IR 05000324/1991011
| ML20138F740 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 04/11/1991 |
| From: | Breslau B, Russell Gibbs NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138F711 | List: |
| References | |
| 50-324-91-11, 50-325-91-11, NUDOCS 9610180051 | |
| Download: ML20138F740 (28) | |
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UNITED STATES pga R44q'o NUCLEAR REGULATORY COMMISSION
/ REclONil g 101 MARIETTA STREET,N.W.
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- ATLANTA, GEORGI A 30323 l \,*...*/. _ .
Report Nos.: 50-325 and 324/91-11 Licensee: Carolina Power and Light Company
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P. O. Box 1551 ( Raleigh, NC 27602
. Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Conducted: March 18 22, and April 1-5, 1991 Team Leader: Non h ~
11, 41 Ron Gibb's Date Signed Inspectors: B. Breslau L. King D. Roberts Approved by: # = 4 N //d/
%. A. Br'eslau, Thief DMe Sign'ed Operational Programs Section, r Division of Reactor Safety SUMMARY Scope:
This routine, announced inspection was conducted in the area of follow-up for the Diagnostic Evaluation Team (DET) findings. This inspection also reviewed previously identified Emergency Operating Procedure (EOP) deficiencies, evaluated the current E0Ps, and reviewed the licensee's corrective actions related to the Safety Evaluation (SER) for tiie licensee's Procedure Generation Package (PGP).
Results:
In the area inspected, no violations or deviations were identified. The licensee's progress in accomplishing the Integrated Action Plan (IAP) to the NRC DET Inspection was satisfactory. The team determined that an extensive effort was applied to revising the E0Ps to meet Revision 4 of the Boiling Water Reactor Owners Group Guidelines. The corrective actions for previously identified findings were thorough and generally corrected previous weaknesses. Review of the licensee's E0Ps noted only minor deficiencies, most of which had been previously identified by the licensee's own validation and verification program.
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9610180051 910416 PDR ADOCK 05000324 0 PDR
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Review of the licensee's corrective actions for the SER on the PGP closed all concerns raised by the SER. The team concluded that the E0Ps would adequately mitigate the consequences of a broad range of accidents and multiple equipment failures, (
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i REPORT DETAILS
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i 1. Persons Contacted
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Licensee Employees i * K. Altman, Regulatory Compliance Manager M. Barton, Senior Reactor Operator
, T. Bradford, Auxiliary Operator
- S. Callis, Licensing Site Representative
C. Cashwell, Reactor Operator
- J. Cribb, QC Manager
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W. Culver, Senior Specialist, Training
D.
Dearie,
Senior Specialist, Operations
! * M. Foss, Regulttory Compliance Supervisor D. Gainvors, Senior Specialist, Training R. Gibbs, Shift Technical Advisor T. Ginn, Reactor Operator
- W. Guise, Training Instructor K. Horn, Shift Foreman
- T. Jones, Sr. Specialist, Regulatory Compliance R. Jones, Reactor Operator .
S. Loose, Senior Specialist, Training i W. Mack, Regulatory Compliance Specialist R. Mayhew, Senior Specialist, Operations L. Modlin, Auxiliary Operator
- J. Moyer, Operations Manager W. Nolan, Shift Technical Advisor Supervisor B. Pergerson, Auxiliary Operator
- B. Polk, Operations Training Manager
- W. Simpson, Control and Administration Manager
- J. Spencer, General Manager W. Tyner, Senior Reactor Operator
- K. Williamson, Engineering Manager (NED)
i Other licensee employees contacted during this inspection included engineers and administrative personnel.
NRC Resident Inspectors
- R. Prevatte, Senior Resident Inspector B. Levis, Resident Inspector D. Nelson, Resident Inspector l
- Attended exit interview -
Acronyms used throughout this report are listed in Appendix E.
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! 2. Review of E0P concerns _. _ _ ___
This inspection was conducted to review the licensee's progress. in the area of Emergency Operating Procedures (E0Ps). The inspection included a review of previously identified E0P concerns, a review of the corrective actions for the Safety Evaluation (SER) on the licensee's Procedure Generation Package (PGP), walkthrough of the Rev. 4, EPG E0Ps', and observation of the use of the E0Ps in the site specific simulator. The
- results of this inspection were as follows
a. Control Room and Plant Walkthrough of E0Ps
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The inspection included a review of the Rev. 4, EPG E0Ps by a physical walkthrough of a sample of the flow charts and supplemental
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procedures in the plant. The details os this walkthrough are
provided in Appendix B of this report. Th( walkthrough of these flow charts / procedures noted only minor teckical and human factcrs deficiencies, most of which had been preiiously identified by the licensee's own E0P verification and v4 idation program. All of the items identified in the Appendix are covered in the licensee's tracking system for resolution. No additional followup of these items is required. .
b. Simulator Scenarios The inspection team observed six simulator scenarios involving the .
use of the E0Ps (see Appendix A for the list of scenarios observed). l The scenarios were extremely challenging, and the E0Ps worked well in mitigating the malfunctions and failures. The observed crew responded adequately to all of the scenarios with the exception of scenario LOR-IP0-28. In this scenario the crew did not recognize the inoperability of the SRVs until late in the scenario, and, as a result, had difficulty in maintaining plant pressure and RPV level which caused delay in resolving the containment hydrogen problem.
As a result, hydrogen increased to approximately 12 percent before the crew was able to get substantially involved in its reduction.
The team concluded, however, that the E0Ps, themselves, would adequately mitigate the consequences of a broad range of accidents and multiple equipment failures, c. Review of SER on the PGP The team conducted a review of the SER on the PGP. This review was conducted to determine if the licensee had accomplished corrective actions to resolve the concerns identified by the SER. The details of this review are provided in Appendix C. Nearly all items in the SER had been adequately resolved. The few remaining items pertained to deficiencies in the E0P writer's guide. These items had been included in a draft revision to the guide which was being routed for final approval. No additional followup in this area is warranted.
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d. Review of IR 88-200 concerns Inspection report 88-200 provided the results of the initial review l of the licensee's E0Ps. The team reviewed the current E0Ps to
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determine if the deficiencies identified in IR 88-200 had been corrected during development of the Rev. 4. EPG E0Ps. The details
- of this review are provided in Appendix D of this report. All items
identified in IR 88-200 had been adequately addressed except three.
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These three items were included in the licensee's tracking system a for resolution. No additional followup of these items is warranted.
3. Action on Previous Inspection Findings (92701)
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j The following items from the- NRC Diagnostic Evaluation Team (DET)
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inspection were reviewed for closure during this inspection:
a. (Closed) Inspector Follow-up Item 50-325,324/88-19-03, No site
- documentation available to. justify not concurrently performing
, actions for power, level and pressure control according to BWROG.
The team found the licensee's PSTG upgrade to the BWROG Rev. 4 guidelines currently follow the EPG actions for concurrently performing actions for power, level and pressure control. The
! licensee E0Ps utilized the reactor scram procedure to prioritize
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certain actions and required sequential accomplishment of those actions ' prior to entry to the concurrently executed EPG-based i procedures. The scram procedure provided initial action steps for f
stabilizing the reactor after a manual or automatic scram. If the
- prescribed actions did not result in a stable condition, the procedure directed the operator to enter the Reactor Vessel Control Procedura or the Level / Power Control Procedure. These procedures
- were designed to provide the appropriate actions regardless of the
! type or severity of the incident. Thus, this methodology meets the
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intent of the ERG. This item is closed.
j b. (Closed) Inspector Follow-up Item- 50-325,324/88-19-04, Steps i accepted in PSTG verbatim from BWROG did not appear in the E0P flowcharts and steps existed in flowcharts that are not documented as to safety impact.
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- The licensee approached the incorporation of Rev. 4 of the BWROG
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ERGS by addressing each step of the ERG in their PSTG. Each step of the ERG was adequately addressed in the PSTG; when deviations were taken in the PSTG, technical justification was provided. The team i also noted that when the E0Ps differed from the PSTG, the licensee
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i provided documentation adequately substantiating the actions taken.
This item is closed.
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L c. -(Closed) Inspector Follow-up Item 50.325,324/89.-34-17, Follow-up on
, implementation and effectiveness of Technical Specifications (TS)
i data base accuracy sample (Reference DET paragraph 2.1.4.1 and IAP 3 item D1.a).
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! This item concerned a weakness noted by the DET in the
! implementation of the surveillance tracking and scheduling system
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(STSS) regarding the accuracy of the STSS data base. The team i concluded that this system was an effective means of scheduling and
! tracking technical specification surveillance, but that this system j
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was not periodically verified to ensure that all TS surveillance
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requirements were tracked by the STSS.
!- As a result of the DET finding, the licensee committed to establish i a sampling program to test the data base integrity. A plan was
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established as an enclosure to an implementation guide for STSS lata
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base verification. This plan involved the performance of a 100 j percent line-by-line verification that the TS surveillance
- requirements listed in Unit 2 TS were included in the STSS data
- base. Subsequent to this verification, a report detailing the
- results of the review and providing recommendations concerning a a similar review for Unit 1 and/or an ongoing long-term program would i be prepared. The completion date for this report was scheduled as
, March 1, 1991. Although this action did not establish a definite
', ongoing periodic review, it would establish a baseline. Procedural controls exist to ensure that additional TS test changes and procedure changes are incorporated into the STSS.
This inspection determined that the review of the Unit 2 TS against the STSS was complete and the report of the results has been issued.
A number of deficiencies with the data base were identified which were not considered to be safety significant. As a result of those deficiencies, the licensee intends to accomplish the following corrective actions:
1) The deficiencies noted by the review will be corrected in the Unit 2 data base, 2) an additional review and validation of each database revision has been implemented by Regulatory Compliance, and 3) a review of the database accuracy for Unit 1, similar to the Unit 2 review, will be conducted. This review is scheduled for completion by December 31, 1991.
Review of the Unit 2 results by the inspectors determined that there were no cases identified where a TS surveillance was missed, or was not performed in accordance with the required frequency, due to STSS data base inaccuracies. Although there is some chance that the Unit I review will . identify a safety significant finding, the probability of this occurrence is considered very low. As a result, i
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- followup of the Unit I results will not be performed orior to closeout of this item.-The licensee's actions to date anc planned actions are considered sufficient to adequately resolve the DET i concern. This item is closed.
i d. (Closed)InsaectorFo'. low-upItem 50-325,324/89-34-26, Follow-up on
results of lucensee's review of recently issued procedures to ensure
! intent of Procedures Administration Manual (PAM)(Reference DET l paragraph 2.1.4.4 and IAP item D13).
As part of the Brunswick Improvement Plan (BIP) in 1982, a l commitment was made to the NRC to establish a nuclear procedure j governing the standardization and preparation of plant procedures.
This was completed in June 1983 with the issuance of the PAM.
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During the spring of 1989, the DET determined that the PAM was not i being implemented effectively. The team noted that there was 1 inconsistency between the PAM and the Plant Operating Manual i
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Administrative Procedure (P0 MAP). Additionally, an inconsistency between the POMAP and the Maintenance Unit Procedure (MVP) was noted
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in that the POMAP did not require a safety evaluation for a
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temporary revision and the MVP did.
! As a result of the DET findings, the licensee committed to conduct a review of recently issued procedures to determine if the
- procedures met the intent of the PAM and to initiate corrective actions, as necessary. The licensee's review concluded that, in
, general, progress had been made in bringing procedures into consistency with the PAM, particularly procedures issued since
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July 1, 1989. However, some inconsistencies were the result of
- inattention to PAM formatting criteria.
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- In order to correct the deficiencies noted by the DET and the
, licensee's own review of this area the licensee initiated several
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corrective actions:
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1) Revision of the site Administrative Procedure to clarify and j strengthen the site's adherence to the PAM.
I 2) Instruction to the BNP Unit Manager's to reinforce adherence I to the PAM.
l 3) Revision of BSP-01, Processing of Site Procedures, to reflect i
the site's intention to write procedures in accordance with the PAM.
4) Revision of Procedure Technical / Safety Reviewer Training to incorporate the need to write procedures in accordance with the PAM.
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5) Revision of implementing instructions for writing of
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procedures to place more emphasis on writing procedures in accordance with the PAM.
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6) Revision of the technical evaluation checklist for procedure {
- -review to include requirements for verifying that procedures are written in accordance with the PAM. ,
7) Review and revision of the PAM to make it a more usable !
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document.
8) Revision of the instructions for ANSI N18.7 reviews to require a check for compliance to the PAM. j NRC inspections documented in inspection reports 90-21 and 90-39, as l well as this inspection, have reviewed these corrective actions for i completion and have assessed the overall effectiveness of these actions. Although all site procedures are not currently written in accordance with the PAM, the mechanisms discussed above have been ;
put in place which will ensure long-term compliance with the PAfl. j Review of the licensee's effectiveness reports indicates an i improving trend in compliance with the PAM. As a result, corrective !
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actions in this area are considered sufficient to resolve the DET concern. This item is closed.
i e. (Closed) Inspector Follow-up Item 50-325,324/89-34-32, Follow-up on adequacy of Emergency Operating Procedure (EOP) revisions and validation / verification (V&V)(Reference DET paragraph 2.1.2.8 and IAP item D28).
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This item noted that the E0Ps were not consistent with the Boiling !
Water Reactor (BWR) Owners Group Emergency Guidelines (OGEG). The 1 procedure format prioritized operator actions according to a predetermined significance and incorporated specific response strategies such as post-scram recovery and implementation of accident mitigation actions during execution of the E0Ps on the simulator.
The licensee's previous response to this issue included action which encompassed revisions to the E0Ps to simplify and match BWR OGEG by preparing a Plant Specific Technical Guideline (PSTG), writer's guide, writing procedures, and performing V&V with subsequent incorporation of changes identified during the V&V process.
Following this process, the licensee would conduct training and/or follow-up training if required. The training process would be utilized to identify needed changes, as well as, enhancing operator E0P familiarity. Additionally, the licensee's response included an agreement to improve the on-going evaluation program to ensure the up-dated E0Ps remain an effective tool for the operators.
The inspection team determined that the E0Ps had completed V&V with changes being incorporated in October 1990. The team found the V&V process to be thorough and comprehensive. The updated procedures had been exercised by each shift, receiving adequate critiques with subsequent procedure changes being incorporated. Al so, the inspection team observed simulator exercises (discussed in section
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2.b above). The exercises observed were determined to provide adequate accident mitigation, with the E0Ps providing the operators with flow charts that facilitated symptomatic assessment. This item is closed.
4. Exit Interview The inspection scope and results were summarized on March 22, 1991 and April 5, 1991, with those persons in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection results listed below. Proprietary information is not contained in this report. Dissenting comments were not received from the licensee. '
Item # Status Description 325,324/88-19-03 Closed IFI, Review of justifications for not performing actions according to BWROG (paragraph 3.a)
325,324/88-19-04 Closed IFI, Review of inconsistencies between the PSTG and the E0Ps (paragraph 3.b)
325,324/89-34-17 Closed IFI, Implementation and effectiveness of -TS data base accuracy sample (ptragraph 3.c) l 325,324/89-34-26 Closed IFI, Results of licensee's review of recently issued procedures to ensure intent of PAM (paragraph 3.d)
325,324/89-34-32 Closed IFI, Adequacy of E0P revisions and validation / verification (paragraph 3.e)
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j Appendix A i Procedures Reviewed
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The following documents were reviewed to assess the licensee's upgrade to Rev.
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4 of the Owner's Group Emergency Procedure Guidelines:
- 01-02, Rev. 041 Shift Turnover Checklist i 01-03.4, Rw. 028 Daily Check Sheets j 01-03.5, Rev. 004 Radwaste Daily Check Sheets i 01-28, Rev 018 Preparation and Review of Operations Procedures 01-37, Rev. 012 Preparation and Review of the Plant Specific Technical
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Guidelines 01-41, Rev. 008 Operator Aids 01-61, Rev. 001 Emergency Operating Procedure Verification and i Validation j OP-10, Rev.018 Standby Gas Treatment System Operating Procedure j EPG, Rev. 4 BWROG Emergency Procedure Guidelines A0P-36 Rev.01 Loss of Offsite Power
A0P-36.1, Rev.01 Loss of 4KV Buses
. E0P-01-UG, Rev. 13 User's Guide l E0P-01-LEP-01, Rev. 9 Alternate Coolant Injection E0P-01-LEP-02, Rev. 9 Alternate Control Rod Insertion E0P-01-LEP-03, Rev. 7 Alternate Boron Injection
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E0P-01-RSP, Rev. O Reactor Scram Procedure
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E0P-01-LVP, Rev. 8 Level /PowerControl
- E0P-01-RVCP, Rev. O Reactor Vessel Control Procedure E0P-02-PCCP, Rev. 2 Primary Containment Control Procedure
! E0P-01-PCFP, Rev. 2 Primary Containment Flooding Procedure i E0P-04-RRCP, Rev. 2 Radioactive Release Control Procedure l E0P-03-SCCP, Rev. 1 Secondary Containment Control Procedure
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E0P-01-RXFP, Rev. 4 Reactor Flooding Procedure E0P-01-SEP-01, Rev. 6 Primary Containment Venting
! E0P-01-SEP-02, Rev. 4 1rywell Spray Procedure j E0P-01-SEP-03, Rev. 3 Suppression Pool Spray Procedure j E0P-01-SEP-04, Rev. 3 Reactor Building HVAC Restart Procedure
> E0P-01-SEP-05, Rev. 5 Primary Containment Purging l E0P-01-SEP-06, Rev. 2 Shutdown Cooling Following Boron Injection E0P-01-SEP-07, Rev. 1 Bypassing RWCU Filter Demineralizers
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E0P-01-SEP-08, Rev. 1 Restoration Procedure
! E0P-01-SEP-09, Rev. O CRD Flow Maximization
- E0P-01-SEP-10, Rev. 2 Jumper Installation Procedure
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Simulator Exercise Guides LOR-IP0-6, Rev. O Simulator Exercise Guide: Fire, Loss of UPS, ATWS without SPDS, Emergency Depressurization, Loss of HPCI and RCIC
! LOR-IPO-10, Rev. O HPCI Failure to Transfer on Low CST Level, Loss of
, Feedwater Heating, Fuel Element Failure, RCIC Steam Line 2 Break with a Failure to Isolate, Emergency
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Depressurization
< LOR-IP0-23, Rev. O Seismic Monitor Failure, Recirc Discharge Line Leak in i Drywell, Failure of Drywell Sprays, Downcomer Failure J
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and Emergency Depressurization LOR-IP0-24, Rev. O Sealed Source Contamination, Circulating Water Leak in:--
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tho Turbine Building, Electrical Problem ATWS, HPCI ~
Injection Valve Failure' Large Break LOCA, Core Spray-Loop Injection Failure LOR-IP0-27, Rev. O Loss of SRV Operability, Small Break LOCA with Fuel Failure, Hydrogen Generation, Primary Containment Venting LOR-IPO-28, Rev. O CRD Pump Shaft Seizure, Loss of E4, Stuck open SVR, ATWS i
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Appendix B _
l i Comments on Rev. 4 EPG E0P Walkthroughs i
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1. E0P Flowcharts ,
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l l General comment: Fourteen notes and three critical steas pertaining to ;
l emergency depressurization of the reactor were shader orange on the i
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l flowcharts, however this coloring scheme was not described in either the l E0P user's guide or the writer's guide. This item was previously I identified by a licensee-initiated audit and was being tracked to resolution.
l 2. E0P-01-SEPs, Supplemental Emergency Procedures
! a General comment: Whenever the SEPs direct installation of jumpers i or LIFT and TAPE of specified wire terminations, the procedure fails
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i to direct the operator to either the front or back of the panel, l
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One operator was observed gaining access to the back of the panel to ;
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the correct location of the terminal board was located in the front l of the panel. '
b. Reference to obtaining SOS signature was observed within the SEPs.
This position has been redesignated as the SF. Further discussion with the licensee indicated that this item was previously identified l
and was being tracked to resolution. ;
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l 3. E0P-01-SEP-06, Shutdown Cooling Following Boron Injection Step 28 directs the operator to monitor RHR warm-up line temperature on E11-TI-3149 on panel XU-51. This indicator is located on panel 601, not XV-51. Further discussion with the licensee indicated that this item was i
previously identified and was being tracked to resolution.
l 4. E0P-02-PCCP, Primary Containment Control Procedure a. Subset PC/P Lists. the instruments used to determine suppression chamber pressure. It does not list instrument CAC-PI-1230. Further discussion with the licensee indicated that this item was previously identified and was being tracked to resolution, b. Subset PC/H Step PC/H-4 directs the operator to read oxygen and hydrogen on CAC-AT-4409 and 4410 which requires several hand calculations to be performed to compensate for primary containment conditions. It does not direct the operator to ERFIS which does not require compensation.
5. E0P-01-LEP-02, Alternate Control Rod Insertion i
a. Step 4b., page 5 and step Ig., page 13 direct the operator to place i the REACTOR MODE SWITCH to " REFUEL" to accomplish individual rod
, insertion, however the Rod Sequence Control System for which this i action was necessary has been removed from both units and this step
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Appendix B 2 is no longer required. Further discussion with the licensee indicated that this item was previously . identified and was being tracked to resolution.
b. Step Id. on page 14: The caution for this step appears four steps prior to the step.
6. E0P-01-LEP-03, Alternate Boron Injection Step d. on page 7 requires the operator to connect one end of the vent rig to the condensate supply header vent valve,1(2)-CO-V304. Both unit's valves are located in areas which are difficult to reach. Further discussion with the licensee indicated that this item was previously identified and was being tracked to resolution.
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Appendix C Details of the SER on the PGP This enclosure provides the details 07the closeout of the SER action items issuert as a result of the licensee's submittal of their PGP. Item numbers in this enclosure correspond to the paragraph numbers in the SER.
-Item A: The E0Ps, PSTG and Deviation Documentation should be brought up to date in accordance with Rev. 4 of the EPG. The licensee has revised the E0Ps and associated documentation to be in compliance with Rev.
4 of the EPG. Validation and Verification of the E0Ps and training of operators in the new E0Ps has also been completed. This item is l closed.
l Item B: Writers Guide Comments:
B.1 The example shown in figure 1 of the writer's guide was not compatible with the requirements of the guide itself. The subject i figure 1 of the writer's guide has been deleted. Review of the l current writer's guide did not note any similar deficiencies. This item is closed.
B.2 The writer's guide did not discuss color coding of the flow charts.
The current writer's guide discusses color coding. This item is closed.
l l B.3 Figure 1 has information or caution symbols placed at the end of the flow chart after action steps. The writers guide should state that information or caution symbols should be placed before the step to which they apply. The current writer's guide includes a requirement that information and cautions be included prior to the step to which they apply. The subject Figure I has also been deleted. This item- i is closed. l l
B.4 Figures 1 and 6 of the writer's guide were illegible or difficult to l read. Review of the current writers guide did not note any l illegible or hard to read areas. This item is closed.
B.5 The writer's guide should be revised to address the following concerns regarding logic terms:
B.S.a The writers guide should specifically discuss the diffe ence between conjunctions and logic terms. This item has been addressed in a draft revision of the writers guide. Issue of i the revised writers guide is being tracked to completion by i FACTS item 9180438. This item is closed.
B.5.b In one example the logic term IF was not underlined for i emphasis. This item has been corrected. This item is closed.
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B.S.c The example and guidance provided for combining 8ND and 98 in j the writer's guide did not agree. This item has been addressed in a draft revision of the writers guide. Issue of l
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l Appendix C 2 the revised writer's guide is being tracked to completion by )
FACTS item 91B0438. This item is closed.
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B.S.d In explaining the combination of logic terms the writer's ,
- guide included an incomplete explanation of the combination of l AN_Q and 98. This item ha
- , been corrected in paragraph 4.7.2.e of the current writer's guide. This item is closed.
B.5.e CANNOT is not included in the t :of logic terms, however, examples in the writer's guide hasize CANNOT as though it were a logic term. This item has been addressed in a draft
! revision of the writers guide. Issue of the revised writer's
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guide is being tracked to completion by FACTS item 91B0438.
This item is closed.
B.S.f The writer's guide should be revised to indicate that "unless" will not be used as a logic term in E0Ps. Review of the I
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current revision of the writer's guide determined that this problem has been corrected. This item is closed. >
t l B.6 The writers guide should be revised to address the following l l concerns regarding referencing and branching: !
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! B.6.a There was an inconsistency between the writer's guide and the l verification and validation checklist concerning referencing l l and branching. This item has been corrected. This item is closed.
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B.6.b The writer's guide should provide specific criteria for when
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requirements are included in the text or are referenced. The t
length of a referenced segment is a possible criteria. Review of this issue determined that the length of statements is not specified, however, the guide has been revised to specify that l statements should be kept as simple as possible containing,
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where possible, only one thought or action. This item is closed.
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B.6.c To aid in referencing, the writer's guide should specify some method, such as tabbing, for easily identifying sections or subsections in end path procedures. End Path procedures no longer exists. Similar text procedures are now tabbed. This item is closed.
B.7 The writer's guide should include instructions for writing the various types of action steps that an operator may take to cope with different plant situations: i
B.7.a The writer's guide should define, discuss and provide examples for the time-dependent steps, concurrent steps, diagnostic steps,etc. The current revision of the writer's guide defines
- the types of steps addressed in this item, however, examples
are not provided. This item has been addressed in a draft
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Appendix C 3 l revision of the writer's guide. Issue of the revised writers
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guide is being tracked to completion by FACTS item 9180438.
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This item is closed.
B.7.b The writer's guide should provide the format and examples for the types of action steps in item B.7.a above. The current 1 revision of the writer's guide defines the types of steps l addressed in this item, however, examples are not provided. i This item has been addressed in a draft revision of the writer's guide. Issue of the revised writers guide is being tracked to completion by FACTS item 9180438. This item is closed.
B.7.c The text of the writer's guide and an example used were inconsistent concerning prov' ding a check off list in cases where three or more objects were used. The incorrect example
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has been removed from the current revision of the writer's guide. This item is closed.
B.8 The writer's guide should be revised to specify the location of printed operator aids. The current revision of the writer's guide provides guidance on the location of figures, table" and operator aids. This item is closed.
B.9 The discussion of flowcharts in the writer's guide should be revised with regard to the following:
B.9.a The writer's guide should specifically address the level of detail to be included in the flowcharts. Review 'of the i writer's guide and the E0P flow charts determined that sufficient guidance for the level of detail is provided in the writer's guide and the amount of detail on the flow charts appears to be appropriate. This item is closed.
B.9.b The writer's guide should discuss the format for the different connecting lines on flowcharts. The different types of connecting lines are not used in the Rev. 4 EPG E0Ps.
Therefore, no guidance is necessary in this area. This item is closed.
l B.9.c The writer's guide should discuss placekeeping aids for l flowcharts. This item has been addressed in a draft revision I of the writer's guide. Issue of the revised writers guide is being tracked to completion by FACTS item 9180438. This item is closed.
B.9.d A section of the writer's guide stated that flowcharts may be I reproduced on a standard blueprint copier but failed to
' discuss how the color coding would be maintained using this
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process. The flowcharts are no longer manufactured the way i the writer's guide described the process. Original Vellum copies plotted on a commercial grade plotter are mounted for
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Appendix C 4 use in the control room to preserve the color. Copies which are reproduced on a blueprint copier and have no color are used for purposes other than operators responding to emergencies. This item is closed.
B.9.e The' writer's guide discussed reducing the size of the blue print copies, thereby, reducing the size of the print. The writer's guide should include requirements to ensure the size of print is legible even under degraded lighting conditions.
The flowcharts are no longer manufactured the way the writer's guide described the process. Original Vellum copies plotted on a commercial grade plotter are mounted for use in the control room. Review of these charts determined that the l legibility of the charts was more than adequate. This item is l closed. '
B.9.f The writer's guide should provide guidance for the formatting, I'
placement and referencing of tables. Review of the current revision of the writer's guide determined that requirements concerning the use of tables has been included. This item is closed.
B.9.g The writer's guide should discuss the format for providing location information for infrequently used equipment. No change to the writer's guide was made in this area. However, no unclear examples of location information were noted by the inspectors during walkthrough of E0Ps and supplemental procedures. This item is closed.
B.10 Additional writer's guide comments conce'ning cautions and notes:
B.10.a A unique method of highl'ghting cautions should be provided. Cautions are sfill included in information blocks, however, the blo'.k is bolded in red. This requirement has been inc* uded in the writer's guide.
This item is closed.
B.10.b The validation and ver fication document addresses precautions but precautions are not discussed in the writer's guide. Precautions have been deleted from discussion in the validation and verification document.
This item is closed.
B.11 The writer's guide should be revised to Nrther address procedure titles:
B.11.a The writer's guide stated that proceat.;a cover sht &
will include a descriptive title, however, U.c ey3 mole
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of the cover sheet provided in the writer's guide diu not have a descriptive title. The example in the current writer's guide does show a descriptive title.
This item is closed.
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Appendix C 5 B.ll.b This item was the same as item 8.11.a except it referenced a different figure in the writer's guide. -
The referenced figure has been changed and is now '
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correct. This item is closed, i
B.12 The writer's guide should state that each caution statement should contain one and only one topic. This ites has been addressed in a draft revision of the writer's guide. Issue of the revised writers guide is being tracked to completion by FACTS item 9180438. This item is' closed.
B.13 The following concerns were noted regarding emphasis techniques:
! * B.13.a The writer's guide stated that underlining may be used l for " Miscellaneous emphasis". The overuse of
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underlining would detract from emphasis in the E0Ps.
This item has been addressed in a draft revision of the writer's guide. Issue of the revised writers guide is bei?g tracked to completion by FACTS item 91B0438. This l item is closed.
i B.13.b Capitalization discussed in the writer's guide should be specifically defined and examples should be consistent with this definition. This ites has been corrected in
! the current revision of the writer's guide. This item
! is closed.
B.13.c Action verbs were capitalized in the examples in the Writer's guide but this use of capitalization was not discussed in the writer's guide text. This ites has been corrected in the current revision of the writer's guide. This item is closed.
B.14 The following concerr.4 were noted regarding vocabulary, syntax, and punctuation:
B.14.a The writer's guide should be expanded to provide a list
,
of words that should be avoided. No change was made by l the licensee as a result of this comment. The writer's
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guide provides lists of acceptable terms to use. Review of the E0Ps by the inspectors did not identify any verbiage that was unclear or confusing. This item is closed.
B.14.b This item was essentially the same as B.14.a. No change was made. This item is closed.
B.14.c The writer's guide should require that only verbs from
- the approved list should be used unless there is no verb
- on the list that conveys the correct meaning. This item i has been addressed in a draft revision of the writer's l guide. Issue of the revised writers guide is being
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tracked to completion by FACTS item 91B0438. This item is closed. __ - _ _ _ _ . _
B.14.d The writer's guide should require that instruction steps be written as directives in the imperative mode. The current revision of the writer's guide includes this requirement. This item is closed.
B.14.e The writer's guide included three examples of incorrect usage of hyphenation. This item has been addressed in a draft revision of the writer's guide. Issue of the revised writers guide is being tracked to completion by FACTS item 91B0438. This item is closed.
B.15 The following concerns were noted regarding action steps:
l B.15.a The writer's guide should require that an action step be wholly contained on a single page. The current revision of the writer's guide includes this requirement. This i item is closed.
B.15.b The writer's guide should be revised to address physical interference between personnel, duplication of tasks, 1 etc. This item is addressed by requirements in the current writer's guide. This item is closed. ,
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B.16 The writer's guide should state that page rotation should be l minimized. This item has been addressed in a draft revision of the l writer's guide. Issue of the revised writers guide is being tracked l to completion by FACTS item 9180438. This item is closed.
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B.17 This item addressed a typo in the writer's guide which has been corrected. This item is closed.
l Item C: Verification and Validation Program
C.1 The description of the validation / verification program should be revised with regard to the following:
l C.I.a The verification / validation program should specify how the E0P
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committee will maintain the E0Ps and should include the general criteria for when verification / validation is or is not
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required. The current verification / validation procedure includes these requirements. This item is closed.
C.1.b The verification / validation program should address how verification and validation will be conducted in the future.
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The current procedure for verification / validation describes how E0Ps will be verified and validated in the future. This item is closed.
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Appendix C 7
, C.2 The verification / validation program should require -validation of E0Ps using the minimum control room staff required by technical specifications. The current Verification / validation procedure includes this requirement. This item is closed.
! C.3 The description of the verification / validation program should be
! revised with regard to the following:
l l C.3.a The verification / validation program should state that I l simulator exercises are the primary means of validation. The program procedure includes this requirement. This item is closed.
l C.3.b The verification / validation program should state that the E0Ps l
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will be re-validated on the plant specific computer once it is i available. No change in the program was needed. Brunswick has had a simulator for some time. This item is closed. j C.4 The verification / validation program should require that walkthroughs l be conducted in each unit's control room and should describe how technical differences between units will be handled. The current
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Verification / validation irocedure includes appropriate requirements in these areas. This item is closed.
l l Item D: Training Program:
D.1 The training program should be revised to indicate that all operators will be trained on the current version.of the E0Ps before going on shift. Review of the training program for licensed and non-licensed operators determined that requirements exist which l require licensed operators to be trained in all of the current E0Ps l prior to assuming a watch in the control room (Reference BSEP/Vol.
l 1, Book 3/TI-104 and TI-201). This item is closed.
l D.2 The training program description should be expanded to discuss the method used to train the operators in the areas where the simulator
! differs from the plant. Also the program should require j walkthroughs in E0Ps that cannot be run on the simulator. The
! training program discussed in item D.1 above requires training in
!
the E0Ps via either the simulator or plant walkthrough and also includes provision for plant and simulator differences. This item is closed.
D.3 The training program description should indicate that operators will be trained to use E0Ps as a team and that each operator will be trained in the role he would be expected to take in an actual
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emergency. This requirement has been added to BSEP/Vol. I, BocL l 3/TI-200. This item is closed.
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D.4 There was no item D.4.
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Appendix C 8 l D.5 Training program objectives should include an approach to training l
to ensure that trainees will:- -
D.5.a understand the philosophy of the E0Ps.
D.5.b understand the mitigation strategy and technical bases of the E0Ps.
D.S.c have a working knowledge of the technical content of E0Ps.
D.5.d be able to execute the E0Ps under operational conditions.
These program objectives have been included in BSEP/Vol. I, Book 3/TI-200. This item is closed.
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Appendix D Closeout of IR 88-200 items
- Thisenclosurearovides5hedetailsofthecloseoutoftheIR88-200 concerns identified in tie original E0P inspection at Brunswick. Item numbers in this enclosure correspond to the paragraph numbers in the inspection report. The inspectors reviewed all of the findings identified in IR 88-200 and the licensee responses transmitted by licensee letter, serial no.BSEP/89-0288, dated March 29, 1989 and consider the findings closed. The inspectors selectively reviewed the licensee documentation to support the responses to IR 88-200 and the details are listed talow.
Paragraph 3, Detailed Inspection Findings 3.1 E0P Program Evaluation 3.1.1,Pg 2 This paragraph discussed difficulty in the shift foreman l implementing the E0Ps without the assistance of the STA i to monitor and control E0P actions involving primary )
containment and radiological release control. Operating Instruction 01-01, Operating Principles and Philosophy, Rev. 24, has been revised to address assisting the shift foreman during E0P execution and to include each persons responsibility during E0P execution. This item is closed.
3.1.1,Pg 3 This paragraph indicated that Primary Containment Control procedure step PC/H-4 indicated the hydrogen monitor readings must be compensated for primary containment conditions. The licensee will instruct the I operators to use ERFIS when available. This has the i'
necessary compensation taken into account. Use of operator aids has been evaluated and E0P-01-SEP-01 has been revised to provide the necessary guidance. This item is closed.
3.1.2,Pg 4 Ensure that all E0P steps are validated on a simulator or by an equally acceptable methodology. Three scenarios were developed to exercise all level control steps. Realistic time lines for RPV level response were developed. The time lines have been incorporated into the computer model of the simulator. The licensee has ,
This item is
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run the scenarios on the simulator.
closed.
3.1.3,Pg 5 Revise Administrative Instruction AI-95 to ensure training is addressed on future E0P revisions. Al-95 has been deleted. 01-61 now requires the E0P committee to determine the training requiremer ts. This item is closed.
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- 3.2 E0P Procedure Verification )
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3.2.lb,Pg 8 Caution No.1 in the Users Guide restricted the use of ,
j the wide range level instruments. The restrictions were 1 2 based on the-location of the reference legs and the )
The limitations
'
lack of temperature compensation.
placed on these instruments are conservative. PM 87-107
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- and 108 will provide temperature monitoring near these i reference legs which will allow a less restrictive limit
- to be used for these instruments. This item is closed.
4 3.2.1(7),Pg 11 The BWROG EPG entry condition for primary
) containment hydrogen concentration was the high
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alarm setpoint (2 percent). The PSTG entry
condition was set at the minimum detectable
- concentration of 1 percent. PMs88-048 and 88-l 049 reduce the alarm point to 1.5 percent, which j is the same as the E0P entry condition. This l item is closed.
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- 3.2.3,Pg 13 A technical justification that the drywell vent path had j 3 sufficient capacity to pass the decay heat load was not l
! performed. The licensee performed a calculation that showed that the vent flow through valves CAC-V9 and CAC-V10 had sufficient capacity. This item is closed.
3.2.3,Pg 14 The Primary Containment Flooding Procedure provided a method for operators to estimate the containment water level by using pressure instruments at the bottom of the drywell. Trending was required because the instrument would be submerged at low primary containment water levels. PM 87-109 installs a permanent pressure gage above the maximum containment water level. The pressure gage has been installed for Unit 1, however the Nuclear Engineering Department is reviewing the method used for temperature compensation. The procedures will be revised when this is complete. The completion of the procedures and the installation on Unit 2 are being tracked by the licensees regulatory compliance items 89B0404 for Unit I and 8980443 for Unit 2. This item is closed.
3.2.4,Pg 15 All figures, tables, and other supporting materials that may be required in the performance of a procedural step should be referenced explicitly in the E0P at the point at which the-information is required. The E0P Writers Guide has been revised to reflect the philosophy that a preferred source of information is referenced in the E0P's. This item is closed.
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Appendix D 3 3.2.4,Pg 16 A consistent method for numbering the E0P steps should be incorporated and documented in the PSWG. The numbering system has been revised to be consistent. The l
E0P Writers Guide has been revised as required. This i-item is closed.
3.2.5,Pg 17 The E0Ps referenced different units than those indicated on the instrument displays. The setpoint table has been removed from the radioactive release control procedure.
Operator aids have been installed on the service water '
l rad monitors and the reactor building roof vent monitor
! to indicate the alarm setpoint. An operator aid has been developed for the main stack rad monitor to tell l the operator what the units of the digital readout are in respect to what mode the monitor is in. This item is closed.
3.2.5,Pg 17 The E0Ps used verbs such as downrange, monitor, cycle,
,
and increase, which were not listed in Table 1 of the l PSWG as approved verbs. The E0P Writers Guide has been
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revised to include all action verbs. This item is l closed.
E0P Validation Using Plant Walkthroughs 3.3.1,6,Pg 18 Primary Containment Control procedure, step PC/P-
- 4, directed the operators to vent the primary l containment drywell through the standby gas i
treatment system (SGTS) in accordance with
!
Operational Procedure OP-10. This procedure only l
permitted venting - through two 1/2 inch lines l (valves V8 and V9) when drywell pressure was
! above .7 psig. In this mode of operation the l SGTS system vent path would have little or no effect on controlling primary containment
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pressure. The licensee should use the 18 inch
! vent damper (F-BFV-RB) for venting, at least l until the pressure in the SGTS train reaches the l limiting operating pressure. The licensee response did ~not address the major concern of pressure buildup, however the procedure did not intend this vent path be used for large pressure buildup. If the operator continues down in the logic of the procedure, step PC/P-17 allows venting by referring to E0P-01-SEP-01, Primary Containment Venting. The inspectors review of I revision 6 of the procedure showed that section 3 l l and 4 of the procedure addressed alternative j paths to be aligned if the pressure continues to build. This item is closed.
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Appendix D 4 2 3.3.1,ll,Pg 19 SEP-06, Shutdown Cooling Following Boron
' Injection, Rev.1, included entry conditions of
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drywell pressure which were below 2.0 psig. The procedure was actually implemented when the shutdown cooling interlocks were fulfilled at the corresponding drywell pressure of 1.8 psig. SEP-
- 06 entry conditions have been revised to be i consistent with the high drywell scram setpoint i of 1.8 psig. This item is closed.
3.3.2,3,Pg 20 During the E0P simulations, the control room
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operators directed the auxiliary operators to perform numerous actions in the plant. These a actions were initiated by the control room operator using the public address system and required the auxiliary operators to find a PA
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i station. Alternate comunication techniques, such as hand-held radios, were not available for comunicating with the operators. A license is i pending issuance from the (FCC) Federal 4 Comunications Comission which will permit operations on two repeaters, 39 portable radios, y
and one mobile radio. This ites is closed.
3.4 E0P Validation Using Plant Simulator
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) 3.4.1,Pg 23 During the simulator scenarios, the fourth scenario
,
required primary venting to control primary containment
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hydrogen concentrations. The loss of power to emergency bus E-3 unexpectedly resulted in the inability of the j operators to perform the primary containment venting 2 procedure because the torus purge exhaust valve, CAC V-l 8, was powered from emergency bus E-3. Further licensee action is needed to ensure that an alternate method is i
available to vent the primary containment during a
' partial loss of power condition. A0P-36.0 (Loss of Offsite Power) and A0P-36.1 (Loss of 4ky Buses) have
'
been developed to deal with A.C. power failures but not
- including station blackout. The combination of A0P-36.0
and 36.1 provide an alternate means to vent primary
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containment during partial loss of power conditions by t using the cross tie breakers between E busses. The
]
criteria for using the cross tie breakers has been established as E0P actions need to be performed and the
emergency bus can not be energized from offsite power or i onsite emergency diesel generators. This item is
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closed.
i 3.5 Operator Interviews
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Appendix D 5
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3.5.1,1,Pg 37 The operators experienced difficulties-. in .__ _
locating and reaching valves outside the cohtrol room. Specifically C0-V304 was difficult. to reach and RCIC CST suction valve C0-V301'needed to have better labeling. PID-G0065A has ~been issued to do preliminary engineering on accessing C0-V304. Operator aids have been hung on valves .
CO-V304 and CO-V301 to make them easier to l locate. This ites is closed. i 3.6 Primary Containment Venting Provisions
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I 3.6,Pg 39 The vent paths used hard piping, but low pressure l
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ducting was installed at transitions to the standby gas treatment system and the reactor building purge exhaust system fans. A recent evaluation by the licensee concluded that the pressure at the fan duct work could exceed acceptable limits and a further evaluation was in progress at the time of inspection. The i evaluation has been completed and determined the pressure at the purge fans to be approximately 36 psia. The Nuclear Engineering Department performed an analysis at 36 psia which resulted in the duct stresses exceeding code allowables.
Additional analysis might qualify the piping,
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however some leakage would be expected. The licensea closed the item based on the NRC issuing Generic Letter M-16 which encouraged utilities to voluntarily install a hardened vent under 10 CFR50.59. The licensee responded with letter, serial no NLS-89-291, dated 10/27/89, which committed to install a hardened vent by either January 1,1993, or during the second refueling outage from the date of the letter, whichever is later. The installation of the hardened vents for Units 1 and 2 are being tracked by the licensees regulatory compliance action items 8980856 and 89B8057. This item is closed.
3.6,Pg 27 The inspection team was also concerned about the ability of operators to establish a vent path during reduced power capability or station blackout conditions. Procedures are being developed for station blackout scenarios.
Alternate methods for venting containment on a loss of AC power will be included in these procedures. The licensee has completed a draft copy of A0P-36.2 Rev.0, Station Blackout.
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! The procedure is presently in tech _ review. The licensee is tracking this item under regulatory compliance item 89B0510. This item is closed.
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i Appendix E Acronyms
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ATWS Anticipated Transient Without Scram BIP Brunswick Improvement Plan BNP Brunswick Nuclear Plant BSEP Brunswick Steam Electric Plant BWR Boiling Water Reactor BWROG Boiling Water Reactor Owners Group CRD Control Rod Drive DET Diagnostic Evaluation Team E0P Emergency Operating Procedure EPG Emergency Procedure Guidelines HPCI High Pressure Coolant Injection IAP Integrated Action Plan LOR Licensed Operator Requalification 0GEG Owners Group Emergency Guidelines OPA Operational Programs Assessment PAM Procedures Administration Manual PGP Procedure Generation Package PID Project Identification Document PSTG Plant Specific Technical Guidelines l PSWG Plant Specific Writer's Guide QC Quality Control RCIC Reactor Coolant Isolation Cooling RliR Reactor Heat Removal RPV Reactor Pressure Vessel RWCU Reactor Water Cleanup SER Safety Evaluation Report SGTS Standby Gas Treatment System SRV Safety Relief Valve STA Shift Technical Advisor STSS Surveillance Tracking and Scheduling System TS Technical Specifications l
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