline
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'd BWST Borated water storage tank DHR Decay heat removal EP Emergency procedure E0P Emergency operating procedure J
EP Engineered safeguards l
GTG Generic technical guidelines HPI High pressure injection
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H2 Hydrogen ICC Inadequate core cooling LPI Low pressure injection MSIV Main steam isolation valve NQAS Nuclear quality assurance surveillance MVP Makeup pump OP Operating procedure OTSG Once through steam generator PSTG Plant specific technical guidelines RB Reactor building RCP Reactor coolant pump RCS Reactor coolant system RSP Remote shutdown panel SGTR Steam generator tube rupture S0TA Shift operations technical advisor STS Standardized technical specifications S/G Steam generator TBD Technical bases document j
V&V Validation and verification VP Verification procedure I
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