IR 05000309/1989081
| ML19325E616 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 10/25/1989 |
| From: | Eselgroth P, Norris B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19325E613 | List: |
| References | |
| 50-309-89-81, NUDOCS 8911080121 | |
| Download: ML19325E616 (33) | |
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1 U. S. NUCLEAR REGULATORY COMMISSION
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' INSPECTION REPORT-
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FACILITY'0OCKET NO.
50-309 (
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INSPECTION REPORT NO.
50-309/89-81 j
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FACILITY LICENSE NO.
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LICENSEE:
Maine Yankee Atomic Power Company
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b 83 Edison Drive g'
Augusta, Maine 04336
. h FACILITY:
Maine Yankee Atomic Power Company Bailey Point Ferry Road i<
Wiscassett, Maine 04578 t
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INSPECTION DATES:
July 17 - 28,1989 i
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INSPECTION TEAM:
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Team Leader:
B. S. Norris, Senior Operations Engineer, NRC
Team Members:
L. J. Defferding, Systems Engineer, PNL i
R. J. Freudenberger, Resident Inspector, Maine Yankee G. S. Galletti, Human Factor Specialist, NRC
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C. M. Meeker. Systems Engineer, COMEX D. T. Moy, Reactor Inspector, NRC
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A. B. Sutthoff, Human Factor Specialist, SAIC R. D. Warner, Licensing Examiner, PNL A.
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.3*:', lab [Y:Barry S. Norris Date
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Senior Operatio Engineer, PWR Section o
26dcf 77 APPROVED BY:
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Peter W. Eselgroth(/ Chief Date PWR Section, OperMions Branch Division of Reactor Safety
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8911080121 891027 PDR ADOCK 05000309 l
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. TABLE OF CONTENTS i
Section Page
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l1.0 E x e c u t i v e S u mm e ry................................................
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2.0 Use of Emergency Procedures as Guidelines v i c e P ro c ed u re s..................................................
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L 3.0 Basic Comparison of Owners' Group ERG
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I with Facility E0Ps...............................................
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4.0 Independent Technical Adequacy Review of
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the Emergency Procedures.........................................
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5.0' Review of the Emergency Procedures by Control Room.and Plant Walkdowns.................................
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6. 0 ' Simul a to r Obse rva ti on...........................................
7.0 On-Going Evaluation of the Emergency Procedures.................. Il
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8. 0 ' EO P U s e r I n t e rv i ew s.............................................
9.0 Ma n a g e m e n t Me e t i n g s.............................................
10.0; Personnel Contacted.............................................
i Attachments i
Do c ume n t s Re v i ewed..............................................
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De fi ci enci e s Iden ti fi ed.........................................
3 Abbre v i a ti o n s & Ac ro nym s........................................
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List of Weaknesses Icentified as Needing Correction.............
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DETAILS
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1.0 EXECUTIVE SUMMARY
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1.1' A special, announced team inspection was conducted of the Maine
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Yankee emergency procedures.
The purpose of the inspection was to l
dete*mine if the emergency procedures used at Maino Yankee were
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I technically correct; that their specified actions could be physically accomplished using the existing equipment, controls and instrumenta-tion; and that the available procedures had the usability necessary to provide the operators with an effective operating tool.
For this c
inspection, the term emergency procedures included the E0Ps, FRPs, A0Ps, and procedures referen:ed within the E0Ps, FRPs, and A0Ps. The inspection included reviewing over 100 documents, observing two operating crews in the simulator, and interviewing 14 facility
personnel.
No violations or deviations were identified as a result of this inspection. One concern was identified as significant; the direction and training given to the operators with respect to how the emergency procedures were to be utilized and implemented was that the emergency procedures were a guidance document and that verbatim compliance was
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not required. Generic concerns identified during the inspection are discussed within the body of the inspection report; those concerns that are specific to an individual procedure are enumerated in Attachment 2.
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The overall assessment of the. emergency procedures in place at Maine
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Yankee at the time of the inspection is that the procedures are generally well written and that the operators should be able to utilize the procedures to mitigate an accident. At the exit meeting on July 28,.1989, NRC management stated that the Maine Yankee program for emergency procedures was very good and he would place the program in the upper 15% of the programs looked at to date.
It was further recommended that the Maine Yankee program be used as an example of a L
well developed program that has been well implemented.
1.2 During the inspection, one of the team members noted that some industrial gas cylinders on site were out of date with respect to proper hydrostatic pressure testing (49CFR173.34). This was a personnel safety concern and potentially a plant safety concern.
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E The facility took prompt action to remove the initially identified cylinders from the site, and performed a thorough search to identify and remove all other out of date cylinders.
The facility has agreed j
to develop a program to address the storage of industrial gases.
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This item is considered closed.
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2.0 USE OF EMERGENCY PROCEDURES AS GUIDELINES VICE PROCEDURES
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During the inspection, it was noted that the Maine Yankee AOPs and E0Ps
were not to be considered verbatim compliance documents but were intended (
to be a guide (procedure 1-200-10, Conduct of Operations). This policy does not support the concept that procedures should be developed such that the operators can implement them as written and that any changes to the procedures should be via a formal process as described in the licensee's Tech '
nical Specifications.
10 CFR 50, Appendix B, Criterion V, states, in part, that " Activities affecting quality shall be prescribed by documented instructions or procedures,... and shall be accomplished in accordance with these instructions or procedures..."
r During discussions, it was determined that the facility management agreed that procedures should be implemented as written, when possible.
The licensee agreed to submit a plan for changing the policy for imple-mentation of the emergency procedures. Tne plan is to contain the speci-fics of how the change will be made, and a schedule of when the change will.be implemented, including training on the change.
The weaknesses identified in paragraph 2.0 will be tracked as Item No.
50-309/89-81-01.
3.0 BASIC COM?ARISON OF OWNERS' GROUP ERGS WITH FACILITY'S E0Ps PURPOSE: To ensure that the licensee had developed sufficient procedures in the appropriate areas to cover the broad spectrum of acci-dents and equipment failures.
3.1 The list of Maine Yankee E0Ps was compared to the Westinghouse Own-ers' Group (WOG) list of Emergency Response Guidelines (ERGS), Revi-sion 1 of the High Pressure Version,.to ensure that the licensee had developed procedures in accordance with the WOG recommendations.
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l facility was in the process of revising the current E0Ps to be consistent with Revision IA of the WOG ERGS.
3.2 It was noted that six of the ERGS were not listed in the table of contents for the Maine Yankee E0Ps, specifically:
l ES -3.2 Post-SGTR Cooldown Using Blowdown
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L ECA-1.1 Loss of Emergency Coolant Recirculation l
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{p ECA-2,1 Uncontrolled Depressurization of All Steam Generator s ECA-3.1 SGTR with Loss of Reactor Coolant - Subcooled
' Recovery Desired ECA-3.2 SGTR with Loss of Reactor Coolant - Saturated Recovery Desired
'ECA-3.3 SGTR without Pressurizer Pressure Control To determine the acceptability of not including the above recommended guidelines, the team reviewed the Maine Yankee justification and background documents supporting the exclusion of the above six ERGS,
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and discussions were held with facility personnel responsible for development of the E0Ps.
In all cases, the justification was adequ-ate, but the documentation supportir.g the justification was not always complete.
The licensee revised the documentation before the end of the inspec-tion to fully explain the justification.
This item is considered closed.
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4.0 INDEPENDENT TECHNICAL ADEQUACY REVIEW 0F THE EMERGENCY PROCEDURES
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PURPOSE:
Review the emergency procedures to assure that procedures are i
technically adequate and accurately incorporate the guidelines of the ERGS.
4.1 The Maine Yankee E0Ps were reviewed to ensure that the procedures were technically adequate and accurat01y incoroorated the guidelines of the WOG ERGS.
Each deviation from the ERGS was reviewed to ensure that:
(1) all deviations were warranted by the plant specific design i
(2) safety significant deviations were reported to the NRC as required,
(3) and prioritization of accident mitigation strategies was correct.
Except as noted below, the E0Ps were technically adequate and accurately incorporated the procedural guidance of the ERGS, 4.2 During the course of the inspection, the team identified the follow-ing concerns:
a.
The setpoints listed in the E0Ps are the same as those listed
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in the Technical Specifications. The initial concern of the I
team was: if an operator waited until the value listed in the procedure was reached before taking manual action, the specific TS limit may be exceeded prior to completion of corrective actions, i
A facility representative responded that the instrument in-accuracies had been taken into account when determining the TS value. And that the Instrumentation & Control (I&C) procedures
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Inspection Report No. 50-309/89-81
required the setpoint of the instrument to be conservative. The
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team reviewed several safeguards setpoints.
In all cases I&C b
procedures used a setpoint more conservative than the Technical Specification limit.
This concern' had been previously identified by an NRC Safety System' Functional Inspection (SSFI) team (see Inspection Report No. 50-309/89-80, paragraphs 3.3.1 through 3.3.4) and is being tracked under that inspection report.
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During the interviews and plant walkdowns, some of the operators
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stated that the use of ECA-0.0 (Loss of All AC Power) was confu-
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sing. Maine Yankee procedure ECA-0.0 directs a transition to AOP 2-90-1, (Plant Shutdown Plan for Fire in Control Room,...
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and/or Station Blackout) prior to the plant being in a stable condition. A transition from the E0Ps (a higher tier procedure)
to a lower tier procedure before the plant is in a stable condi-tion is not consistent with the WOG guidelines for usage of the E0Ps. However, it is reasonable to initiate concurrent actions, such as manually starting an emergency diesel generator, to mitigate the event while remaining in the E0P.
To determine if there was a need for improvement in the logic in the procedure, a scenario was developed and run on the simulator by two different operating crews.
The expected actions sequence did not occur with the first crew, the second crew mitigated the event by means other than strictly following the procedure.
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This lack of consistency substantiated the difficulties described by the operators with executing ECA-0.0.
The facility has agreed to review the transitions within ECA-0.0 and clarify the hierarchy of the various operating procedures.
The weakness identified in paragraph 4.2.b will be tracked as Item No. 50-309/89-81-02.
c.
The effects of harsh containment on the steam generator and pressurizer level indications were verified to be addressed in the E0Ps. The definition of what constitutes harsh containment was clearly defined within the background documents; however, the definition was not defined within the E0Ps themselves.
Some operators correctly stated that high containment radiation and high containment pressure were the parameters monitored; other operators incorrectly stated that the parameters were high containment radiation and high containment temperature.
The facility has agreed to clarifying the definition of harsh containment and to train the operators.
This item is considered closed.
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The concept of harsh environment needs to be considered for the effects on other qualified equipment outside of the containment
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These instruments could be subject to i
a harsh environment during a steam line break inside of the l
tornado proof building.
L The licensee agreed with the above concern and has committed to developing harsh environment values for the steam generator k'
pressure transmitters.
The licensee has discussed this issue with the WOG, and the WOG is considering making this a generic L
issue.
The weakness identified in paragraph 4.2.d will be tracked as Item No. 50-309/89-81-03, i
e.
The Technical Data Book (TDB) is a compilation of approved graphs and charts, used by the engineering and operations staffs. The readability of some of the material in the control
room copy of the TDB was poor. The poor readability appeared
to be due to a lack of attention during the reproduction of the
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material; i.e., copies were r.ot made from the original document, and care was not taken during the reproduction to ensure that the copy was legible and complete. The readability of the simu-lator copy of the TDB was worse than that of the control room
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copy.
The facility has agreed to review the condition of the TDB and
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ensure that all pages are complete and legible.
This item is considered closed.
5.0 REVIEW OF THE EMERGENCY PROCEDURES BY CONTROL ROOM AND PLANT WALK 00WNS PURp0SE: To assure that the emergency procedures can be successfully accomplished.
5.1 Licensed and non-licensed operators were utilized to walkdown the procedures listed in Attachment 1.
The walkdowns were conducted in the control room and in the plant to ensure that:
(1) actions
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required by tne procedure could be accomplished using the installed I
equipment, instrumentation and controls; and (2) procedural guidance l'.
was clear and detailed enough such that operator confusion and error would be avoided.
I No instances were identified where the step could not be performed I
using the installed equipment, instrumentation and controls.
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as detailed in paragraph 5.2, the procedures were clear and provided I
sufficient detail for the operator to complete the step.
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5.2. During the reviews and walkdowns of the procedures, deficiencies were identified and discussed with the licensee prior to the exit meeting.
The licensee acknowledged and committed to correction of the identi-fied deficiencies.. In many cases, the licensee had already identi-fied the deficiency and corrective action had been started. Defici-encies considered to be generic procedural weaknesses are listed i
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Cautions and notes contain action steps, which is contrary to the guidance contained in the writer's guide.
b.
Several procedural steps contained double negatives.
c.
Several steps were repeated within a procedure unnecessarily.
Those deficiencies identified within specific procedures that were not covered by the generic weaknesses identified above are listed in Attachment 2 of this report.
The weaknesses identified in paragraph 5.2 and those identified in Attachment 2 will be tracked as Item No. 50-309/89-81-04.
5.3 Although not specific to procedures, the team considered labeling and operator aids to be generic weaknesses, a.
The labeling in the control room and in plant is rot always consistent with the terminology used in the procedure. Addi-tionally, labels are not always complete; i.e., the label will not include either the component number or the component name.
b.
The use of operator aids in the control room and in plant is an effective tool to be provided to the operators. However, the aids need to be carefully controlled to ensure that only approved aids are used and that information posted as an aid is current. Many examples were identified by the inspectors of operator aids that were not being controlled by the existing program.
Specific examples included:
(1) Magnetic labels used in the control room (and simulator) to indicate where the spare
charging pump is aligned and which service water header is iso-I lated; (2) in the PAB, detailed instructions for operation of
the auxiliary charging pump were posted but no control or appro-
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val stamp was affixed.
The weaknesses identified in paragraph 5.3 will be tracked as Item No. 50-309/89-81-05.
5.4 The Alarm Response Procedures are not stand alor,e documents, but are entered via various AOPs ( AOPs 2-36, 2-37, 2-38, and 2-39).
These AOPL contain the generic objective, discussion, and precautions asso-ciated with a certain set of ARPs; this is followed by a single I
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procedural step which directs the operator to refer to the specific-ARP for further action. The ARPs contain the operator actions
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required for response to each individual alarm.
During the inspection, it was noted that the method for use of the ARPs was not consistently applied by operators.
The operators were not clear as to which set of procedures were the guiding documents.
E It is apparent that corrective action on the use of the ARPs and the AOP3 is needed to ensure a consistent determination by tha operators
of which procedures to use.
The weakness identified in paragraph 5.4 will be tracked as Item ia No. 50-309/89-81-06, 6.0 SIMULATOR OBSERVATION
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PURPOSE:
To assure that emergency procedure training provided the operators with the necessary information background and to ensure that the emergency. procedures can be correctly imple-mented under emergency conditions.
6.1 Utilizing the site specific simulator, the team assessed the adequacy of the training on the emergency procedures by observing the actions
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of two crews of licensed operators during unreheersed scenarios designed to exercise the crews familiarity with and ability to uti-li e the emergency procedures, t
The scenarios were developed with the intent of providing the team with an opportunity to; a.
Observe the crews' performance to validate or resolve concerns resulting from the review of the emergency procedures, 1-b.
Assess the licensee's operating philosophy with respect to the emergency procedures, especially where initial reviews identi-fied differences from the Emergency Response Guidelines, c.
Assess the human factors elements associated with the perform-ance of the procedures in a "real time" situation, and d.
Assess the operating crews' diagnosis of accident conditions and transitions from one E0P to another E0P (or AOP).
L 6.2 The scenario sets consisted of:
l First Crew
i Scenario 1:
Loss of condenser vacuum / inadvertent safety injection (Use of A0P 2-2 and E0P E-0)
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Scenario 2:
Fire in emergency diesel generator room (resulting in
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a minimum TS crew remaining in the control' room)
followed by a loss of all AC power.
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(Use of A0Ps 2-90-0, 2-90-1 and E0P ECA-0.0)
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Steam generator tube rupture concurrent with a steam line break.
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Scenario 4:
Feedline break inside containment.
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Second Crew:
Scenario 1:
Plant trip on loss of both heater drain tank pumps with an (ATWS).
(Use of E0Ps E-0 and FR-S.1)
Scenario 2:
Loss of instrument air resulting in a plant trip.
(AOP 2-28 and E0P E-0)
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Scenario 3:
Loss of all AC power.
(Use of E0Ps ECA-0.0, ES-0.1 and A0P 2-90-1)
Scenario 4:
Fire in emergency diesel generator room (resulting in a minimum TS crew remaining in the control room)
followed by a steam generator tube rupture concurrent with a steam line break.
(Use of AOPs 2-10, 2-25 and E0Ps E-2, E-3)
Scenario 5:
Failure of the plant computer prior to a plcr,t trip with a loss of all feedwater.
(Use of E0Ps E-0, ES-0.1 and FR-H.1)
6.3 Observations:
a.
Both crews observed were capable of utilizing the procedures to mitigate the accidents. When required, there was no hesitancy to enter the Function Restoration Procedures.
b.
One scenario with each crew began with a fire in the plant which required the response of the fire brigade.
The SOS is the fire L
brigade leader and the ACR0 is a fire brigade member. This
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resulted in the minimum TS crew (consisting of the PSS, CR0 and
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NSE) in the control room.
Both crews were able to appropriately implement the procedures restoring the plant to a stable condi-tion.
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c.
The team noted that there were variations among the crews with respect to the methodology used when implementing the AOPs concurrently with the E0Ps. During some scenarios, the concurr-ent implementation of AOPs and E0Ps resulted in the PSS and the
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SOS simultaneoutl:/ providing direction to the control board operators.
From discussions with the crew members, it was determined that the policy is dependent on the preference of the PSS. The team stated that a consistent policy of how the AOPs and E0Ps should be implemented concurrently appeared necessary to prevent simultaneous direction being given by two supervisory individuals to one operator.
The licensee agreed to evaluate the circumstances which resulted in the above condition of concurrent E0P and A0P activities and implement appropriate actions.
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The weakness identified in paragraph 6.3.c will be tracked as Item No. 50-309/89-81-07.
d.
The team observed that a rail in front on the electric panel (installed to prevent inadvertent contact with the controls)
blocked the operators view of some of the indicators.
The rail had been reviewed for human factor considerations prior to its installation.
The facility agreed to re evaluate the design and placement of the rail.
No further NRC followup is required.
e.
When an E0P was revised, the required operator training had been determined by the ATM00.
Per discussions with the Training Manager, it was determined that formal criteria had not been utilized to determine when the training should be accomplished (i.e., before the change is issued, af ter it is issued, or is training required at all) and the environment in which the training would be most appropriate (i.e., classroom, simulator, read and sign while on shift). However, criteria had recently been established in a joint effort between the Operations and Training Departments.
The licensee agreed to including the criteria in an operations department procedure to ensure consistent implementation.
The weakness identified in paragraph 6.3.e will be tracked as Item No. 50-309/89-81-08, i
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The Maine Yankee simulator was the first simulator in the country to be certified in accordance with NRC regulations c
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g (specifically 10 CFR 55.45(b)(iii). As part of the certifica-
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tion process, the facility established annual simulator fidelity evaluations.
During the inspection, the team identified several
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differences between the' simulator and the control room.
No significant differences were identified by the team which had not been previously documented in the licensee's simulator fidelity evaluation.
The licensee's annual simulator fidelity evaluation included (1)
a survey of the operations department personnel and (2) a report
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which outlined the approved differences in the simulator.
The annual evaluation should be a valuable aid in enhancing the use-fulness of the simulator as an operator training tool.
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7.0 ON-GOING EVALUATION OF THE EMERGENCY PROCEDURES PURPOSE: Determine if the licensee has established a long term evaluation program for the emergancy procedures as recommended in Section 6.2.3 of NUREG-0899.
7.1 A review of the Maine Yankee system of on going' evaluation and revi-sion of E0Ps was conducted to assess whether the licensee's current system could ensure high quality E0Ps over time. The system was evaluated on the basis of a number of elements, including but not
. limited to:
a.
the completeness of a method for ensuring that changes in plant design, technical specifications, technical guidelines, the writer's guide, referenced plant procedures, and the control room are promptly reflected in the E0Ps; b.
completeness of a method for revising the E0Ps to reflect find-ings from operational experience and use, training experience, simulator exercises, and control room and plant walkdowns; c.
the timeliness of revisions to the E0Ps when incorrect or incomplete information is identified; d.
the adequacy of the system for determining necessary training, validation, and verification, when procedures are changed or revised; e.
the adequacy of basis documents, including technical guidelines and writer's guide; f.
the adequacy of verification and validation; and g.
the effectiveness of a system of soliciting and utilizing feedback from procedure users and other cognizant personnel.
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The team determined that most aspects of the Maine Yankee system were well done.
Specifically, the use of a combined writer's guide for
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all operating procedures, the development of an E0P Steering Committ-ee.to address necessary E0P revisions and the inclusion of Training Department representation on that committee. However, several impor-tant components of on going E0P maintenance were considered defici-
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ent, with a potential for degradation of E0P quality and integrity over time.
These areas of concern are detailed in the following paragraphs.
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7.2 Writer's Guide:
Because of the important information contained in cautions, it is particularly important that they be emphasized in a way_that attracts operator attention and distinguishes cautions from procedural steps and notes.
The Maine Yankee writer's guide does not define a method of emphasis for cautions that clearly distinguishes them from the a
less significant information contained in notes.
In addition, the
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Maine Yankee writer's guide does not address any aspect of flowchart-l
' format, although this'fotmat is used within the E0P set.
The facility agreed to review the writer's guide based on the comments of the inspection team and to revise the writer's guide, as appropriate.
The weaknesses identified in paragraph 7.2 will be tracked as Item
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No. 50-309/89-81-09.
7.3 Changes to the Procedures:
In. order to assure that revisions to the procedures are appropriate, accurate, and consistent, the system for changing procedures is expected to be complete and consistent.
The system used by Maine Yankee for revising E0Ps has three weaknesses which may reduce the quality of the E0Ps over time.
a.
Two programmatic defects contribute to scattered responsibility for the E0Ps and eliminate a central control source for any
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E0P.
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(1) While individual crews are assigned responsibility for a subset of the E0Ps, this responsibility extends only to the biennial review process and some of the changes initiated by the operations department; changes may be incorporated without the assigned crew being involved. Therefore, the attempt to control procedures by crew assignments does not address all aspects of procedure changes.
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(2) The operations department holds many of the recommended
changes until the next revision of.a specific procedure is
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being processed. Because the E0P coordinator is not always made aware of these changes, the effectiveness of the E0P
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coordinator is reduced.
b.
Two programmatic faults lead to discouragement of operator-
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input on E0P changes and improvement.
(1) Individuals who want to initiate a change to the E0Ps are required to provide a rewrite of the step (s) they wish to change, as well as complete all research on technical and format implications of the change.
This burden on the initiator of a change greatly discourages operators from-r
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suggesting improvements to the procedures, thereby depriving the E00 change process of certain recommendations based'on operational experience.
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(2) When an individual suggests a change to an E0P, no acknowledg-ment of the acceptance or rejection of the change is provided.
l This lack of response with respect to the resolution of proposed changes also discourages operator input.
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c.
No method exists for easy re-issuance of E0P pages with typo-graphical error corrections or minor format revisions. This
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results in errors in the E0Ps in use that are not revised for a long period of time.
E0Ps containing such errors suggest a lack of concern over the quality of the procedures that could lead to
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less confidence in overall E0P integrity by operators.
Currently, revision of E0Ps due to changes in procedures refer-enced by or referencing the E0Ps, changes in plant labeling, or
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revision of standard steps is dependent upon the memory of the E0P coordinator. No system of tracking cross-references exists
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to assure that these changes are promptly and accurately
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reflected in the E0Ps, increasing the likelihood that the proce-dures will degrade in accuracy over time.
'
The weaknesses identified in paragraph 7.3 will be tracked as Item No. 50-309/89-81-10, 7.4 Verification and Validation Program:
A thorough and complete verification and validation of new proce-dures, and changes to those procedures, will ensure that:
(1)
adherence to the basis documents (i.e., the technical guidelines and L
the writer's guide) is maintained; (2) the language and level of information is appropriate for the user; (3) there is a correspond-ence between the procedures and the plant hardware; and (4) the procedures will function as intended.
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While it appeared that the procedures functioned as intended i
c (i.e, validated), this review of the Maine Yankee E0Ps indicated
.
that not all of the above objectives had been met (i.e. verified).
'
Indications of weaknesses in the verification program are: (1)
the writer's guide defines "go to" and " refer to" as the terms to be used for transitions and references to procedures; in a
number of the procedures, "per" was used to indicate' references; (2) throughout the procedures, cautions and notes contain y
action steps, in contrast to writer's guide direction that no L
actions were to be included in cautions and notes; and (3)
numerous instances of differences between the procedures and.the
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f plant labeling,
,
To ensure that all aspects of the writer's guide, including
!
those items identified above, are reflected in the final product, a mechanism is needed to guide the verification
,
process, such as a detailed checklist of writer's guide items.
To assure that the procedures accurately reflect plant nomen-clature, verification must include in plant walkdowns of the procedures. Maine Yankee lacks both~of these elements in their verification program.
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Decisions about necessary reverification and revalidation are made by a committee composed of engineering and operations representatives.
The absence of committee membership by the training department as a source of expertise on observed operator use of the procedures may deprive this part of the process of valuable input.
-
The weaknesses identified in paragraph 7.4 will be tracked as Item No. 50-309/89-81-11.
8.0 E0P USER INTERVIEWS PURPOSE: To augment and clarify findings from other inspections tasks through interviews with procedures users, developers, trainers, and other appropriate plant staff.
Interviews were conductea with fourteen Maine Yankee personnel; including
,
reactor operators, senior reactor operators, plant operators, design engi-neers, simulator training instructors, QA representatives, and facility management. The interviews were used both to corroborate and augment inspection findings.
The specific results of the interviews are reflected in the appropriate sections of the inspection report.
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9.0 MANAGEMENT MEETINGS 9.1. PRE-EXIT MEETING (July 27, 1989)-
The details of the inspection findings were discussed with facility management at the working pre-exit meeting. The purpose of the pre-exit was:
(1) to ensure that the facility understood all of the findings; (2) to give the facility a chance to comment on the findings, as
,
appropriate; and (3) to obtain commitments from the facility with respect to correction of the valid findings.
9.2 EXIT MEETING (July 28,1989_1 The major inspection findings were reviewed and the remainder of the
!
findings were summarized. The Plant Manager reconfirmed the facility's
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commitments with respect to the deficiencies noted.
10.
PERSONNEL CONTACTED:
Licensee R. Blackmore, Manager, Operations Department
- E. T. Boulette, Vice President Operations, Plant Manager
!
- A. J. Cayia, Assistant Manager, Operations Department
- R. N. Chase, Quality Programs - Project Engineer
- R. Crosby, Senior Licensing Engineer
- C. D. Frizzle, Maine Yankee - President
- J. H. Garrity, Vice President Licensing & Engineering l
- R. R. Lawton, Jr., Manager, Safety Engineering & Operations Support
- S. E. Nichols, Licensing Supervisor
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- J. A. Niles, Plant Shift Supervisor l
- A. R. Shean, Manager, Training l
- G. N. Stowers, Staff Supervisor OSD (EOP Coordinator)
- G. D. Whittier, Manager, Nuclear Engineering & Licensing
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State
- P. J. Dostie, State Nuclear Safety Inspector NRC
- R. J. ' Freudenberger, Maine Yankee Resident Inspector
- G. S. Galletti, Human Factors Engineer, NRR
- J. R. Johnson, Chief, Projects Branch 3, DRP, RI
- 0. T. Moy, Reactor Inspector, ORS, RI
- B. S. Norris, Senior Operations Engineer, DRS, RI
- W. H. Regan, Jr., Chief, Human Factors Branch, NRR
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NRC Contractors
- .C. M. Meeker,' Systems Engineer, COMEX
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- R. D. Warner, Licensing Examiner, PNL
- Attended Pre-Exit Meeting on July 27, 1989
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- Attended Exit Meeting'on July 28, 1989 l
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ATTACHMENT 1 o
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DOCUMENTS REVIEWED Document Document Rev No./
' Number-Title <
Date i
WESTINGHOUSE OWNERS GROUP:
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WOG' Emergency Response Guidelines
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WOG Emergency. Response Guidelines 1A
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EMERGENCY OPERATING PROCEDURES:
E-0 Emergency Shutdown from Power or Safety Injection
ES-0.0 Event Rediagnosis
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ES-0.1 Reactor Trip Response
ES-0.2 Natural Circulation Cooldown
ES-0.3-Natural Circulation Cooldown with Steam Voids in Vessel (with PITS)
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ES-0.4 Natural Circulation Cooldown with Steam Voids in Vessel (without PITS)
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ECA-0.0 Loss of All AC Power
ECA-0.1 Loss of All AC Power Recovery, SI Not Required
ECA-0.2 Loss of All AC Power Recovery, SI Required
e E-1.
Loss of Primary or Secondary Coolant
ES-1.2 Post-LOCA Cooldown and Depressurization
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ES-1,3 Transfer to Recirculation Cooling (RAS)
ES-1.4 Establishing Hot Leg Injection
ECA-1.2 LOCA Outside Containment
E-2 Steam Line Break
E-3 Steam Generator Tube Rupture
ES-3.1 Post-SGTR Cooldown Using SG Backfill
ES-3.3 Post-SGTR Cooldown Using Steam Dumps
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FUNCTIONAL RESTORATION PROCEDURES:
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l F-0.1 Subcriticality Status Tree
l-FR-S.1 Nuclear Power Generation /ATWS
t FR-S.2 Loss of Shutdown Margin
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F-0.2 Core Cooling Status Tree
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FR-C.1 Inadequate Core Cooling
FR-C.2 Degraded Core Cooling
FR-C.3 Saturated Core Cooling
F-0.3 Heat Sink Status Tree
l FR-H.1 Loss of Secondary Heat Sink
1 FR-H.2 Steam Generator Overpressure
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FR-H.3 Steam Generator High Level
FR-H.4 Loss of Normal Steam Release Capabilities
l FR-H.5 Steam Generator Low Level
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-ATTACHMENT 1 (cont.)
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DOCUMENTS REVIEWED
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e Document' Docudent Rev No./
' ' Number Title Date FUNCTIONAL RESTORATION PROCEDURES (cont.)
':. F-0.4 Integrity Status Tree
FR-P.1 Imminent Pressurized Thermal Shock Condition
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FR-P.2 Anticipated Pressurized Thermal Shock Condition
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.F-0.5'.
Containment Status Tree
FR-Z.1 High Containment Pressure
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'FR-Z.2 Containment Flooding
s FR-Z.3 High Containment Radiation Level
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.F-0.6 Inventory Status Tree
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FR-I.1 High Pressurizer Level
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FR-I.2.
Low Pressurizer Level.
O i
FR-1.3 Voids in Reactor Vessel
- ABNORMAL' OPERATING PROCEDURES
- AOP 2-2 Loss of Condenser Vacuum
i AOP 2-3 High Energy Line Break (HELB) Isolation System Actuation
A0P 2-7 Excess Steam Demand
AOP.2-10 Loss of Pressure Control /RCS Leak
AOP 2-11 Loss of Instrument Bus
c AOP 2-12 BUS 5 and/or BUS 6 Under Voltage
A0P 2-16 Partial Loss of Load
l AOP 2-17 Post-Accident Hydrogen Control
l AOP 2-20 Reactor Regulating System Failure
AOP 2-21 Misa11gned (Dropped) CEA
AOP 2-22 Uncontrolled Reactivity Addition
A0P 2-23 Inoperable CEA
A0P 2-25 High Radiation Levels
AOP 2-26 Abnorr/a1 Loss of Refueling Cavity Level (CRS-1)
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AOP 2-27 Corrosive Contaminants in the Steam Generators
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A0P 2-28 Loss of Control Air
AOP 2-29 Loss of Containment Control Air
A0P 2-30 Loss of Containment Integrity
AOP 2-31 Service Water Header Rupture
AOP 2-33 Loss of PCC
AOP 2-34 Loss of Core Decay Heat Removal Capability While Shutdown
AOP 2-35 Refueling Accidents
AOP 2-36 Response to Safeguards Annunciators, MCB and Diesel Generators 16 L
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I A1TACHMENT7.(cont.)
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DOCUMENTS REVIEWED p
Document
- Document Rev No./
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- Number Title Date s
I ABNORMAL OPERATING PROCEDURES (cont.):
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L A0P 2-37 Non-Safeguards Annunciators
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AOP 2-38 Response to PAB Annunciators
AOP 2-39 Response to Annunciators: Water Treatment, H2 Panel, Auxiliary Boiler, and P-2C Local Panel
A0P 2-40 High Wind, Hurricane or Tornado
E AOP 2-41 Earthquake
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AOP 2-42 Flooding
i AOP 2-43 Control Room Isolation
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AOP 2-44 Control Room Evacuation
AOP 2-45 Emergency Loop Shutdown
- AOP 2-46 Loss of Offsite Power While Shutdown or Post Trip
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AOP 2-90-0 Plant Fire Assessment
. AOP 2-90-1 Plant Shutdown Plan for fire in Control Room, Control Room Cable Chase, Protected Cable Vault, Cable Tray Room (Protected), Protected Switchgear Room &/or Station Blackout
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- AOP 2-90-2 Plant Shutdown Plan for Fire in Containment, Spray
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Pump Area, Steam Feed Valve House, Containment
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Electrical Penetration South EL. 46'
AOP 2-90-3 Plant Shutdown Plan for Fire in PAB EL. 11'
AOP 2-90-4 Plant Shutdown Plan for Fire in PAB EL. 21'
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AOP 2-90-5 Plant Shutdown Plan for Fire in Reactor MCC EL. 21'
& 33', and Containment Electrical Penetration Room North EL. 46'
n A0P 2-90-6 Plant Shutdown Plan for Fire in Emergency
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Feed Pump Room
AOP 2-90-7 Plant Shutdown Plan for Fire in Turbine Hall, Circulating Water Pump House
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AOP 2-90-8 Plant Cooldown from Alternate Shutdown Panel (ASP)
- QUALITY ASSURANCE IMPLEMENTING PROCEDURES l
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0-03-1 Control of Activities Affecting Permanent Design Changes
0-05-1 Procedure Preparation, Classification, Format,
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Use and Adherence
0-05-2 Procedure Writers' Guide
0-06-4 10 CFR 50.59 Determination
l 0-06-4 Emergency Operating Procedure Maintenance Program
0-10-1 Inspection Program
0-14-2 Temporary Modification Control
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Inspection Report No. 50-309/89-81
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ATTACHMENT 1(cont.)
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DOCUMENTS REVIEWED
. Document Document Rev No./
Number Title Date PRIMARY OPERATING PROCEDURES:
'l-12-6 Control Room Ventilation
OPERATIONS DEPARTMENT CLASS C PROCEDURES 1-200-7 System & Componer:t Labeling
' '
-1-200-9 Independent Operating Procedure Review
1-200-10 Conduct of Operations
1-200-13 Operating Dept. Interface with Design Change Activities20-201 E0P Verification
'O 20-202 E0P Validation
OPERATIONS DEPARTMENT CLASS D PROCEDURES:
1-300-2 Maine Yankee Operational Information Posting System
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ADMINISTRATIVE MANUAL:
F.2 Supervisory Guidelines, Table of Organization
LESSON PLANS:
R0-L-8.1 Emergency Shutdown from Power or. Safety Injection and Response R0-L-8.5 Loss of All AC Power and Recovery R0-L-8.7 Suberiticality Challenge and Recovery R0-L-8.9 ~ Heat Sink Challenge and Recovery R0-L-8.12 Containment Challenge and Recovery R0-L-8.23 Introduction to Emergency Operating Procedures, Emergency
.
I Operating. Procedures Users' Guide j
OTHER DOCUMENTS:
1.
QA Evaluation Report No. 89E-015, Maintenance of Emergency l
Operating Procedures i
2.
Audit of Maine Yankee Emergency Operating Procedures, Final
Report, May 1989, General Physics Company I
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E0P Audit Action Plan, Status of Issues Identifies during
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Internal and General Physics Audits, 7/14/89
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4.
E0P Philosophy Steering Committee Minutes, 6/29/89
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5.
Plant Operations Review Committee Charter i
6.
Plant Opera' ions Review Committee Subcommittee Charter -
Procedure Review 7.
Guidelines for Procedure Development & Review, Rev 0, 4/16/87 8.
. Simulator Exercise Guide, MY-T-61-84, Rev 2
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ATTACHMENT 2 DEFICIENCIES IDENTIFIED p
The deficiencies noted below were all discussed with the facility staff l-prior to the exit meeting. All comments were understood and accepted by the facility.
For some of the comments, additional facility response is-included.
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L Generic:
1.
Valve lists do not exist for the various ESFAS actuations (SIAS, CIS,etc.)
2.
When an alarm.is referenced in the procedure, addition of the alarm window number in the procedure would aid the operator.
3.
The definition of harsh containment is not included within the E0Ps.
4.
When equipment is in the overhead, a ladder or other means of access is needed.
5.
Some of the procedures direct transitions to steps or procedures that no longer exist.
E-0: Emergency Shutdown from Power or Safety Injection 1.
Step 2, pg 3:
The AER column allows for one stuck rod; the RNO column does not give this latitude.
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2.
Step 8, pg 5:
The AER column does not define whether the minimem flow is for each loop of for total flow.
3.
Step 16, pg 8:
This step plhces severe limitations on the allowed pump configurations.
4.
Step 179, pg 9:
j This step is redundant.
!
5.
Step 13.b.2, pg 10:
The operators do not perform this step as written; instead, they verify the yellow light lit.
ES-0.1: Reactor Trip Response 1.
Step 13.a.2:
Guidance is needed to ensure the fan is running.
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ATTACHMENT 2 (CONT.)-
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DEFICIENCIES IDENTIFIED i
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2.
Step 9:
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.P-10B istincorrect, should be P-98.
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3.-
Step 11 RNO:
Procedure does not allow operation of other pumps if desired combinations cannot be achieved.
4.
Attachment'B, Step 12:
.
FIC-1301 is incorrect, should be FIC-1303.
ES-0.2: Natural Circulation Response j
l1.
' Steps 23 and 24:
Procedure' has the operator check if RCS temperature may be reduced, but
'
does not provide for' stopping of the cooldown.
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. Facility Response: The Operations Department will investigate. Also, they will check ES-0.3 and ES-0.4.
ES-0.3: Natural Circulation Cooldown with Steam Voids in Vessel (w/ PITS)
'1.
Step 2,'RNO a:
L Why is 44'F subcooling required?
i Facility Response: 'Will ensure step is correct or delete if unnecessary.
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2.
Step 5, RNO g:
-This step does not direct a return to the beginning of Step 5.
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ES-0.4: Natural Circulation Cooldown with Steam Voids in Vessel (w/o PITS)
1.
Step-1:
A note is needed to address possible rapid decrease in PZR level when RCPs are started.
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ECA-0.0: Loss of All AC power 1.
Step 5, RNO b.1:
The position of MS-T-163 is difficult to verify, i
2.
Step 23, RNO b:
The operator performing the walkdown did not know how to perfora this task, the appropriate procedure is not referenced.
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3.
Step 27.a. RNO:
The task appears to rely on the operation of interlocks?
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ATTACHMENT 2 (CONT.)
DEFICIENCIES IDENTIFIED i
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.ECA-0.1: Loss of All AC power Recovery _, SI Not Required
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Step 4.c:
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The reference to the power supply is incorrect.
It should be MCC-7a and in MCC-Ba, t,
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2.
Step 13:
LO-7 and LD-8 are not checked open, they may have been closed in ECA-0.0.
'ECA-0.2: Loss of All' AC Power Recovery. SJ Required t
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Step 4:
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This. step does not identify the standby CS pump (P-61S) as a possible LPSI
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pump.
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E-2: Steam Line Break
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Step 5, RNO, pg 7:
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(a) Does not include an option to feed directly from the PWST.
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(b) No procedure exists for sluicing from the PWST to the DWST.
E-3: Steam Generator Tube Rupture
1.
Step 4, pg 5:
Step directs the clearing of " White tags" from isolation valve breakers and disconnects, but there is no similar step removing the Orange danger tags on the RCS loop isolation valves. These tags must be removed prior to conducting step 4.d., which strokes all RCS loop isolation valves.
2.
Step 10.d, pg 8:
Charging Header flow controller "FIC-212/CH-F-38" is labeled incorrectly.
,.
3.
Step 12, RNO a, pg 10:
Should read "G0 TO STEP 13" vice 14.
4.
Step 14, RNO b.(4) and RNO c, pg 10 & 11:
Title of A0P 2-46 is incorrect.
5.
Step 15, RNO d, pg 12:
Step does not provide a refererce to a procedure to complete the actions specified.
6.
Step 17, RNO c.(3), pg 14:
This step does not alert the Control Room personnel that taking control at the ASP will produce an instrument alarm. (T-1-7).
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Inspection Report No._50-309/89-81
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ATTACHMENT 2 (CONT.)
DEFICIENCIES IDENTIFIED
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7.
Step 21, Caution 2, pg 18:
l The caution prohibits operation of the PORV's if Quench Tank pressure i
exceeds 75 psig. The same caution in the ERGS only alerts the operators to the fact that the Quench Tank may rupture and create harsh containment conditions.
.
8.
Step 23, RNO a, pg 20:
This step directs the operator to " Return to Step 17", but does not direct the operator to the caution prior to Step 17.
9.
Step 40.a.(1).,pg33:
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"FW-M-366" is incorrect, should be "FW-M-336".
10. Attachment C, Step (12), pg 37:
(a) The second step directs the operator to trip the P-2C Recirculation control switch.
This switch is no longer installed, the function is now being performed by the P-2C Recirculation Controller.
(b) The P-2C pump's discharge temperature indicator TI-1311 is located ten feet above the walking deck and cannot be read with the current access.
ES-3.1: post-SGTR Cooldown Using SG Backfill 1.
Step 3.b, pg 3:
This step directs the adjustment only of EFW flow.
There are conditions whereby Main Feedwater pumps may still be operating and the condition is not addressed.
2.
Step 7, RNO a. and b, pg 5:
Reference to the note prior to Step 8 is missing.
3.
Step 11.b, pg 8:
.
"PCO-103" is incorrect, should be "PIC-103".
4.
Step 19, pg 13:
Section 4 is incorrect reference, should be 6.5.
5.
Attachment B, Step 4, 9, and 14, pg 16:
No wrench is maintained in the locker along with the pressure gages that are instailed in this step. The wrench would facilitate the performance of this step.
ES-3.3: Post-SGTR Cooldown Using Steam Dumps 1.
Step 1.a. pg 2:
The working of this step dif fers from the identical step in E0P ES-3.1.
the working of this step should be consistent in these two procedures.
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ATTACHMENT 2(CONT.)
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DEFICIENCIES IDENTIFIED
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2.
Step 12 RNO e, pg 10:
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"9" is incorrect, should be "10".
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3.
Step 21.b.(1)(b), pg 15:
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This step uses the term "HPSI header supply valve breakers" while E0P ES-
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3.1, Step 17.d (1)(b), on page 13, uses the term "HPSI header isolation valve ACBs."
4.
Step 23, RNO b, pg 17:
"18" is incorrect, should be "21".
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5.
Step 24, pg 17:
" Sect. 4" is incorrect, should be "Section 6.5" since that is the com-mencement of RHR recirculation, j
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FR-C.1: Inadequate Core Coolino 1.
WOG Step 3:
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The step is missing, l
i FR-C.2: Degraded Core Coolino l
1.
Attachment B, Step 6:
,
CH-A-156 is incorrect, should be CH-P-156.
F-0.3: Heat Sink Status Tree
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1.
The actual flow rates that define the " MINIMUM FOR DECAY HEAT REMOVAL" are not be entered in the top decision block.
2.
The "1000 pSIG" value used in block #3 does not agree with the value specified in the referenced recovery procedure, FR-H.2.
p FR-H.1: Loss of Secendary Heat Sink F
1.
Step 1, RNO a, pg 2:
This information would be more appropriate as a caution before the step.
2.
ATTACHMENT A, Step (2), pg 20:
The installed tags on valves CD-26 and CD-27 are switched.
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3.
ATTACHMENT A, Step (3), pg 21:
Valve CO-123 is int.orrectly identified twice in this step.
FR-H.2: Steam Generator Overpressure
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No comments.
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Inspection Report No.- 50-309/89-81
A','TACHMENT 2 (CONT. )
DEFICIENCIES IDENTIFIED FR-H.3: Steam Generator High Level No comments.
FR-H.4: Loss of Normal Steam Release Capabilities 1.
Step 1, RNO c, pg 3:
The steps to start the AFW Pump (P-250) are sequenced inefficiently. The steps require the operator to start the evolution on the second platform, then proceed to the first platform, then go to the third platform, and finally back to the first platform. A more efficient sequence of steps may be possible.
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FR-I.2: Low Pressurizer Level 1.
Step 6:
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This step challenges the pressurizer heater interlock.
AOP 2-2: Loss of Condenser Vacuum 1.
Step 4.4.2:
The correct title of OP 1-2-1 is Investigation and Evaluation for
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Recovery from an '{9 scheduled Reactor Trip, l
AOP 2-3: High Energy Line Break (HELB) Isolation System Actuation
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1.
Section 2.0, pg 1:
l There is important information contained in the discussion section.
This information would be useful in the body of the procedure at the appro-t priate location.
AOP 2-7: Excess Steam Demand 1.
Step 5.4.1:
This step does not appropriately direct a transition to E-0.
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AOP 2-12:
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BUS 5 and/or Bl[S 6 Under Voltage 1.
Step 4.2.4:
This step does not appropriately direct a transition to E-0.
AOP 2-21: Misa11gned (Dropped) CEA 1.
Several abbreviations are used in this procedure that are not defined in the Proccdure Writers Guide (0-05-2) paragraph 6.1.18.b(4):
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Inspection Report No. 50-309/89-81
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ATTACHMENT 2 (CONT.)
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L DEFICIENCIES IDENTIFIED
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i Step 2.6.3, pg 1 "KW/FT" and "FRT".
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Step 2.8.1.a. pg 2. "S/0".
!
l Step 5.2.1.c, pg 5. " SOT".
!
E Step 5.2.9, pg 7. " MOD" and "RE".
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l Step 5.2.10, pg 7. " INCA".
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2.
Step 5.3.7. Caution and Note, pg 9:
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The Caution and Note do not appear on the page which contains the
step that they apply to in accordance with the Procedure Writers Guide,
i paragraph 6.1.10.b.(6).
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AOP 2-23: Inoperable CEA 1.
Step 4.1, pg 1:
i The step specifies attempting withdrawal of the CEA as the first part of t
the itmediate action. There are possible situations where inserting the
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CEA would be the more appropriate action, j
i AOP 2-25: High Radiation levels l
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2.
General Comment:
I The physical condition of the procedure in the control room is poor and
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needs repair, i
2.
Step 6.8:
Reference to the BWST RMS should be deleted since tho instrument has been removed.
j AOP 2-27: Corrosive Contaminants in the Steam Generators-
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Step 5.5.4, pg 7:
i There is confusion among operators as to the S/G 1evels that are referred
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to in this step. Some operators thought the 10% WR was supposed to be 10
inches not percent wide range and the 25% figure is not defined as wide range or narrow range.
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ATTACHMENTS A, B, AND C, pg 11, 12, & 14:
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These graphs do not conform to the Procedure Writer's Guide, paragraph
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6.1.14.a.
L AOP 2-33: Loss of PCC l
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General Comment:
An evaluation of the prompt isolation of some PCC loads may provide l
I additional time to correct a PCC system problem, or may prevent a problem resulting from a loss of PCC cooling,
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Inspection Report No. 50-309/89-81
i ATTACHMENT 2 (CONT.)
DEFICIENCIES IDENTIFIED AOP 2-36: Response to Safeguards Annuncistors. MCB and Diesel Generators
No specific procedural comments; see paragraph 5.4 of the report for comments relative to the usa of the ARPs.
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AOP 2-37: Non-Safeguards Annunciators No specific procedural comments; see paragraph 5.4 of the report for comments relative to the use of the ARPs.
AOP 2-38: Response to PAB Annunciators No specific procedural comments; see paragraph 5.4 of the report for comments relative to the use of the ARPs.
AOP 2-39: Response to Annunciators: Water Treatment, H2 Panel, Auxiliary Boiler, and P-2C Local Panel
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No specific procedural comments; see paragraph 5.4 of the report for comments relative to the use of the ARPs.
AOP 2-43: Control Room Isolation 1.
Step 5.2:
Fan FN-15 is required to be checked locally, a separate step in the procedure appears warranted.
AOP 2-44: Control Room Evacuation 1.
Discussion Section & Step 5.65:
The discussion section states that the normal / alternate switches are to be left in normal; Step 5.65 directs the operator to select alternate on the PAB emergency panel power selector switch.
The contradiction needs
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to be clarified.
2.
Note sfter Step 3.0:
Directs the operator to go to 2-90-1; a transition to ECA-0.0 appears warranted.
3.
Step 5.5.5:
The operator is directed to determine sub-cooling but is not given guidance as to how it should be accomplished.
4.
Step 5.5.6:
The breaker control power fuses are note conspicuously identified as to function; i.e., " closing power" or " trip power" vice "UC" or "UT."
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L Inspection Report No. 50-309/89-81
ATTACHMENT 2 (CONT.)
DEFICIENCIES IDENTIFIED j
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5.
Caution after Step 5.7.2:
Cautions should be located before the step.
AOP 2-90 SERIES:
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Ventilation drawing attachments on all the 2-90 series AOP's are of poor quality.
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ADP 2-90-0: Plant Fire Assessment
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1, Step 6.1:
(a) Zone 12 does not show up on fire protection zone mimic.
(b) All of the zones shown on the fire protection zone mimic do not appear on the list in step 6.1.
(c) Some of the zones on the mimic are listed in the symptom sections of other 2-90 series procedures but are not on the list in step 6.1.
AOP 2-90-1: Plant Shutdown Plan for fire in Control Room, Cor. trol Room Cable Chase. Protected Cable Vault. Cable Tray Room (Protected),
Protected Switchgear Room &/or Station Blackout 1.
Step 6.4.15:
CPU-23 is not required to be checked because ECCS verifies alignment.
The inspector found the valve positioned properly but the chain did not secure the valve properly and the valve handle was removable, i
AOP 2-90-6: Plant Shutdown Plan for Fire in Emergency Feed Pump Room 1.
Step 4.2: references figures which are not provided in this procedure.
f AOP 2-90-8: Plant Cooldown from Alternate Shutdown Panel (ASP)
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Section 2.0, bullet #5:
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If the MS line flooding method is used and the lines are not pinned or
supported, a warning about the possibility of line breakage appears
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varranted.
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Step 5.1:
Instructions are not provided as to how head temperature is to be i
obtained.
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Step 6.1.3:
It's not possible for operators outside the control room to tell if 3 out
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of 4 RCS pressure channels are less than 1685 PSIG.
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Step 6.3.1:
This step is redundant to step 6.1.5.A.4.
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Inspection Report No. 50-309/89-81
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t-ATTACHMENT 3 f
ABBREVIATIONS & ACRONYMS
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l AC Alternating Current ACR0 Assistant Control Room Operator p
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ADV Atmospheric Dump Valve
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AER Action / Expected Response (left-hand column of E0Ps)
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A0 Auxiliary Operator
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AOP Abncrmal Operating Procedures
ARP Alarm Response Procedure
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ATMOD Assistant to the Manager, Operations Department
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ATWS Anticipated Transient Without Scram (
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BAST Boric Acid Storage Tank
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CE Combustion Engineering L
CEA Control Element Assembly
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CFR Code of Federal Regulations i
CRO, Control Room Operator
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CRS Control Room Supervisor
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CST Condensate Storage Tank
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CV Contr:>l Valve
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DC Direct Current DCRDR Detailed Control Room Design Review EDG Emergency Diesel Generator
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EFW Emergency Feedwater E0P-Emergency Operating Procedures (as described in RG 1.33)
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' Emergency Procedures (includes E0Ps/AOPs/ referenced procedures)
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ERG Emergency Response Guidelines l
ESF'
Engineered Safeguards Feature
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ESFAS Engineered Safeguards Features Actuation System
F Degrees Fahrenheit l
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F/m Degrees Fahrenheit per minute
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FRP Functional Restoration Procedure (a subset of the E0Ps)
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GTG Generic Technical Guidelines
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HPSI High Pressure Safety Injection
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I&C Instrumentation & Control
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INPO Institute of Nuclear Power Operations
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LCO Limiting Condition of Operation LOCA Loss of Coolant Accident LPSI Low Pressure Safety Injection i
w MOV Motor Operated Valve i
NLO Non-Licensed Operator l
NRC Nuclear Regulatory Commission
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NRV Non-Return Valve NSE Nuclear Safety Engineer
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Inspection Report No. 50-309/89-81
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f ATTACHMENT 3(cont.)
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ABBREVIATIONS & ACRONYMS
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OG Owners' Group i
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PAB Primary Auxiliary Building PGP Procedure Generation Package PORV Power Operated Relief Valve
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PSTG Plant Specific Technical Guidelines L
PSS Plant Shift Supervisor
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PZR Pressurizer
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QA Quality Assurance
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RCP Reactor Coolant Pump i
RG Regulatory Guide
RO Reactor Operator i
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RNO Response Not Obtained (right-hand column of E0Ps)
RPS Reactor Protection System SER Safety Evaluation Report SFAC Safety Function Acceptance Criteria SOS Shift Operating Supervisor SPDS Safety Parameter Display System SRO Senior Reactor Operator STA Shift Technical Advisor TBD Technical Basis Document
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TDB Technical Data Book
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TS Technical Specifications
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V&V Validation & Verification WO Writers' Guide i
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Inspection Report No. 50-309/89-81
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ATTACHMENT 4 i
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LIST OF WEAKNESSES IDENTIFIED AS NEEDING CORRECTION
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Item No.
Description Para. No, f
50-309/89-81-01 Guidance that the E0Ps and AOPs were not to be 2.0
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considered as verbatim compliance documents, but i
as a guide.
L 50-309/89-81-02 Clarification of relationship between ECA-0.0 4.2.b
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and AOP 2-90-1.
50-309/89-81-03 Incorporation of harsh environment effects on 4.2.d
instrumentation outside of the containment.
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50-309/89-81-04 Resolution of generic procedural weaknesses 5.2 identified within the text of the report and
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technical concerns identified in Attachment 2 of
the report, i
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50-309/89-81-05 Correction of plant weaknesses identified during 5.3
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the procedure walkdowns; 1.e., labeling i
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deficiencies and control of operator aids.
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50-309/89-81-06 Establishment of policy with respect to how the 5.4
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ARPs are to be entered and used.
t 50-309/89-81-07 Establishment of policy with respect to how the 6.3.c i
AOPs and E0Ps are to be implementea concurrently.
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50-309/89-81-08 Development of a procedure delineating the 6.3.e l
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criteria for determining training requiremeits
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for revisions to E0Ps.
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r 50-309/89-81-09 Correction of weakr. esses identified in the Maine 7.2 Yankee writer's guide.
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50-309/89-81-10 Establishment of a program for that addresses 7.3 l
the process for changes to procedures; including responsibility, mechanism for recommending changes, and system for issuance of pages with
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minor administrative errors.
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50-309/89-81-11 Strengthening of the verification and validation 7.4 i
program.
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