IR 05000327/1988014

Insp Repts 50-327/88-14 & 50-328/88-14 on 880208-12.No Violations or Deviations Noted.Major Areas Inspected: Evaluation of Licensee Resolution of Inspector Followup Items Re Emergency Operating Procedures

ML20151E256
Person / Time
Site:	Sequoyah
Issue date:	03/23/1988
From:	Lewis M, Shymlock M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151E246	List: IR 05000327/1988014 ML20151E242
References
50-327-88-14, 50-328-88-14, NUDOCS 8804150163
Download: ML20151E256 (22)

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ACCf00 UNITED STATES

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NUCLEAR REGULATORY COMMISSION REGloN 11

$ 101 MARIETTA STREET, * 's AT L ANT A, GEORGI A 30323 Jil

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9 . .d...f Report Nos.: 50-327/88-14 and 50-328/88-14 Licensee: Tennessee Valley Authority 6N38 A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and OPR-79 Facility Name: Sequoyah 1 and 2

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Inspection Conducted: February 8-12, 1988 Inspector: 'fN Owba 3// G / 8I M. Lewis, T' sam Leader 0' ate Signed Team Members: W. Dean P. Moore ApprovedM.by:j'ymiock, ChisfI]]_

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Operational Programs Section Division of Reactor Safety SUMMARY Scope: This special announced inspection was conducted to evaluate licensee resolutions of inspector followup items related to emergency operating procedure Results: No violations or deviations were identifie PDR O ADOCK 05000327 DCD

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REPORT DETAILS t Persons Contacted Licensee Erployees C. Benton, Simulator Training Section Supervisor

• T. Howard, Quality Services Supervisor

• G. Kirk, Compliance Licensing Manager

• A. Rosenberg, Engineering Assurance Engineer

• E. Slinger, Projects Manager

• S. Spencer, Nuclear Engineer

• G. Strickland, Nuclear Engineer

• J. Sullivan, P0RS Supervisor

• G. Terpstra, Program Coordinator

• J. Walker, Operations Support Group Manager

• B. Willis, Operations Superintendent Other licensee employees contacted included engineers, technicians, operators, and office personne OSP Attendees

• F. McCoy, Section Chief, Sequoyah NRC Resident Inspectors

• K. Jenison

"Attended exit interview on February 12, 1988 Exit Interview The inspection scope and findings were summarized on February 12, 1988, with those persons indicated in paragraph 1 abov The inspectors described the areas inspected and discussed in detail the inspection findings. In addition, the inspectors discussed the commitments made by the licensee as noted in paragraphs 4b, g, and h. No dissenting comments were received from the licensee. The item identified to the licensee as requiring completion prior to Unit 2 restart (Mode 2) is indicated below by the word "Restart "

Item Number Status Description / Reference Paragraph 327, 328/88-14-01 Open IFI - Resolution of items identified during review of the ECAs (paragraph 4b and Appendix A)

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327, 328/88-14-02 Open IFI - Operator training on ECAs, PAM instrumentation, and head vent system (paragraphs 4b, g, and h)

Restart 327, 328/87-61-02 Closed IFI - PGP revisions relating to E0P writers' guide. V&V, and operator training (paragraph 4a)

327, 328/87-61-03 Closed IFI - Review of implementation, or

/ justification for not imple-menting, ECA and ES procedures, including V&V and operator training (paragraph 4b)

327, 328/87-61-04 Closed IFI - Review of resolutions of findings identified during the technical aGequacy review of E0Ps (paragraph 4c and Appendix B)

327, 328/87-61-05 Closed IFI - Review of resolution of E0P items identified as variances from the writers' guide (paragraph 4d and Appendix C)

327, 328/87-61-06 Closed IFI - Review of resolutions for inspector findings with regard to V&V of the E0Ps (paragraph 4e and Appendix D)

327, 328/87-61-07 Closed IFI - Review of E0P setpoint calculations, and associated E0P revisions, V&V, and operator training (paragraph 4f)

327, 328/87-61-08 Closed IFI - Revision of E0P lesson plans and simulator training to emphasize use of qualified instrumentation (paragraph 49 )

327, 328/87-61-10 Closed IFI- Revision of E0Ps to reflect head vent system deficiencies (paragraph 4h)

3. Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection, 4, Licensee Actions on Previously Identified Inspection Findings (92701)

Units 1 and 2

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4 (Closed) Inspector Followup Item 327, 328/87-61-02, Procedures Generation Package (PGP) Revision The licensee's PGP was submitted to the NRC for approval on January 13, 1986. This PGP contained descriptions of programs and methods used to develop and maintain emergency operating procedures (E0P), and conduct operator training on the E0Ps. The NRC reviewed the licensee's PGP and identified several outstanding issues which are documented in inspection report number 327, 328/87-61 dated February 1,1988. The licensee then revised the PGP, and by letters dated January 15 and February 26, 1988, resubmitted the revised PGP to the NRC for review. The revisions to the PGP addressed specific concerns regarding the design differences between the Sequoyah units and the generic Westinghouse plant; the emergency contingency action (ECA) and event specific (ES) procedure development and/or upgrade; E0P setpoint selection and control; E0P maintenance measures; and the E0P writers' guide, validation and verification (V&V) program, and training program. The NRC completed its review of the revised PGP, and will be transmitting an SER to the licensee approving the revised PG The submittal of the acceptable PGP effectively resolves inspector followup item 327, 328/87-61-02, (Closed) Inspector Followup Item 327, 328/87-61-03, Implementation, or Justifications for Not Implementing, ECA and ES Procedure During a previous inspection of the licensee's E0Ps, the licensee made commitments regarding the development of additional ECA procedures and the modification of an ES procedure prior to Unit 2 restart (Mode 2). Specifically, the licensee committed to modify ES-0.3, Natural Circulation Cooldown, to provide an acceptable strategy to address vessel voiding; provide justifications for not writing ECA-3 3, SGTR Without Pressurizer Pressure Control, due to an upgrade of the pressurizer power operated relief valves (PORVs) to safety grade; and write and implement the following ECA procedures:

ECA-1.1, Loss of Emergency Coolant Recirculation, ECA-1.2, LOCA Outside Containment, ECA-2.1, Uncontrolled Depressurization of All Steam Generators, ECA-3.1, Steam Generator Tube Rupture (SGTR) With Loss of Reactor Coolant - Subcooled Recovery Desired, and ECA-3.2, SGTR With Loss of Reactor Coolant - Saturated Recovery Desire The licensee also committed to complete prior to Unit 2 restart (Mode 2), the V&V process and operator training for each new procedure implemente As noted in inspection report number 327, 328/87-61, the NRC has determined that controlled voiding into the reactor vessel upper head (OH) is an acceptable strategy provided it can be done using safety grade equipment with NRC approved procedures and licensed operators trained in the use of these procedures. The Westinghouse Owner's Group (WOG) ES procedures, ES-0.3, Natural Circulation Cooldown with Steam Void in the Vessel (with Reactor Vessel Level Indication System (RVLIST) and ES-0.4, Natural Circulation Cooldown

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with Steam Void in the Vessel (without RVLIS) constitute such a procedur The inspectors reviewed the licensee's revisions to ES-0.3, revision 3, and determined that the procedure provides the operator with an acceptable strategy for natural circulation cooldown while controlling voiding in the reactor vessel U This scrategy is equivalent to the use of the WOG guideline The inspectors concluded that the revisions to ES-0.3 resolve the licensee's commitments in this are With regards to the licensee's commitment to provide justification for not writing ECA-3.3, the inspectors noted that the licensee submitted the justification to the NRC by letter dated January 15, 1908. The .iustification is currently under review by the NR The inspectors also verified that tha licensee developed and implemented the ECAs consistent with their commitment by reviewing each newly developed ECA, including its associated V&V, The procedures were determined to be technically adequate, and the V&V was found to be conducted in accordance with the licensee's PGP. Several inspector concerns were identified during the technical review of the ECAs, as listed in Appendix A to this report. The licensee committed to resolve these concerns by incorporating these changes with revisions made to resolve operator feedback comments generated during week 1 of their 1988 requalification progra Resolution of the items listed in Appendix A will be inspector followup item 327, 328/88-14-0 The inspectors reviewed licensed operator training on the newly developed ECA This review consisted of observations of classroom and simulator training, an evaluation of lesson plans and a review of examination items developed for testing operator comprehension of the materials presented in clas Observations of classroom and simulator training indicated that the training on ECAs was adequat The lesson plans were well developed and adequately covered the intent and basis for the procedures, including individual steps. The only deficiency ncted was that there was not an enabling objective for understanding the basis for the procedural actions although the bulk of the lesson plan addressed this area. Understanding the basis for procedural steps is an enabling objective in the other lesson plans associated with SQNP E0Ps. The inspectors noted that this enabling objective should be included in examinations to ensure operator comprehensio In conclusion, the training provided on the ECAs was determined to be adequat However, at the time of this inspection, all operators scheduled for Unit 2 restart (Mode 2) had not yet completed the required trainin The licensee reaffirmed its commitment to complete ECA training prior to Unit 2 restart. The inspectors stated that completion of ECA training for operators involved in restart would be inspector followup item 327, 328/88-14-0 .

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The adequate implementation and V&V of the ECAs, revisions to ES-0.3, and the submittal of justification for not implementing ECA- resolves inspector followup item 327, 328/87-61-0 (Closed) Inspector Followup Item 327, 328/87-61-04, Resolutions of Technical Adequacy Review Finding The licensee committed to resolve prior to Unit 2 restart (Mode 2),

specific inspector concerns relating to the technical adequacy of E0Ps and their associated step deviation document These concerns were designated as IFI 327, 328/87-61-04, and were documented in an inspection report dated February 1,198 The inspectors reviewed the licensee's resolutions of each of the concerns identified during the technical adequacy review of the E0P The specific resolutior.s are described in Appendix B to this repor In general, the inspectors determined that the licensee effectively resolved the concerns identified as IFI 327, 328/87-61-04, (Closed) Inspector Followup Item 327, 328/87-61-05, Re.olution of Writers' Guide and Human Factors Review Finding During the previous E0P inspection, the inspectors reviewed selected E0Ps for compliance to the plant specific writers' guide, and observed the usability of the E0Ps by operators in the training simulator for human factors consideration The inspectors identified several inconsistencies between the E0Ps and writer's guide. The licensee committed to resolve those inconsistencies prior to Unit 2 restart (Mode 2), as documented in IFI 327, 328/87-61-0 The inspectors reviewed the licensee's resolutions of each of the concerns. The specific items, along with a description of the corrective measures, are included in Appendix C to this report. The licensee adequately resolved the inspe' tor concerns, (Closed) Inspector Followup Item 327, 328/87-61-06, Resolutions of Validation and Verification Program Review Finding Several specific corcerns were identified during the inspectors'

review of the EOP validation and verification program, and during the conduct of control room walkdowns. IFI 327, 328/87-61-06 documents the licensee's commitment to resolve these concerns prior to Unit 2 restart (Mode 2).

The inspectors' review of the licensee's resolutions indicated that the licensee adequately addressed the inspector concern The specific resolutions are described in Appendix D to this repor (Closed) Inspector Followup Item 327, 328/87-61-07, Plant Specific E0P Value This item delineated the concern that the licensee did not have a central document for controlling E0P setpoint At the time of the inspection, the licensee documenttd and controlled setpoints

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associated with the E0Ps through a variety of existing programs and documents including the Precautions, Limitations, and Setpoint (PLS)

manual, the technical specifications, computer programs, the procedure revision and review process, the surveillance testing program, and instrumentation setpoint manual These various programs and documents were not cross-referenced to the E0Ps to ensure that the E0P setpoint bases, commitments, and requirements are considered when the setpoints are revise The licensee has established an E0P setpoint document in the form of a table titled Emergency Operating Procedure Setpoint Table, drawing number 47E250-1, revision 0. The table lists 104 WOG instrumentation requirements, along with their E0P trigger setpoint, reference document number, and instrumentation loop Many of the reference documents (58) were recently generated by the Department of Nuclear Engineering (DNE) in response to post-accident environmental conditions. The inspectors performed a review of the accuracy of calculations contained in the reference documents, and noted no discrepancie In addition, the inspectors performed a review of the licensee's Precautions, Limitations and Setpoints document, SQN-PLS, revision 9, against those E0P setpoints reference to this documen No referenced discrepancies were note A 100 percent review of E0P procedures against the setpoint table was performed. The inspectors found no inconsistencies or discrepancies between them, g. (Closed) Inspector Followup Item 327, 328/87-61-08, Revision of E0P Lesson Plans and Simulator Traini During the previous E0P inspection, the inspectors expressed concern i over the lack of procedure guidance and trair.ing on the use of qualified instrumentation while utilizing the E0Ps. The licensee committed to revise E0P lesson plans and simulator training to emphasize the use of qualified instrumentation for E0P trigger setpoints, as documented in IFI 327, 328/87-61-0 A review of the lesson plan for E-0, Reactor Trip or Safety Iniection, revealed that it has been adequately revised to emphasize the use of Post Accident Monitoring (PAM) instrumentation. Procedure E-0 is an entry procedurs for the E0P network, and thus is used when the emergency procedures are exercised. Additionally, during the cor. duct of simulator training exercises, it was noted that the operators made a concerted effort to use PAM instrumentation, and that instructors emphasized its us The inspectors' review of the licensee's resolutions indicated that the licensee adequately addressed the inspector concern r--_____ _

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8 The inspectors noted that the licensee had not completed the actual training on the use of PAM instrumentation for operators involved in restart. The licensee committed to complete this training prior to Unit 2 restart (Mode 2), and this commitment will be tracked as a part of inspector followup item 327, 328/88-14-0 h. (Closed) Inspector Followup Item 327, 328/87-61-10, Revisions of E0Ps to Reflect Head Vent Deficiencie This item involved two E0Ps: FR-I.3, Response to Voids in Reactor Vessel; and FR-H.1, Response to Loss of Secondary Heat Sink. The head vent on the reactor vessel has been identified as having deficiencies that, while not being of the type that would render the system inoperable, would nonetheless behave in such a way as to

, mislead the operator in determining the functional status of the head ven The head vent system utilizes two Target Rock solenoid valves in series; one valve acts as a block valve and the other as a throttle valv In addition, each of the valves has a bypass line and a second solenoid valve for redundant capabilit As designed, the licensee would first open the block valve and then slowly open the second solenoid valve to throttle and control the head ventin The licensee has found that upon opening the block valve, the corresponding throttle valve opens to 60 percent and then reclose The concern was that the operator may not be aware of this ,

intermittent release when the block valve is opened and that the valve could stick 60 percent open, resulting in continuous ventin In addition, the licensee was experiencing problems with instrumentation that rendered a positive indication of head vent position in the control room as required by item II.B.1 of NUREG 073 The inspectors reviewed FR-I.3, revision 2, dated Jenuary 18, 1988, to determine whether the licensee had addressed this deficiency in the head vent system. The following caution statement was placed prior to step 19: "When the reactor head vent block valve is opened,

the throttle valve will cycle open and close. If the throttle valve does not close, then close both block valves." The following caution statement was piaced prior to step 20: "The reactor head vent throttle valve position indication may not be accurat The PRT level, press, and temp should be monitored to verify throttle valve position." The inspectors found these added caution statements to adequately address the head vent deficiencies with regard to FR- The inspectors also reviewed FR-H.1, revision 2, dated January 12, 1988. The licensee had deleted reference to the head vent from step 15 which relates to the RCS bleed pat The bleed path i s now designated as being through the pressurizer relief line The licensee conducted an evaluation that demonstrated that the required

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amount of bleed could be achieved by this path and that the head vent line was not significant in its contribution to the blee The inspectors agreed with these changes to the procedure in that they adequately addressed the concern of the head vent deficiency by removing it from the procedure altogethe The licensee committed to provide training on FR-I.3 to all licer. sed operators involved in Unit 2 restart (Mode 2). This will be another part of inspector followup item 327, 328/88-14-0 i. Other The development of a lesson plan discussing the bases behind and the usage of the Foldout Page for the E0Ps was recommended in the inspection report number 327, 328/87-61 dated February 1,1988. The inspector observed that, due to the creation of specialized Foldout Pages for the ECAs, training on Foldout Page usage and understanding is even more desirable. The licensee indicated that they are currently in the process of developing such a lesson plan and will implement it during the 1988 requalification cycle.

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Appendix A Technical Review Comments The following provides descriptions of concerns resulting from technical reviews of the licensee's newly implemented ECAs and their associated step deviation documents. Resolution of these items will be inspector followup item 327, 328/88-14-0 . SQNP ECA-1.1, Loss of Emergency Coolant Recirculation Step 17d requires further guidance in informing the operators to bring the RCS to atmospheric conditions. The licensee indicated that they would add a phrase directing the operators to "cooldown to Cold Shutdown" to provide the necessary guidanc . SQNP ECA-1.2, LOCA Outside Containment Step 3e should identify which RHR cross-tie valves are intended to be operate The licensee indicated that the specific valves to be operated will be included in this ste . SQNP E-2, Faulted Steam Generator Isolation The guidance to transition to ECA-2.1. Uncontrolled Depressurization of All Steam Generators, is contained within a caution instead of a procedura.1 step. The writer's guide recommends that actions be written into procedural steps, instead of cautions and notes. It was also noted by several operators while reviewing the procedure, that placing this direction in a procedural step would better facilitate the necessary transition to ECA-1.2. The licensee indicated that they would include this procedural guidance in a ste SQNP ECA-2.1, Uncontrolled Depressurization of All Steam Generators Steps 17 and 18 of ECA-2.1 instructs the operator to reset Phase A and B, and restore instrument air to containment. The WOG version of this procedure has these actions taken immediately after SI is reset, which occurs much earlier in the procedur The possibility exists that a Phase B signal will occur, requiring valves to be locally operated to restore instrument ai These steps would be more logically placed af ter the step where SI is reset, to give time for the auxiliary operators to complete the local actions. The licensee indicated that relocation of steps 17 and 18 to coincide with the WOG procedure would be don _ _ - _ _ _ _ _ _ _ _

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5. SQNP ECA-3.1, Steam Generator Tube Rupture With Loss of Reactor Coolant-Subcooled Recovery Required Steps 14b and c of ECA-3.1 do not provide the operators guidance whether to use narrow or wide range steam generator (SG) level indication. The licensee indicated that they will clarify this step by adding "narrow range" to the S/G level indication required, Step 22c of ECA-3.1 does not provide adequate guidance to the operators on the parameters that are to be monitored while stopping the Emergency Core Cooling System (ECCS) pumps. These parameters are listed in a substep following the step where the pumps are secure The licensee indicated they will reorder the appropriate steps so that the operators are made aware of parameters to monitor before securing an ECCS pump, Step 27 of ECA-3.1 does not provide adequate guidance to the operator's in determining what constitutes proper operating conditions for the reactor coolant pumps. The licensee indicated that the procedure will be revised to instruct the operator to refer to S01-68.2 for proper operating parameters, The foldout page for the ECA-3.1/3.2 series has the operator "Go To" E-2, Faulted S/G Isolation, if a SG has low pressure or if pressure is decreasing in an uncontrolled manner. E-2 does not have a procedural step that directs the operator to return to either of the ECA-3 series procedures. The licensee indicated that the wording "Go To" will be revised to "Refer To" on the appropriate foldout pages, Step 11b of ECA-3.1 instructs the operator to check if SG pressure is

"Stable or Increasing". The Response Not Obtained (RNO) for this step has the operators isolate the af fected SGs per E-2, if the pressure in a S/G is low or decreasing. This step combination can be confusing to the operators, particularly when S/G pressure is decreasing as a result of operator actions or as a result of normal system behavior due to injection of colder auxiliary feedwate This step combination also exists in other procedures, such as E- The licensee indicated they will review all of E0Ps, and revise the RNO for this generic step to indicate usage of E-2 for SG isolation is only required if the decrease in pressure is "Uncontrolled".

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Appendix B Resolution of Concerns Resulting From Technical Reviews of E0Ps The following provides Orief descriptions of specific concerns resulting fro technical reviews of the -licensee's E0Ps and associated step deviation documents, 'as well as the licensee's resolutions of those concern The inspectors determined that the licensee effectively resolved each concern identified belo . SQNP E-0 Reactor Trip or Safety Injection, Rev. 3 Step 17 of E-0, revision 2 does not appear to be appropriate for inclusion in an emergency procedure. The licensee indicated that Step 17, which addressos local monitoring of the emergency raw cooling water traveling screen wash and strainer operation, is to be delete The licensee removed the step requiring monitoring of the ERCW travelin,a screen wash and strainer operation from E-0, and incorporated the requirement in a more appropriate procedure (procedure E-1, Loss of Reactor or Secondary Coolant). Step 18 of E-0, revision 2 directs the operator to verify natural circulation. The word "verify" means "to observe that an expected characteristic or condition exists and, if necessary, to take actions to make the condition occur." An operator interviewed on natural circulation was not aware of the time frame required to establish natural circulatio Because establishing natural circulation would take some period of time, the inspectors recommended that the step be changed to indicate that the appropriate parameters be monitored and actions taken until natural circulation was confirmed. The licensee is considering moving the natural circulation verification methods to the foldout page, and revising training to clarify time frames expected for establishing natural circulatio This comment is applicable to all SQNP E0Ps that require similar verification of natural circulation, including E-1 and ES- Step 18 of the SQNP E-0 procedure, revision 2, was appropriately revised such that operators are instructed to monitor natural circulation. The inspectors also verified that other emergency procedures, such as ES-1,1, ES-0.3, E-1, ES-3.1 were also revised accordingly. The licensee has incorporated the natural circulation parameters on the E-series procedure foldout page to provide the operators with additional guidance, This item was closed during the previous E0P inspectio .

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2. SQNP ES-0.3 Natural Circulation Cooldown, Rev. 3 The procedural guidance in the caution preceding step 15 of revision 1 to ES-0.3 is inadequate in the event of a rapid void formation in the reactor hea The licensee committed to resolve this item in the PGP submittal as discussed in Section 5 and Items a. and b, above are one item, and were incorrectly numbered as separate items. The inspectors confirmed that revision 3 of ES- adequately provides the operators with additional guidance in the event of a rapid void formatio The licensee's PGP submittal contained additional information relating to ES- This additional information was also determined to be adequat The 50 F subcooling in step 15 of revision 1 to ES-0.3 should be core exit thermocouple readings. Since all subcooling readings are core exit thermocouple readings, the procedure should either state this in the beginning of the procedure or each time reference is made to subcoolin In revision 3 of ES-0.3, step 15a was revised to indicate that subcooling is based on core exit thermocouples. In addition, other similar steps in the procedure were also revised accordingly, Step 22 of revision 1 of ES-0.3 contains temperature and pressure value; for placing the residual heat removal (RHR) system in servic These values do not agree with the Precautions, Limitations and Setpoint (PLS) Manua The temperature and pressure values were compared to the E0P setpoint document and were dett e 'ned to be correct. The licensee will review the PLS values, Step 24 of ES-0.3, revision 1 should contain the value of 200 F instead of 212 The inspector verified that the correct value has been included in revision 3 to ES- Step 25 of ES-0.3, revision 1 should state "entire RCS < 200*F".

ES-0.3, revi sion 3 ef fectively indicates that the entire RCS should be less than 200 , SQNP E-1 Loss of Reactor or Secondary Coolant, Rev. 4 Procedure E-1, revision 2, substep 9a, RNO failed to instruct the operator to proceed to step 1 Exclusion of this additional instruction could result in the operator incorrectly progressing from Substep 9a, RNO to substep 9b. The licensee committed to revise the procedure such that the operator would correctly proceed to step 1 _

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The inspectors reviewed revision 4 of E-1, and verified that substep 9a ,

correctly instructs the operator to proceed to the next ste . SQNP ES-1.1 Post LOCA Cooldown, Rev. 1 1 This item was closed during the previous E0P inspection, ES-1.1, revision 0, step 10a, RNO does not provide the operator with adequate guidance for proceeding in the procedure if RCS subcooling is not satisfie The licensee committed to determine the appropriate progression and revise the procedure accordingl Revision 1 of the procedure was reviewed by the inspectors. The licensee revised step 10a, RNO to provide the operator with specific directions for progressing through the procedur This item was closed during the previous E0P inspection, Step 12, RNO of ES-1.1, revision 0, also introduces confusion regarding operator progression through the procedure. The item is related to the concern described in step 10a, RNO, and will be resolved with resolution of 10 The inspectors verified that the confusion was removed from this step in revi sion 1 of ES- This item was closed during the previous E0P inspectio . SQNP E-3 Steam Generator Tube Rupture, Rev. 3

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incorporated in E-3, revision 2. The WOG caution states that if the turbine-driven auxiliary feedwater (AFW) pump is the only source of feed flow, steam supply to the pump must be maintained from at least one S The licensee's justification for not duplicating this caution is that the caution is incorporated in step 4, RNO of E- A review of this procedure indicated that the presentation of this caution within the procedural step was not clear, and subsequent operator action during an emergency could result in isolation of the steam supply, hence resulting in a loss of secondary heat sink. The licensee committed to either include more guidance within the step or restate the cautio The inspectors verified that the licensee added a caution, consistent with the WOG guideline, prior to the applicable step in the E- Step 6 of E-3, revision 2. provides for depressurization of the RCS following identification and isolation of the ruptured SG. Once the requirement of step 6 has been *.atisfied (i.e. , depressurization is begun), step 7 is entered. The inspectors' concern arises when, b; step 70, RCS pressure is checked for stable or increasing conditio _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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During simulator observations, the inspectors noted that the operators had difficulty in verifying RCS pressure as being stable or increasing while conducting a controlled depressurizatio Conversations with licensee personnel indicated that since the ECAs are being implemented, this concern no longer poses a problem because the operators would be directed to ECA-3.1, Steam Generator Tube Rupture, Loss of Reactor Coolant, Subcooled Recovery Desired, when necessar The inspectors verified that revision 3 of E-3 was appropriately revised to direct the operator to ECA-3.1.

6. SQNP ES-3.1 Safety Injection Termination Following Steam Generator Tube Rupture, Rev. 1 Step 13c, RNO of ES-3.1, revision 0 does not contain a note concerning minimizing cycling of the power operated relief valve (PORV) as contained in the WOG guideline. The licensee committed to reinstate this note within the procedure to bc consistent with other steps regarding the same conditio ES-3.1 was appropriately revised to include the note to minimize cycling of the PORV . SQNP ECA-0.0 Loss of All AC Power, Rev. 2 Revision 1 of ECA-0.0, step 16, RNO gives the operator the ption of either allowing the accumulators to inject or stopping the e ctor coolant system (RCS) cooldown. The WOG guideline only allows for pping the RCS cuoldow The Step Deviation Document does not prr se sufficient justification for this deviation, and therefore shou 1 . De revise ECA-0.0, revision 2, deleted the reference to the accumulator injection, and allowed for the RCS heatup consistent with the WOG guideline . SONP FR-H.1 Response to Loss of Secondary Heat Sink, Rev. 2 Step 5, RNO of the SQNP procedure does not provide adequate guidance j with respect to the time frame secondary systems are unavailable before considering tripping the reactor coolant pumps.

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information speci fying the amount of time secondary systems are unavailable before considering tripping the pumps, is provided.

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continuation of the procedure into the bleed and feed actions before

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, 1 l FR-H.1 was revised to prevent cor inuation into the feed and bleed actions before it is warranted, by instructing the operators not to '

proceed until all SG levels are less than 25%. Substeps 13a and+ 13b of revision 1 to FR dH.1 are reversed from the i order in which they occur in the corresponding WOG guideline. No '

step deviation documentatios exists to support this chang .

The procedure was revised tc change the order of these steps such that the;. are corisistent with the WOG guidelines. Specifically, feed and bleed is initiated, the RCPs are stopped, the block valves ar?

opened, and then the PORVs are opene' i

~ Step 17 of the WOG guideline has been incorporated irito step 12, RNO of FR-H.1, revrh on 1. This should also be included as either a step or a caution following step 13 of the SQNP procedure to meet the intent of the y0G guideline The procedure was revised to include step 17 from the WOG guidehne in the appropriate step of the SQNP procedure, Step 15a of revision 1 to FR-H.1 should clearly delineate the required parameters for bleed and feed termiptio The re quired parameters for feed and bleed were ircorporated into FR-H.1, revision Step 15e of FR-H.1, revision 1 should be clarified tk indicate the order in which the components are operate The licensee clorified the procedure to indicate the order in which the components grould be operate Guidance in substep 15f of revision 1 to FR-H.1 should be prepited prior to substep 15 FR-H.1 was ievised to present the guidance in the correct location in the proced s . SQNP FR-5.1 Response to Nuclear Power Generation /ATWS, Rev. 2 in the SQNP FR-S ' procedure, revision 1, eh licensee elected not,to trip the turbine within 30 seconds, as reiommended in the WOG, but to delay the turbine trip until step 4, after normal and emergency'

boration. The licensee's justification provided for not tripping the turbine within 30 seconds of an ATW5 included a TVA computer analysis

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for a postulated loss of feedwater/ATWS even According to the licensee's analysis, the RCS ASME service level C pressure limit i would not be exceede The Step Deviation Document also indicated that it'woula be difficult to train the operators to trip the turbine j within the recommended 30 second .

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In response tv an <NRC draft SER request for further information on this Heviation, the licensee indicated on January 13, 1986, plans to impiement an' ATWS mitigation system circuity (AMSAC). The AMSAC system inc)udes a logic to actuate a turbine trip and auxiliary feedwater pump start upon sensing low-low steam generator water level. As indicated in a letter to the NRC dated October 11, 1985, the AMSAC sistem was scheduled for implementation for Unit 2 by the end of 'the: cycle 3 refueling outage and for unit 1 by the end of cycle 4 ci<ueling outage. In a letter dated October 31, 1986, the licensee. f evised the schedule for unit 2 to the end of the cycle 4 refuelir/; putage,

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j The ATWS concern will be addressed in the safety evaluation report of the licensee's PG Step 4 of the WOG guideline recommends that if pressurizer pressure

. is in excess of the p0RV setpoint, the operator should verify that the PORV opened, or manually open the PORV and decrease pressure 200 pst below the setpoint before closing it. The WOG indicates that the operator must' verify closure of the PORV, util1 zing the block valves if necessary, in revision 1 of FR-5,1, the licensee does not addressed the pressure at which the PORV should be reclosed or verified ;1osed','

The licensee revised FR-5.1 to include the pressurc at which the PORV should be verified closed, The WOG guideline recommends in step 6 that auxiliary feedwater ( AFW)

flow be verified to be adequate in gallons per minute. The bases for this flow verification is to ensure the maintenance of a secondary heat sink and adequate heat remova The licensee does not incorporate a plant specific AFW flow value in revision 1 to FR- but substitutes verification of SG water level greater than 25 percent. The justification of this deviation indicates that the SQNP i has included an, automatic AFW 1evel control system which is different

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from the WOG re ference plan The concern with the SG 1evel verification versus AFW flow indication is that AFW flow may be ir; adequate to maintain the SG 1evel initially observed under these ATWS conditions. The licensee committed to revise step 7 of FR- to require the operator to monitor SG water level versus checking one tim The licensee revised the procedure by requiring that the operators monitor the SG levels, Step 10 of the WOG requires the operator to identify a faulted SG and

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step 11 provides the direction for isolation the faulted SG, Step 12 I then requires the operator to verify subcriticality and the RNO requires the operator to continue to borat If boration cannot be performed, the RNO requires the operator to allow the RCS to heat up.

l The basis for allowing the heatup is to allow the moderator

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temperature cae ficient and the doppler effecty te! add Eeoative , " I- l

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reactivity afid r(educe nuclear power. Thelicensee'sFR-T.iprocedure

.) t does not cover the isolation o'< a faulted SG' but direi.its (Fg. operator I'!~

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to go to E-2, Fault $ Stear 6 Ge erator IsolaMch. . The .6;)r.cern i s that ~'

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the operator- is /icyrje,>to F2' ie step .8 oria: Op reaching step 9 whichdirectqti/ operator,toverifysuberMicality. Since E-2 does ve not redirect the operato/ back te .F9-S.1 ,forlowing faulted SG T[

isolation, a verification of' the if fi'ctiveness nf, boration and

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' 'subcriticality is not performed. The licensee committed to replacea l

, ) the direction "go to" E-2 with "refer to." This would -required E-2 ) ! ,

j to be performed corlcurren ly with FR-S.1 and ensure a verification,nf t' '

subcriticality and continued boration if require .y

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d The procedure was approprf ately revised to refer the operator to D2. ' 5 :'

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< / 5 1 SQNP f, FR-P.1 Response to Pressurized Thersal inocb.Rev. 2 -

,- j Step 3 of revision 0 to FR-P.1 instructs dhe operasor to minimize RCS ' ' '

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cooldown by' cor, trolling 3Hk if irt service. -The c$rrupending WOG X guideline states if RH2,'it in service, then'stop pny cooldown for '

RH The diff9rence in philosophy could be dsleading to operations ,5 i personnel. The' licersee has committed to revise the stepq r

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Procedure FR-P.1 s% re.h5 ed to be consistent 6th ;he WOG philoso:hy j

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7i Step 8 of the Wd guideline requires th.t ~ psb 3 ment air be / (I

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established to contaioment following reseti cf phase l and phate B ll

, ; containmed . i solations. The libensee has dmittad, in revision 0 to ,

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their prdcedure,ithe action to e stabi .'sh instrument air t o ,-

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r, containment. The step should ts present' in? the procedure in that ,

instrument air, does isolate en phne 9, .wl failure to reestablish'

ins'irument air csuld impede the operationT L safety grade equipmen The' licensee ha>' committed to rei State the requiremer,t to establish

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, instrument ai The procedu l e was revised to require opeNtors to ensure that d,

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containment air supply is in service.

l t r Step 14 of revision 0 t 3 FR-P.1, wuch estaolished normal bharging i flow, is not consistent saith the sJme step / other procedure: The

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' portion of the step missing deals w't'ilseai . water injection flow and l

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maintaining pressurizer level corr.i j t . /These items should be included in the step for consistenc The licensee has committed to revise the steps to be consisten ,' ,/

This ste / was revised to include establishing seal water injection '

finw an stable pressurizer lever, consistent Mith othe SQNP ,

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'19 Appendix C Resolution of Concerns Resulting From Human Factors / Writers' Guide Review

. The following are inspector comments of resolutions of inspector concerns i resulting from . human factor reviews of the SQNP E0Ps. The inspectors

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determined that the licensee adequately-resolved each concern identified belo , SQNP E-1 Loss of Reactor or Secondary Coolant, Rev. 4

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The writers' guide states that "High-level steps are those steps that tell the user "what" to do. Substeps of the high level step may be used to tell the user "how" to accomplish the high-level ste Contrary to. the above, .high-level step 14 of E-1, revision 2, instructs the operator to -

terminate SI. whereas the substep instructs the operator to balance ECCS injection with the break flow. This inconsistency could prove confusing to the operato The licensee agreed to revise step 14 to assure y consistency between the high level step and the associated substep This step was revised such that the high level step is consistent with the subste . SQNP ECA-0.0 Loss of All AC Power, Rev. 2 The action for step 2 of revision 1 to E-1 is to check that RCS has isolated. Substeps b and c of this step are to verify this actio These actions are contradictory by the definition presented in the writer's guid Step 2 was revised, correctly using the term verifying and introducing consistency between the high level step and its associated substep The action for Step 8 of E-1 is to check SG status while substep 8a has the operator perform manipulation of controls. To perform manipulation of controls is not in accordance with the writers' guide definition of "check".

Step 8 was revised to correctly use the term verify consistent with the writer's guide definitio Step 19 of revision 1 instructs the operator to check containment hydrogen control equipment, but the substeps instruct the operator to manipulate controls. This is an example of the improper usage of terms defined in the writer's guide.

l Step 19 was revised to remove the inconsistency between the high level step and its associated substep . -n n-- ,...,,-r--- ,.,, _

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20 SQP FR-H.1 Response to Loss of Secondary Heat Sink, Rev. 2 Step 13, RNO, of revision 1 of FR-H.1 does not conform to the writers' guide in that the action is not labelled consistent with its associated subste This step was revised such that the RNO column is consistent in addressing the high level step, Steps 15e and 15f should be separated into their own high level steps for procedure FR-H.1, revision Steps 15e and f were separated into their own high level step . SQNP FR-P.1 Response to Pressurized Thermal Shock, Rev. 2 Step 5, RNO of FR-P.1, revision 0, requires that if no RCP is running then attempt to start one RCP and reference 501-68-2 if necessary. The word reference is not consistent with the writers' guide which states that when transiting to another procedure for guidance or direction, and remaining within the procedure in effect, that the words "refer to" shall be use The licensee committed to change "reference" to "refer to." Additionally, the wording "if necessary" implies there is no requirement for the operator to use the procedure. System Operating Instruction (S0I) 68-2, revision 2, Reactor Coolant Pumps, is a category A procedure. According to Administrative Instruction (AI-4) revision 64 Preparation, Review, Approval, and Use of Site Procedures / Instructions, all category "A" procedums shall be present during task performance. Therefore, the words

"if necessary" are not appropriate and the licensee comitted to remove them from the procedur Step 5 was revised by removing the word "reference" and incorporating

"per", consistent with the writers' guide. The phrase "if necessary" was delete . SQNP E-F0P Foldout Page, Rev. 1 The SQNP foldout page, revision 0, provides criteria for safety injection (SI) reinitiation. This foldout page is applicable to all SQNP emergency procedure The WOG guidelines recommend criteria for both SI reinitiation and actuation. The criteria are identical for the two, but the operator actions are different. Actuation requires actuating the SI signal and reinitiation requires manipulation of SI equipment as necessar The WOG guidelines specify different actions for different procedures. The licensee committed to define actuation and reinitiation in the writer's guid The tenn "SI Reinitiation/SI Actuation" was defined in the writers' guide, and is consistent in the procedur !

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Appendix 0 Resolutions of Concerns Resulting From Verification / Validation Review of E0Ps Specific resolutions of the inspector comments resulting from-the control room walkdowns and the review of the verification and validation programs are provided below. The inspectors determined that the licensee adequately resolved each concern identified belo . SQNP E-0 Reactor Trip or Safety Injection, Rev. 3 Step 7 of revision 2 to E-0 directs the operator to verify main feedwater (MFW) isolation. A comment, designated as Step 7~of E-0 in the validation program, states that no position indication is available in the control room on the AFW bypass valves. The licensee's resolution indicated that the comment was true but implementation of the step, which listed all valves which receive MWF isolation, was included in training. The comment was therefore not included. The inspectors interviewed an operator who stated that an Auxiliary Unit Operator would be dispatched to verify position of the MFW bypass valve Af ter discussion of the procedure step, the licensee agreed to revise E-0 to provide the method of verification of the status of the MFW bypass valve The licensee revised Step 7 by adding the method of verification of the status of the MFW bypass valves. Specifically, this step was revised to require local verification that the MFW bypass valves are closed if MFW flow is indicated, Step 4 of revision 2 to E-0 directs the operator to "Check if SI Actuated." If the response is not obtained, the operator is to

"Check if SI is required . . ." The operator interviewed indicated that he would check the "SI Actuated" annunciator and the reactor trip first out annunciato.'s to determine if SI is require The inspectors commented that it is more appropriate to check instrumentation for the specific parameters that cause SI actuation, for example, RCS pressure low, rather than rely on annunciator windows. The licensee agreed to provide training to assure that operators check the appropriate instrumentatio This step was revised to provide specific parameters to be checked if SI is required, such as low pressurizer pressur Du.ing control room walkdowns, the inspectors noted that instrumentation used to verify containment pressure in Step 12 had different scales among the four indicators. The licensee stated that this discrepancy had been identified during the control room design review (CROR) and was to be corrected under that progra !

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The inspectors verified that the containment pressure indicator scale differences were identified by a CRDR human engineering discrepancy sheet (number 5143).

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2. SQNP ES-0.2 Safety Injection Termination, Rev. 1 Step 9e of revision 2 to ES-0.2 directs the operator to "Open seal water return FCV-62-61 and -63." During control board walkdowns, the inspectors noted that valves FCV-62-9A and -22A are labeled seal water return valve The licensee indicated that the appropriate label for FCV-62-61 and -63 would be include in the procedure, or that procedure step would be reworde Step 9 of the procedure was reworded to remove the confusion regarding the label of FCV-62-61 and 63.

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