IR 05000338/1990011
| ML20044B033 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/05/1990 |
| From: | Lawyer L, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20044B030 | List: |
| References | |
| 50-338-90-11, 50-339-90-11, NUDOCS 9007170230 | |
| Preceding documents: |
|
| Download: ML20044B033 (64) | |
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p. 28?g'o UNITED STATES-3'.
- NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET. N.W.'
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Report Nos.:' 50-338/90-11 and 50-339/90-11
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Licensee: -Virginia Electric and Power Company Glen Allen, VA 23060
Docket Nos.:
50-338 and 50-339 License Nos. :
NPF-4 and NPF-7 Facility Name: -North Anna 1 and 2-Inspection Condu ad:
June 4-15 Inspector: 4 j)
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TO L.Mir7f'er, Team tEader I (/
Date Signed
NRC Team Members:
L. Garner
L'. King K.'Poertner
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'S. Sanders
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Contractors:
L. Haney, INEL
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S. John,on, INEL
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Approved by:
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,7 T., A. Peebles,. ChiTeF
_D6te' Signed
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Operations Branch.
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Division.of Reactor Safety
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SUMMARY
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- Scope:
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- This; wasy a special announced Emergency Operating Procedure i(EOP): ts[m
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inspection.
Its purpose was to veri fy that the North Anna E0Ps :were-..
, technically accurate and that their.specified actions'.could be Laccomplished using: existing. equipment, controls and instrumentation.
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Results:
The overall assessment. concluded that the E0Ps adequately covered the. broad.
range of ' accidents and equipment failures necessary for safe shutdown of the t
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plant. -The ' team: identified weaknesses in the licensee's E0P procedural-
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adequacy as evidenced by:
lack.of ' detail in procedures (paragraph -3),
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technical inadequacies (paragraph 3), improper content in notes and cautions (paragraph 3), labeling errors (paragraph 4 andi Appendix 0), and wording c
! inconsistences ' (paragraph 7).
A second weakness identified was the need to
. review the technical basis for the AOP on refueling cavity leak (paragraph 3).
The ' team identified a strength in the use of multidisciplinary groups to tperiodically audit' E0Ps (paragraph 6). A second strength identified was in the development of an E0P Integrated Document set (paragraph 2). A third strength
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9007170-230 900707
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PDR ADOCK 05000338 O
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identified was the development and implementation of a computerized alarm:
response. procedure _ system (paragraph.-4),
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.The. team. reviewed the Safety Evaluation Report (SER)- on the licensee's'
Procedures Generation Package (PGP) commitments and determined.that it had been completed.' Violations or deviations-were not identified in this report.
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x REPORT DETAILS 1-Persons contacted
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Licensee employees M. Allen, Supervisor - Nuclear Training (OPS)'
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- D. Beith, Human Factors Specialist - Station Procedures Group J.- Blankenship, Shift Supervisor - Operations
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- M. Bowling, Assistant Station Manager - North Anna Power
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Station B. Counts, Control Room Operator - Operations
'M. Crist, Operations Coordinator - Nuclear Training J. Crossman, Assistant Shift Supervisor - Operations G.'Crum, Control Room Operator - Operations
- J. Daily, Contractor - Procedures Group L. Edmonds, Superintendent - Nuclear Training
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R. Garrett, Unlicensed Operator - Operations D. -Hawkins, Assistant Shif t Supervisor - Operations G.-Jewett, Assistant Shift Supervisor - Operations
- G. Kane, Station Manager - North Anna Power Station
'L. Kelly, Unlicensed Operator - Operations q
- P. Kemp, Supervisor - Licensing a
- J, Liberstein,- Engineer - Licensing
K.. Link, Control. Room Operator - Operations K. Maher, Unlicensed Operator - Operations M. Powell, Assistant Shift-Supervisor - Operations R. Rogers, Shift Supervisor - Operations q
- R. Saunders, Manager - Licensing Program a
B. Scott, Unlicensed Operator. - Operations T. Shelton, Control Room Operator - Operations
- R.. Simpson, Engineer - Licensing
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- J. Smith, Manager - QA, North Anna Power Station
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B. Spencer, Control Room Operator - Operations (
'*D. Stadler, Supervisor - Corporate Nuclear Safety G. Stott, Control Room Operator - Operations
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- J. Voissem,-Lead E0P Writer - Station Procedure Group.
- J. Wilson, Assistant Vice President Nuclear Operations (
Other.-licensee employees contacted but not named in this report included
= engineers, technicians, operators, trainers and office personnel.
NRC personnel I
- P. Kellogg, Chief,' Operational Programs Section
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NRC Resident Inspectors
- M. Lesser, Senior Resident Inspector
"L. King, Resident Inspector
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- Attended exit' interview on June 15, 1990.
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Procedures reviewed'during this inspection are listed in Appendix A.-
A list of abbreviations used in this report is contained in Appendix E.
2.
E0P/GTG comparison
~The team compared the index of Nortn Anna E0Ps and A0Ps against the index
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of WOG ERGS and the list of emergency procedures recommended in Regulatory Guide 1.33. The team confirmed that the licensee had developed sufficient procedures to encompass the spectrum of at
'ents and equipment failures addressed by the ERGS, Reg. Guide 1.33 and t-.
JFSAR.
The team confirmed that the licensee had identified ES-0.4 as the only vendor GTG which would
.not be developed into PSTGs. This procedur(, Natural circulation cooldown with steam void in-vessel (without RVLIS), was deemed as not required since operability of RVLIS was a Technical Specification requirement.
The licensee. defined their PSTG as the E0P deviation basis documents. the E0P;setpoint document and the WOG ERGS. The. licensee had made changes.to-individual E0P~ steps'from those recommended by the ERGS. This was done to.
adapt those steps to the plant configuration, to improve human factors or
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to comply with the! writer's guide.
The team determined that the E0P
' Integrated Document set, a separate book containing each procedure with its associated deviation, validation and verification documents, simplified maintenance.of the E0Ps. This document set provided the E0P-
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writer with a comprehensive yet easy to use document which provided the required technical constraints.
This was considered a strength.
The licensee submitted an E0P PGP, including a writer's guide, to the NRC for review and approval in 1983. An NRC SER on the North Anna procedures generation package -was. issued on August 23', 1985. The:; team reviewed the SER.and determined that there were no open-items.
No violations or deviations were identified in this area.
3.
Independent technical adequacy review of the E0Ps The. team reviewed the procedures listed in= Appendix A to determine their technical ' adequacy.
They found that those procedures either followed the vendor. recommended step sequence or deviated from it with acceptable documented deviations in most cases.
Exceptions to this are noted in Appendix B.
The team found AP-52, Loss of refueling cavity level during refueling to be def.icient in that its purpose and entry conditions could lead an operator to use it for mitigation of a gross cavity seal failure leak. The licensee provided calculations to support leak rates only up to 4000 gpm.
The basis of the procedure also assumed operator action to mitigate the leak after about 4 minutes.
In addition, consideration of loss of power to the manipulator crane during the emergency may not have been adequately
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considered. The team also questioned the calculated radia' tion-levels as a-function of time at the refueling bridge. The licensee agreed that these-questions warranted an engineering review of AP-52, The deficiencies in AP-52 were identified as IFI-338,339/90-11-01.
In addition, the team found as a weakness, that the emergency procedures lacked details. For example, the steps to perform emergency boration were not identified.(B II 2 b).
Valve locations for hard to find valves were not given in Attachment 2 to ECA-2.1 (B III 6 i and j) and the hiternative instrument air valves used for securing the main steam isolation valves on Unit 2 were inaccessible (B III 6 k). The deficiencies related to lack of details in procedures were identified as IFI-338,339/90-11-02.
The team found many procedures to be technically inadequate.
In one.
example, E-1 step 4 required the operator to verify that the S/G blowdown radiation monitors read normal (B I 2 a).
This cannot be accomplished unless-the breakers for one main feed pump are racked to test and closed -
before resetting the blowdown trip valves, In another, ECA-0.2 did not specify the indications to be checked in order to determine adequate seal cooling.
Also, the team identified that the operators had trouble j
locating equipment when performing electrical A0Ps.
The operators could
not locate the spare 4160 volt breaker that would be used to crosstie the d
Unit 2 emergency busses (B VI 23 f and 24 f). The team also discovered a i
discrepancy in the procedures in the Control Room. Two procedure files,
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ECA-2,1 and ES-0.2B, in the Unit 2 file cabinets were found to be missing the CAP (B II 4 a and B III 6 a). The technical inadequacy of procedures
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was identified as IFI-338,339/90-11-03.
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The team also identified improper content in notes -and cautions as a weakness.
For example, notes and cautions used in E-3 contained either s
actions, implied actions or conditional actions (C II 3). The improper l
content of cautions and notes was identified as IFI-338,339/90-11-04.
i Technical deficiencies identified by the team included the: inadequacy of -
many AOPs. The AOPs were.. in some cases, incomplete, lacked guidance and conflicted with the E0Ps.
For example, AP-50.1 allowed a cooldown rate
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which could cause void formation in the reactor upper head (B VI 52.k).
No violations or deviations were identified in this area.
4.
-Review of the E0Ps and A0Ps by inplant and control room walkthrougFs
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'The-team conducted plant and control room walkthroughs on the E0Ps and A0Ps listed in Appendix A.
The walkthroughs were conducted for the
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following reasons:
1) to confirm that the procedures could be followed
and would accomplish the stated purpose; 2) to verify that the listed i
instrumentation and controls were consistent with the installed plant equipment; and 3) to ensure that the listed indicators, annunciators and controls were available to the operator.
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The E0Ps AND AOPs were found to accomplish their stated purposes except for the items noted in Appendix B.
a Indidators, annunciators and controls referenced in the E0Ps were found to
- be available to the operators except as noted in Appendix B.
The team also evaluated the location and availability of the E0PS in the o
control room and verified that the current revisions were maintained.
To-aid the operators in quick recognition of the E0Pr and'other operations procedures,.the licensee required Unit 1 procedures to-be printed on blue
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paper, Unit 2 procedures to be printed on buff paper and common (shared)
procedures to be printed on pink paper.
Two sets of E0Ps and AOPs were maintained in.the control' room for each of the units. Additionally,_the licensee had-incorporated the ARPs into a computer system that facilitated i
operator response to Control Room annunciator alarms..This ' ARP usage i
feature was considered a strength.
While the results of the walkthroughs were : generally acceptable, many
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discrepancies in the areas of technical adequacy, writer's guide j
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adherence, and human factors were noted.
The most significant I
deficiencies noted during the walkthroughs were in the lack of detail in j
the procedures and in the technical inadequacies.
The technical content i
of the AOPs was found to be. of significantly lower-quality than -that-l
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contained in the E0Ps.
Technical and human factors discrepancies are noted in Appendix B while writer's guide discrepancies are noted in-
- L Appendix C and are identified as IFIs 338,339/90-11-05 and 06,
A general finding was labeling inconsistencies. A listing of the labeling j.
inconsistencies identified by the team are provided ' in - appendix 'D.
Following are examples of items appearing in appendix 0.
ECA-2.1-attachment 2 identified ~ instrument air valves IA-343, -352 and:-361 while the valves were labeled IA-426, -419 and :-424, respectively.
AP-10.12 mis-identified the following: a breaker identified'as supply to' the swing charger was labeled locally at the panel as supply to MCC-1H1-4;'a breaker identified as supply to the normal charger was also labeled locally at the : panel' as supply to MCC-1H1-4 and a breaker identified as EDG-1H
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Diff. Protection Relays was labeled locally at the panel as spare.
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The inadequacies and inaccuracies in E0P nomenclature.and labeling are
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identified L1 IFI 338,339/90-11-07.
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No violations or deviations were identified in this area.
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,5.
Simulator observation s
The team observed two crews performing the following scenarios on the NAPS
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.1 (1) SGTR with steamline break
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(2) Loss of all AC power without SI required
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(3)-Mode 3 LOCA with a loss of emergency recirculation
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(4) Main feedline break with failure of one SI train to.
actuate
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(5)'Feedline break with loss of all feedwater capability j
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During the above. simulator scenarios, the E0Ps were found to be adequate to nitigate the consequences of the accidents and were sufficiently clear
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to be correctly implemented under emergency conditions.
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The simulator was able-to generate plant conditions expected for those-
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scenarios-listed above.
i The EOPs did not cause interference between board operators nor was there
any significant, unnecessary duplication of operator effort.
Based on the team's observation of the selected scenarios, they concluded that the licensee-lacked a formal requirement for placekeeping.1 This was
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- evidenced by inconsistent or nonexistent placekeeping during the scenarios.
No violations or deviations were identified in this area.
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Management control of E0Ps and A0Ps j
The team reviewed the licensee's procedures which addressed their' E0P
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maintenance program.
Their procedures incorporated the following
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- Writer's Guide
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- V&V Guidelines
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- EOP Revision Process
- Maintenance of Related Documents (basis, setpoints, etc.)
- Feedback from Training, Operating Experience, etc.
- Plant Modifications
- WOG ERG Revisions
- Training on Revisions J
- Safety Evaluations / Engineering Evaluations
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- Human Factors Involvement
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- Management Involvement
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- Periodic. Procedure Reviews The license's program for maintaining the E0Ps required that all changes to the procedures be accomplished via the revision process to ensure that all changes 'were properly reviewed and validated prior to use. The team requested a review copy of the 50.59 evaluations associated with the last revision to ECA-3.2.
The licensee determined that a 50.59 screening r
review.had not been performed for the last revision to ECA-3.2.
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licensee also determined that 50.59 screening - reviews had 'not been performed for.the last revisions to E-0 and FR-H.1.
The licensee determined that the screening reviews had not been performed due to the fact that the controlling administrative procedure. had been recently
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revised and -the requirement to perform the review had been omitted. The i
licensee initiated a station deviation report to document the deficiency, performed the required screening reviews and' changed the controlling administrative procedure to require that the screening review be performed.
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The licensee had performed an E0P assessment during April 2-20, 1990.
This assessment was performed by the Corporate Nuclear Safety (CNS) group and identified 338 ' items for review.
The licensee had taken action to resolve 282 of those items.
The. licensee's assessment was an aggressive in depth examination of the.E0Ps, supporting procedures ano
'cumentation.
During the inspection the licensee agreed to perform per'od audits of the E0P program using a multidisciplined group, knowledgaole i. E0P use and content at least every. 24 months.
The team identifle: A periodic audit of emergency procedures by a technically qualified wroup to be a strength.
.The NRC team inspection identified about 300 items in E0Ps and about 150 items ; n. AOP s.
Of the 300 E0P items identified by the NRC team, the
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licensee's audit had identified slightly over 25 percent. An additional 50 percent of the items identified by the NRC team were similar to an item a
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identified by the licensee's audit or to one of their audit generic y
comments.
The -licensee was instituting an abnormal procedure upgrade project to 3 upgrade the abnormal procedures ' to the E0P format and enhance the technical ~ content of the procedures. This program was in the early stages of development.
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No violations or deviations-were identified in:this area.
7.
'EOP user interviews The team conducted interviews with six licensed operators. Two SR0s and four R0s were interviewed. The interviews were conducted to sample the operators' opinions on the quality, usability and adequacy of the E0Ps; to collect information on the approach to training and to augment the identification of specific deficiencies in the E0Ps.
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Generally the operators were confident that the E0Ps would work and-could
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be used in an actual emergency. ' Operators understood the division of responsibility in the control room, felt staffing was adequate except for some accidents (i.e. ' loss of power), reported minimal problems locating i
and physically using procedures in the control room, felt there were minimal technical inadequacies in the E0Ps and expressed a need for more information in E0Ps in some selected areas.
Half of the interviewees expressed some difficulties in understanding logic statements, action steps, cautions, and notes. Operators stated they generally used check
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offs or sticky tabs for placekeeping, however, placekeeping became difficult during complicated evolutions.
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'Theyshad received; training in communications in the control room and
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communications ~ to outside the control room.
They felt communications
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- communications equipment). There was some concern by the operators about
selected local. actions. The training program was generally rated positive by the operators. Generally the operators exhibited a level of knowledge L
compatible with the use of the E0Ps.
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The ' team made a comparison-between North Anna's vmiter's guide for l
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dual-column procedures and NUREG-0899 in terms of topic areas and content.
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The writer's guide addressed the appropriate topic areas as indicated by j
L the: sections contained in NUREG-0899. However the writer's guide s'ections
were of ten written in a manner that was nonrestrictive resulting in a
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lack of specificity as compared to NUREG-0899. The specific areas of the writer's guide that were nonrestrictive resulting in impact on the E0Ps i
and the user's ability to perform them are discussed in Appendix C,.
-section I.
A' formal "EOP user's guide" had not been published; however, an operations U
standard for procedure usage was incorporated in the operator training.
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A finding identified by the team during the inspection was,the use of inconsistent wording for the same action between different steps and. between different procedures.
Examples of these inconsistencies
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included-the following. E0P ES-0.2b step 9 and step 16 had inconsistent twording for initiating RCS depressurization, Step 9 included cycling
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' pressurizer heaters, while step 16 did not.
ECA-0.0, ECA-0.1, ECA-0.2
g and AP-33.2 (step 5.1)- used different wording regarding'RCP seal cooling
. isolation.
Inconsistent wording for the same actions is identified as j
IFI-338,339/90-11-08.
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No violations or deviations were identified in this area'.
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Follow up on previous inspection findings
A a.
(Closed)
IFI-338,339/87-39-01, Inadequate E0P's for-natural
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- circulation. The cooldown curves exceed those in the TS.
The team-i reviewed the'cooldown curves in the TS and 3ared them to the E0Ps-
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and no differences were found.
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(Closed) IFI-338,339/87-39-02, Failure to follow the PGP commitments for natural circulation cooldown.
The team found that the'Rev. la-
procedures followed the PGP commitments, c.
(Closed)
IFI-338,339/87-39-03, Licensee to review incorrect -exam
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questions with licensed operators.
The team found that'the exams are reviewed the day they are taken by the operators.
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(Closed) IFI-338,339/87-39-04, The simulator cannot perform mode 6
.or 5 operations. The team found the simulator will now model many mode 5 operations. Per ANS 3.5-1985 section 3.1.1.(1) the simulator is not required to model mode 6 operations.
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(Closed) IF'I-338,339/87_-39-05, Superseded procedures in use at the e.-
simulator. The team found that the procedures at the simulator were current, i
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-(Closed) IFI-338,339/87-39-06, Security of assembled exams on word processor. The team found that all exams were secured in the vault, g.
(Closed)= IFI-338,339/87-39-07, Training in clearence and tagging for l
NL0s with ' prior experience. The team reviewed documentation to show
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that training occurred,
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(Closed) IFI-338,339/87-39-08, Training in natural circulation cooldown. The team reviewed documentation to show that training had occurred.
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Exit interview i
The inspection scope and findings were summarized on June 15, 1990, with
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those persons indicated in paragraph 1.
The NRC described the areas
inspected and discussed in detai1 ~ the inspection findings listed below.
No proprietary material is contained in this report.
No dissenting comments were received from the licensee.
q Item Number Description, Paragraph j
IFI 338,339/90-11-01 Inadequate cavity level procedure,
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paragraph 3 j
A IFI:338,339/90-11-02 Lack of-detail in procedures, j
paragraph 3 and Appendix B
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IFI-338,339/90-11-03 E0P technical -inadequacies paragraph 3 and Appendix B q
'IFI 338,339/90-11-04 Improper content in notes and
cautions, paragraph 3 IFI'338,339/90-11-05 E0P technical and human-factors j
deficiencies, paragraph 4 and
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Appendix B
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IFI.338,339/90-11-06 E0P writer's guide deficiencies, I
paragraph-4 and Appendix C i
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IFI 338,339/90-11-07 E0P nomenclature and labeling
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inaccuracies, paragraph 4 and
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Appendix D
-IFI 338,339/90-11-08 E0P use of inconsistent wording for the same actions, paragraph 7 i
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APPENDIX A
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.c PROCEDURES REVIEWED
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E-0.
Reactor Trip Or Safety Injection REV 8 f
E-1 Loss of Reactor or Secondary Coolant REV 2
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E-2-Faulted Steam Generator Isolation REV 2
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E-3 Steam Generator Tube Rupture REV 4 e
ES-0.0,-
Re-Diagnosis.
REV 1
- ES-0.1 Reactor Trip Response
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REV 7
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.ES-0.2AL Natural Circulation Cooldown with CRDM Fans' REV 6
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ES-0.2B Natural: Circulation Cooldown without REV 5-CRDM Fans ES-0.3 Natural-Circulation Cooldown with Steam REV 3
Void-in Vessel (with RVLIS)
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.SI Termination REV 3 N.
.ES-1.2 Post LOCA Cooldown and _Depressurization REV 4
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ES-1 3.
Transfer to Cold-Leg Recirculation REV 2
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~ES-1.4 Transfer to Hot-Leg Recirculation REV 3-
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t ES-1.5
. Transfer from. Hot Leg Recirculation to REV 0 l
Coldileg; Recirculation
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'ES-3.1 Post-SGTR Cooldown Using Backfill REV 4 J.
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. Post-SGTR Cooldown Using Blowdown REV 4 ES-3.23 Post-SGTR Cooldown Using Steam Dump REV 3 i
ECA-0.0- Loss of all AC Power.
REV 3.
ECA-0.1 Loss-of all AC Power Recovery without SI REV 3 s
' Required-ECA-0.2 Loss 0f All AC Power With SI Required REV 1 o
ECA-1.1_. Loss Of Emergency Coolant Recirculation-
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'ECA-1.2~
LOCA Outside Containment REV 1
- ECA-2,1 Uncontrolled Depressurization of all Steam REV'3
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ECA-3.1 SGTR with Loss of Reactor Coolant -
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Subcooled Recovery Required
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'ECA-3.2 SGTR with Loss of Reactor Coolant REV'4
' Saturated Recovery Required-ECA-3.3 SGTR Without Pressurizer Pressure Control REV 3
'F-0 Critical Safety Function Status Trees REV 0 (FR-S.1
. Response To Nuclear Power Generation /ATWS REV 1 FR-S.2 Response.to Loss'of Core Shutdown REV 1
FR-C.1--
Response to Inadequate Core Cooling REV 3 J
FR-C.2 Response to Degraded Core Cooling REV 3 H
FR-C.3'
Response to Saturated Core Cooling REV 1 FR-H.1 Response to Loss of Secondary Heat Sink REV 3 FR-H.2-Response to Steam Generator Overpressure REV 1 m
FR-H.3 Response to Steam Generator High Level REV 1
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FR-H.4.
Response to Loss of Normal Steam Release Capabilities REV 1
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FR-H.5 Response to Steam Generator Low Level REV 1 l
FR-P.1 Response To Pressurized Thermal Shock REV 3 i
Condition.
i FR-P.2 Response to Anticipated Pressurized Thermal REV 1
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Shock Condition l
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FR-Z.1 Response to High Containment Pressure REV 1
- FR-Z.2 Response to High Containment-Sump Level REV 1 FR-Z.3-Response To Containment High Radiation REV 1
FR-Z.4 Response to Containment Positive Pressure REV 0 i
FR-1.1 Response to High Pressurizer Level REV 2
'FR-I.2 Response to Low Pressurizer Level REV 1 FR-I.3
,Respnnse to Voids in Reactor Vessel REV 3 AP-1.1 RCCA Deviation from Tavg. Control REV 12 AP-1-2 Continuous Rod Insertion REV 9
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AP-1.3 Continuous Rod Withdrawal
'REV 9 AP-1.4-Dropped Rod REV 13 AP-1.5
. Full Length Rod Out'of Alignment REV 10 i
- Malfunction of Individual Rod'
REV 2 I
Position Indication
.AP-3 Loss of Vital Instrumentation REV 7 AP-3.1 Loss of Vital Instrumentation Reactor REV 1
Coolant Flow
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AP-3.2 Loss.of. Vital Instrumentation Pressurizer REV 1
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Level
.AP-3.3 Loss'of Vital Instrumentation Pressurizer REV 1 Pressure
AP-3.4 Loss of Vital Instrumentation Loop REV 2 Delta T/TAVG
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AP-3.5 Loss of Vital Instrumentation Containment
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Pressure -
l AP-3.6 Loss of Vital Instrumentation Steam REV 1 l
- Generator Level AP-3.7 Loss'of Vital Instrumentation Steam Flow REV 1
-AP-3.8 Loss.of Vital Instrumentation Feed Flow REV 1 AP-3.9 Loss of Vital Instrumentation Steam Pressure REV 1
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l AP-3.10 Loss of Vital Instrumentation Turbine Stop REV 0
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Valve Closure Signal AP-3.11 Loss of Vital Instrumentation Turbine First REV 3 Stage Pressure
. Loss of Vital Instrumentation Auto Stop 011 REV 1 i
Low Pressure
.
AP-4.1 Malfunction of Nuclear Instrumentation REV 0 (Source Range)
- AP-4.2 Malfunction of Nuclear Instrumentation-REV 0
>
(Intermediate Range)
AP-4.3 Malfunction of Nuclear Instrumentation REV 5 (Power Range)
y
-.
..
'%
%
Appea11x A-3-
AP-4.3 Vibration and Loose Parts Monitoring Panel REV 0
~ Alarm LAP-5.1 Unit 1 Radiation Monitoring System REV 14
'AP-5.2 Common Radiation Monitoring System REV 11 AP-5.3 Kaman Radiation Monitoring System REV 0 Malfunction AP-10.1 Loss Of Electrical Power REV 13 d
AP-10.2 Restoration Of Switchyard REV 6
=AP-10.3 Restoration Of RSS Transformers REV 6 AP-10.4 Restoration Of Transfer Busses REV 4
<
.AP-10.5 Restoration'Of "1H" 4160 Volt Emergency Bus REV 7
.AP-10.6 Restoration Of "1J" 4]60 Volt Emergency Bus REV 3
,
AP-10.7 Restoration Of "2H" 4160 Volt Emergency Bus REV 1
AP-10.8 Restoration Of "2J" 4160 Volt Emergency Bus REV 1'
AP-10.9 Restoration Of 480 Volt Emergency Bus REV 2 AP-10.10 Restoration Of 480-Volt Emergency M.C.C. 's REV 2 i
AP-10.11-Restoration Of Semi-vital Busses REV 1
AP-10.12 Restoration'of DC Busses REV 1
!
AP-10.13 Restoration Of AC Vital Busses REV 3
AP-10.22 Restoration'Of Station Service'480 Volt REV 0
'!
Busses AP-10.23. Restoration Of Station Service 480 Volt REV 1 MCC's
'
AP-13'
Loss of.One or More Circulating Water Pumps REV 4 AP-14 Low Ccndenser Vacuum REV 3 i
AP-18L Increasing Containment Pressure REV 3 i
AP-20-Operation From the Auxiliary Shutdown Panel REV 9 j
AP-22.1 Loss of 1-FW-P-2 REV 7 I
f AP-22.2 Loss of 1-FW-P-3A REV 6 AP-22.3 Loss of 1-FW-P-3B REV 5
'
AP-22.7 Loss 1 of Emergency Condensate Storage Tank REV 7 AP-24.1 Large Steam Generator Tube Leak REV 10 AP-24.2 Small Steam Generator Tube Leak REV 6 AP-26 Loss-of Main Generator Voltage Control REV 0
)
AP-27.1 Loss of. Spent Fuel Pool Level REV 1 i
AP-27.2 Loss of Spent Fuel Cooling System REV 0 l
AP-27.3 Dlacing Nitecsen Backup in Service to SFP
.REV 0
l Gate Seals
!
.
AP-30 Fuel Failure During Handling REV 0
=!
AP-33 Reactor Coolant Sump Seal Failure REV 4 l
AP-33.2 Loss of RCP Seal Cooling REV 0
~
AP-36 Seismic Event
"'REV 10 AP-39.0 In plant Flooding REV 0
l'
.AP-39.1 Flooding of Turbine Building REV 0
AP-39.2l Service water Flooding in Auxiliary Building REV 0 i
<
l AP-40 Abnormal Level in North Anna Reservoir (Lake)REV 5 AP-40.1 Potential Flooding of Turbine Building REV 0 j
i AP-40.2 Dam Failure Assessment and Notification REV 1 AP-41 Severe Weather Conditions REV 4 l
AP-45 Generator Core Monitor Alarm REV 0 l
)
i
+
-:
T
- e 3
- a'
.
' Appendix'A
a
.
AP-48 Charging Pump Cross Connect REV 0 AP-49 Loss.0f-Normal Charging REV 1 l
AP-50.1-Control Room Fire REV 0
'
AP-50.2 Emergency Switchgear Room Fire REV 0-AP-50.3 Cable Vault and Tunnel Fire REV 0 AP-52-Loss of Refueling Cavity Level During REV 3 Refueling AP-54-Accidental, Unplanned or Uncontrolled REV 4 Radioactive Gaseous Waste Release OP-6.5 Operation of the 1H Diesel Generator in the REV 12
-
Control Room Emergency Mode-l
.-
'
,0P-6.6
.0peration of the IJ Diesel Generator in the REV 9 Control. Room Emergency Mode
'OP-7.3 Filling, Draining, Pressurizing and Venting REV 26 SI Accumulators
' 0P.-12. 5 High Radiation Containment Sump Sampling-REV 1
'CP-0P-30 Sampling.the A,B and C. Steam Generator None Blowdown CP-0P-185 Sampling A,B and C Steam Generator Blowdown None from OLCMS
_.
EPIP-4.23 Post Accident Sampling of Reactor Coolant REV 8 EPIP-4.25 Liquid Effluent Sampling During an Emergency REV 5 VPAP-0502 Procedure Process Control REV 0
!
VPAP-0506 E0P Development, Revision and Maintenance REV 0
.!
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-- 7,
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g f
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a i.
APPENDIX B TECHNICAL AND HUMAN FACTORS COMMENTS This appendix contains technical and human factors comments and observations.
- Unless specifically stated, these comments are not regulatory requirements.
However, the licensee acknowledged the factual content of. each of these
-
comments.
The licensee agreed to evaluate each comment, to take appropriate action and to document that action.
These items will be reviewed ' during a
,
future NRC-inspection.
,
I.
E comments:
'
1.
E-0 Reactor trip or safety injection a.
Step 6 RNO:
This step directed the operator to start the emergency diesel generators, but failed to provide specific actions or OP reference.
_j b.
PSTG DEV, step 8:
The deviation document did not adequate'y j
justify moving S/G sample and blowdown trip valve position to J
Attachment 2.
An AMSAC actuation signal or an AFW-actuation j
signal also would have _ caused valves to close.
Since these
signals were associated with the assurance of feedwater
isolation, the valves were appropriately checked at step 8.
!
-
I c.
PSTG DEV, step 9:
The deviation document justification j
statement identified component ' cooling water.
as a
!
safeguards sequenced' load.
An operator -was unsure of the
!
specific meaning or intent of this terminology.
]
i d.
Step 14a and c:
" INDICATED" failed to specify a measurable i
standard and thereby direct the operator to the RNO.
l i
e.
Step 14c2: The low-head SI cold leg ~ injection valves were not l
-
indicated to be de-energized, locked open valves. Actions to
!
re-energize were not listed, j
f.
Step 15b, 26b and 29a RNO: The value used for minimum AFV flow, I
setpoint L.4 (340 gpm), ensured only adequate heat removal with l
no RCPs running. In comparison, E-0.1 step 2c used setpoint L.7'
l (400 gpm) as an additional minimum AFW flow requirement when the-
!
RCPs were running.
Engineering documents provided < did not j
address the issue of the cooling effects of the SI flow versus
the reduction in AFW flow.
This documentation was needed to justify the reduced AFW flow value.
?
.
.
.
J
.
,
.w
,
7,.,.
e
_'
s
.
t.
.. _
l Appendix Bi
i
,
_g.
PSTG DEV, step 20-N2:
The deviation document justification'
statement incorrectly stated that potential consequences of_ seal
,
injection loss was added to the note. The consequences were not-listed.
'
h.>
Step 20d:
The substep to check of valves on charging pump recirculation actually described a high-level action separate from.the check of RCP status. The step.needed to be divided into two steps, i.
Step 26b:
Same as step I5b above.
j
_j.-
Step 29a RNO:
Same as step 15b above.
k.
Step 33c4:
This step failed to clearly identify' that the
'
operator was required to perform six actions to open the these valves.
The labels for the-valves were BD-TV-100 A, B,-C, D, E and F.
1.
. Step 33d1:
S/G sample trip valves (43-S0V-SS 111A, B, C) were t normally operated by chemistry at local sample panel SG 1-EI-CB26, This. step did not identify the need to contact chemistry, m.
Step 35 RN0:
This step listed _several possible RCS to PRT leakage paths,'but described no methods to direct the operator in the' evaluation, n '.
Attachment.1 step 3:
This. step had the operator check for amber or green' indication for the containment air recirc. fans.
Two fof-these fans were in PTL and therefore :had - no light =
indication.
~'
o.
Attachment -2 step 11b6:
This step -instructed the operator to o
push both NORMAL stop buttons. The' buttons which needed to be i
pressed were the EMERGENCY. stop buttons and both = need - to be
.
pushed : simultaneously but : the directions did not specify that.
<
" -
" Simultaneously" was used in steps 2a and 13bl when two. devices
,
were required to generate a signal.
'
p.
Attachment 2 step 11c6:
Same as-Attachment 2 step 11b6 above, q.
Attachment 2 step 13 RNO: The referenced OP involving the same i
action differed from the one referenced in 1-E-0 and the one referenced in 2-E-0 with the former listing 1-0P-63.2 and the
'
latter li sting 1-0P-21.10.
-
,
t l
V
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k'y~
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.:
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' Appendix B'
l l
?
E-1 1.oss of reactor or secondary coolant 2 '.
,
t
,a.:
Step. 4:
S/G blowdown radiation normal could not be verified
!
without racking both breakers for one main feed pump to test and closing the breakers.
The S/G blowdown' trip valves could then
!
'
be opened, i
x
\\
3.
E-2 Faulted steam generator isolation j
.,
a.
Step 4b: This step did not provide instructions to isolate the:
!
faulted steam generator if other than the normal feedpath was'in
"
service,
'
b.
Step 4b RNO:
Same as step 4b above.
!
'
c.
Step 6b: This step did not specify that both rest.t buttons are;
'L.
required to be actuated for the reset to occur.
- d-
. Step 7b:
Same as step 6b above, o
4.
E-3.. Steam generator tube rupture
.
a.
Step 3e2 RNO: This step required closing of the two condenser steam dump. valves (J handle switches).
The steam dump mode selector was an identical J handle switch positioned to the.
immediate. left ofc the right hand steam dump valve switch and-x increased the possibility of a selection-error.
'b.
Step. 3f: This step required local operation of. ruptured S/G(s)
'$
steam supply valve (s). [MS-18, MS-57, MS-95].
Valve access was
= limited. environment temperature - was o high, and tags were-difficult to read.
'
'c.
Step 4a RNO:
This step-was written as a continuous action and
there was no formal method to aid operators in remembering all
'
of the open continuous action steps.
'
.d.
-Step Sa RN0: The-breakers required by this step were identified I
with labels' that appeared pink rather than purple as was.
designated for the proper color coding.
The operator on.the
walkdown agreed the labels appeared pink. Other breakers in the
,'
'
! area had orange labels that were badly faded. The appearance of the. colors increased the possibility of operator error in
>
,
. discrimination between the two colors under time pressure and
under possible emergency lighting conditions.
,
e.
Step 7b: In this step an action step was' imbedded as a substep under a check. This increased the potential for the operator to
'
j overlook the action.
f.
Step 13b RNO: This step required the operation of at least one
,
of three valves within a high temperature environment that could a
l L
incapacitate an operator if strenuous operations or lengthy H
stays were required.
I
'
,
}
~
^
!
.a
.
.
,
.. _ -.
,
J Appendix B
4 J
'
,
J g '.
Step 18a RNO:- This step required the opeutor to monitor three parameters but provided no specific directien as to what changes-to look for or' expect.
h.
Step 31b RNO:
Same as step 4a RNO above.
l 1.
Step 32a RNO:
Same as step 4a RNO above.
J.
Step 33a RNO:
Same as step 4a RNO above.
k.
Step 35 third bullet:
This step required the performance of a relatively complicated local action requiring continuous communication between the two units outside the control. room and monitoring of a steam pressure gauge not located where the i
valves were operated locally.
No phones were within reach of the locally operated component or in the immediate area.
No
'
specific direction or reference we.s provided for the performance of:this action.
1.
Step 35 fifth bullet: This step required local operation of at least one'of three valves in the main steam valve house. Access to the valves required crawling or duck-walking several yards in very - limited -space and high environmental temperature.
A flashlight was required to locate the valves due to inoperative-local lighting. The valves were relatively high above the floor in a confined space and the labels were difficult to access and
-
read.
The operator on tM walkthrough required referring ' to.
i drawings in the control room to locate.the valves.
j m.
Step 41a RN0:
Same as step 4a RNO above, n.
Step 44: This step provided the-operator with-three options for post SGTR cooldown but did not provide direction regarding a-
,
preferred' method. The operator on the walkthrough indicated he believed there was a preferred method.
o
,
II.
ES comments:
1.
ES-0.0 Re-Diagnosis a.
No comments.
j 2.
ES-0.1 Reactor trip response a.
Step 2c:
The operator did not easily identify total feed flow prior to feedwater isolation. With the feedwater system still supplying flow through the feedwater bypass valves, the operator
)
read indicators that were calibrated in pounds per hour. Only
'
the AFW flow was read in gpm. No operator aid was available to quickly convert between units.
i i
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~ ~
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1.,
)
n6*-
a Appendix B.
.5
.l
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b.
Step.3 RNO: The operator action to initiate emergency boration
'
.
was not designated nor was an emergency boration procedure
>
I referenced. These actions were listed in FR-S.1 and AP-20.
,
a.
"
c.
PSTG DEV, step 3: The value of 21 minutes.for boration used the i
design flow of the boric acid transfer pumps.
Flow for the pumps was measured to be lower-than design.
The pump design-flow was 75 gpm while measured flow was approximately 65 gpm.-
Step deviation documentation did not adequately address this
[
difference.
,
,
3.
ES-0.2A Natural circulation cooldown with CRDM fans
.
.
This step required the operator to determine the amount a.
Step 2:
of boron to add,for cold shutdown boron concentration.
A A
reactor operator could not find the value for RCSf mass when U
using the equation provided on curve 1-SC-2.2.
b.
PSTG DEV Step 5: Adequate justification for specifying.the use of three CRDM fans was not provided.in the deviation document
>
referenced engineering item no. 32.
,
c.
Step 6c: This step did not provide an operating band around 33
,
percent in which to maintain S/G 1evel.
-"
d.
Step 9: This step did not provide a preferred method to' check
.
letdown in' service.
During plant ~ walkthroughs, different
!
methods were used by licensed -operators. One. method included.
,
valve and pump-status but no flow verification.
.
e.
Step 17: This -step did not adjust sea 1' injection-flow after
'
placement of-an additional letdown - orifice in service and adjustment of the letdown pressure control' valve.
- !
f..
Step 18b RNO: This step required power to be restored to the SI
'
accumulator valves. Neither the valve number nor the breaker
,
compartment was provided in the step.
4.
ES-0.2B Natural circulation cooldown without.CRDM fans a.
CAP:
The Unit 1 procedure copies in the Control Room file cabinet did not contain the required CAP.
The procedure reader's copy on the Control Room computer shelf did contain-s
,
the CAP.
,
b.
Step 2c: This step did not provide an operating band around 33 i
'
percent in which to maintain S/G 1evel.
>
c.
Step 5: This step did not provide a preferred method to check
~1etdown in service.
During plant walkthroughs, different methods were used by licensed operators. One method included
>
valve and pump status but no flow verification.
I
M?
!
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,
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1, l*
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r, a.:
- e l'
l Appendix B-6~
!..
d.
Step 14:.This step did not adjust seal injection flow after-
,
placement L of an additional letdown orifice in service and
,
,
'
adjustment of the letdown pressure control valve.
.
e.
Step 16: This step did not specify that-the pressurizer heaters are required to be used to maintain pressure,
,
f.
Step 17b RNO: This step required power to be restored to the SI-accumulator valves.
Neither the valve number nor the breaker compartment was provided in the-step.
g.
Step 20:
This ' step was not in its required location prior to.
step 17.
h.
Step 2Ea: This step required the operator to determine that the--
. i entire RCS was less than 200 degrees F.
No method was provided-to accomplish this task as discussed in the ERG,
'U a
5.
ES-0.3 Natural circulation cooldown with steam void in vessel 1(with
- (
w
a.
PSTG DEV CAP Step 3: The step required starting ofian RCP'when-tho' conditions of OP-5.2 were met. The ERG required RVLIS" upper?
!
range level indication greater than 95% or,-pressurizer leve1 < 72%
li and subcooling greater than 55 F prior to. starting an.RCP. jThe
'
-
deviation was not justified in the deviation document.and the
,
,*
.
step was inadequate.
a b.
.PSTG DEV Step 1c RNO:
This step stated "if conditions are
- t
,
established for starting an RCP,then do steps Ic and Id."
The
1 ERG required return to step lb. The deviation was not justified:
i andLtheMstep was-inadequate, c.
PSTG DEV Step 3d RNO: Thisstepstated"Trytoestablishl normal
"
letdown.
IF letdown' cannot be1 established, then use: one pressurizer PORV.
Go to step 4."
The ERG stated "Depressurize RCS using one. pressurizer PORV.
Go to-step 4."
The deviation <
'
was not justified and the step was inadequate.
J
!
6.
No comments.
>
.
n 7.
ES-1.2 - Post 'LOCA cooldown and depressurization-a.
Step 4 RN0: This step was written as.a continuous action but c
there was no formal method to aid the operator in remembering all of the open continuous action steps. This step used the conditional statement IF required, THEN... but provided no L
specific guidance on how to determine if required.
L l'
.
r
-_
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+ '
,
Appendix B
h
'
b.
Step 6 RNO: :This step inferred continuous actions but there was
'
no formal method to aid the operator in remembering all' o/ the open continuous action steps, c.
Step 7c1 RNO: This step required the operation of at least one of three valves within a high temperature environment that could incapacitate' an operator if strenuous operations or lengthy
.
. stays were required.
'
<
-
i d.
Step 11b RN0: This step was written as a-continuous action but
.
there-was no formal method to aid the operator in remembering all of the open continuous action steps, i
e.
Step 18b:-- In this step an action step was imbedded as a substep.
under a check. This increased the potential for the operator to overlook the action.
f.
Step 20b:
This step required using pressurizer. spray' to ~
depressurize the RCS.
Substep b required using: pressurizer.
heaters "as necessary" but provided no direction or criteria ton make this ' determination.
Operators on walkthroughs indicated they' did' not.know why the heaters would be used during
-
depressurization,
,
g.
Step 24b: This step required a status check using an attachment from another procedure.
r h.
Step 28a RNO: S'ame as step 11b RNO above.
,
<
'
1.
Step 29e:
This step required the performance of a relatively q
-
W complicated loc:il' action requiring' continuous communication,
-between the two untts outside the control room and monitoring of
?
a steam' pressure gauge not located at the valves operated locally.
No phones were within reach of the locally. operated g
i component or in the immediate area. No specific direction or q
reference was provided for the performance of this action.
, ',
Lj.
Step 30a RNO:
Same as step lib RNO above.
8.
ES-1.3 Transfer-to cold leg recirculation j
_;
'
!
-No comments
!
9.
ES-1.4 Transfer to hot leg recirculation j
a.
Step la2:
This-step required the operation from the control-l room of two MOVs. The MOVs must be energized locally from the
>
!
<
cable vault and this was not indicated in the procedure.
.
,
{
10.
ES-1.5 Transfer from hot leg recirculation to cold leg recirculation
i
!
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s
<:
.
.A g
Appendix B
J t
a.
Step 1: The step required a -key to actuate the valves. The i
'
keys labeled no. 25 in the key locker contained two keys which
_
were not the specified ILL L403 key, b.
Step 2:
This step verified two charging pumps available. The desired action was to verify the pumps in service.
,
11',
ES-3.1 Post-SGTR cooldown using backfill
,
a.
Step Sc1 RNO: This step required the operation of at least one o
of three valves within a high temperature environment that could incapacitate an operator if strenuous operations or lengthy stays were' required.
'
b.
Step _8b:
This step required using pressurizer spray to i
depressurize the RCS, Substep b required using pressurizer '
>
- heaters "as necessary" but provided no ' direction or criteria to a
make this determination.
.c.
Step 10a RNO: TThis step was written as a continuous action but
'
there was-no formal method to aid the -operator in remembering the open continuous action steps.
+
12.
ES-3.2 Post-SGTR cooldown using blowdown
+
>
.No comments.'
y
-
13.
ES-3.3 Post-SGTR cooldown using steam dump
~
No comments.
'III. ECA comments:
1.
'ECA-0.0 Loss of all AC power a,
. Step 3c:
This step required _ verifying excess letdown isolation valves-closea.
These valves are deenergized during normal i
operation.
{
b.
PSTG DEV Step 4: This step failed to identify' a required AFW flow value. This was not adequately addressed in the deviation
,
document.
- c.
Step 4a:
This step required verification of the turbine driven AFW pump - running.
Indication that the pump was running was-not available in the control room,
.
d.
Step 4b:
This step directed the verification of turbine driven AFW discharge valve, FW-MOV-2000 - open. Valve indication v:ould not be available.
!
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y
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s..
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[
lAppendixB
'
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s e.
Step, Sal: This step required starting of the emergency diesel.
'
'
generators : from the control room. by pressing the START-pushbutton.
The pushbutton was labeled EXC. START.
The
emergency diesel generator' selector switch had to be placed in manual remote prior to pressing the pushbutton and the step did not reference a two minute time delay in the circuitry.
j L
f.
Step Sal ~ RNO:
The referenced OP's could not be performed as
'
+
,
written to accomplish the RNO.
g.
Step 9c RNO: This step directed manual operation -of a valve.
,
The valve would be operated locally,
h.
Step 12: This step required check of the condenser air ejector a
radiation
< normal and S/G blowdown radiation - normal'. These t
'
instruments would not have power available, t
1.
Step 14b:.This step did not provide guidance for stopping the j
DC turbine oil. pump or DC air. side seal oil pump prior to ij turbine.- stopped, generator hydrogen
. vented depending on DC
bus voltage / loads.
j.
Step 14d: This step required notification of TSC personnel to determine other nonessential loads. The TSC may not be manned, k.
Step 15: This step was identified as a continuous action. The'
,
= step was not referenced on-the continuous action'page.
l
!
1.
PSTG DEV Step 16-C: This step-failed to caution.the operator to j
. maintain :S/G narrow range level-in at least one intact S/G.
,
This was not properly addressed in the deviation document.
m.
PSTG DEV. ERG Step 22:
This step. in the ERG required check' of I'
containment radiation levels.
Deletion of this step from-the j
L E0P was not properly addressed in the deviation document.
.
I n.
Step 24a: This step required-battery chargers to be verified j
energized.
Indication was not available in the control room.
.
!
t o.
Step 24d:
This. step required heat tracing to be.. verified
energized.
Indication was not available in.the control room, p.
Attachment 2:
This attachment used the word " Ruptured'! instead of " Faulted" in the heading of the first column.
!
i 2.
ECA-0.1 Loss of all AC power recovery without SI required.
j
.
i a.
Step 10b:
Step.16 of ECA-0.0 depressurized intact S/G to 145
?
psig.
Step 26d of ECA-0.0 transitioned to step 1 of ECA-0.1.
Step 10b of ECA-0.1 required putting the S/G PORV in automatic.
t The S/G PORVs would only control in actematic between 600 and
1400 psig.
)
i
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!
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<
[
w L
- .
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T-l Appendix B.
-10-l
-
.
b'
Step-12: There'was only local indication unless the operator
.
verified flow by trying to start a component ' cooling water pump.
c.-
Step 15: Tnis step required AP-33.2 be--initiated. Step; 5.of
.AP-33.2 closed MOV-1381 and Step 16 of ECA-0.1 opened MOV-1381.
-
The steps in AP-33.2 and ECA-0.1 were not - coordinated.
The control room operator would have needed to coordinate with the auxiliary operator,
,'
d.
Step 16d:'This step opened seal return MOVs whereas AP-33.2 Step 5.6d locally' opened MOV-1381, e,
Step 16a RNO: This step required the operator to go to step 17 which established letdown.
The corresponding step in.AP-33.2-branched to-step 5.7, which established seal injection.
!
'3'
ECA-0.2 Loss of all AC power with SI required l
,
a.
Step 1: This stop did not detail the parameters:or indications-used ;to verify seal cooling isolation. One operator' indicated that-isolation of the seal injection valves was adequate while the attachment additionally isolated component cooling water return from the RCP seals.
The wording of this action-was inconsistent across the ECA-0 series, b.
Step 1.RNO:
This step specified action performed in ECA-0,1.
t The seals could' also have been isolated in. ECA-0.0 and this
'
procedure entered directly from there (ECA-0.0).-
c.
~ Step Sbli This step was redundant to action; performed in step
1.
Step 1 was the entry step for all transitions to.this
"
procedure.
d.
PSTG DEV, step 8:
The deviation document did not adequately
justify the' addition of this step to check SW-system status.
ERG step 4 background document stated the intention of this was to establish all-ESF equipment operability.
.
e.
Step 9 RNO:
An operator expressed doubt about the ability-to
?
locally close the stub bus breaker with the RHR pump switch not in PTL because of an electrical interlock.
'
f.
Step 10a:
This step did not indicate that some of the actions were done ' locally.
SFP cooling required local operation-of-
,
valves.
Boron recovery system isolation required control -room and local operation of valves.
g.
Attachment 1:
The steps for RCP seal cooling isolation were
,
l incomplete.
Procedures ECA-0.0 and AP-33.2 had additional action that closed valve M0V-1381.
,
i
-
.
,
.c
'(
.
,h
t I
Appendix B
-
4..
ECA-1.1. Loss of emergency coolant recirculation
,
a.-
Step 4 RNO:
This step directed the operator to establish conditions for containment air recirc fan operation, but failed-to provide specific actions or OP reference.
b.
Step: 6a:,
The operator read the-recirc spray sump level
,
. instrument to be greater than 1 foot, 5 inches. However the e
divisions on-the meter face were three-for every one foot, A
allowingJthe operator to read level only to the nearestc2 inches.
c.
Step 7bl RNO:
The operator read the labels for CDA reset with
-
.
difficulty since the metal covers hide a portion of the. labels.
'
d.
St'ep 27:
This step did not-identify AP-48 as procedural:
a guidance for the cross-connect of the charging pumps.
e; PSTG DEV:
The technical reason for blocking the high steamline.
g flow.with low Tave SI was inadequate.
The intent of blocking
this signal as described in the ERGS was to prevent the main j
steamline isolation.
,
5.
ECA-1.24 1.0CA outside containmenc a.
Step 2a2:
This step required the operation from the control i
room of two'MOVs. The MOVs must be energized locally from the'-
cable vault'and this was not indicated in the procedure.
6.
ECA-2.1 Uncontrolled depressurization of all steam generators
'
a.
CAP: -The Unit i2 ' procedure copies _ in the'. Control.-Room file-
'
cabinet did contain 'the required CAP. _ 'The. procedure reader's copy 1 on the Control ' RoomL computer-shelf and-the copy _at.the _
a auxiliary shutdown panel did not contain the CAP.
'
~ lternate method' of-b.
Step 1.f:
This step did not -provide an a
-
'
using SPDS to verify valve position.
c.
PSTG DEV. Step 6a,b: There was no explanation in the de'iation v
document (also different than deviation document for 1-E-1 Step 4).
,
',
d.
Step 6f: There was no explanation.in the deviation document, e.
Step 8:
The metal cover over the phase A & B reset buttons covered the-name plates on Unit 2.
On Unit 1 there were no
-cover plates over the phase A reset buttons.
'
f.
Step 10a:
2.5% was difficult to read on the scale.
9 Attachment 1 Step le RNO: This statement was different than the
'
corresponding step in ES 0.1 Attachment I which directed: the-operator to dump stea g, f:7
.
-
p
,'
.,,
I
.
. Appendix B
,
h, Attachpent 2:
General comment on Attachment. Several of the
valves were difficult to find.
I
'
1.
Attactment 2:
Local isolation 1-IA-438.
If this valve was I
securad the main steam isolation valve shut time was uncertain.
J.
Attaciment 2: Alternative 1-MS-23,61,99 were difficult for the operator to find and their location was not specified.
j t
k.
Attachhent.2:
Local isolation valves 2-IA-571, 2-IA-575 and t
2-IA-583, were difficult -to find for all operators.
They were
'
in the tverhead and not accessible.
No ladder was available.
The proceiure did not require isolation of IA-573,577, and 582 which are easily accessible.
In order for the valves to close sooner it Jas necessary to bleed off the air at the transmitters.
7.
ECA-3.1 SGTR with lo;s of reactor coolant - subcooled recovery required a.
Step 7a:
This step verified a value at the bottom of the instrument scale, b.
Step 13c RNO: This step did not provide an adverse containment
-
value, c.
Step 22-N1:
This note contained an action.
,
'
d.
Step 28b:
This step did rot provide the desired range for maintaining pressurizer level, e.
Step 32a RNO: This step did not define "as necessary".
'
f.
Step 32b RNO:
Same as step 32a RNO above.
g.
Step 33c RNO: This step required power to be restored to the SI accumulator valves.
Neither the valve number nor the breaker
- i compartment was provided in this 5.ep.
h.
Star '4ab.
This step did not provide an RNO.
'
i.
Step 46c:
This step required purging a S/G.
There was no
,
procedure referenced for performing the task.
>
8.
ECA-3.2 SGTR with loss of reactor coolant - saturated recovery a.
PSTG DEV CAP Step 4: This continuous action required entry into E-2 if S/G pressure was decreasing in an uncontrolled manner or any S/G was completely depressurized.
The ERG stated "unless needed for RCS cooldown".
This deviation from the ERG was not addressed in the deviation document.
The action was not
,
consistent with the criteria stated in step 3.
.
e
r7
.
'
I
.
,
.
..
-
i-Appendix B
i b.
Step 1:
This step stated " consult TSC for guidance to make up from Unit 2 RWST by cross-connecting RWSTs using RP system".
The TSC may not be manned.
i c.
PSTG DEV Step 11: The ERG contained a caution "After
'
stopping any SI pump, RCS pressure should be allowea to
stabilize or increase before stopping another SI pump".
l The deletion of the caution statement was not adequately.
justified in the deviation document.
d.
PSTG DEV Step 29:
This step had an incorrectly referenced S/G
!
level.
The procedure used the value 20 percent.
The ERG
specified a value showing S/G 1evel just in the narrow range,
including allowances for normal channel accuracy.
This value r
equates to 10 percent. This was not adequately addressed in the i
deviation document.
'
9.
.ECA-3.3 SGTR without pressurizer pressure control a.
Step 2a: The RCPs were not designated.
,
b.
Step 4b(1),3,& 4:
These steps contained no RNO.
.
c.
Step 11:
This step failed to direct the operator to the corresponding RNO in the event that the operator performed the AER and achieved unsatisfactory results, d.
Step 13: This step lacked details.
e.
Step 14b:
Same as step 13.
It failed to list the components.
j f.
Step 14c:
This RNO verified service water alignment to the required component cooling water heat enhangers..The Unit 2 service water valve configuration to component cooling water heat exchangers, SW-MOV-208A and SW-MOV-208B (open)', did not provide the heat exchangers with the proper. valve alignment to line up Unit 2 service water, g.
Step 16a:
Same as step 14b above.
h.
Step 16b:
Same as step 14b above.
1.
Step 17a:
Same as step 14b above.
.
j.
Step 17a RNO:
Same as step 14b above. The step ina jequately instructed the operator to manually load the equipment on the AC-Emergency bus as required.
When the walkthrough was performed, 1:
the operator stated that the selection of the equipment was scenario dependent.
In addition, the logic statement improperly
,
used the bullets to list the equipment under the emergency conditions. Consequently, the step failed to reflect that the choice of equipment is scenario dependent.
l
,
E
- .
'
.
.
e L
Appendix B
k.
Step 18 RNO: This step lacked the necessary details to isolate the auxiliary steam loads. Drawing FM 72 A and B showed various ways and individual loads.
1.
Step 19e RNO: The step failed to furnish an RNO.
m.
Step 23a.d-h:
Same as step 14b above.
n.
Step 24b, RNO:
Same as step 14b above, o.
Step 25:
This step lacked details. Unlike other similar E0P steps, this step failed to provide direction on contacting chemi stry.
p.
Step 27b 32a,35c:. In these steps which alternately bled the intact and ruptured S/Gs to the condenser, the procedure was not sufficiently clear to prevent operator confusion about wheth;r the intact or the ruptured S/G should be used.
q.
Step 27b,32a,35c:
Same as step 14b above.
IV.
FR comments:
1. -
FR-S.1 Response tc nuclear power generation /ATWS a.
Step 2a:
" Simultaneous" was not used in this step. The action described in this step was the same as that of step 2a of E-0, however the wording was not the same, b.
Step 4b:
This step failed to describe any alternative to emergency boration.
The RWST and the BIT were available as a source of borated water and should have been included in the RNO step.
c.
Step 4c: An operator expressed uncertainty as to the meaning of the term " rapidly decreasing". He stated that the intent was to identify whether the flux showed any decrease (not increasing or steady).
d.
Step 11: This etep did net adequately ensure isolation of a faulted S/G. Neither the S/G blowdown valves nor the decay heat release valve were checked closed as was identified in step 4 of E-2 for the same actions, e.
Step 11a3 RNO:
The operator was instructed to locally isolate the MFRBV block valve.
The location of the handwheel for
.
2-FW-54 was beyond the end of the platform the operator stood
'
on..The valve handwheel was easier to reach from the platform access ladde b
'.
,
!
'e Appendix B
f.
Attachment 2, step Ic RNO:
The operator indicated he would-attempt to trip the MG set by operating the input breaker control switch. This action was not addressed.
2.
FR-S.2 Response to loss of core shutdown No comments.
3.
FR-C.1 Response to inadequate core cooling i
No comments.
4.
FR-C.2 Response to degraded core cooling a.
Step 2a RNO: This step provided four alternative actions to the operator but provided no preferred order or specific direction on how to perform the alternatives.
The operator on the walkthrough indicated there was a preferred order and that references to ops for the actions would be useful.
b.
Step 2b RNO:
This step was written as a continuous action but there was no formal method to aid the operator in remembering the open continuous action steps.
,
c.
Step 10b RNO:
This step provided five alternative actions but provided no preferred order.
The operator on the walkthrough indicated there was a preferred order, d.
Step 13-C: This caution was located near the bottom of the page while most of the related steps were on the following page, e.
Step 14b RNO:
Same as step 10b RNO above, f.
Step 15 RN0:
Same as step 2a RNO above.
g.
General comment on FR-C.2:
This procedure contained many transitions (eight transitions on pages six and seven alone).
This could increase the probability of operator errors and place I
keeping problems, especially when the operator is under i
l-stress during an emergency.
5.
FR-C.3 Response to saturated core cooling l
a.
Step 1: This step was ambiguous in stating the prior status of l
the RHR system.
During a walkthrough, a licensed operator.
Indicated that this step should be clarified to better define
]
L the intent.
'
b.-
' Step 2a RNO:
This step did not provide detailed instructions for aligning the system, c.
PSTG DEV, Step 2b RN0:
The deviation document referred to ERG f
steps 11 and 15 which do not exist.
l
'e L
l
,
!
Appendix B~
!
i d.
Step 2c:
This step required verification of SI flow via instruments 2-SI-FI-1945 and 2-51-FI-1946.
These instruments had not been calibrated during the last refueling outage with
the result that they were 14 months past their normal two year
'
calibration period.
Deviation report 90-766 and 90-767 were
-
issued. Subsequent calibration revealed that these instruments
were still within their calibration acceptance range, r
e.
Step 2c RNO:
Same as step 2a RNO above, f.
Step 3a RNO:
This step did not provide the valve or breaker compartment designations.
,
6.
FR-H.1 Response to loss of secondary heat sink No comments.
7.
FR-H.2 Response to steam generator overpressure
,
a.
PSTG DEV, Step 4:
The deviation document did not justify why the MSTV valve was specified to be opened in place of the MSTV
bypass valve as specified in the ERG.
b.
Step 4: This step did not provide sufficient detail in that the configuration in which to operate the turbine-driven AFW pump
,
was not specified,
'
c.
Step 6:
This step did not include alternate feedwater flowpath valves in-the list of valves for isolation of a S/G.
d.
Step 7 RNO:
This step contained less detail than step 4 to accomplish the same action as step 4.
e.
Step 8:
Same as step 4 above.
8.
FR-H.3 Response to steam generator high level a.
Step 3: This step did not include alternate feedwater flowpath valves in the list of valves for isolation of a S/G.
b, Step 8a: This step did not specify that both reset buttons are required to be' actuated for the reset to occur.
c.
Step 8b:
Same as step 8a above, 9.
FR-H.4 Response to loss of normal steam release capabilities
'
No comments.
'
l
-
-
9f
.
,
.
O Appendix B
10.
FR-H.S Response to steam generator low level a.
Step 4 RNO:
The step required AFW flow to affected S/G to be limited to 100 gpm.
100 gpm was tne first increment on the flow meter.
11.
FR-P.1 Response To Pressurized Thermal Shock Condition a.
Step la RNO: The operator stated S/G PORV indication was demand position only.
Verifying the valves closed cannot be performed from the control board, b.
Step 4:
This step provided no details for checking the BIT in service. This differed from actions in other procedures, c.
Step 7:
This step provided no details for the resetting. The L
operator is required to simultaneously push two buttons in one of two places.
d.
Step 16b RNO:
Valve identification was not adequate since equipment mark numbers were not provided.
Also, an operator indicated that an administrative 1y controlled key would be required to operate breakers, e.
Step 20b:
The actions described were not sufficient to align service water if the other unit was supplying the header.
Local alignment of some valves was required.
12.
FR-P.2 Response to anticipated pressurized thermal shock condition a.
Step 2:
This step required the operator to check BIT isolated but provided no valve numbers. The operator on the walkthrough indicated that valve numbers for BIT isolation would be useful.
13.
FR-Z.1 Response to high containment pressure a.
No comment.
14.
FR-2.2 Response to high containment sump level a.
General:
The concern with flooding -in containment was that critical plant components needed for plant recovery could be damaged and rendered inoperable. The procedure did not identify a maximum level, the flood level, or what equipment would be lost at various levels, b.
Step 1: The step did not identify all sources of water into the containment sump, instrumentation used to identify sources of water were not listed and isolation valves were not listed.
I
n O
.
'
.
Appendix B
c.
Step 2:
The step required chemistry to sample the containment sump.
Component cooling may not be availabic to support sampling.
15.
FR-Z.3 Response to containment high radiation No comments.
16.
FR-Z.4 Response to containment positive pressure a.
Step 13:
This step required the operator to verify RWST level greater than three percent. The zero to 100 percent scale on the indicator was difficult to read at the top and bottom of the t
scale.
The operator on the walkthrough indicated a need for narrow range indicators for top and bottom scale ranges.
!
17.
FR-I.1 Response to high pressurizer level a.
Step 2a2 RNO: This step did not require-that valve CH-MOV-1373 be opened to establish a recirc path for the charging pump to be started, b.
PSTG DEV, Step 2d:
The step stated " check RCP seal cooling".
This statement was not contained in the ERG The deviation was not justified in the deviation document, c.
PSTG DEV, Step 3a RNO: The step stated "go to step 4".
The ERG
.
stated "go to step 5".
The deviation was not justified in the I
deviation document.
d.
Step 7:
The step required all available pressurizer heaters be energized.
There was not a caution to alert operators that the emergency diesel generators could be overloaded if they were supplying bus voltage.
18.
FR-I.2 Response to low pressurizer level J
No comments.
.
I 19.
FR-I.3 _ Response to voids in reactor vessel a.
Step 3b2 RNO: This RNO verified service water alignment to the required component cooling water heat exchangers.
The Unit 2
.
service water valve configuration to component cooling water
l heat exchangers, SW-MOV-208A and SW-MOV-2088 (open), did not
'
provide the heat exchangers with the proper valve alignment to line up Unit 2 service water.
V.
CSFST comments:
1.
F-0 Critical safety function status trees, attachment 1
-I
-
l E
!
.
,
Appendix B
-
i a.
PSTG DEV: The E0P setpoint F.8 documentation did not provide
adequate justification for use of the specified RVLIS
level to indicate that the upper head is full, i
- VI '.
AP comments:
!
1.
AP-3 Loss of vital instrumentation
!
'
a.
General:- The procedure had not been-revised and updated to the
=E0P format.
b.
Step 5.1: The step did not require the performance of AP-3.1 if the' unit was in mode 1 less than 10% power.
The step did not require the performance of AP 3.3 if the unit was in mode 3 less than 2000 psig. The step did not require the performance of AP 3.4 if the unit was in mode 3 less than 543 F.
This is contrary to the requirements of the technical specifications.
2.
AP-3.1 Loss of vital instrumentation reactor coolant flow-a.
General: The procedure had not been revised _and updated to the E0P format.
3.
AP-3.2 Loss of vital instrumentation pressurizer level a.
General:
The procedure had not been revised and updated to the E0P format, b.
Step 2: The step contained two substeps identified as 2.1.
c.
Step 3:
The step contained two substeps identified as 3.1.
,
4.
AP-3.3 Loss of vital instrumentation pressurizer pressure a.
General: The procedure had not been revised and updated to the E0P format.
5._
.AP-3.4 Loss of vital instrumentation loop delta T/TAVG a.
General: The procedure had not been revised and updated to the
,
E0P format.
6.
AP-3,5 Loss of vital instrumentation containment pressure a.
General:
The procedure had not been revised and updated to the E0P format.
7.
AP-3.6 Loss of vital instrumentation steam generator level a.
_ General: The procedure had not been revised and updated to the E0P format.
!
It i
-
I
cc k
.
?
o
,
- '
g
[
Appendix B
<
i 8.
-AP-3.7 Loss of vital instrumentation steam flow L
a.
. General:
The procedure had not been revised and updated to the E0P format.
9.
AP-3.8 Loss of vital instrumentation feed flow r
I a.
General.:
The procedure had not been revised and updated to the E0P format.
10. AP-3.9 Loss of vital instrumentation steam pressure g.
a.
General:
The procedure had not been revised and updated to the
'
E0P format.
11. AP-3.10 loss' of vital instrumentation t':.oine stop valve. closure
-
signal a.
Gene al:
The procedure had not been revised and updated to.the EOF format.
12. AP-3.11 Loss of vital instrumentation turbine first stage pressure a.
General:
The procedure had not been revised and updated to the E0P format.
13.
AP-3.12 Loss of vital instrumentation auto stop oil low pressure
'
- a.
General:.The procedure had not been revised and updated to the.
E0P format.
14. - AP-5.1 Unit I radiation monitoring system a.
Step. 6.1.1b:
The trend recorder readout was not in leakrate units (gpm). The operator had to use-a posted operator aid to convert the output cpm to gpm.
15. AP-5.2 Common radiation monitoring. system a.
Step 5.3: A note was not included prior to this step to explain'
the consequences of the hi-hi radiation signal (Control Room F
isolation with bottle activation);.
'
'AP-5.3 Kaman radiation monitoring system malfunction
!
No comments.
{
17.
AP-10.1 Loss of electrical power n
,. -
-.
,
a o
.
L e, '
i Appendix B
I a.
Step 1 RNO:
The transitions indicated were confusing. The i
orerator could feel that he or she was being directed to other precedures withcut the requirement to complete this one, b.
Step 4 RNO: This step did not direct the operator to attempt to start a pump.
Forced circulation would be preferred over natural circulation.
c.
Step 5: The value of forty percent S/G level was not justified.
E0P levels were directed to fifty percent.
L
'
d.
Step 8 note:
The note prior to step 8 was ectually an RNO action for step 8.
-
'
18.
AP-10.2 Restoration of switchyard
'
a.
Step 5.1: There was no guidance on which steps of procedure AP-10.1 were the applicable steps completed.
b.
Step 5.4 note:
This note was actually a step performed, c.
Step 5.10 note: This note was actually an RNO action for step
'
5.10.
&
d.
Step 5.11 note: This note was actually an RNO action for step 5.11.
e.
Step 5.15 note: This note was actually an action performed in step
'
5.15.
19. AP-10.3 Restoration of RSS transformers
!
a.
Step 4.1:
There was no guidance on which. steps of procedure
,i AP-10.1 were the applicable steps completed, i
20. AF-10.4 Restoration of transfer busses a.
Step 4.1:
There was no guidance on which steps of procedure AP-30.1 were the applicable steps completed.
21. AP-10.5 Restoration of "1H" 4160 volt emergency bus a.
Step. 4.1: There was no guidance on which steps of procedure AP-10.1 were the applicable steps completed.
b.
Step 5.1.1: The step did not provide direction to transition to Ap-10.4 if transfer bus F was not energized.
I c.
Step 5.1.2:
Those breakers that had no pull-to-lock position were incorrectly placed under this action. Those breakers were not specified in a separate step.
t
.
...
..
___
___-_
.
e'
'
Appendix B
d.
Step 5.1.10: This step was incorrectly placed here rather than in procedure AP-10.9.
e.
Step 5.2.2:
Those breakers that had no pull-to-lock position were incorrectly placed under this action. Those breakers were not specified in a separate step, f.
Step 5.2.10:
This step was incorrectly placed here rather than in procedure AP-10.9.
g.
Step 5.2.10 note: If step 5.2.10 had been removed, this note would have been moved to step 5.2.9.
h.
Step 5.3.1: This section ended with the attempt to start the diesel.
The operator was not directed to further recovery actions, i.
Step 5.3.2: This section ended with the attempt to close the breaker.
The operator was not directed to further recovery-actions, j.
Step 5.3.3: This section ended with the attempt to control m
diesel speed. The operator was not directed to further recovery actions.
k.
Step 5.4.2:
Those breakers that had no pull-to-lock position-were incorrectly placed under this action. Those breakers were not specified in a separate step.
1.
Step 5.4.13: This step was incorrectly placed here rather than in procedure AP-10.9.
m.
Step 5.4.13 note: If step 5.4.13 had been removed, this note would-have been moved to step 5.4.12.
22. AP-10.6 Restoration of "1J" 4160 volt emergency bus a.
Step 4.1: There was no guidance on which steps of procedure AP-10.1 were the applicable steps completed, b.
Step 5.1.1: The step did not provide direction to transition to Ap-10.4 if RSS transformer bus A was not energized, c.
Step 5.1.2: Those breakers that had no pull-to-lock position were incorrectly placed under thi< action. Those breakers were not specified in a separate step.
!
d.
Step 5.1.10:
This step was incorrectly placed here rather than
!
in procedure AP-10.9.
I
E o
,
L c,'
!
Appendix.B
e.
Step 5.2.2:
Those breakers that had no pull-to-lock position were incorrectly placed under this action. Those breakers were not specified in a separate step, f.
Step 5.2.10:
This step was incorrectly placed here rather than
in procedure AP-10.9.
g.
Step 5.2.10 note: If step 5.2.10 had been removed, this note would have been moved to step 5.2.9.
h.
Step 5.3.1: This section ended with the attempt to start the
,
diesel.
The operator was not directed to further recovery actions.
1.
Step 5.3.2: This section ended with the attempt to close the breaker.
The operator was not directed to further recovery actions.
J.
Step 5.3.3: This section ended with the attempt to control diesel speed. The operator was not directed to further recovery actions.
23. AP-10.7 Restoration of "2H" 4160 volt emergency bus
,
a.
Step 4.1:
There was no guidance on which steps of procedure AP-10.1 were the applicable steps completed, b.
Step 5.1.1: The step did not provide direction to transition to AP-10.4 if transfer bus E was not energized, c.
Step 5.1.2:
Those breakers that had no pull-to-lock position
,
were incorrectly-placed nder this action. Those breakers were
'
not specified in a separue step.
d.
Step 5.1.3:
The instructions "do not push" needed to be a caution statement prior to the step.
'
e.
Step 5.1.10:
This step was incorrectly placed here rather than in procedure AP-10.9.
f.
Step 5.2.2:
No operator was able to locate the spare breaker for 25H1 cubicle. One of the operators did call the Control Room and found that the breaker was stored in a spare cubicle in the 2J switchgear, g.
Step 5.2.4: Those breakers that had no pull-to-lock position
!
were incorrectly placed under this action. Those breakers were
!
not specified in a separate step.
I h.
Step 5.2.8:
The verb " proceed" was used instead of " initiate".
" Proceed" conveyed concurrent performance of the procedures.
'
I i
!
- .
<
.
L Appendix B
!
!
1.
Step 5.2.15:
This step was incorrectly placed here rather than in procedure AP-10.9.
.
j.
Step 5.2.15 note: If step 5.2.15 had been removed, this note would
"
have been moved to step 5.2.14.
k.
Steps 5.2.16 and 5.2.17:
These steps were not listed prior to the. transition t0 AP-10.9.
These steps also failed to g
differentiate Mtween those actions carried out locally and
,
those performed in the Control Room.
-
1.
Step 5.3.1: This section ended with the attempt to start the diesel.
The operator was not directed to further recovery actions, v
m.
Step 5.3.2: This section ended with the attempt to close.the breaker.
The operator was not directed to further recovery.
actions, n.
Step 5.3.3: This section ended with the attempt to control
'
diesel speed. The operator was not directed to further recovery actions.
24. AP-10.8 Restoration of "2J" 4160 volt emergency bus
a.
Step 4.1:
There was no guidance on which steps of procedure AP-10.1 were the applicable steps completed, b.
Step 5.1.1: The step did not provide direction to transition to
'
AP-10.4 if transfer' bus F was not energized, c.
Step 5.1.2:
Those breakers that had no pull-to-lock position were incorrectly placed under this action. Those breakers were
-
not specified in a separate step.
.
d.
Step 5.1.4:
The instructions "do not push" needed to be a caution statement prior to the step, e.
Step 5.1.11:
This step was incorrectly plated here rather than in procedure AP-10.9.
f.
Step 5.2.2:
No operator was able to locate the spare breaker for 25H1 cubicle.
One of the-operators did call the Control
,
Room and found that the breaker was stored in a spare cubicle in the 2J switchgear, g.
Step 5.2.4:
Those breakers that had no pull-to-lock position were incorrectly placed under this action. Those breakers were
,
not specified in a separate step, i
..
-
-
- ,
.'
Appendix B
h.
Step 5.2.8:
The verb " proceed" needed to be replaced with
" initiate" since this verb conveys concurrent performance of the procedures, 1.
Step 5.2.15: This step was incorrectly placed here rather than in procedure Ap-10.9.
J.-
Step 5.2.10 note:
If step 5.2.10 had been removed, this note would have been moved to step 5.2.9.
k.
Steps 5.2.16 and 5.2.17:
These steps were not listed prior to the transition to AP-10.9.
These steps also failed to differentiate between those actions carried out locally and those performed in the Control Room.
1.
Step 5.3.1: This section ended with the attempt to start the diesel.
The operator was not directed to further recovery actions, m.
Step 5.3.2: This section ended with the attempt to close the breaker.
The operator was not directed to further recovery actions.
-I n.
Step 5.3.3: This section ended with the attempt to control diesel speed. The operator was not directed to further recovery actions, o.
Step 5.4.3: Those breakers that had no pull-to-lock position were incorrectly placed under this action. Those breakers were not specified in a separate step.
p.
Step 5.4,14:
This step was incorrectly placed here rather than in procedure AP-10.9.
q.
Step 5.4.14 note: If step 5.4.14 had been removed, this note would have been moved to step 5.4.13.
,
25. AP-10.9 Restoration of 480 volt emergency bus a.
Step 4.1: There was no guidance on 'which steps of procedure Ap-10.1 were the applicable steps completed, b.
Step 5.2.2: The wording was unclear as to whether a transition to Ap-10.11 was required.
j c.
Step 5.2.7:
The step failed to list appropriate DC loads and the ratings.
d.
Step 5.6.8:
Same as step 5.2.7 above.
e.
Step 5.10.6:
Same as step 5.2.7 above.
l l
e s
.
[
Appendix B
'
I
i
'
!
26. AP-10.10 Restoration of 480 volt emergency M.C.Cs
'
a.
Step 4.1:
There was no guidance on which steps of procedure
AP-10.1 were the applicable steps completed.
,
27. AP-10.11 Restoration of semi-vital busses
'a.
Step - 4.1:
There was no guidance on which steps of procedure AP-10.1 were the applicable steps completed.
b.
Step 5.8.7: This step described automatic actions that occurred p
and therefore should have been a note.
c.
Step 5.10.2:
Three separate actions were listed below this step.
None of these actions had a separate sign-off block.
!'
28.
AP-10.12 Restoration of D.C. Buses a..
Step 6.2.3 note: This note did not apply to attempting to energize bus I-I.
b.
Step 6.2.2: A key was needed from the T.S.C.
i i
c.
Step 6.3.2 through 6.3.8: These steps did not give a complete list of what failed. The load list was not referenced, d.
Step 6.8.3 note: This note did not ' apply to attempting to energize bus I-III.
e.
Step 6.15.3 through 6.15.7: Same as comment for Step 6.3.2
>
above, f.
Attachment 3: The procedure does not show breakers-23, 24, 25 f
and 26.
g.
General comment: This procedure does not require taking the key to close the cross ties. The load lists on the doors of panels were not being kept up.
There were many cases of mislabeling.
In some cases such as the normal and swing charger outputs the list was wrong. Breakers labeled as spares on the door of cabinets were in use.
29. AP-10.13 Restoration of AC vital busses
>
a.
Step 4.1:
There was no guidance on which steps of procedure AP-10.1 were the applicable steps completed, b.
Step 5.3.5:
An operator stated that if the sola was not energized, he would not expect the sync light to be lit.
L
+
'
~.
-
[
t
.,
..
Appendix B
!
c.
Step 5.4.1: The procedure did not direct the operator to trip
the reactor in order to prevent a challenge to the reactor protection system prior to tripping all the RCPs.
d.
Step 5.9.5:
Same as step 5.3.5 above.
e.
Step 5.15.5:
Same as step 5.3.5 above.
f.
Step 5.16.1:
Same as step 5.4.1 above, g.
Step 5.21.5:
Same as step 5.3.5 above.
h.
Step 5.25.5:
Same as step 5.3.5 above.
1.
Step 5.26.1:
Same as step 5.4.1 above.
J.
Step 5,31.5:
Same as step 5.3.5 above.
k.
Step 5.36.5:
Same as step 5.3.5 above.
1.
Step 5.37,1:
Same as step 5.4.1 above.
m.
Step 5.42.5:
Same as step 5.3.5 above.
30. AP-10.22 Restoration of station service 480 volt busses a.
General:
Locations were not provided for the switchgear.
b.
Step 4.1:
There was no guidance on.which steps of procedure AP-10.1 were the applicable steps completed.
31.
AP-10.23 Restoration'of station service 480 volt MCCs a.
General:
Locations were not provided for the MCCs.
Two operators could not find the selected, MCC without reference to
,
the load list book, b.
Step 4.1: There was no guidance on which steps of procedure AP-10.1 were the applicable steps completed.
32. AP-13 Loss of one or more circulating water pumps Q';
a.
Step 5.4.3: This step required submission of an
"M. R." but the
,
operator on the walkdown indicated that ~ the current terminology
'
'
is-work order, b.
Step 5.5: This step required submission of "MR's" as required
.but the operator on the walkthrough indicated that the current terminology is work order.
i
o
.
i
O f
.
..
l Appendix B
'
i
'
c.
General on AP-13: This AP was not yet rewritten to comply with
i the writer's guide.
'
'
33.
AP-14 Low condenser vacuum a.
Step 5.1: This step directed the operator to carry out EP-1 if i
the reactor was tripped.
The operator on the walkthrough
'
indicated the proper reference procedure was E-0.
b.
General on AP-14: This AP was not yet rewritten to comply with
,
the writer's guide.
34. AP-18 Increasing containment pressure
!
a.-
General: The procedure had not been revised and updated to the
!
E0P format.
'
'
35. AP-20 Operation from the auxiliary panel a.
Step 4.1b: This step did not define the relationship between E-0 immediate actions and the immediate actions after the manual
'
reactor. trip required by this step.
b.
Step 4.1c RNO:. This step indicated that it must be completed
'
prior to exiting the control room. This was not necessary since the action to be performed was outside the control room.
c.
Step 5.5b RNO:- This step required local trip of the MFW pump
!
breakers. During walkthroughs, a licensed operator indicated
,
that an automatic start signal may be present.' If a signal was
.
.
present, the breaker would reclose until the start signal was
,
removed. No instructions were provided to defeat the auto start
'
signal.
!
d.
Step 5.6: This step did not provide an RNO to use the alternate feedwater flow path valves if required.
'
t e.
Step.5.7b RN0: This step did not provide a caution concerning emergency diesel generator loading prior to operating pressurizer heaters.
.
f.
Step 5.8 RNO:
This step did not require control to be transferred to the local station if level is in an acceptable
- +
band, g.
Step 5.9a:
This step did not verify the position of the
!
controller prior to placing the local-remote switch to local.
'
h.
Step 5.9b: This step maintained S/G pressure between 985 and
,
1005 psig with an instrument which had a 50 psig increment
~
scale,
,
,
A
<
.
'
..
Appendix B
'
r i
Step 5.11b2: This step did not specify whether the action was
to be taken -in the control room or at the auxiliary shutdown panel.
-j.
Step 5.11b3: This step referred to trip-reset switches located on breakers. This was a misnomer in that the switches function as local-reset switches not as breaker controls.
l k.
Step 5.11c2:
Same as step 5.11b2 above.
i 1.
Step 5.11d2:
Same as step 5.11b3 above. The switches were not l
located on the breakers as indicated but on the associated
'
transformer panel.
'
36. AP-22.1 Loss of 1-FW-P-2 turbine-driven AFW a.
Step 1-C:
This caution did not provide what the limitations
'
were.
b.
Attachment 3 Step 1: The step specified the breaker position to be open with the result that AFW could not be supplied to a S/G from the control board switch as intended, t
c.
Attachment 3 Step 3:
This step incorrectly identified FW-MOV-100A as FW-MOV-1000, 37. AP-24.1 Large steam generator tube leak a.
Step 3 RNO: The step stated " perform the any or all". The step should have stated " perform any or all".
The step did not provide a level reference value at which to trip the reactor.
-
b.
Step 22: The step stated " verify letdown - in service". Letdown
,
would have been isolated et this point in the procedure.
!
38.
AP-24.2 Small steam generator tube leak.
>
a.
General:
The procedure had not been revised and upd9ted to the
,
E0P format.
,
,
39. AP-27.1:
Loss of spent fuel pool level a.
Step 4:
The RNO for this step was placed at the bottom of the RNO column for step 3 and made it appear as if there was no RNO for step 4 plus made an incorrect RNO for step 3.
~
-
b.
Step 10b, e and d: This step was confusing to the operator on the walkdown because it required closing a valve, opening another valve and then opening the valve originally closed. The i
operator on the walkthrough did not know the rationale for this specified sequence of manipulations and the procedure provided no information.
..
it-o
.
l,,
.. '
i
.
Appendix B
40; AP-27,2:
Loss of spent fuel cooling system 4.
No comment, 41. AP-27.3:
Placing nitrogen backup in service to SPF gate seals a.
No comment.
'42.
AP-30:
Fuel failure during handling a.
General:
This AP was not yet rewritten to comply with the writer's guide.
,
b.
Step 5,4:
A note following this step indicated that equipment and procedures for performing this step are not provided or written.
43. AP-33.2 Loss of RCP seal cooling a,
5,5:
This step did not clearly specify that it was
'
- <mpting to align component cooling water valves to all RCPs, cring the walkthrough, a reactor operator incorrectly indicated that the step applied only to the affected RCP, 44, AP-39,0 In plant flooding
,
a, General: The AP referenced AP-39,1 and 39,2. The procedure was redundant, 45, AP-39.1 Flooding of turbine building a..
General:
The procedure.had not been revised and updated to the E0P format,
- ,,
46, AP-39.2 Service water flooding in auxiliary building a,
General:
The procedure had not been revised and updated to the E0P format, b.
Step 5,1:
The step stated "MOV SW 2040 or 2040".
The step should have stated "MOV SW 203D or 204D",
47, AP-40 Abnormal level in North Anna reservoir (lake)
a, General:
The procedure had not been revised and updated to the E0P format.
The procedure was not consistent with the requirements of AP-40,1, Potential Flooding of Turbine. Building, b.
Step 5.5: The step required that EPIP 1.01 be initiated when lake level reached 256 feet.
EPIP 1.01 was required to have been initiated at 254 feet.
!
'1 l
..
e
.
,
.;'
Appendix B
48.
AP-40.1 Potential flooding of turbine building P
a.
General:
The procedure had not been revised and updated to the E0P format.
The procedure was not consistent with the requirements of AP-40, Abnormal level in North Anna reservoir (lake).
,
I b.
Step 5.3: The step required initiation of the EPIPs when lake-level reached 255 feet.
EPIP 1.01 was required to have been initiated at 254 feet, c.
Step 5.18: The step stated " Notify electrical dept. to locally disconnect the following batteries: 1-1, 1-III,' 2-1, 2-III".
This step was contrary to the requirements contained in the technical specifications for DC battery operability. The step did not require that containment integrity be established within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> as required by the technical specifications.
49.
AP-48 Charging pump cross connect a.
General: The common (Unit 1 and Unit 2) are numbered under Unit 1 only. This did not allow the operator to easily determine the applicable Unit for a procedure without reference to the procedure. The location of common procedures in only Unit 1 file drawers created a concern.
An operator stated he would feel uncomfortaole crossing Unit I control area during an emergency to get a common procedure (AP-47).
b.
Step 4.1: This step referred to procedure EP-0 instead of E-0, c.
Step 4.2:
Same as step 4.1 above.
Also, the title for referenced procedure EP-0 contained the typographical error "of" instead of "or",
d.
Step 5,0:
Throughout this section the use of emphasis techniques for "af fected" and " unaffected" was inconsistent.
The variations included all letters lowercase, first letter capitalized, all letters uppercase and some were also underlined.
e.
Step 5.6:
This step combined two separate actions, initiate emergency boration and control flow with the FCV bypass valve, into one step.
Emergency boration steps were not described.
The method to control flow with the charging header bypass valve was not described (local manual action).
f.
Step 5.8: This step led the operator to believe that the action could be performed in the Control Room while actually the action was performed locally (attachment 1 and 2).
g.
Step 5'9:
This step provided no conditions that were satisfactory for the completion of emergency boration.
e
.
!
,'
'
Appendix B
"
h.
- Step 5.10:
An operator expressed concern that this step could lead to dilution of the RCS for the unaffected unit if that unit had a higher shutdown margin than the affected unit.
i.
Step 5.13:
All pertinent procedures are not stated in this
'
step.
This procedure could have been entered from the ECA-0 series procedures.
50. AP-49 Loss of normal charging a.
Step 5.3:
The area radiation monitors were not identified.
i -
b.
Attachment 1 and 2, step 2: The RCP seal injection valves were not identified either by their noun name or by their equipment mark number.
51. Ap-50 Fire protection operations response a.
Step 4.1: States to sound the fire alarm for 10 seconds. This is not normally the first step due to spurious alarms.The alarm is normally verified as valid first.
52. AP-50.1 Control room fire a.
Step la: This step should be before Step 1. The reactor was not tripped, b.
Step Sb: This step listed key number 81 to Appendix "R" locker instead of the correct key number 82.
c.
Step 6b: Attachment number 10 would have required two operators if the diesel was to be placed on the line.
The voltage and speed controls were on a separate panel from the indication.
These panels were widely separated, d.
Step 7b:
The shift clerk does not perform communications, e.
Step 9a:
It was not possible to determine whether the breaker was closed from-spring discharged indication.
The red flag
. indication was not utilized, f.
Step 25: There was no instruction as to how to determine if the fans were running, g.
Step 28b: This step stated 200 degrees subcooling unlike procedure ES-0.2B Step 9a which stated greater than 180 degrees, b.
Step 27b: This step required the operator to maintain subcooling greater than 50 degrees F.
Step 13b of ES-0.2A required greater
'
than 80 degrees F.
I
i e
l
.
,8
>
Appendix B
I
1.
Step 26:
AP-50.1 pressurizer level was required to be greater than or equal to 20 percent. R.C cooldown rate less than i
25 degrees F per hour. Step 7 of ES-0.2B required between 20 percent and 29 percent J.
Step 28c:
These curves were different than those for ES-0.2A.
k.
Step 27a RNO: This step did not establish a cooldown rate of 15 degrees F an hour without fans whereas ES-0.2B established a minimum subcooling limit of 180 degrees and a maximum cooldown
,
rate of 15 degrees per hour to prevent steam void formation.in the reactor upper head. AP-50.1 used 200 degrees subcooling and i
a 25 degree per hour cooldown rate.
No reference was provided to ES-0.3.
'
1.
Step 29 caution and note : A nine hour hold period was used and ES-0.2B used 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> in Step 15.
,
m.
Step 31:
This step used a value of 950 psig for isolating accumulators and ES-0.2B used 1000 psig, n.
Step 29a RNO: This step used a nine hour wait. Same as step 29 note and caution above.
o.
Step 35a:
Same as step 9a above.
p.
Attachment 3 la:
One RNO stated establish required ducting.
Training was inadequate in this area.
The operators also experienced difficulty in obtaining the right key to open the door to get to the duct work. In the training film for Appendix R equipment walkdown the clarity was poor and the voice could
not be heard in several parts of the film including the part about the duct work and main steam valve house, q.
Attachment 4A Step 2c: The valve number for instrument air shut was not included.
r.
Attachment 7A Step 4b: There was no mark number on the switch.
-'
s.
Attachment 8 Step 4 RNO: The ' training film states to use the i
hand control on the bulkhead to start fans but the RNO had no instructions, t.
Attachment 12 (any steps associated with it): Several switches and breakers were labeled different than the procedure.
53. AP-50.2 Emergency Switchgear Room Fire a.
Step 1: Same as comment for step la of AP 50.1.
b.=
Step 8a: This step requires a key to operate breaker.
,
.-
- - _ _ _ _ _-_ ___ _ _ _ _ __ _ - - _ - _ _ - - -
...
I
'
,
Appendix B
c.
Step 10a RNO: Requires the operator to go to step 11. Step 10b also states go to step 11. This is a contradiction, d.
Step _13a:.This step required the operator to perform part #2 of Attachment 8. There is no part #2 to Attachment 8 but there is an attachment 8B.
ti 54. AP-50.3 Cable vault tunnel fire a.
Step la: This step should be before step 1. The reactor was not tripped,
,
b.
Step Ba: A key was required to transfer the switch. This step did not mention a key, c.
Step 10a RNO: Same as step 10a RNO of AP-50.2 above.
55. Ap-52:
Loss of refueling cavity level during refueling a.
Purpose:
The stated purpose and entry conditions could lead an operator to use it for mitigation of a gross cavity seal failure leak. The 1censee provided calculations to support leak rates only up to 4000 gpm. -The basis of the procedure also assumed operator action to mitigate the leak after about four minutes.
In addition, consideration of loss of power to the man %ulator crane during the emergency may not have been adequately considered. The team also questioned i
the calculated radiation levels as a function of time
!
at the refueling bridge.
The licensee agreed that these questions warranted an engineering review of AP-52,
!
,
b.
Step 8:
This step was missing, i
t I
--_
_ _ _
_ _ - _ _ _ - _ _ _ _ - _
l
.
.
'
o APPENDIX C WRITERS' GUIDE COMMENTS This appendix contains writer's guide comments and observations.
Unless specifically stated, these comments were not regulatory requirements. However, the licensee acknowledged the f actual content of each of these comments.
The licensee agreed to evaluate each comment, to take appropriate action and to document that action. These items will be reviewed during a future NRC inspection.
I.
Inadequacies in the writer's guide.
The writer's guide included appropriate topics as indicated by NUREG-0899, however, it did not thoroughly address each aspect of the procedures, nor did it define restrictively the methods designated for use in order to assure consistency within and between procedures and to retain that consistency over time and through personnel changes.
The following weaknesses contributed to problems and inconsistencies in the E0Ps or allowed for future inconsistencies in the revision or development process:
1.
Section 6.4.8 of the writer's guide failed to state if the procedure name is required in addition to procedure number when procedures are identified in branching and referencing.
2.
Section 6.4.8c Referencing, stated specific steps of supplemental procedures should be considered for incorporation into the original procedure instead of referencing.
The writer's guide failed to provide restrictive criteria for consideration.
3.
Section 6.4.8a Transitions, stated that if steps that are to be repeated are not lengthy, then consider repeating the information and not using the transition. The writer's guide did_ not establish the criteria for this decision and therefore is nonrestrictive.
4.
Section 6,4.4 stated "Do not include actions within cautions."
In practice this guidance was not followed and numerous instances of action statements within cautions were identified.
Operators are trained to expect action steps to be numbered and located in sequence in the AER and RNO columns of the procedure.
Actions that are located in a caution or note are likely to be missed due to operator expectations about how the procedures work.
5.
Section 6.4.2a stated that "A step identified in the Westinghouse ERG background as a Continuous Action Step should be identified by an asterisk to the left of the step number, unless the procedure text
clearly indicates that it is a continuous action by using continuous
!
action verbs (e.g., maintain, monitor), or is specified in a note or a caution." The team had several concerns with this statement: (1)
The use of the term "should" was non-restrictive. (2) Use of asterisks to identify continuous action steps helped ensure that
s e
.
A
Appendix C
i these steps were not ovu )oked, but this advantage was lost when y
steps with continuous action verbs were not marked with an asterisk.
(3) Insufficient guidance was provided as to whether placement of asterisks was only allowed on high level steps, or was acceptable for t
substeps and in the RNO column. (4) The definition suggested that the-continuous action was implied in notes and cautions. This definition appeared to contradict section 6.4.4 of the writer's guide which stated that notes and cautions shall not contain action steps. (5)
The use of WHEN THEN logic terms indicate a continuous action and were not addressed as such in the writer's guide.
6.
Section 6.4.2(d) cefined continuous action steps as " performed any time after they are presented or are steps that require continuous
.
monitcring before an action can be accomplished".
This definition
'
included non-sequential steps in the definition of continuous action steps and may result in confusion and difficulty in procedure control.
7.
Section 6.3,4 stated that equipment mark numbers should be included as substeps when needed for clarification, the noun name and equipment mark numbers should be used when identifying local equipment, and a reference to a piece of equipment should be used consistently throughout the procedures. The use of the term "should" rather than "shall" implied that there were criteria for noncompliance with this guidance. The writer's guide failed to state that criteria.
8.
Section 6.4 provided direction for writing action steps. No guidance was provided for acceptability and/or format for action substeps under high level CHECK steps.
9.
Section 6.4.2 of the writer's guide failed to address a method for-identifying an order of preference for alternative actions when
,
alternative actions were listed in a step.
10.
Section 6.4.1d guide stated, "As a general rule, branching to other-procedures should take place from the RNO column."
The writer's guide failed to restrictively define the criteria for when branching to other procedures would be acceptable in the AER column.
11.
Section 6.4.2j stated that "an underline space shall be provided at the high-level step for a check mark to signify the action of the y'
step has been completed."
This guidance failed to consider place j
keeping for portions of procedures which were repeated.
'
12.
Section 6.4.3 (d.6) failed to include, in the list of parentheses usage, the use of parenthesis around the letter "s" at the end of a word to indicate that the singular or plural form of the word may apply, t
o, o
Appendix C
13.
Section 6.4.4 stated that a caution may be repeated at any time throughout the procedure but fails to define the criteria for caution repetition.
'
14.
Section 6.2.2 stated that "the instruction pages shall have a border on all sides of the page" but did r.ot define the size of the border.
,
II.
Deviations from the E0P writer's guide.
1.
E-0 Reactor trip or safety injection a.
Continuous Action Page:
The title for continuous action page differed from that specified in writer's guide section 6.2.4 by omitting "for".
b.
Step 8 :
This step used parenthesis
"s" in a manner not specified in the writer's guide section 6.4.3.d.
"P-T-L" abbreviation did not agree with Attachment 13, c.
Step 26a, c and d:
Underlining and capitalizing of "not" disagreed with writer's guide section 6.4.7.
d.
Attachment 1:
The layout of the equipment / component descriptions failed to follow the WOG writer's guide specifications that action steps will be-relegated to only the lef t-hand column.
Also, the listing did not conform to the plant-specific writer's guide section 6.4.2.g to have equipment lists separated by a blank line into groups of no more than four items.
'
e.
Attachment 2:
Same as Attachment I above.
,
2.
E-2 Faulted steam generator isolation c.
Step 2:
The word "0R" in a high level step was not underlined as required by the writer's guide.
3.
E-3 Steam generator tube rupture a.
Entry conditions:
Asterisks were used in a manner inconsistent with the writer's guide, b.
Step 3-C: The two items in this caution were written indicating continuous actions.
c.
Step 4-C:
This caution did not contain a statement of consequence.
The item was written implying a continuous action, d.
Step 5-C:
This caution was written as an action with conditional logic. Also no consequence was stated.
l e.
Step 13-N:
The first two items in this note contained i
conditional action _.
[
- d.
'
.
Appendix C
,-
!
f.
Step 29-C: This caution contained a conditional action, g.
Step 34-C: This caution implied a continuous action.
i h.
Step 40-C1, C2:
This caution contained two conditional actions, f
1.
Step 40-N: This note contained an action, j.
Attachment 2 Step 1:
This step used asterisks in a manner inconsistent with the writer's guide.
4.
ES-0.1 Reactor trip response a.
Entry conditions: The use of the asterisk was not in accordance with writer's guide section 6.3.4.d.2.
b.
Continuous action page:
same as entry conditions above, c.
Step 4a2 RNO:
The term " turn off" is not identified in the writer's guide attachment 11.
5.
ES-0.2A Natural circulation cooldown with CRDM fans a.
Step la:
Referenced procedure title was different from that stated.
b.
Step 4b:
The expected response to a check action was not
written in upper-case as required by the writer's guide, c.
Step 4c: A check action was used with an implied action in that no RNO was provided to align the component.
I d.
Step 4c:
Same as step 4b above.
'
e.
Step 13-N:
This note implied a continuous action,
'
l f.
Step 16a RNO:
Same as step la above.
6.
ES-0.2B Natural circulation cooldown without CRDM ft is
{
'
a.
Step 1-N3:
This note contained a continuous actson.
b.
Step 9-N:
Same as step 1 above.
,
7.
ES-1.2 Post LOCA cooldown and depressurization a.
Entry conditions:
An asterisks was used in a manner inconsistent with the writer's guide, b.
Step.5-C: This caution contained a conditional logic continuous action and contained no statement of consequences.
c.
Step 7-N:
This note contained conditional and continuous
action.
.
.
.'
Appendix C
d.
Step 12-C:
This caution contained two conditional actions, e.
Step 12-N: This note contained an action, f.
Step 19-C:
Same as step 12 caution above.
g.
Step 19-N:
Same as step 12 note above.
8.
ES-1.4 Transfer to hot leg recircul. ion a.
Entry conditions: An asterisk was used in a manner inconsistent with the writer's guide, b.
Step 5: This step directed the operator to RETURN TO procedure and step in effect.
In the writer's guide RETURN TO is specified for use in transitions but not for branching.
9.
ES-1.5 Transfer from hot leg recirculation to cold leg recirculation a.
Step 2g RNO:
This step directed the operator. to RETURN TO procedure and step in effect.
In the writer's guide RETURN TO was specified for use in transitions but not for branching.
b.
-Ste, 3a:
Hyphenation was used in a manner inconsistent with that specified in the writer's guide, c.
Step 4a:
Same as step 3a above, d.
Step 5:
Same as step 29 above.
10.
ES-3.1 Post-SGTR cooldown using backfill a.
Entry conditions:
Asterisks were used in a manner inconsistent with the writer's guide.
11.
ECA-0.0 Loss of all AC power a.
Attachment 3 Step 1: This step contained inappropriate use of asterisks.
12. ECA-0.2 Loss of all AC power with SI required a.
Entry conditions :
Tha use of the asterisk was not in accordance with writer's guide section 6.3.4.d.2.
,
b.
Step 6-C1:
This caution contained action to vanitor level and transition at a specific setpoint. This did not agree with the conditions of cautions specified in NUREG-0899, c.
Step 6-C2:
This caution contained action to monitor specific parameters and start some er,uipment.
This did not agree with the conditions of cautions specified in NUREG-0899.
,
p+
j y-m
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+
e
' Appendix C
i'
,
.
This' step used "P-T-L" abbreviation not'specified in-d.
Step 6-N:
-
. writer's guide attachment 13.
.
,
,
e.
Step 9:. This step used parenthesis
"s" in a manner not-
'specified in the writer's guide section 6.4.3.d.
,
,
13.
ECA-1.1. Loss of emergency coolant _ recirculation i
a.
Entry conditions: The use of the asterisk was not in accordance I
,
with writer's guide'section 6.3.4.d.2.
b.
Step
'lNO :
This step used parenthesis
"s" in a manner not.
i speci'iled in the writer's guide section 6.4.3.d.
,
i
"
'
c.
Step 26:
"P-T-L" abbreviation did not agree with attachment 13'.
_
14. 'ECA-1.2 LOCA outside containment
"
,
-a.
Entry conditions:
An asterisks was 'used in' a manner inconsistent with the writer's guide.
'
15.
ECA-3.1 SGTR with loss of reactor coolant - subcooled recovery desired
,
!
a,
' Step 2: The word "AND" in a high level step was not underlined as. required by the writer's guide.
.
b.
Step 10b RNO: The expected response to a verify action was not'
,
written in_ uppercase as required by the writer's guide, j
]i c.
Step 16-N1:
This. note contained-a continuous action.
d.
' Step 16-N2:
This note contained an action.
i e.
Step 16-N3:
Same as step 16 note 2 above.
f.
Step 21b: This step did not contain an action verb.
g.
Step 22-C1:
This caution contained a. conditional action.
O h.-
Step 22-C3:
Same as step 22 caution above.
i 1.
' Step 22-N1:
This note contained an implied action.
j.
Step 22d1: The~ referenced procedure title was dif ferent - from
-
that stated, k.
' Step 24a RN0:
This step used underlining in a manner inconsistent with that specified in the writer's guide.
1.
' Step 24d RN0:
Same as step 24a RNO above, i
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n-y
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,
.
...
> j
,
Appendix CL
[
m.
Step:29-C1:
Same as step 22 caution 1 above, I
n.
Step 29-C3:
Same as step 22 caution 3 above.
o.
. Step 29 N1:
Same as step 22 note 1 above, p.
Step 29a RNO: The referenced procedure title was different from that stated.
-q.
Step 36: This step was structured -in a manner not defined in the writer's guide.
r.
Step 40c1:
The expected response to a check-action was not written in the upper-case as. required by the writer's guide.
i s.
Step 40c2:
Same as step 40c1 above.
'16.
ECA-3.3 SGTR without pressurizer pressure control
'
a.
= Step.13:
Check is improperly used according to_ the writer's guide.
- b.'
Step 14a:
Same as step 13 above.
,
!
'!
c.
Step 14b:
The verb verify is misused.
d,-
Step 20:
The verb check was-used instead of the verb observe.
i-Also,-verify is not the proper. action verb.
l
e.
.
The caution failed to provide a statement' of -
'
pox.e ial consequences for the warning.
9:
f.
step 32a:
The. step improperly selected alternatives =to-
'
- p essv*
he ruptured steam generator.
The choice to Nra
'-v...:tivity into containment systems is a : final-
<r
x RNO is required -to be in agreement; with the c
.c, a. +.,
g.
n Mt -
This step failed to provide an RNO in-the event of
f adverse conditions.
'
I
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,
.
i
'
17f FR-C.2, P.esponse to degraded core cooling.
l,i
a.
Entry conditions-An asterisk-was used in a manner. inconsistent i
'
with the -writer's guide.
'
il b.
Step 1-C:
This caution contained a continuous action-
'
.
c.
Step 4-N note:
This note contained information related to
.
possible core damage and was not written as a caution with a statement'of consequence.
.i
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y
^
Appendix-C
1; d.; -Step Sb: This step directed the operator to RETURN T0 procedure
,
and step in effect.
In the writ'er's guide RETURN T0 is-i i
specified.for use in transitions but not for branching, e..
Step-13-C: This caution was located near the bottom of the page
'
while-most of the related steps were on the following page.
.
18.
FR-C.3 Ret.;:enta to saturated core cooling a.
b p,lrt: This caution contained a conditional action, tn k ep 1-N1: This rm c:,r.tained an action.
c.
Step 4: This step directed the operator to RETURN T0 procedure
!
and step in effect.
In the writer's guide RETURN T0 was specified for use in transitions but not for branching.
'
19.
FR-H.2 Response to steam generator overpressure a.
Step 1: This step directed'the operator to RETURN-T0 procedure and step in effect.
In the writer's guide RETURN TO was specified-for use in transitions but not for branching.
b.
Step Sc: _ This step was structured in a manner not defined 'in
,
the writer's guide.
'i c.
Step 5d:
Same as step 1 above.
d.
Step-6-C:
This caution contained an action.
e.
Step 2:
The word "0R" in a high level step was-not underlined
-
as' required by the writer's guide.
f.
Step 9: _Same as step.1 above.
,
20.
FR-H.3. Response to steam generator high level a.
Step 4d:. This step directed the operator to RETURN T0 procedure'.
and step in effect.
In the writer's guide RETURN T0 was specified for.use in transitions but not for branching.
- b.
Step 9:
Same as step 4d above.
21.
FR-I.3 ~. Response to voids in reactor vessel
-
a.
Step-18-C: :This note is instructing action.
In addition, the action is an'RNO.
22.
FR-P.1 Response To Pressurized Thermal Shock Condition
a.
Entry conditions: The use of the asterisk was not in accordance
-
with writer's guide section 6.3.4.d.2.
L
.
-,
,
!
E a=.
,
i'
Appendix-C
-
l, b.
Step 1; RNO:
This step used parenthesis "s" in a manner not i
specified in'the writer's guide section 6.4.3.d.
,
c.
Step 25-C: This caution contained action to ensure a soak time
>
of one hour. This did not agree with the conditions of cautions.
specified in Nureg 0899.
23. _FR-P.2 Response to anticipated pressurized thermal shock condition
-a.
Entry conditions: An asterisk was' used in a manner inconsistent with.the writer's-guide.
!
I b.
Step 15: This step directed the operator to RETURN T0 procedure
'
and step in effect.
In the writer's guide RETURN. T0 is
'
specified-for use'in transitions but not for branching.
'24.
FR-S.1-Response to nuclear power generation /ATWS a =.
Entry conditions: The use of the asterisk was not in accordance1 with writers guide section 6.3.4.d.2.
,
b.
Step-2b RNO: This step used "P-T-L" abbreviation not-specified in writer's guide attachment 13,
'
.
c.
_ Step.10:
This' step used - parenthesis."s" in a manner not specified in the writer's guide section.6.4.3.d.
d.
Step'11:and RNO: This step used parenthesis "s" in a manner not specified in the writer's guide 'section 6.4.3.d.
'
.
e.
Step 12b RNO:,This step used "do" as a referencing term thatfis-not in accordance' with the-terminology of the _ writer's guide section 6.~4.8.c.
f.
Attachment 1, step 11a: The equipment. mark numbers were not used to identify the turbine trip test valves.
This was not in
_
'
accordance with the= writer's guide section 6.3.4.e.
l 25.
FR-S.2 Response to loss of core shutdown a.
Step 3-C:
The.' caution failed to provide a statement of
potential consequence. In addition, the caution instructed the operator' to borate _ until adequate shutdown margin was-established.
It never _ defined adequate or provided operator aids to establish' shutdown margin.
26.
FR-Z.1 Response to high containment pressure a.
Entry conditions: An asterisk was used in a manner inconsistent with the writer's guide, b.
Step 6: This step directed the operator to RETURN T0 procedure and step in effect.
In the writer's guide RETURN T0 is specified for use in transitions but not for branching.
.
- - -
- -
-
-
- -
kh,L i
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h 27.
FR-Z.4 Response to containment positive pressure r
a.
Entry conditions: An asterisk 'was used 'in a-mannerLinconsistent.
l
. ith the writer's guide.
'
w i.n b.
Step 7: This step directed the operator to RETURN T0 procedure
s'
and step in effect.
In ~ the writer's guide RETURN T0 'is
,f specified for use in transitions but not for branching,
,
pz
c.
Step 17:
Same as step 7 above, l
>.
28; 'AP-20 Operation from the auxiliary shutdown panel
,
a.
Step 4.lc 'RNO:
This step used underlining in a manner-inconsistent with that specified in the writer's guide.
-
,
b.
Step 5.1: ~ This step provided an initials space instead of an underlined ' space.as a highlevel step placekeeping aid ~ as required by the writer's guide, c.
Step-5.2:
Same as step'5.1 above.
,
d.
-Step-5.3:
Same as step 5.1 above.
!
f e.
Step 5.4:
Same as step 5.1 above, f.
-Step 5.5:
Same as step 5.1 above.
t ec,
'g.
Step 5.6:
Same as step 5.1 above.
- p
!!n h.-
Step-5.7:
Same as step 5.1 above.
m 1.
Step 5.8:-
Same as step 5.1 above.
l a
,n it J.
Step 5.'8a:
The expected response to a verify action was.not
- dB written.in upper-case as required by the writer's guide.
,
W:
,
k.
. Step 5.8b:
The action was defined -by a verb not included in
mg
writer's guide attachment 11.
s 1.
Step 5.9:
Same-as step 5.1 above.
,
j m.
Step 5.10:
Same as step 5.1 above.
,
w.
~
9tr n.
Step >5.11:
Same as step 5.1 above.
o.
Step 5.12:
Same as step 5.1 above.
!
Dj 29. A0P-52 Loss of refueling cavity level during refueling
.
a.
. Step 4-C:
No colon was used contrary to the writer's guide.
.
.
'
' Oi'?
J
,s'
'
. =,.
,
, %
,...
- N
=-Appendix C-
'b.
-Step 4: The ' vet b " commence" was used contrary' to' the writer's guide (attachment 11),
'
i j
.
ci Step 4bi The verb " start" was 'used contrary to the writer's
-
i guide-(attachment 11).
d.
Step 4b RNO:
Same as step 4b above.
i
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-
,
r APPENDIX D NOMENCLATURE
,
This appendix contains basic plant nomenclature weaknesses.
For example,
,
instances where writer's guide application to the E0P would cause the reader to-
expect an exact nomenclature match with component nomenclature, yet there was-u'
no match.
It alsooincludes instances where a complete match was neither
-
required:nor _found and the mismatch or lack of label was sufficient to cause -
concern. The licensee agreed in each case to evaluate the problem and make the appropriate changes.
These items will be reviewed during a future NRC
+
inspection.
.
STEP /PG.
E0P NOMENCLATURE COMPONENT NOMENCLATURE
,
,
' Procedure E-0-
<
Att. 1 shroud cooling fans CRDM fans
Procedure E-2
Bypass MSTV BYPASS Procedure ECA-0.0 5.a.1 START EXC. START
"
Procedure ECA-2.1
'
Att.2 IA-343 IA-426 P.1 -
-
Att.2 IA-352 IA-419 P.1-Att.2 IA-361 IA-424 P.1
Procedure ECA-3.1-10 :
1-RM-RM-154 1-RM-RMS-154
'
Procedure ECA-3.2 o
L
'2.b AUTO-STANDBY None
'
Procedure ES-0.1
Steam. Dump Interlock Steam Dump Mode Sel (unit 2 Switches only)
i
.,
_.
_
i
.
.;
,
.
G.
.
,
- Appendix O'-
.
S,
,
.
Procedure FR-S.1
'
L 7a Blender Control Make-up Mode Selector Sw
,
Procedure AP-1.5
@
- 5.9.2 Bank selector switch Control rod switch mode
i
.
Procedure AP-1.7-4.1 Rod control Control rod switch
q Procedure AP-10.7 5.2.16 2H1-2NB4 and 2H1-2NC2 Not labeled
]
undervoltage reset
pushbutton Procedure AP-10.8
,
l m
.5.2.16 2J1-2NB3 undervoltage Not labeled reset pushbutton Procedure AP-10.10
'
General Various MCC loads Local MCC load labels j
,
. Procedure AP-10.12 j
Att.1,
. Swing Charger MCC-1H1-4 P.3=
'
Att'1'
Normal Charger-MCC-1H1-4
- P 3
'
l;
,
.Att.1 Inverter.1-I-Manual bypass switch
,
P.3.
,
..- Att.1 EDG-1H Diff.
Spare cj f.
. P. 4 --
l Protection' Relays
.
'
Procedure AP-10.23
.i General Various MCC loads Local MCC load labels
!
Procedure AP-20 l
l; 5.4 RNO-TV-MS-211A 2-MS-TV-211A l
TV-MS-211B 2-MS-TV-211B
'
O
'
,
.
- ' *
-
.,
Appendix D'
5.6 MOV-FW-200D 2-FW-MOV-2000
>
MOV-FW-2008 2-FW-MOV-200B MOV-FW-200C 2-FW-MOV-200C i
5.8a FCV-2122 2-CH-FCV-122
[
5.8b HCV-2200A 2-CH-HCV-2200A
-
HCV-2200B 2-CH-HCV-2200B HCV-2200C 2-CH-HCV-2200C 5.9 PCV-MS-201A 2-MS-PCV-201A PCV-MS-201B 2-MS-PCV-201B (
PCV-MS-201C 2-MS-PCV-201C j
5.11b1 HCV-2200A 2-CH-HCV-2200A HCV-2200B-2-CH-HCV-2200B
!
HCV-22000 2-CH-HCV-2200C
'
.
FCV-2122 2-CH-FCV-2122
,
5.11c1 HCV-FW-200A 2-FW-HCV-200A
,
HCV-FW-200B 2-FW-HCV-200B HCV-FW-200C 2-FW-HCV-200C TV-MS-211A 2-MS-TV-211A TV-MS-211B-2-MS-TV-2118 MOV-FW-200A 2-FW-MOV-200A i
MOV-FW-200B 2-FW-MOV-200B
.
'
M0V-FW-200C 2-FW-MOV-200C MOV-FW-2000 2-FW-MOV-2000-
5.11c2 TV-MS-211A 2-MS-TV-211A TV-MS-211B 2-MS-TV-211B'
.
5.11e PCV-MS-201A 2-MS-PCV-201A
!
PCV-MS-201B 2-MS-PCV-201B PCV-MS-201C 2-MS-PCV-201C Procedure AP-30 5.2.3 A00-HV-107 1, 2, 3 HV-A00-107-1 and 4 HV-A00-107-2
'
HV-AOD-107-3 HV-A00-107-4 g
Procedure AP-33 i
2.1 2-CH-FR-2154A FR-2154A 2.2 No.1 Seal leakoff hi flow RCP 1A-B-C Seal leak hi flow 2.3 No.1 Seal leakoff lo flow RCP 1A-B-C Seal leak lo flow
!
,
a
,.
[; 3'-(
J
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lj
._
,
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Y,
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.....
,
.-
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'
,
Appendix D
-
,
i
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..
-
g -
'
.
j
.
5.1
'RCP Seal water return' flow RCP seal water leak-off flow
'
5.2u RCP No.1: seal leakoff RCP seal leak off isolation j
-
.
+
Procedure AP-33.2
'
5.1 MOV-1381 1-CH-MOV-1381 5.2
'TV-IA-102A'
1-1A-TV-102A-
!
TV-IA-102B 1-IA-TV-102B l
-
,
,
5.6c
'MOV-1380 1-CH-MOV-1380 l
-
f 5.6 RNO-MOV-1380 1-CH-MOV-1380 i
~5.6d-
-MOV-1381 1-CH-MOV-1381 ll
-
'
5.6f RNO MOV-1381 1-CH-MOV-1381
.e-5.6g; LMOV-1381, 1-CH-MOV-1381 5 '. 7 a _
Charging /SI pump Charging pump
.5.7c
.TI-1133-TI-1-133 ij Note: -All nomenclature applicable to both Units 1&2 unless-otherwise specified.
.-
l'
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!
'
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'
,
-
-
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..
_ _ _ _ _ _
_
_ _ _ _- _ _ _ - _ _ _
_
---.
..
,
t j
-
E JL^
+
,.
APPENDIX E
'
l ABBREVIATIONS-
'
AER
. Action Expected Response A0-Auxiliary Operator AOPL Abnormal Operating Procedures AP Abnormal Procedures ARP Alarm Response Procedures-ATVS-Anticipated Transient without Scram
- CAP Continuous Action Page-CC Component Cooling
!
CNS Corporate Nuclear Safety
. CST Condensate Storage Tank DBA-Design Basis Accident i
EDG Emergency Diesel Generator
.i EOF Emergency Operating Procedure
!
ERG Emergency Response Guidelines i
"
FCV-Flow Control Valve
,
,,
GTG-l Generic Techical Guidelines
,
HCV:
Hand Control Valve
~
. Motor Control Center
.i MCR-Main Control Room
MFRBV Main Feed ~ Regulator Bypass Valve
'
MSTV.
Main Steam Trop Valve
. NAPS North Anna Power Station
>PGP ProceduresiGeneration Package l
PORV Power'0perated Relief Valve.
'
PSTG Plant Specific Technical Guidelines
"
!DT PSTG DEV-PSTG Deviation PTL'
Pull to' Lock
?.
RNO-Response'Not Obtained SDD
'
Step Deviation Document g
SER'
Safety Evaluation Report
J S/G Steam Generator
-
L SGTR Steam-Generator Tube Rupture
'
(g; SI-Safety: Injection SNSOC Station Nuclear. Safety.and Operating Committee 4 :.
ESPDS.
Safety Parameter Display System SS-Shift Supervisor-1 nTS Technical Specification
- w:
LTSC-Technical Support Center.
'
fr si" V&V'
Verification and Validation VPAP Virginia Power Administrative Procedure lsi WOG.
Westinghouse Owner's Group
<
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.
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I r
t.k 5
'
'f!
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.
Cp b
x
_ - -. _ -.. -.