IR 05000317/1989080
| ML20248A611 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 07/27/1989 |
| From: | Eselgroth P, Norris B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20248A608 | List: |
| References | |
| 50-317-89-80, 50-318-89-80, NUDOCS 8908080347 | |
| Preceding documents: |
|
| Download: ML20248A611 (34) | |
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U.
S. NUCLEAR REGULATORY COMMISSION INSPECTXON REPGRT FACILITY DOCKET NOs.
50-317 and 50-318 INSPECTION REPORT NOs.
50-317/89-80 and 50-318/89-80 FACILITY LICENSE Nos.
DPR-S3 and DPR-69 LICENSEE:
Baltimore Gas & Electric Company P.
O.
Box 1475 Baltimore, Maryland 21203 FACILITY:
Calvert Cliffs Nuclear Power Plant Units 1 & 2 MD Rts 2 &4 P.
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Box 1535 Lusby, Maryland 20657 INSPECTION DATES:
May 15 - 26, 1989 INSPECTION TEAM:
Team Leader:
B.
S. Norris, Senior Operations Engineer, NRC, RI Tean Members:
L. J. Defferding, Systems Engineer, PNL D.
T. Moy, Reactor Inspector, NRC, RI S.
B.
Sun, Systems Engineer, NRR A.
B.
Sutthoff, Human Factor Spec., SAIC R.
D. Warner, Licensing Examiner, PNL SUBMITTED BY:
d/ / _,
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'harrv' S'. Nobris D(te '
Senibr' Operations Engineer PWR Section 7"2 b N APPROVED BY:
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Peter"W. Eselg/ th, Chief Date PWR Section, erations Branch Division of Reactor Safety SUMMARY:
A special, announced inspection was conducted to determine the adequacy and completeness of the Calvert Cliffs Emergency Operating Procedures.
For this inspection, the Emergency Operating Procedures included the EOPs, AOPs, and all procedures references within the EOPs/AO^ s.
F 6908080347 890802 PDR ADOCK 05000317 Q
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Inspection Report Nos. 50-317/89-80 & 50-318/89-80
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No violations or deviations were identified.
Two concerns were classified as potentia] restart issues.
They were:
the philosophy that the EGPs were to be used as a guideline vice verbatim procedural compliance, and the adequacy of the flowchart in EOP-0
used to determine which of the EOPs should be entered l
to mitigate the event (paragraphs 2.0 and 4.3.a,
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respectively).
It is requested that a response be I
provided, in writing, detailing the plans and schedule j
for correction of the above two concerns.
Additional I
generic concerns are discussed within the body of the
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inspection report; those concerns that are specific to an individual procedure are enumerated in Attachment 2.
There are four attachments to this report:
j Attachment 1 - Documents Reviewed Attachment 2 - Deficiencies Identified Attachment 3 - Abbreviations and Acronyms
Attachment 4 - List of Weaknesses
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i Inspection Report Nos. 50-317/89-80 & 50-318/89-80
j DETAILS l
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1.0 PERSONNEL CONTACTED:
Licensee W.
Birney, Operations Procedures Group
- R. E.
Denton, Manager-Quality Ass.Tance Department I
- J. E. Gilbert, Supervisor-Operations Procedures
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- J. R.
Hill, Supervisor-Operations Tiaining l
- J. Lippold, General Supervisor-Technical Services Eng.
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F.
Lohr, Assistant General-Supervisor Operations
B.
B. Meowen, Senior Engineer-Performance Engineering
J. A. Minalcik, Principal Engineer-Nuclear Engineering
- M. D. Milbradt, Licensing Engineer i
- K. J. Nietman, General Supervisor-Nuclear Training l
M.
D.
Patterson, Principal Engineer-I&C l
P.
Pieringer, Supervisor-Independent Safety Eval. Unit j
- L.
B.
Russell, Manager-Calvert Cliffs
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- K.
B. Umphrey, Operations Procedures Group
- J. N. Wilson, Operations Procedures Group l
HEC G.
S.
Galletti, Human Factors Engineer, NRR
- R. M. Gallo, Chief, Operations Branch, DRS, RI
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- D. T. Moy, Reactor Inspector, RI I
- B.
S. Norris, Senior Operations Engineer, RI l
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Pritchett, Resident Inspector, Calvert Cliffe
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- S.
F. Shankman, Chief, Procedures & Training Section, NRR S.
B.
Sun, Reactor Engineer, NRR j
NRC Contractors
- L. J.
Defferding, Systems Engineer, PNL
- A.
B.
Sutthoff, Human Factors Specialist, SAIC
- R.
D. Warner, Licensing Examiner, PNL
- Attended Pre-Exit Mesting on May 24, 1989
- Attended Exit Meeting on May 25, 1989 i
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Inspection Report Nos. 50-317/89-80 & 50-318/89-80
2.0 USE OF EOPs AS GUIDELINES VICE PROCEDURES During the inspection, it was identified by the team that the management of Calvert Cliffs endorsed verbatim compliance with the normal procedures, but had promulgated a policy that the EOPs were to be used as guidelines.
With respect to the EOPs, this policy does not support the concept that procedures are developed such that the operators can implement them as written and that changes to the procedures are to be by a formal process described in the licensee's Technical Specifications. A facility representative stated that the operators would feel " locked in to the procedures" if they were not given the latitude to modify the procedure if a condition arose that was not specifically addressed by the EOPs.
The team identified to the facility that during emergency conditions, 10CFR50.54(x) allows the operators to take reasonable action that departs from a license condition when that action is immediately needed and no action consistent with licenae conditions that can provide adequate or equivalent protection is immediately apparent.
The regulations define explicitly when this option may be invoked.
Additionally, 10CFR50.54(y) states that a licensed senior reactor operator must approve the action prior to its being taken.
The licensee agreed to submit a plan for changing the policy for implementation of the EOPs.
The plan is to contain the specifics of how the change will be made, and a schedule of when the change will be implemented, including training on the change.
The plan is to be submitted and approved before the restart of the units.
(Item 50-317/89-80-01)
No violations or deviations were identified with respect to this functional area.
3.0 BASIC COMPARISON OF OWNERS' GROUP ERG WITH FACILITY'S EOPs PURPOSE:
To ensure that the licensee has developed sufficient procedures in the appropriate areas to cover the broad spectrum of accidents and equipment failures.
The list of Calvert Cliffs EOPs was compared to the CE Owners' Group list of Emergency Procedure Guidelines (CEN-152, Rev 2) to ensure that the licensee has developed procedures in accordance with the CEOG recommendations.
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Inspection Report Nos. 50-317/89-80 & 50-318/89-80
By a review of the table of contents.of the EOPs, it was initially determined that the facility's EOPs were consistent with CEN-152, Rev 2; it-was later discovered thtt the table of contents had an old title for EOP-2.
The final determination was that.the licensee had incorporated the basic CEOG guidance with one exception.
CE has guidance for a Loss of Forced Circulation procedure; Calvert Cliffs has put its Natural Circulation procedures into the AOPs.
Additionally, the licensee has developed an emergency procedure for Station Blackout.
Station Blackout was an addition to the CEOG guidance of CEN-152, Rev 3.
The facility committed to revising the current EOP-2 to incorporate the Loss of Forced Circulation guideline.
Additionally, they stated that they were in the process of reviewing CEN-152, Rev 3, with plans of rewriting all of the
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EOPs to be consistent with the later revision.
(Item 50-317/89-80-02)
No violations or deviations were identified with. respect to this functional area.
4.0 INDEPENDENT TECHNICAL ADEOUACY REVIEW OF THE EMERGENCY l
PROCEDURES l
PURPOSE:
Review the emergency procedures in office to assure that procedures-are technically adequate and accurately incorporate the guidelines of the ERGS.
4.1 The Calvert Cliffs EOPs were reviewed to ensure that the procedures were technically adequate and accurately incorporated the guidelines of CEN-152, Rev 2.
This review verified that:
(1) the vendor step sequence was foi). owed, (2) the exit / entry points were correct, (3)
l transfer between procedures was defined and appropriate
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for procedures performed concurrently, (4) minimum staffing was met, and (5) notes and cautions were used appropriately.
Each deviation from CEN-152 was reviewed to ensure that:
(1) safety significant deviations were reported to the NRC as required, (2) all deviations warranted by the specific plant design were incorporated,.and (3)
prioritization of accident mitigation strategies were correct.
Adverse containment values were also verified to be present in the procedures for the steam generator and pressurizer level readings.
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Inspection-Report Nos. 50-317/89-80 & 50-318/89-80
The team determined that, in general, the EOPs accurately incorporated the procedure guidance of CEN-152 and were technically adequate.
This determination was based on_the following. findings observed during the review of the Calvert Cliffs procedures:
a.
The EOPs generally followed the CEN-152, Rev 2, step sequence with detailed instructions for the operator actions required to cool down the plant to the entry conditions for a normal operating procedure or place the plant in a stcble condition.
b.
Entry points in the EOPs were clearly stated and could be followed by trained reactor operators.
Exit from the EOPs to the Functional Recovery Procedure is required if the Safety Functions
status check indicates a loss of another safety
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function.
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Notes and cautions within the emergency procedures were generally clear and were appropriately located in the emergency procedures.
d.
The plant specific values were consistent with the plant design.
e.
The CEN-152 prioritization of the accident safety i
function hierarchy was maintained in the EOPs.
4.2 During the course of the emergency procedures review, the team identified a number of technical concerns within the emergency procedures.
These concerns are listed along with the licensee's responses in
Attachment 2 of this report.
The concerns mainly focus
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on three areas:
a.
omissions of major steps on items specified in the
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CEN-152' guideline without adequate justifiention for the omissions, b.
unclear wording of steps, and c.
deficiencies in control room meters required to-complete a step in the emergency procedure.
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Inspection Report.Nos. 50-317/89-80 & 50-318/89-80
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In response, the licensee acknowledged the. technical deficiencies identified by the inspection team, and
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agreed to either correct the.EOPs to be. consistent wi.i CEN-152 or to strengthen the justification for'the
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deviation.
In some cases,,the deficiencies had been l
identified by the licensee and corrective action had I
been started.
The team determined that the resolutions
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(The deficiencies identified in Attachment 2 will be
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tracked as Item 50-317/89-80-03)
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4.3 The team determined that the following deficiencies impaired the effectiveness of the EOPs and that corrective action was required a.
EOP-0 uses a simplistic flowchart and a break
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identification chart to direct the operators to (
l the correct.EOP.for use in mitigating the event.
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The break identification chart and half of the safety functions acceptance criteria flowchart can l
be bypassed if the operator believes a single-event diagnosis is possible.
CEN-152 provides three symptom based aids (two f]owcharts and one table) which require the operator to review symptoms of the event before deciding which EOP.to
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enter.
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The licensee agreed to reviso the symptom based diagnostic chart for use in conjunction with EOP-O.
A draft of the diagnostic chart had been submitted to the operations department for comment prior to the end of the inspection.
The licensee agreed to implement the revised diagnostic chart before restart of the units.
(1 tem 50-317/89-80-04)
b.
EOP-8 includes the status of the vital auxiliaries =
in the Safety Function Status Checks, but EOP-8 has no operator actions or references to procedures on how to recover a vital auxi'.iary
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that may be lost.
Since these auxiliaries are i
plant specific, CEN-152' suggests plant specific action on how to recover any. auxiliary that may be lost or.is below acceptable criteria.
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'The licensee has-agreed to include a section within EOP-8 for the recoveryJor. restoration of vital auxiliaries.
.(Item.50-317/89-80-05)
No violations or deviations were' identified.with respect.to
'this functional area.
5.0 REVIEW OF THE EMERGENCY PROCEDURES BY CONTROL ROOM AND PLANT WALKDOWNS PURPOSE:
To assure that the emergency procedures can be successfully accomplished.
5.1 All of the procedures listed'in Attachment'l were
! walked down in the control room and/or in the plant, as-appropriate.
Licensed operators and non-licensed personnel were utilized'dur'ing the walkdowns to verify that the procedures specified actions could be accomplished by the operators using the; existing equipment, controls, and instrumentation.'
Generally, there are a large-number of deficiencies associated with the labeling on the centrol boards and in the plant.
Specifically,,the deficiencies.
associated with the labeling could be' divided into three categories:
a.
the nomenclature in'the' procedure.wasinot-consistent with the labeling on.the control' boards or on the equipment in the plant, b.
the procedure referred to a. component by the name,.
but.the label referred,to the component-by.the number (or vice versa), and'
c.
some components in-the' plant.were.not: labeled.
A licensee representative stated that a program was in process,to review the labeling as part offan earlier.
Detailed: Control Room Design-Review (DCRDR).
Details of the program are to be provided to the NRC for review, along with a schedule for completion.
(Item 50-317/89-80-06)
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' Inspection Report Nos. 50-317/89-80 & 50-318/89-80
5.2 The team noted that a set of EOFs and AOPs were maintained near each of the units control boards at all times, with a third set near the CRS.
The procedurcs were verified to be of the latest revision and free of any handwritten marks or changes.
No violations or deviations were identified with respect to this functional area.
6.0 SIMULATOR OBSERVATION 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 implemented under emergency conditions.
6.1 The team assessed the adequacy of the emergency procedure training by observing twa crews of licensed
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operators during unrehearsed operations in the site specific simulator of scenarios designed to exercise the crews familiarity and ability to utilize the
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emergency procedures.
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6.2 During the observation of the crews, the team had the opportunity to:
a.
Observe the crews' performance to validate or resolve concerns resulting from the table-top review of the emergency procedures, b.
Assess the licensee's operating philosophy with respect to the emergency procedures, especially where initial reviews identified differences from CEN-152.
c.
Assess the human factors elements associated with the performance of the procedures in a "real time" situation.
d.
Assess the operating crews' diagnosis of accident conditions and transitions from one EOP to another EOP (or.AOP).
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t Inspection Report Nos. 50-317/89-80 & 50-318/89-80 lor 6.3 The scenario sets consisted of:
First Crew:
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Scenario l':
Loss.of' Forced Circulation /Offsite Power Available (Use.of EOP-0 and AOP-3E)
Scenario 2:
Station Blackout performed'by minimum TS crew (Use of EOP-0 and EOP-7)
Scenario 3:
Loss of Coolant Accident / Steam Line
' Break inside Containment (Use of AOP-2A, EOP-0,'EOP-5 and.EOP-8)
Second Crew:
Scenario 1:-
Uncomplicated Reactor. Trip (Use of AOP-7G, EOP-0 and EOP-1):
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Scenario 2:
Loss of Forced Circulation / Loss-of Feed (Use of EOP-0, AOP-3E and'EOP-3)
Scenario 3:
Loss of Feed / Steam. Generator Tube Leak (Use of EOP-0, EOP-3 and EOP-8)
6.4 Observations:
a.
Both' crews were given a condition of loss of'all RCPs due to a loss of the' associated 13KV bus.
Both crews performed the'immediate actions.of EOP-O and then transitioned from'the.EOPs to an AOP without being specifically directed-to do so.
b.
During one scenario, the audible ~ annunciators were" lost due to a simulator malfunction.
The crew did'
not take actions to try-to. correct;the situation but made the assumption that'therejwas a simulator problem.
c.
Each crew was required to perform a: scenario with the minimum Technical Specification crev allowed-(i.
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two Ros, two SROs, and an unlicensed STA).
Each crew performed' satisfactorily during the scenario.
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e Inspection Report Nos. 50-317/89-80 & 50-318/89-80
The training staff stated that they do not periodically train the crews in a minimum staffing situation; in fact, the crews in the simulator in
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general appeared to be larger than the number of licensed personnel actually available in the control. room during plant operations.
d.
During a station blackout condition, the lighting in the. simulator does not match that in the control room, e.
Noise levels in the simulator were louder than in the actual control room..This was due mainly to the adjacent HVAC equipment in the simulator, f.
The binding methods of the EOPs is.not consistent between the control room and the simulator.
The inspection team had the simulator bindings changed to reflect the method used in the control room.
This binding method sometimes interfered with the operators performance in the simulator in that they were bulky to use and carry, g.
Both crews were able to use the procedures to mitigate the accidents.
When required, there was no hesitancy to enter the functional recovery procedure.
(Item 50-317/89-80-07)
No violations or deviations were identified with respect to this functional area.
7.0 ON-GOING EVALUATION OF THE EMERGENCY PROCEDURES PURPOSE:
Determine if the licensee has established a long term evaluation program for the emergency procedures as recommended in Section 6.2.3 of NUREG-0899.
7.1 A review of the Calvert Cliffs system of on-going evaluation and revision of EOPs was conducted to assess whether the licensee's current system could ensure high quality EOPs over time.
The system was. evaluated on the basis of a number'of elements, including.but not limited to:
(1) the completeness of a method for ensuring that changes in plant design, technical l
specifications, technical guidelines, the writer's.
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guide, referenced plant procedures, and the control room i
are promptly reflected in the EOPs; (2)-completeness of l
a method for revising the EOPs to reflect findings from
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Inspection Report Nos. 50-317/89-80 & 50-318/89-80
1 operational experience and use, training experience, simulator exercises, and control room and plant walkdowns; (3) the timeliness of revisions to the EOPs when incorrect or incomplete information is identified; j
(4) the adequacy of the system for determining training, validation, and verification, when procedures
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are changed or revised; (5) the adequacy of basis documents, including technical guidelines and writer's guide; (6) the adequacy of verification and validation; and (7) the effectiveness of a system of soliciting and utilizing feedback from procedure users and other cognizant personnel.
7.2 The team found that some aspects of the Calvert Cliffs system were well done.
Specifically, the method for reflecting relevant changes in plant design and reference materials in the EOPs was complete, the method for integrating findings from operational use and training was complete, revisions appeared to have been made in a timely manner, and the method for soliciting feedback and integrating useful changes into the procedures appeared effective.
7.3 However, several important components of on-going EOP maintenance were considered deficient, with a potential for degradation of EOP quality and integrity over time.
These areas of concern are:
a.
Writers' Guide In order to prepare clear, consistent EOPs that will aid the operator and help to minimize errors that can occur when operators use procedures during emergency situations, a complete and clear writers' guide is necessary.
Lack of restrictive guidance in a writers' guide will lead to dependence on the procedure writer's preference and increasing variation in the procedures over time and through personnel changes.
This is particularly relevant in that the Calvert Cliffs'
procedure development group is staffed on a rotational basis by licensed operators.
The potential inconsistencies could reduce the quality and usability of the procedures and could reduce the effectiveness of training on the EOPs.
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Inspection Report Nos. 50-317/89-80 &.50-318/89-80
A number of deficiencies were identified in the l
Calvert Cliffs writers' guide.
These deficiencies l
result in a writers' guide that does not provide i
sufficient nor adequate restrictive guidance to
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ensure ongoing production and revision of high I
quality procedures.
The following list of
examples is not intended to be inclusive, but l
rather to illustrate the deficiencies identified
in the Calvert Cliffs writers' guide:
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(1)
Movement within and between procedures can be
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disruptive and confusing and cause j
unnecessary delays and errors.
The Calvert
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Cliffs writers' guide defines the terms "per" i
and " implement" to indicate referencing and
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branching, respectively.
However, because no
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special emphasis is given these terms, they
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may be overlooked.
Because of the potential
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for errors when referencing and branching, it-
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is particularly important that these terms be
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clearly emphasized and consistently used.
l The lack of emphasis may be related to the many deviations from the writers' guide directions found within the procedural i
directions for referencing and branching.
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(2)
Because of the difficult nature of decision
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making during emergencies, it is important that decisions be clearly identified and
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simply and consistently structured.
The special format for decision steps adds to the ease with which operators can perform these i
steps because format itself holds meaning.
It is clearly recognizable to the operator as
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a decision step, even before the content has been understood.
Therefore, it is important l
that terms defined for use in decision steps i
be reserved for that purpose only, as much as possible.
The Calvert Cliffs writers' guide j
defines the word "OR" as a combination logic
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term and peacekeeping aid and allows three i
potential formats for its use.
This multi-
use, multi-format approach dilutes the
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effecti*: ness of the special decision step l
structure and format, and increases the potential for confusion and error.
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(3)
The Calvert Cliffs EOPs include a diagnostic flowchart for use after the performance of the immediate actions.
However, the_Calvert Cliffs writers' guide lacks any guidance on the preparation or structure of flowcharts.
(4)
The use of simple, consistently applied action verbs will increase the ease with which operators understand and thus perform procedural steps.
Likewise, complex words or use of words with fine or ambiguous distinctions can lead to difficulty in operator comprehension.
The Calvert Cliffs writers' guide verb list includes a number of verbs with similar or identical meanings.
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Examples are:
initiate, commence and start; and ensure, verify, and confirm.
(5)
The principles by which EOPs are controlled are intended to minimize confusion and error during performance in a highly stressful environment.
Any written information that an
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operator is required to read and perform during an emergency has the potential for i
leading to operator error if it is not presented in the proper format.
Therefore, all materials used by operators during an emergency should be considered part of the EOP system and should be subject to the same stringent format and development requirements as the EOPs.
The Calvert Cliffs writers'
guide does not address the preparation and structure of the many OIs, AOPs, and job performance aids that fell into the EOP system.
(6)
The step numbering system described in the
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writers' guide does not clearly address step numbering for the alternate action column.
As a result, in some cases there is duplication of numbered steps in the alternate action column (e.g., EOP-5, pg 28 of 41, step 1.1).
In addition, the alphanumeric system for numbering steps is quite lengthy.
Because the alpha character used to identify the box steps is not carried over when substeps exceed one page, it is not always clear exactly to which box step a substep is related.
The potential for confusion in this system is high.
Clear definition in the writers' guide of a
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Inspection Report Nos. 50-317/89-80 & 50-318/89-80
l complete and restrictive method.for uniquely i
numbering procedure steps in_both columns
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would have prevented these problems.
i (7)
The structure of substeps is not clearly defined.within the writers' guide.
The writers' guide states that substeps will contain " specific guidance" how to complete the-boxed step; however, substeps take the form of both complete steps and_ elements of lists within the procedures.
Because the writers' guide does not define and restrict
the structure =of substeps, they are inconsistently presented throughout the procedures.
These inconsistencies can make
the procedures more difficult to use and
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understand with a potential'for confusion and
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error.
(8)
The Calvert Cliffs writers' guide does not define standards for print size, type style, and procedure attachments.
(Item 50-317/89-80-08)
l b.
Verification and Validation Program:
Thorough and complete verification and validation of new procedures and of-significant changes and revision will ensure (1) adherence to the basis documents (i.e., the technical guidelines and the writers' guide) ; (2) that the language-and level
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l of information is appropriate for the users; (3)
l that there is a correspondence between the procedures and the plant hardware; and (4)lthat the procedures will function as intended.
(1)
The Calvert Cliffs EOPs included evidence that not all of these objectives had been.
met.
While it appeared that the procedures functioned as intended, numerous examples-were found of deviations from the writers'
guide, deviations from the technical guidelines, and deviations between the
nomenclature used in the procedures and that found'on plant labeling.
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Inspection' Report Nos.. 50-317/89-80 & 50-318/89-80 11 6 -
.For example,'while the writers' guide defines
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"per".and " implement".as the terms used for directing referencing and branching,7 numerous-other terms were used to' indicate these-functions within the EOPs; ' including
" complete" and implicit references-to<NEOGs and the steam 1 tables.. Cautions and. notes throughout the procedures contained-action steps, and logic terms were often' structured-
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'in a complex-and ambiguous manner.
(2)
In addition, the AOPs and OIs that are~also used.during emergency ~ situations did not'
appear to have been subjected'to any'
verification against the writers' guide or.
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plant hardware, and had not.been. subjected to-validation of local plant actions.
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.Related to this, the verification' checklist included in.the writers' guide: includes-
subjective criteria and is not sufficiently detailed to ensure adequate desktop verification against the writers' guide.-
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(Item 50-317/89-80-09)
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c.
Independent quality group' involvement:
q In order to-assure adequate review ofl procedures, it'is-importantithat~an independent' quality 1 review.
j be incorporated:into both the initial development
and the ongoing maintenance:of:the procedures.
j While it appears-that;an' effort was madeLto
involve independent reviewers in the development
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and revision.of the' procedures, ongoing i
involvement.in review'of'the procedures is i
lacking.
The annual QA audit. function' includes
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only'a; sample of operations. procedures.which may!
l or may not include any.EOPs,Jand when included,
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the review is not intended to address substantial j
content and structure issues.
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(Item 50-317/89-80-10)
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Inspection' Report Nos. 50-317/89-80 & 50-318/89-80
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d.
Method for controlling cop es of procedures:
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l The current method for indicating that a copy of a procedure (specifically EOPs) is controlled-is by
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E2t stamping the procedure as " uncontrolled." This system does not provide a me.thod by.which an individual copy would not be mistakenly identified
as a current controlled-copy; thereby, allowing
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for substitution of current copies with outdated copies.
It provides no way to differentiate j
between an actual controlled copy of a procedure j
and a copy of the controlled copy.
Additionally, j
the current system does not provide controlled copies with a unique identifying number.
Also, job performance aids, such as the immediate l
action plaques located on the control boards and
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the diagrams mounted in the plant,. lack any identifying number or revision date.
No method exists for indicating to the users that these operator aids are the current, approved revision.
i (Item 50-317/89-80-11)
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e.
Responsibility for the EOPs:
Because of the importance'of presenting information required during emergency situations in a carefully designed, consistent' manner; and
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because of the importance of controlling the l
ongoing maintenance and revision of these information sources, it is important'that all types of information materials required by operators during emergencies be subject to the same requirements.
The Procedure Development and Modifications Acceptance Group of Operations is responsible for
procedures.
However, a different organizational unit is responsible for plant and control room labels.
The NEOGs. referenced throughout the EOPs i
are developed and controlled by the Fuels
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As a result, labels have no real relationship to the EOPs and in fact use a completely ~different abbreviation and acronym list.
The terminology on labels conflicts with that used in the EOPs, which i
is based on actual operator language and holds more meaning for the users.
The NEOGs lack an adequate table of contents and need tabs to aid l
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Inspection Report Nos. 50-317/89-80 & 50-318/89-80
operator access.
In addition, the quality of the NEOG reproduction is highly variable and some graphs are extremely difficult to read.
These problems result from the multiple sources of responsibility for EGP support elements and lack of application of the Writers' guide principles to all information presented to operators during an emergency situation.
They have a direct relationship to difficulty in use of the EOPs and could lead to error in performance during an emergency.
In addition, this divided responsibility increases the possibility that information that should result in changes in the EOP system might not reach the appropriate source.
(Item 50-317/89-80-12)
No violations or deviations were identified with respect to this functional area.
8.0 EOP USER INTERVIEWS PURPOSE:
To determine the EOP users opinion of the EOPs and their technical evaluation of the adequacy of the EOPs.
Interviews were conducted with eleven Calvert Cliffs personnel; including reactor operators, senior reactor operators, plant operators, design engineers, QA engineers, and senior level managers.
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.
9.0 E_XIT MEETINGS PRE-EXIT MEETING (May 24, 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 refute the findings, as appropriate; and (3) to obtain commitments from the facility with respect to correction of the valid findings.
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Inspection Report Nos. 50-317/89-80 &c50-318/89-80 19-EXIT MEETING (May 25, 1989)
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The major inspection' findings were reviewed and'the.
remainder of the findings were summarized.
The; Manager--
Calvert Cliffs was asked tof, confirm the, facility's, commitment with respect. Items /89-80-011and 89-80-04; the.
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confirmation was reiterated in'that the facility would
< provide, prior to. restart of leither unit,= the' plans and-schedule for correction of'the above two open Items.-
At.noftime during the inspectica was' written' material given to the licensee.
The licensee also indicated that the-information to be covered in this report does-not constitute proprietary information.
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ATTACHMENT 1 DOCUMENTS REVIEWED Document Document Rev.No./
Number Title Dste
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l COMBUSTION ENGINEERING OWNERS GROUP:
CEN-152 C-E Emergency Procedures Guidelines
CEN-152 C-E Emergency Procedures Guidelines
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EMERGENCY OPERATING PROCEDURES:
EOP-0 Post-Trip Immediate Actions
J EOP-3 Total Loss of All Feedwater
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EOP-4 Excess Steam Demand
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EOP-5 Loss of Coolant Accident
EOP-6 Steam Generator Tube Rupture
EOP-7 Station Blackout
EOP-8 Functional Recovery Procedure
Attachments
i ABNORMAL' OPERATING PROCEDURES:
i AOP-1A Inadvertent Boron Dilution
1 AOP-2A Excessive Reactor Coolant Leakage
AOP-3B Loss of Shutdown Cooling
AOP-3E Loss of Flow / Natural Circulation 0/0
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.AOP-3F Natural Circulation Cooldown
l AOP-3G Malfunctions of Main Feedwater' System
j AOP-4A Loss of Containment Integrity
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AOP-6A High Reactor Coolant Activity
AOP-6B Accidental Liquid Waste Release
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AOP-6C Accidental Gaseous Waste Release
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AOP-6D Fuel Handling Incident
AOP-6E Loss of Refueling Pool Level
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AOP-7A Loss of Saltwater Cooling 6/6
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AOP-7B Loss of Service' Water
AOP-7C Loss of Component Cooling 7.
AOP-7D Loss of instrument Air
AOP-7E Main Turbine Malfunction 4/5 AOP-7F Loss of Load
AOP-7G Partial Loss of Condenser Vacuum
AOP-7H Loss of Plant Computer
AOP-7I Loss of Power to Class 1-E and Non-Class 1-E Busses
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ATTACHMENT 1 (cont.)
DOCUMENTS REVIEWED Document Document Rev No./
Number Title J2gLte f
i AOP-8 Reactor Trip Recovery
j AOP-9 Alternate Safe. Shutdown Procedure /
l Control Room Evacuation-2/2
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AOP-10 Abnormal Chemistry Conditions
l OPERATING PROCEDURES:
i OP-3 Normal Power Operation 24/17 OP-4 Plant Shutdown from Minimum Load
to Hot Standby
OP-5 Plant' Shutdown from Hot Standby to Cold Shutdown'
30/0 OPERATING INSTRUCTIONS:
,l OI-1A Reactor Coolant System and Pump Operations
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OI-1B Quench Tank Operations
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OI-1G RC Vessel Head and Pressurizer Vent System
OI-2A Chemical and Volume Control System
OI-3 Safety Injection, Shutdown Cooling, and Containment Spray 34-
01-15 Filling CCW Head Tank
i OI-16 Filling SRW Head Tank
OI-17D Miscellaneous Waste Processing System
01-19 Instrument Air 10/8 OI-24 Cooling the Refueling Pool
OI-27E SMECO Offsite Power Station
OI-29 Saltwater System
OI-32 Auxiliary Feedwater System
OI-41A Hydrogen Recombiners
OI-42 CEDM Operation
OI-43A Main Turbine Shutdown
OI-49 Operability Verification
OPERATIONS ADMINISTRATIVE PROCEDURES OAP-86-3 Procedure Writers Guide 01/05/88 OAP-86-3 Emergency Operating Procedures Writers' Guide 03/04/89 OAP-87-1 Emergency Operating Procedures 07/12/88
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ATTACHMENT 1 (cont.)
DOCUMENTS REVIEWED Document Document Rev No./'
Number Title Date CALVERT CLIFFS INSTRUCTIONS:
CCI-101K Review and Approval Procedures for Proposed Calvert Cliffs Procedures 09/09/88 CCI-119F Shop / Lab Memos 09/09/88 CCI-140E Shift Staffing 12/14/88 CCI-300I Calvert Cliffs Operating Manual (CCOM)
09/09/88 CCI-304C Nuclear Operations Unit Records Control 09/09/88 CCI-308C Temporary Notes, Operator Aids and.
Permanent Labels 02/01/89 SURVEILLANCE TEST PROCEDURES:
STP-055A Containment Integrity Verification
STP-0-65 Saltwater System
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CP-217 Specifications and Surveillance Steam ~ Generators ~
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CP-218 Specifications and Surveillance Condensate
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Feedwater and Main Steam System
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EMERGENCY RESPONSE PLAN IMPLEMENTING PROCEDURES:
ERPIP-4.1.8.3 Containment Hydrogen Sample
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Ir.spectict,R6purt Nos. 50-317/89-80 & 50-318/89-80
ATTACHMENT 2 DEFICIENCIES IDENTIFIED GENERIC:
1.
When entry conditions for a procedure list an indication that will also annunciate an alarm, the alarm window title and location should be listed vice a subjective statement.
Example:
" Loss of Condensate... (C15)" vice loss of condo:.4te storage tank inventory.
2.
Some mw.ers that have high/ low alarms associated with them also have markers on them'that indicate what the alarm setpoint is, other meters do not.
The facility should be consistent.
3.
When verifying a parameter as less than or greater than a setpoint, it should be clarified as to whether all indications must meet the criteria, only one ir.01 cation, or an average of them all.
4.
The latitude allowed to the Ros needs to be clarified with respect to the alt <2rnate actions within the EOPs.
Some crews allow the Ros to take the <.1 ternate actions and then inform the CRS, other crews require the ROs to request permission from the CRS before performing the alternate action.
5.
It is recommended that at the top of each page within the EOPs, the step be identified with the complete designator; i.e.,
III.E.1.b.
6.
If it is not readily apparent to the operator where an action must be performed, then list within the procedural step the location; i.e., panel number, switchgear room, outside at the condensate tanks, etc.
7.
It needs to be proceduralized as to how the Peacekeepers are to be ted in the control room.
Is the CRS supposed to initial the blocks, note the time started / stopped, etc?
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ATTACHMENT 2 (cont.)
DEFICIElrCIES IDENTIFIED
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EOP-0:
POST-TRIP IMMEDIATE ACTIONS i-1.
Step E.1.1 & E.1.2, pg 7.
There are no calculation results available to support the technical adequacy of the setpoint for CIS of 2.8 psig and CSAS of 4.25 psig.
Since the setpoints are less than the TS values, the lack of calculations does not represent a safety problem.
However, to comply with the NUREG-0899 i
requirements, it is necessary to prepare the calculations l
and include the results in the setpoint documents.
EOP-2:
1.
Note preceding step III.M.7, pg 10:
Should add to the step that overfill could cause the
"degasifier" inlet pressure high level alarm.
EOP-3:
TOTAL LOSS OF ALL FEEDWATHE 1.
Step I.F, pg 3:
l Precaution warns not to add water to a "... dry S/G
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The procedure needs to define what is meant by a dry S/G; i.e.,
below the indicating range.
l 2.
Step III.F.1, pg 5:
I This step requires the operator to shut the VCT Makeup valve; there is no SHUT position on the panel, only OPEN and AUTO.
3.
Step III.F.5, pg 6:
This step requires a calculation of shutdown margin using NEOG-11.
There are four different graphs in NEOG-11; additionel.q, there are actual procedures to calculate the l
SDM in 1 5's-10.
(This comment is specific to Unit 2, but is l
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applicable to Unit 1.)
k 4.
Step III.G.1.a, pg 6 l
l Unit 0 has moved the annunciators for the "SGIS A(B) BLOCK
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PERM 7.TTED" to above the controls and indications for the
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Unit 1 still has the window at the l
opposite end of the control boards (i.e., above the controls q
for the safety injection pumps).
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5.
Step III.G.1.b, pg 7:
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Same comment as above for the "PSRS PRESS BLOCK A(B)
PERMITTED" annunciator.
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ATTACHMENT 2 (cont.)
DEFICIENCIES IDENTIFIED 6.
Step III.G.6, pg 8:
This step should be changed to a NOTE that is on-going
through-out the rest of the procedure.
7.
Step III.H.1, pg 9:
A CAUTION should be added before this step that warns the operators that a potential exists for removal of all auxiliary feedwater sources for both units.
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8.
Step III.H.4, pg 11:
An additional step should be added to address the possibility of using the fire main as a source of water for l
the AFW pumps; similar to the option provided in EOP-8, pg
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i 9.
Step III.K.7, pg 17:
j Add to the end of the step:
and open the 8 inch outlet
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valves."
10.
Step III.K.13, pg 17:
This step should be changed to a NOTE as on-going infor.ation.
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11.
Step, M, pg 19:
Add as an alternate action:
"If not, then go to Step N."
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Step M.9, pg 20-
The second part of the IF statement is confusing, delete.
13.
Step IV, pg 39:
Clarify which containment temperature is being checked under the SFAC for Normal Containment Environment parameters.
(Cavity or dome temperature?)
14.
Step IV, pg 40:
Under the SFAC for Normal Radiation Levels External to Containment, there is no consistency with respect to listing of the radiation monitor by number.
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ATTACHMENT 2 (cont.)
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DEFICIENCIES IDENTIFIED EOP-4:
EXCESS STEAM DEMAND
1.
Steps III.K.5, pg 12, O and P, pg 15, & Y, pg 15:
j The above ateps need to be added such that the procedure
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will be consistent with CEN-152, steps 14 and 15, 33 and 34, and 24, respectively.
2.
Step III.G.4, pg R:
No specification is given in the procedure for which indication should be used to confirm the containment spray flow, should be 1-FI-4148/4149, 3.
Step III.I, pg 9:
The step only identifies the parameters te be used to
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determine which S/G is the affected one.
ihould add how the
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given parameters vill trend.
4.
Step III.P.C, pg 16:
j Detailed instructions should be given in this step as to how the HPSI flow should be raised.
5.
Step III.Y.2, pg 21:
The instruction " consider r.eggering RCP motor" should be reworded to clearly state who is to do what.
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EOP-5:
LOSS OF COOLANT ACCIDENT f
1.
Step II.G.1, pg 9:
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The HPSI flow referred to in thi6 step is the total flow to I
the four loops.
The operator must add the flow indication j
form four flow meters, however, this is not_ indicated in the step nor on the referenced chart.
The licensee indicated that a combined flow indication from all four flow meters is to be installed.
2.
Step III.Z.1.x, pg 33:
The step directs the operator to obtain a 12 F/m heatup rate by adjusting the shutdown cooling temperature controller.
It should direct the operator to control the heatup rate at less than 12 F/m.
EOP-6:
STEAM GENERATOR TUBE RUPTURE 1.
Step 23 of CEN-152:
This step is not included in the EOP.
The licensee has agreed to evaluate the HPSI throttling and termination criteria and include this step if appropriate.
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ATTACHMENT 2 (cont.)
DEFICIENCIES IDENTIFIED EOP-7:
STATION BLACKOUT 1.
Page 3:
Add a precaution similar to that in'EOP-3 with respect to the 400F differential' temperature with auxiliary ~ spray.
2.
Step II.B, pg 4:
Add' note that only the telephone and the sound-powered' phone-systems will be working.
3.
Step III.E.2.c & preceding note, pg 6:'
Reword the note to show the recovery action of aligning the
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liquid nitrogen system to the AFW. flow control valves; and show the aligning of the turbine building nitrogen system to the AFW control valves as an alternate action.
Include in:
l the alternate action the procedure that should be referenced
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for the' turbine building supply.
4.
Step III.U.1-3, pg 15:
The steps listed in the recovery action column should.be in the alternate action column.
The recovery action should be to attempt to open the SRW vel.ves (1600, 1637,8,9), and if successful then start at least on instrument air compressor.
5.
Step Y, pg 19:
The steps listed are really indications of voiding.
The recovery action should be "IF indications of voiding-exist, THEN proceed to Step Z."
the alternate action would be "IF l
indications of voiding do not exist, THEN continue to l
monitor for voiding and proceed to step AA."
6.
Step III.AA.3, pg 21:
Identify which cavity cooling temperature is being monitored.
Per the operators, it should be the' Neutron Detector Holder (s) on recorders 1(2)-TR-13/14.
7.
Step III.AF.11, pg 29:
a Reword:
WHEN RCPs restarted, THEN complete Administrative
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Post-Trip Actions (step AH) of this procedure and implement-I OP-3/4.
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EOP-8:
FUNCTIONAL RECOVERY PROCEDURE 1.
The format for this procedure is different from the format used for the-other EOPs.
Consideration'should be given to l
revising EOP-8, as appropriate.
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j ATTACHMENT 2 (cont.)
DEFICIENCIES IDENTIFIED j
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EOP ATTACHMENTS 1,
Attachment 2, Panel 2024A, pg 4 :
The caution following steps a, b, and c needs to be added after steps e and f also.
AQP-3B:
LOSS OF SHUTDOWN COOLING 1.
Step I.12.d, pg 9:
The conduct of this step could take up toLfour hours (per the operators during the walkdown).
Per thefdiscussion on pg 4 of the procedure, the time for the fuel to become uncovered could vary from 46. minutes to slightly over 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.
2.
Step II.D.2.d, Attachment 2, pg 4:
The valve listed in the step for 12 LPSI Pump is incorrect.
The correct number is 1-IS-525.
AOP-3E:
IOSS OF FLOW / NATURAL CIRCULATION 1.
Before Step E, pg 4 :
To be consistent with the EOPs, the steps for void identification ano elimination should be added.
I 2.
Steps III.I pg 6,
& III.J.1, pg 7:
The values for BAST leve2 and RCP seal temperature should be consistent with those values listed in the EOPs.
BOP-3F:
NATURAL CIRCULAT_ ION COOLDOWN 1.
Step B, pg 3:
The step should be revised to be consistent with the EOP; i.e.,
remove the reference to a 60" decrease in BAST level.
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ACCIDENTAL LIOUID WASTE RELEASE j
I 1.
Note on pg 7:
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This should be a step vice a note.
AOP-6D:
FUEL HANDLING INCIDEN2 l
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1.
Step II.C.2, pg 1:
The number for the particulate main vent radiation monitor is incorrect; should be 1(2)-RE-5414.
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ATTACHMENT 2 (cont.)
DEFICIENCIES IDENTIFIED AOP-6E:
LOSS OF REFUELING POOL LEVEL 1.
Step II.A.S.a, pg 6:
The monitor number provided is incorrect, the monitor is local.
2.
Step II.B.13, pg 8:
The appropirate section of OI-24 to be implemented is difficult to determine.
3.
Appendix 1, Step I.B.2, pgs 1 & 2:
Most of the valves in this step ar inside of contaminated areas.
l 4.
Appendix 2, Step 7, pg 2:
This step should be placed before step 6, and a note provided to ensure that the valve is 5% open before starting the LPSI pump.
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AOP-7A:
LOSS OF SALTWATER COOLING l
1.
Attachment 3, step 6c, pg 2:
Valve number 2-SW-5156-CV should be 2-SW-5178-CV in the procedure, and the label on the control panels is also incorrect.
AOP-7D:
LOSS OF INSTRUMENT AIR - UNIT 1 &Z 1.
Indication c, pg 4:
Although the valve is still installed in the plant, there is no longer an indication of the valve position in the control room.
2.
Indication d, pg 4:
Reword:
"The standby Plant Air Compressor..."
3.
Step I.C.1, pg 7:
The NOTE after this step should include the alarm setpoint since action is required if the alarm setpoint is approache _ _ _ _ - _ _ _ _ _ - _ _ - _ _ _ _
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ATTACHMENT 2 (cont.)
DEFICIENCIES IDENTIFIED AOP-7F:
LOSS OF LOAD I
1.
Indications B & C, pg 3:
I This procedure is common to both units; hewever, the terminology is different for the two units due to different
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turbine-generator controls being installed.
The procedure
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needs to be clarified.
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AOP-7I:
IQES OF POWER TO CLASS 1-E AND NON-CLASS 1-E BUSSES 1.
This procedure was not walked down.
However, this document
_3 is not useable as a procedure; it'is only a listing of loads
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on the busses.
Additionally, there is no index or priority I
to the listings.
AOP-9:
ALTERNATE SAFE SHUTDOWN PROCEDURE / CONTROL ROOM EVACUATION l
I 1.
Steps I.C.7.a u I.C.8.d:
These steps incorrectly use the verb "eifects" rather that
"affects."
Licensee has agreed to correct these steps.
2.
Steps I.C.11.a(1) & I.C.11.a(5):
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i These steps direct the operator to maintain subcoo2ing i
between 30F and 200F; this is in conflict with EOP-6 and EOP-7, which require subcooling between 30F and 140F.
3.
Step I.C.14.c(2):
This step directs the removal of three check valves and their reinstallation upside down.
This task would be performed by a mechanic, not a plant operator.
The related
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procedure needs to be subject to the sane requirements as
the operating procedures' intended for use during an i
emergency.
The licensee has agreed to investigate'whether a
procedure exists for this task and to' ensure that adequate
procedural guidanca is provided.
4.
Step II.C.14.a:
The diagram of the RCP breaker is.very hard to read.
The licensee has agreed to correct this problem.
5.
Steps II.C.16 & III.C.13 (Unit 2 copies):
Steps 16 a, b, and c on the Unit 1 procedure were replaced by CR-86-328 to direct initiation of SGIA at the ESFAS panel.
The same change has been made on Unit 2; however, the procedure text has not been modified.
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ATTACHMENT 2 (cont.)
DEFICIENCIES IDENTIFIED l
6.
Steps II.C.53 & II.C.55.a (Unit 1) and II.C.49.e & II.C.51.a (Unit II):
Reference to Attachment 1 in the first step (listed for each unit) should match the reference to Attachment 1 in the j
second step (listed for each unit).
7.
Step II.C.55.a (Unit 1) and II.C.51.a (Unit 2):
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These steps state that pressure should not be allowed to exceed normal operating pressure.
The steps should indicate that pressure should not be allowed to exceed 2250 psia.
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Steps II.C.57 & III.C.57 (Unit 2):
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The procedure suggests that these steps can only be j
performed in the control room; while the entry conditions j
for the procedure might entail an inaccessible control room.
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Because these steps can be performed from outside of the l
control room, the procedure should clearly indicate sach.
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Step II.C.59.a (Unit 2):
This step lists Unit i valve numbers.
AOP-10:
ABNORMAL CHEMISTRY CONDITIONS l
1.
Title:
The procedure title should be clarified to indicate that
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this procedure applies only to steam generator and condensate chemistry.
2.
Steps 4 & 5, pg 8:
Action is required in this procedure for immediate action if conductivity exceeds certain values.
Chemistry procedures RCP-1-211 and CP-217 do not require the chemistry
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technicians to report these values to operations.
OI-27E:
SMECO OFFSITE POWER STATION i
1.
Step V, pg 8 and 7 other locations within procedure:
l Add a caution to ensure that BOTH diesel generators that can i
supply the 4KV vital bus have their respective breaker I
controllers in PULL-TO-LOCK such that a diesel generator and SMECO cannot be paralleled unintentionally.
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Inspection Report Nos. 50-317/89-80 & 50-318/89-80
ATTACHMENT 3 ABBREVIATIONS & ACRONYMS AC Alternating Current ADV Atmospheric Dump Valve AOP Abnormal Operating Procedures BAST Boric Acid Storage Tank CCI Calvert Cliffs Instruction CE Combustion Engineering CEA Control Element d6sembly CEOG CE Owners' Group CFR Code of Federal Regulations CRO Control Room Operator CRS Control Room Supervisor CST Condensate Storage Tank CV Control Valve DC Direct Current DCRDR Detailed Control Room Design Review EDG Emergency Diesel Generator EFW Emergency Feedwater EOP Emergency Operating Procedures (as in RG 1.33)
EP Emergency Procedures (includes EOPs, AOPs, and referenced procedures)
ERG Emergency Response Guidelines ESF Engineered Safeguards Feature ESPAS Engineered Safeguards Features Actuation System F
Degrees Fahrenheit F/m Degrees Fahrenheit per minute FW Feedwater GTG Generic Technical Guidelines HPSI High Pressure Safety Injection I&C Instrumentation & Control INPO Institute of Nuclear Power Operations LCO Limiting Condition of Operation LOCA Loss of Coolant Accident Li'SI Low Pressure Safety Injection i
MSIV Main Steam Isolation Valve MSI Main Steam Line Isolation MOV Motor Operated Valve NLO Non-Licensed Operator NRC Nuclear Regulatory Commission OG Owners' Group OI Operating Instruction OP Operating Procedure PGP Procedure Generation Packege PSTG Plant Specific Technical Guidelines PORV Power Operated Relief Valve PWS Plant Watch Supervisor PSR Pressurizer QA Quality Assurance
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Inspection Report Nos. 50-317/89-80 & 50-318/89-80
ATTACHMENT 3 (cont.)
ABBREVIATIONS & ACRONYMS RCP Reactor Coolant Pump RCS Reactor Coolant System RG Regulatory Guide RO Reactor Operator RPS Reactor Protection System SER Safety Evaluation Report SFAC Safety Function Acceptance Criteria SGIA Steam Generator Isolation Actuation SPDS Safety Parameter Display System ST'
Senior Reactor Operator Sb Shift Supervisor STA Shift Technical Advisor TBD Technical Basis Document TS Technical Specifications V&V Validation & Verification WG Writers' Guide
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J ATTACHMENT 4 l
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LIST OF WEAKNESSES Item Paragraph Humber Description Number 50-317/
Policy that the EOPs were to be used as 2.0 89-80-01 guidance vice verbatim compliance.
50-317/
The CC EOPs were not-consistent with the 3.0 89-80-02 CEOG' guidance of recommended procedures; specifically,.there was not a procedure for loss of forced circulation.
50-317/
Resolution of technical concerns' identified 4.2 89-80-03 in Attachment 2 of the report.
50-317/
EOP-0 diagnostic aid was not consistent with 4.3.a 89-80-04 CEOG guidance; i.e.,
the' current aid was event based vice symptom based.
50-317/
EOP-8 does not include a section.for 4.3.b 89-80-05 recovery or restoration of vital auxiliaries.
50-317/
Labeling in the control room and in plant is.
5.1 89-80-06 (1) not consistent with the procedures or (2) missing.
50-317/
Inconsistencies exist between the simulator 6.4.d,e 89-80-07 and the control room.
&f 50-317/
The writers' guide contains-deficiencies.
89-80-08 7.3.a 50-317/
There is inadequate verification and
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89-80-09 validation associated with-the EOP. process.
7.3.b 50-317/
The procedures are lacking an adequate j
89-80-10 independent quality. review.'
7.3.c
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50-317/
The method of controlling copies of-a 89-80-11 procedures is inadequate.
7.3.d
50-317/
There are several disconnected organizations k
89-80-12 responsible for maintenance of the EOPs.
7.3.e
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