IR 05000416/1991002
| ML20029A918 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/12/1991 |
| From: | Breslau B, Linda Watson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20029A910 | List: |
| References | |
| 50-416-91-02, 50-416-91-2, NUDOCS 9103050102 | |
| Download: ML20029A918 (30) | |
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e Report No.: 50-416/91-02 Licensco: Entergy Operations, Inc.
P.O. Box 756 Port Gibson, MS 39150 Docket No.: 50-416 Licenso No.: NPF-29 Facility Namo Grand Gulf Nucicar Station Innpaction Conducted:
January 20, 1991 - February 1, 1991 Inspectors bX (Ju<
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u. Dreslau, Team Leader Dato Signed
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Team Members:
R. Gibbu B. Holbrook Approved by: ;f en S e
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L. Watson, cfil C P
~'Date Signed
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Operational Programs Section Division of Reactor Safety SUMMARY Scope:
This was a special announced Emergency Operating Procedure (EOP) follow-up team inspection.
Its purpose was to verify that correctivo actions for previous findings in the area of omergency and abnormal operating procedures were adequate.
Results:
The team determined that an extensivo effort was applied to revising the E0Ps to meet Revision 4 of the Boiling Water Reactor Owners Group Guidelines.
The correctivo actions were thorough and gonorally corrected the previous weaknessos.
Significant improvement was noted in the EOPs.
The team concluded that the EOPs would adequately mitigate the tonsequences of a broad range of accidents and multiple equipment t' allures.
Within the areas inspected, no violations or deviations were noted.
However, wonknesses were identified:
Attachment 28 to the EOP did not provido sufficient detail for obtaining additional Boron (Reference paragraph 2.b.6)).
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Laboling discrepancies exist between plant and procedure nomenclature (Reference paragraph 2.c.3)).
Also, concerno noted in the Safety Evaluation for the Proceduro Conoration Packago voro not fully addressed (Reference paragraph 2.h.3) and 4)).
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REPORT DETAILS 1.
Persons Contacted Licensco employees
- M.
Bakarich, Manager, Materials, Purchasing, and contracts R.
Carroll, Senior Reactor Operator B.
Cupit, Reactor Operator L. Daughtery, Superintendent, Plant Licensing
- J.
Dimmotto Jr., Manager, Plant Maintenanco
- W.
Eiff, Principio Quality Engineer
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- C, Ellsacssor, operations Superintendent J. Fostor, Auxiliary Operator
- R.
From, Auditor, Quality Programs
- C. Hutchinson, General Manager J. Moisner, Director Nuclear Licensing
- J.
Reaves, Managor, Quality Services
- J. Roberts, Managor, Performance & Systems Enginocring
- W.
Russell, Emergency Proceduro Operations Coordinator
- J.
Shelly, Operations Training Superintendent C.
Stafford, operations
- J. Summers, Comp 11anco coordinator
- J.
parrish, Managor, Plant operations other Licensoo employoon contacted included engincors, technicians, training staff, operators, and oi ico personnel.
NRC Representativos
- L.
Lawyor, Chief operator Licensing, R~II
- J.
Mathis, Senior Resident Inspector
- T.
Peeblos, Chief Operations Branch, R-II
- Attended exit interview on February 1, 1991 Acronyms used throughout this report are listed in the last paragraph.
2.
Review of E0P concerns NRC inspection report 88-06 identified EOP technical adequacy concerns, plant labeling / procedure differences, and missing procedures to carry out EOP stops.
The report further-noted the licensoo's inability to determino EOP speciflod paramotors to the preciolon identified in the E0P and that the equipment operators woro unable to locato the necessary equipment to carry out EOP tasks on the control
_ rod drive system.
Additionally, the report noted that the plant modification to instrumentation on reactor water level was not consistent with EOP analysis basis and that the licensco continued to uso event based off normal procedures, l
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i rather than symptom based procedures.
Also, numerous human
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factor concerns with a strong potential for operator error
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woro found to exist within the EOPs.
This inspection ovaluates the adequacy of the actions taken by the licensoo to address those and other EOP concerns as delineated in inspection report 88-06 and as addressed in
the SERI responso dated July 8, 1988.
The EoPs in Appendix A woro reviewed to assure that the procedures woro
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i technically adequato and accurately incorporated revision 4
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of the BWORG guidelines.
A comparison of the plant specific technical guidelinos to the EPGs and EPs was also performed.
]i Differences worc assessed for adequate technical justification.
Interviews with plant personnol and j
mant-'ement, as voll as,-observations on the plant simulator I-were also used to assess the licensee's correctivo actions.
The following paragraphs provido the teams assessment of the
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licensee's correctivo actionau
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a.
Basic EOP/DWR Group Emergency Proceduro Guidelino comparison
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A comparison of the facility ?. ops and the BWR Owners Group Emergency Procedure Guidelines, Revisicn 4 was
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conducted to ensure that the licensco had proco~uros as indicated in the EPGs.
The licensco's EoPs are in agreement with the EPGs concerning the type of
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procedures required to respond to symptoms as specified in the EPGs.
b.
Independent Technical Adequacy Review of the Emergency operating Proceduros
1)
EOP/0NEP Interface i
A previous concern noted, that during accident conditions, the operators would enter and uso event based ONEPs to diagnose the event.
Operators did not have clear direction when the EOPs became the controlling document unless
otherwise directed by tha EOPs.
Interviews during this inspection showed an adequate understanding by the operators in the EOP entry conditions and when to entor the EOPs based
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on these conditions occurring.
The inspectors
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noted that several plant conditions would require entry into the ONEPs, which would not require entry into the EOPs.
The ONEPs reviewed stated that entry into the EOFs also may be required.
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2)
Plant Specific Technical Guidelines Paragraph 4.2 of inspection report 80-06 reported that the licensee's PSTG was not in accordance with section 2.5.2 of NUREG-0899.
To correct this problem the licensoo doloted the old PSTG, developed a now PSTG mooting the guidelinos of the NUREG, and developed a now procedure for control and use of the now PSTG.
The current PSTG includes the EPG stops with the plant specific information, the deviations betwoon the EPG and PSTG with justifications, the deviations betwoon the PSTG and EOPs with justifications, and the calculations which support the deviations.
However, during EOP walkthroughs, the inspector
noted that EP-2 did not require execution of RC/L, RC/P and RC/Q concurrently.
The EPG and PSTG, Attachment 2, pago 12, step RC-1 override requiroc
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the execution of RC/L, RC/P and RC/Q concurrently.
This step is not included in the EOP flowchart.
Additional "Implomontation Justification" should bo documented to doccribe the formatting of EP-2 and EP-2A and how it satisfies this requirement.
The licensco stated that implomontation
justification will be added to fully explain the human factors concepts that woro implomonted into s
the EOP flow charts and how this format satisfies the identified requirement of concurrent execution.
The inspector also noted that it was not cicar how auditable documentation of changos including justification will be maintained.
The licensco stated that the PGP will clearly define the requiremont for justification of changes to the PSTG and future EOP changes that cause deviations from the PSTG.
The requirements cross reference list page will be used to document changes to each procedure along with justification for each
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change.
The changes will be incorporated by March 3, 1991.
No additional PSTG problems woro l
noted by the inspectors during this inopoction.
3)
RPV Level Control Entry Condition
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The previous inspection noted that the EOP deviated from the EPG ontry condition concerning the RPV level control scram set point.
The EPG clearly stated +11.4 inchos, but the licensoo had
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heen using a non-conservative -41.6 inches as the entry condition and the technical justification
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for this deviation was lacking.
The inspector's review of the licensoo's
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correctivo actions for this deficiency revealed i
that the licenseo took immediato action by issuing a TCH to correct EP-2 t7 reflect the correct entry level of +11.4 inches.
The licensco's subsequent EPIp correctivo actions included updating the EOPs to revision 4 of the BWORG guidelines.
The present revision of EP-2, revision 19, reflects
+11.4 inches as the RPV water lovel scram entry set point.
4)
Design Modification Program - Top of Active Fuel Indicative Chango Inspection report 88-06 identified a weakness in the design modification program.
A previously issued design change replaced the fuel zone lovel indicator with one~which was not labeled with the TAF marking as described in the PSTG deviation document.
Thoro was however, a chart near the
fuel zone level indicator showing different RPV levels including TAF level.
This deviation from the PSTG was not documented in the PSTG deviation document.
The licensee has addressed the design modification weakness by adequately revising operations
proceduro 02-S-01-21, DCP/ TEMP ALT /TECil SPEC /TSPS Review and Training, Revision 4.
This procedure requires design changes, temporary alterations, or technical specification changos be reviewed to determine impact on the EOPs.
This procedure also directs that a determination be made as to necessary training requirements to support plant changes.
Additionally, the current PSTG does not stipulate which instrument to use in determining
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TAF level.
Thoroforo, the fuel zone level indicator does not deviato from the pSTG.
5)
RPV-Level Control - ADS Initiation Step RC/L8 I
The previous inspection reported that EP step RC/L8 was not consistent with the EPG.
The EPG stated that if RPV water level could not be
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maintained above TAF and the ADS timer had initiated, the operator chould prevent automatic RPV depressurization by resetting the ADS timer.
Step RC/L8 of the EOP indicated that if the level
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falls bolow -150.3 inchos, then dolay ADS in.tiation.
This stop implied that the oporator d
should wait for the level to reach -150.3 inches and then dnlay the ADS initiatioA.
The inopoctor's review of this item revealed that the.licensoo took imaediato action by doloting tho reference to -150.3 inch 9s and added an "IF THEN"
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action instruction to RC/L8.
The inatt uctions directed the operator to delay ADS initiation if RpV water level could be maintained abovo -167 inches.
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The inspectors also noted that the licensec's
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subsequent Ep-2, revision 19, adequately addressen inhibiting ADS initiation.
This had been accomplished by an overrido stop.
Overrido stop 28 questions the operator about whether RPV lovel can be maintained abovo -167 inches.
If the responso is yes, then the operator goes to decision stop 29 which asks whether the ADS timor has initiated.
If the responso is yes, the operator is directed to inhibit ADS.
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6)
Boron Addition TI'om the Condensato Storage Tank The previous initial procedural steps required the lowering of the CST to 20 feet and adding 5,000 pounds of borax and boric acid.
The proceduro also directed adding an additional 2,b00 pounds of each chemical for use of systems that take auction higher in the CST.
The additional 2,500 pounds of ea'ch chemica3 were not available on nito.
The lic.onsco has formalized their calculations to cuppors that oven with raising the CST level without adding an additionni 2,500 pounds of each
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chemical, a sufficient amount of boron would be injected into the vossol.
The licensoo provided calculations to support the requirements to pince thu Reactor in cold xenors froo shutdown condition with the addition of the 5,000 lbs of each chemical to the CST and has doloted the procedural requirements for the addition of the 2,500 pounds of each chemical.
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During the team's reviou of the Alternato SLC Injection, Attachment 28 to the Emergency Procedure, a now concern was noted.
The procedure states, in part, to obtain 5,000 pounds of borax and 5,000 pounds of boric acid from the warehouse and transport to the CST area.
The operators were I
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not certain whero to find the chemicals or how the chemicals were to be transported to the CST area.
Additionally, the operators woro not familiar with the details of ho's ti got the chemicals to the top of the CST for addition to the tank. The procedural stops, being hroad and incompleto, could have caused an extenelve timo lapse in the
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completion of the task.
Durang a condition that
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would require this evolution, e.g.,
an ATWS, with the normal Standby Liquid Curirol system inoperable, a significant tine delay could result in fuel damago.
This item in suspector follow-up
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item 50-416/91-02-01.
7; 1:PG Caution #6 - Temperature Af fects RPV Lovel Inuic6 tion The previous inspection identified a problem concerning caution #6.
The licensoo simplified EPG Caution #6 to warn tho opera (vrs about inaccuracios of RPV lovel instrum:tatation whtn the containment temperaturo excoods the twrmal operating rango.
It only warned t::o oforators about shutdown and upset RPV water 16vals and did not provido warning for other RPV lovel ranges nuch as fuel zone, narrow range and wine *ango.
V,tumontation was reviewod and adequate j\\stification was provided for the F?d dovj0 tion.
Tha licensoo's analysis demonstrat'sd that it,11 RPV lesal inaccuracios which may be caused by e.igh containment temperatures worc not possible for tLo above doloted instruments doo to the unique plant design.
However, the licensoo reworded the caution and changed Caution #6 to Caution #1. The caution now '.ncludes wide range, upset range and
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shutdown rango lovel instruments.
ai EPG Caution /0 - NPSH Requirements for ECCS Pumps, EP-2 r
Tea provie s inspection report identified a cotv9rn W.L.) EPG Caution #8.
The caution provided warADQ to the operators about NPSH requirements involv3v..t supprossion pool temperature and level requiremostss Maintaining those parameters would ensure adeaunto NPSH requirements of the pumps taking suction from the suppression pool.
The licensee ha< doloted the caution and incorporated the intent Itto steps SP/L-16 through SP/L-22 of EP-3.
The 1 censoo had also provided an analysis
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which indicte d that as long vs suppression pool
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level was indicated on the control room meter, NPSH was not a concern for the pumps.
The licensee's documentation did not explain in detail the basis for modification of EPG caution /8.
The licensee's current EOPs, which conform to the Rev. 4 EPG guidelines, incorporates the NPSH suppression pool level concern and not the temperature limit concern into Caution #5.
The EOPs warn the operators that Vortex limits may be exceeded if the suppression pool level decreases to less than 14.5 foot.
The licensee's documentatica was reviewed and adequate justification was provided for the EPG deviation.
9)
ContainFJnt Venting This issue involved the question concerning the noted differences between the licensee's venting limit of 17.25 psig, weich was thought to be based on the design limitations of the vent path, not being the same as the design pressure of the containment-This vnuld allow a containment pressure of 56 psig.
The inspector's review of the current EP-3, revi111on 21, indicates a venting limit of 22 psig.
Further review of the licensee's documentation revealed adequate justification for this limit.
The limit is based on the design limit of the installed valver.
10)
Analysis Bases Paragraph 4.10 of inspection report 88-06 reported that the licensee was using traditional licensing or design basis analytical methods for post accident conditions rather than best estimates which are encouraged by the EPG.
The specific items cited to support this conclusion were in cautions #6 and #8 of the licensee's EOPs.
Caution #6 of the licensee's old EOPs was replaced in the most current EOPs with the plant specific EPG, Rev. 4 caution #1, which clarified the caution concerning the reliability of RPV level instrumentation.
Caution #8 of the licensee's old EOPs was replaced in the most current EOPs with i
the plant specific EPG, Rev. 4 caution /5, which clarified the caution concerning pump vortexing limits.
Discussion with licensee personnel determined that best estimates (vice traditional
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c-licensing or design basis analytical methods) we.=
used in the development of all of the current-I'
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c.
Control Room and Plant walkthroughs
1)
Ability to Read the Meters to the Precision Stated in the EOP A concern had been identified during the previous inspection about the ability to read control room meters to the precision as stated in the EOPs.
The concern also stated that the meter and E0P units should be the same to prevent confusion.
An evaluation was performed on various parameters stated within the EOPs to determine the ability to accurately read the main control room meters. It
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was determined the readability of the instruments was satisfactory and the control room meters were in-the same units as stated in the EOPs.
The operators showed a tendency to read the meters conservatively when asked to read selected meters.
No further concern is warranted in this area.
2)
Containment Venting Inspection report 88-06 identified that the venting ptocedure SOI 04-1-01-M41-1, Containment Cooling System, revision 25, had not been included as-part of the EOP validation and verification process.
Also, the warning directing the operator to obtain concurrence from the Emergency director
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prior to venting the containment, as written, was
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not consistent with the EPG.
Additionally, the-venting procedure was not specific on the guidance to reclose the vent valves.
The inspector determined that the licensee had incorporated containment venting requirements into ONEP 05-1-02-III-5, Automatic Isolation (Safety Related), Revision 22.
Further review coupled with a walkthrough of EP-3 and Attachments-13 and 14 determined that the licensee's corrective actions adequately met the guidance of the EPG.
3)
NRC inspection report 88-06 Executive Summary
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indicated that numerous plant labeling / procedure differences-existed.
These discrepancies were noted during plant walkthroughs and inoffice reviews.
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9-It was readily apparent to the inspectors tliat tha licensee has made an extensive effort to correct this area.
However, labeling errors were noted between the plant / procedures.
A few examples are provided in Appendix B, Section 1.d.2) and Appendix C,-Section 2.
This area will be inspected during a future inspection.
This is considered inspector follow-up item 50-416/91-02-02.
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d.
Simulator Scenarios During this inspection, one simulator ecenacio was run on the Grand Gulf simulator.
The purpose wres to determine-that-the EOPs provided-operators with sufficient guidance such that responsibilities and required actions for individuals and the team are
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clearly outlined.
It was determined, through observation, ti.at the EOPs did provide sufficient guidance and information to mitigate the plant upset conditions.
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However, during the simulator scenario, the operating crew demonstrated a weakness in Communications, and Command and Control.
The plant training staff acknowledged the indicated weakness and with plant management, stated.these weakness will be adequately addressed to meet the licensee's performance s
expectations.
e.
Human Factors Analysis of EOPs Paragraph 7 and Attachment C of' inspection report 88-06-discussed a number.of human factors weaknesses in the -
sites EOPs. These weaknesses were categorized as follows:
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Excessive and unclear use of transitions l
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Incorrect use of logic statements l-L 3)
-Excessive memory requirements 4)
Overly ~ complex and inconsistent sentence structure
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. Incorrect use of cautions and notes 6)
Inadequacies concerning the physical condition of the procedures-7)
Inadequacies in the EOP writer's guide and l-
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8)
Miscellaneous deficiencies The inspectors reviewed the current EOPs (written to Rnv. 4 of the EPGs) and the writers guide for the types of weaknesses identified in the previous inspection.
The inspt tors concluded that there was a significant improvement in the EOPs.
Transitions had been minimized, logic statements and sentences were clear and concise, memory requirements had been reduced, actions had boon removed from notes and cautions, and there was effective use of color coding to aid operators in the use of the flow charts and graphs.
The writers guide had been revised to strengthen requi, aments and no deviations from the writers guide were observed in the EOPs.
A detailed discussion of each of the previously identified weaknesses and their resolution is included in Appendix C of this report, f.
Verification and Validation The previous inspection identified a concern with the Verification and Validation of the EOPs.
The Assessment and Resolution phase was not conducted by a multidisciplinary team, and the EOP revisions were not reviewed by human factors specialists.
During this inspection, an evaluation of the EOPs, interviews with plant management and operations personnel, and a review of Procedure, 01-S-06-41,
" Verification and Validation of Emergency Procedures" were conducted.
These reviews indicated the V&V process uses a multidisciplinary team that includes human factors specialists.
g.
QA Involvement in the EOP Program This item reported that the licensee's QA organization was not performing auditing functions of EOP Covelopment.
The inspectors reviewed the licensee's 1991 Audit Program Plan.
This plan contains programmatic requirements to audit EOPs and simulator implementation during requalification cycle training.
1.dditionally, QA is in the review and approval chain for EOP changes.
The licensee completed comprehensive audits in December 1988 and August 1990 to verify programmatic adequacy, effectiveness, and implementation of the EOPs.
The inspector's review of the audit results determined that adequate management oversight is provided for maintenance of EOPs.
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h.
Review of SER on PGP The inspectors reviewed the licensee's corrective actions, which were based on the Safety Evaluation of the licensco's Procedure Generation Package.
This review was conducted as follows:
1)
PSTG The SER stated that the PSTG should be revised to conform with revision 4 of the BWROG EPGs.
The SER further stated that safety significant deviations should be documented, justified, and archived for future reference.
The team reviewed the completed documentation and determined that adequate justification was provided where the PSTG deviated from the EPG.
2)
Writer's Guide Specific concerns delineated in paragraph 2.B.
of the SER were not fully implemented.
Four discrepancies, noted between the SER and the writer's guide are listed below:
a)
The writer's guide did not agree with the referencing and branching format of the SER, b)
The writer's guido did not address overuse of underlining words, c)
The writer's guide did not prevent hyphenation at end of text.
d)
Action verb list was not inclusive.
The licensee stated the wri'cer's guide will be revised to correct the identified-discrepancies.
The corrective actions will be completed by March 30, 1991.
The inspectors found that the new writer's guide was adequate.
However, when the above items are addressed, the writer's guide will afford suffici a guidance to provide for consistent 1 spared and revised, high quality EOPs.
3)
V&V The inspectors found that the licensee has not fully addressed the SER items on V&V.
The licensee did not include that simulator exercises and control room walkthroughs will be exercised
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with the minimum control room staff required by the Technical Specifications.
This area will be reviewed as part of inspector follow-up item 50-416/91-02-03.
4)
Training The inspectors found that the training concerns raised in the SER had not been addressed by the licensee in their current administrative controls and practices.
The following is a list of concerns noted in the SER that were not addressed:
a)
Section 5.4.2, page 5-2, refers to figure 5-1, but this figure had not been included in the PGP.
The PGP should be revised to include Figure 5-1.
b)
Section 5.4, page 5-2, should be revised to state that both the normal staff complement and Technical Specification minimum staffing will be used in simulator exercises and control room walk-throughs.
c)
The training program description should be expanded to indicate that all operators will exercise all EOPs on the simulator or, for those areas not conducive to simulator training, in control room walk-throughs.
4)
The training program should state that the operators' knowledge and performance on the use of the EOPs will be evaluated during and after training and that appropriate follow-up training will be conducted, if necessary.
Operators should also be tested after retraining.
The licensee's corrective actions will be reviewed during a future inspection.
This is considered
inspector follow-up item 50-416/91-02-03, 3.
Exit Interview An exit interview was conducted on February 1, 1991, with those persons indicated in paragraph 1 above:
The inspectors described the areas inspected and discussed in detail the inspection results noted below.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
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Item:
Status Description /ParAgtaph 50-416/91-02-01 Open IFI - Procedural steps in Attachment 28 to Alternate SLC Injection woro incomplete concerning obtaining Boron from the warehouse, (Paragraph 2.b.6)).
50-416/91-02-02 Open IFI - Plant labeling / procedure discrepancies continue to exist, (Paragraph 2.c.3)).
50-416/91-02-03 Open IFI - SER training items have not been addressed in the PGP, (Paragraph 2.h.3) & 4)).
4, Acronyms ADS Automatic Depressuization System BWROG Boiling Water Reactor Owners Group DCP Design Change Program ECCS Emergency Core Cooling System EP Emergency Procedures EPG Emergency Procedure Guidelines NPSH Net Positive Suction Head ONEP Off Normal Emergency Procedure PGP Procedures Generation Package psig Pounds Per Square Inch PSTG Plant Specific Technical Guidance RCIS Reactor Coolant Injection System RPV Reactor Pressure Vessel SER Safety Evaluation Report SERI-System Energy Resources, Inc.
SLC Standby Liquid Control System SOI System Operating Instruction-SPDS Safety Parameter Display System TAF Top of Active Fuel TCN Temporary Cnange Notice QA Quality Assurance
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Appendix A The following documents were reviewed to assess the licensee's upgrade to Rev. 4 of the Owner's Group Emergency Procedure Guidelines:
PSTG, dated September 19, 1989, Amendment 2 Attachment I to the PSTG, EPG to PSTG Deviation Justification Attachment II to the PSTG, PSTG to EP Step Correlation SER For Grand Gulf Nuclear Station, Dated July 18, 1990.
The following procedures were reviewed in assessing the adequacy of the EPs:
Administrative Procedures:
01-S-06-37, Rev. 5 Revision and Control Of Emergency Procedures 01-S-06-39, Rev. 4 Control and Use Of Plant Specific Technical Guidelines 01-S-06-41, Rev. 2 Verification and Validation Of Emergency Procedures Operations Procedure:
02-S-01-21, Rev. 4 DCP/ Temp Alt / Tech Spec /TSPS Review and Training Emergency Operating Procedures:
EP-2, Rev. 19 RPV Control EP-2A, Rev. 19 RPV Control -ATWS EP-3, Rev. 21 Containment Control EP-4, Rev. 18 Auxiliary Building and Radioactive Release Control 05-S-01-EP-2, Rev. 19 Attachment 1 Defeating RCIC SP Water Level Suction Transfer Interlock Attachment 2 Defeating RCIC Low RPV Pressure Isolation Interlocks Attachment 3 Defeating All RCIC Isolation and Non-mechanical Turbine Trip Interlocks Attachment 4 Defeating HPCS High SP Water Level Suction Transfer Interlock Attachment 5 Defeating HPCS RPV Level 8 Isolation Interlock Attachment 6 Defeating Reactor Feed Pumps RPV Level 8 Trips Attachment 7 Defeating Auxiliary Building, Containment, and Drywell Instrument Air Isolation Interlocks Attachment 8 Defeating MSIVs and MSL Drains RPV Low Level 1 Isolation Interlocks Attachment 9 Defeating All MSIVs and MSL Drains Isolation Interlocks
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.
Appendix A
Attachment 10 Defeating Drywell Cooling Isolation Interlocks Attachment 11 Defeating RWCU Isolation Interlocks Attachment 12 Defeating RHR SDC Injection Valves Isolation Interlocks Attachment 13 Containment Venting / Defeating Centainment Vent Path Isolation Interlocks Attachment 14 Containment Venting Attachment 15 Defeating Drywell Purge Compressors Start Signals Attachment 16 Defeating Containment Purge Path Low RPV Water Level and High Drywell Pressure Isolation Interlocks Attachment 17 Defeating All Containment Purge Path Isolation Interlocks Attachment 18 Defeating ARI/RPT Logic Trips Attachment 19 Defeating RPS Logic Trips Attachment 20 Defeating RC&IS Control Rod Drive Blocks Attachment 21 De-energizing Scram Solenoids Attachment 22 Opening Individual Scram Test Switches Attachment 23 Manually Venting The Scram Air Headers Attachment 24 Venting CRD Overpiston Volumes Attachment 25 Injection Into The RPV With Condensate Transfer Attachment 26 Injection Into The RPV With The Fire Protection Water System Attachment 27 Injection Into The RPV With The SLC Test Tank Attachment 28 Alternate SLC Injection Attachment 29 Primary Containment Water Level Determination
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Appendix B
E Details of HF and Technical Comments 1.
EOP Example Closeouts From Inspection Report 88-06, Attachment B a.
Item A.1 This item identified that step RC/Q-19-directs the de-energization of scram solenoids by opening breakers.
The referenced breaker numbers did not agree with breaker numbers in the plant.
__
Step RC/Q-19 no longer exist for the current revision of the EOPs.
EP-2A, step 26, references the opening of the scram breakers by performing attachment 21.
A walkthrough evaluation of attachment 21 determined the breaker numbers listed-in the attachment correctly matched the breaker numbers indicated in the plant.
This item is closed.
2)
Item A.2:
iais item identified that step RC/Q-30 stated to vent the control rods and direct the effluent to radwaste or to the suppression pool.
-
The operators were unaware of the location of the stainless steel hoses used for this venting.
Step RC/Q-30 no longer exist for the current revision of the EOPs.
EP-2A, stop 26, directs the venting of the control rods by completing attachment 24.
A walkthrough evaluation of-attachment 24, which directed the operators to obtain the necessary equipment from-the control
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room EOP cabinet, indicated operators were able to-locate the-equipment necessary to perform the CRD
-
venting.
This' item is closed.-
3)
Item A.3:
This item identified that. step RC/Q-14 provided instructions to-inject boron into the RPV using either the CST or RWCU systems. - The RWCU procedure number was "Later".
The licensee has modified the EOPs and this step-is now on EP-2A, step 20.
This stop addresses-
~
alternate injection with RCIC or HPCS and attention is directed to EOP attachment 28.
This item is closed.
4)
Item A.4:
This item identified that the spacing of If/Then-statements on various EOP flow patha were inconsistent.
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Appendix B-
The licensee has modified the EOP flow charts.
The If/Then statements no longer exist.
This item is closed.
5)
Item A.5:
This item identified that Caution 20 on EP-2 did not list the procedure number required to defeat the RCIS interlocks.
Caution 20 no longer exist for the present revision of the EOPs.
EP-2A, step 26 now references attachment 20, which is used to defeat the RCIS interlocks.
This item is closed.
6)
Item A.6:
This item identified that various steps in RC/P-2 gave direction to transition to various flow paths for steam cooling conditions.
The above comments are not applicable for the present revision on the EOPs.
The requirement for various transition points are not required during steam cooling.
This item is closed.
7)
Item A.7:
This item identified that Notes 37 and 32 on EP-2 are reversed.
The licensee has modified the EOPs and the intent of the notes are now incorporated into EP-2A step 2 and step 6.
This item is closed.
8)
Item A.8:
This item identified that several steps of EP-2 and entry conditions for RC/Q-4, RC-1, RC/Q-1 and RC/Q-40 contained misaligned underlining.
The licensee has revised the EOPs and the above comments are not applicable for the current revision.
This item is closed.
9)
Item A.9:
This item identified a concern about the ability to start both CRD pumps following a load shed concurrent with a LOCA and ATWS.
The breakers were required to be locally reset and would be inaccessible.
The licensee has-incorporated this open item
,
concern into the Budget Year Projects List, 88-069-RF05, for disposition.
This item is closed.
b.
EP-3, Containment Control 1)
Item B.1:
This item identified a deficiency with an inappropriate reference to an SPDS display.
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Appendix B
The licensee determined that their SPDS displays were not adequate to support the Rev.
As a result, permission was requested (and granted) from the NRC to display only the first screen of SPDS (which contains the overview of plant paramotors) until a computer upgrade project could be completed.
As a result, SPDS ic not currently referenced by the EOPs.
This item is closed.
2)
Item B.2:
This item reported that valvo P11-F039, referenced in procedure 04-1-01-P11-2, did not have a handwheel attached, and that no work order had been issued to correct this condition.
The handwheel on this valve has been replaced.
No other valve handwheels were noted as missing during the walkthroughs performed during this inspection.
This item is closed.
3)
Item B.3:
This item reported that there were no procedures to initiate RCIC or HPCS when needed to increase suppression pool level.
Procedures have been developed and are referenced by the appropriate EOP.
This item is closed.
4)
Item B.4:
This item identified a typographical error on curve SP/L-1.
This error has bc 7
corrected on figure 7 of the current EOPs.
This item is closed.
5)
Item B.5:
This item reported that procedure 04-1-01-P11-2, Refueling Water Storage and Transfer System could not be performed without lifting containment isolation.
Operators were questioned concerning their knowledge concerning this area and were knowledgeable of this fact.
This item is
,
l closed.
l 6)
Item B.6: This item reported that the location of valves was not identified in procedure 04-1-01-P11-2.
The writers guide requires that location of infrequently used components be specified in EOPs.
The valves in this procedure are frequently used and walkthroughs of this procedure determined that the operator had no problem identifying valve locations.
This item is closed.
7)
Item B.7:
This item identified a deficiency concerning an incorrect reference to note 9 on the EOP.
This condition has been corrected in the current EOPs.
This item is close ___
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Appendix B_
c.
EP-4, Radioactive Release 1)
Item C.1:
This item identified that SPDS display 9,
attached to steps RR-3 and RR-5, was found not to be inservice and would not be for an extended period.
The licensee determined that their SPDS displays were not adequate to support the Rev.
As a result, permission was requested (and granted) from the NRC to display only the first screen of SPDS (which contains the overview of plant parameters) until a computer upgrade project could be completed.
As a result, SPDS is not
.
'
currently referenced by the EOPs.
This item is closed.
2)
Item C 2:
This item identified that procedure numbers for systems listed in step RR-2 should be added to the step.
This condition has been corrected in the current EOPs.
This item is closed.
3)
Item C.3:
This item identified that Note 38 listed primary systems.
RCIC was not one of the systems listed in Note 38.
This condition has been corrected in the current EOPs.
This item is closed.
I d.
EP-5, Secondary Containment Control 1)-
Item D.1:
This item identified that Tables SCL-l'
SCR-1 and SCT-1 had many inconsistencies between instrument numbers and plant labels and the location columns of the tables were incorrect.
The instrument-numbers, labels and location columns are no longer part of the current revision of the EOPs.
Table 3 of EP-4 list alarms and their locations for parameters that are entry conditions.for the Auxiliary Building.
This item is closed.
2)-
Item D.2:
This item identified that procedure 04-1-01-M71-1 contained numerous minor discrepancies.
The majority of the discrepancies have been corrected or no longer apply for-the current procedure revision.
However, the following items still remain uncorrected:
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Appendix B
Attachment V stop (5) references panel 1H13-P872 which should be panel lH13-P871.
Attachment V, stop (6) references panel 1H13-P871 which should be panel 1H13-P872.
3)
Item D.3:
This item identified that steps SC/T-2 and SC/L-7 use the word " area". The word should be
" area (s)".
This comment is not applicable to the current revision of the EOPs.
This item is closed.
e.
EP-12, Emergency Depressurization, Revision 0
-
1)
Item E.1:
This item identified a deficiency concerning incompatibility of an EOP chart and an SPDS display.
The licensee determined that their SPDS displays were not adequate to support the Rev.
As a result, permission was requested (and granted) from the NRC to display only the first screen of SPDS (which contains the overview of plant parameters) until a computer upgrade project could be completed.
As a result, SPDS is not currently referenced by the EOPs.
This item is closed.
2)
Item E.2:
This item concerned missing entry and exj arrows.
The current EOPs were reviewed for this condition and no deficiencies were noted.
- This item is closed.
3)
Item E.3:
This item concerned the incorrect use of a note.
All notes were deleted when the Rev.
This item is closed.
4)
Item E.4:
This item concerned a deficiency related to entry and exit points.
No similar conditions were noted on the current EOPs.
This item is closed, f.
Item F.1:
This item identified that steps RF-9 and RF-10 referred to SPDS display 22.
The licensee determined that their SPDS displays were not adequate to support the Rev.
As a result, permission was requested (and granted) from the NRC to display only the first screen of SPDS (which contains the overview of plant parameters) until a computer upgrade project
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Appendix B
could be completed.
As a result, SPDS is not currently referenced by the EOPs.
This item is closed.
2)
Item F.2 This item reported that stop RF-24 had a " greater than" symbol in it.
The use of the symbol was different than the words "at least" in steps RF-25 and RF-29.
No similar conditions were noted on the current EOPs.
This item is closed.
3)
Item F.3:
This item identified that Note 35 provided the operator with a list of thermocouples.
Drywell and containment "TC" did not agree with plant documentation (i.e. M71-TE-NO20A).
Revision of the new EOP has deleted the need for this note.
This item is closed.
4)
Item F.4:
This item identified that EP-13 steps RF-13, RF-18 and RF-22, as well as EP-14 stop LP-34, listed a system as " Condensate Transfer."
A similar step in EP-11, stop LR-7, referred to this system as "Condensato and Refuel Storage Water" system.
Revision of-the EOPs has corrected this concern.
This item is closed, g
EP-14, Level / Power Control, Revision 0 1)
Item G.1:
This item identified that step LP-28
-
and step LP-29 referenced various SPDS screens when more appropriate screens were available.
The licensee determined that their SPDS displays were not adequate to support the Rev.
As a result, permission was requested (and granted) from the NRC to display only the first screen of SPDS-(which contains the overview of plant parameters) until a computer upgrado project could be completed.
As a result, SPDS is not currently referenced by the EOPs.
This item is closed.
2)
Item G.2:
This item identified that steps LP-11 and LP-12 referenced procedure, 04-1-01-B21-1 and note 41, fe' the steps necessary to bypass the MSIV low level trip interlocks.
The relay labeling referenced in note 41 was different from
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Appendix B
those listed in the plant panels.
The current revision of EP-2, step 54, references attachment 8 for the steps necessary to bypass the MSIV low level trip interlocks.
A walkthrough evaluation was performed using attachment 8.
It was determined the attachment labels correctly matched the plant panel labeling.
This item is closed.
3)
Item G.3:
This item ident.fied that EP-2 and EP-3 caution 28, recommended using instruments M-71-TR-605A through D, to monitor Suppression Pool temperature.
Caution 28 does not appear in the current revision of EP-2 and EP-3. The operators are directed to monitor and maintain Suppression Pool temperature below 95 degrees and instrument numbers were not referenced.
This item is closed.
4)
Item G.4; This item identified that the position of notes 34 and 36 as well as the position of EP-li and EP-13 were reversed.
The above comments are not applicable for the current revision of the EOPs.
Notes 34, 36, and EP-11 and EP-13 do not exist.
This item is closed.
5)
Item G.5:
This item identified that step LP-4, Caution 28 was missing-a brief description as required by procedure 01-S-06-37.
The above comment does not apply for the current revision of the EOPs.
Caution number 28 does not exist.
This item is closed.
6)
Item G.6:
This item identified that a concern was noted that cautions could be missed due to transition entry points within the LP steps of the EOPs.
An evaluation was performed for EP-2 and EP-2A. It was determined that cautions should not be missed during transitions, if the present sequence of steps are correctly followed.
This item is closed.
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Appendix B
2.
Comments on New EOPs a.
Several labeling deficiencies (procedure nomenclature did not match component label plates)
were noted on Attachment 7 which was referenced by this Ep through Attachment 9.
2)
During the procedure walkthrough, the operator was not able to use Table 2 of Attachment 29, Containment Level Determination, to determine containment level.
Also, step 2.7 referenced the wrong step, it should have referenced step 2.6 not 2.5.
The licensee informed the inspectors that a wide range containment level instrument was installed during the recent refueling outage because of the complexity of determining containment level when above 25 feet.
EOP training on the use of this new instrument is scheduled to begin February 18, 1991.
The Attachment will remain as a alternate method of level determination.
The typo will be corrected and additional training will be conducted on the use of the Table 2.
3)
Attachment 26 did not identify which hookups would need extra hose, which need ladders to reach valves or where fire hose spanners are located.
Since some of the rooms for FW hookup are contaminated, predetermining hose and ladder needs
.
would reduce personnel exposure.
b.
EP-2A, RPV Control-ATWS Step 6 of EP-2A lacks sufficient detail to ensure operators could determine if 853 lbs. of boron had been injected into the RPV.
The licensee indicated this may be a training deficiency and would address the concern, c.
EP-3, Containment Control Several labeling deficiencies (procedure nomenclature did not match component label plates) were noted in SOI 04-1-01-P11-2 which was referenced by this EP.
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Appendix B
d.
EP-5, Secondary Containment Control An evaluation of the alarms listed in table 3 of-EP-4 was conducted.
The inspector noted that the alarms associated with the Aren Water Levels referenced EP-5, which has been deleted.
Some alarms associated with the Area Temperatures were not at their designated locations, and others did not reference possible entry into the EOPs.
The licensee was extremely responsive to the noted problems and conducted a review of EP-4, table 3 alarms.
The licensee identified additional deficiencies and issued a TCN for short term corrective actions.
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APPENDIX C Details of Human Factors and Writer's Guide Closcouts From Attachment C of Inspection Report 88-06 1.
Excessive and Unclear Use of Transitions a.
Excessive Transitions:
This item reported that there were an excessive number of transitions within and between flow charts to the point of becoming confusing to the operators.
The current flow charts have been greatly simplified in this area.
The number of flow charts has been reduced to a total of four.
Additionally, a conscious effort has been made to reduce the number of transitions.
Observation of the operators during the simulator scenario determined that they were able to follow the charts with relative case.
This item is closed, b.
Excessive Ptimber of Transition methods:
This item concerned the number of transition methods that were used in the old flow charts.
Again, the number of transitions and the transition methods have been significantly reduced.
Operators had no problem in following the new charts.
This item is closed, c.
Incomplete References:
This item concerned the manner in which references to other sections of the EOP flow charts were referenced (by EP # and Step #), and also how non-EOP procedures were referenced (by Procedure #,
only).
The simplification of the flow charts has improved this area.
References to the EP # and step #
is-still used.
Reference to attachments (which are an integral part of the flow charts) is by Attachment #
only, Reference to other procedures such as SOIL is by number and title.
The methods of referencing is no longer a problem.
This item is closed, d.
Placekeeping:
This item identified the need for the development of a placekeeping mechanism to help ensure that operators would not loose their place when working their way through the EOPs.
This was based on the fact that there were so many charts, their physical size and the fact that there was no adequate space available to lay the charts out during use.
As previously discussed, the number of charts and the number of transitions has been greatly reduced.
Also, the design of the control room and simulator desks was considered in the development of the new EOP flow charts.
The charts have been designed so that two of the charts are visible at all times underneath a piece of glass on the operators desk.
The other two charts are printed front and back, and these two charts are not used at the same time.
I
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Appendix C
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The operator, therefore, always has one chart laying over the other two charts when they are being used which does not appear to cause any problem.
,
Additionally, the operator observed ici the simulator used a colored marking pen to keep his place as he proceeded through the charts.
This practice is not mandatory, but is left to the discretion of the operator.
Placekeeping, therefore, is no longer a concern.
This item is closed.
2.
Incorrect Use of Logic Statements a.
Incorrect structure of logic statements:
This item addressed the fact that logic statements in the old EOPs were overly complex containing embedded logic statements and transitions.
Additionally, the logic statements were noted to lack the "IF" "THEN" format and were written in the "BEFORE, THEN,-IF, UNLESS" kind of format which was unnecessarily complex.
Review of this area determined that the writer's guide had been revised to require that only specified types of logic statements be used.
Additionally, the EOPs had been written in accordance with this guidance and the logic statements had been greatly simplified.
This item is closed.
b.
Inconsistent use of decision symbol:
This item concerned the use of logic statements inside of action statement rectangles, in lieu of the use of logic statements in-the form of-a "yes" "no" format and use of the-diamond shaped decision symbol.
The new EOPs rely heavily on the diamond symbol and the "yes" "no" format.
This item is closed.
3.
Excessive Memory Requirements a.
This item reported a concern over the excessive memory burden placed on.the operators during use of the old EOPs.
The concern was based on the fact that
" motherhood" or " retainment" EPG entry conditions had to be remembered by the operators as they worked through the EOP flow charts.
This condition has-been.
corrected in=the Rev.
4, EPG EOPs by placing those i
L requirements in the body of the flow charts in the form of decision statements and highlighting the diamonds in
-
red.
The statements are also repeated throughout the charts in appropriated places.
This item is closed.
4.
Overly Complex and Inconsistent Sentence Structure a.
This item reported that sentences throughout the EOPs l-were written in a complex manne _.
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Appendix C
The sentences used multiple action verbs, embedded logic and unnecessary information with complicated and indirect language.
Review of this area determined that the writers guide has been revised to address these issues.
Additionally, review of the EOPs determined a marked improvement in sentonce structure and simplification of logic.
This item is closed.
,
5.
Incorrect Use of Cautions and Notes a.
Caution placement:
This item addressed a concern that cautions were placed in the EOPs in a manner such that critical information may be lost by the operator.
This item was addressed in the Rev.
4, EPG EOPs by color coding the caution # jn the EOP step and the cautions themselves in yellow so that the information in the caution jumps out at the operator.
This item is closed, b.
Operator actions included in cautions and notes:
This
'
item reported that the old EOP cautions and notes included operator action statements in lieu of warning the operator of the possible consequences of actions.
Review of the current EOPs determined that all notes have been either deleted or incorporated into the EOPs as action statements.
The cautions in the current EOPs mirror the EPG cautions with plant specific information included where appropriate.
This item is closed.
6.
Physical Condition of the Procedures a.
Size:
This item reported that the flow charts were too large to use effectively on the desk space available.
This item was previously discussed in item 1.d above.
This item is closed.
b.
Print size and quality:
This item reported that the print size of the old EOPs was too small for degraded lighting conditions, and that the reproduction was poor.
The Rev.
4, EPG COPS are very large with large print.
The reproduction quality is excellent.
This item is closed, c.
Lamination:
This item reported that the old EOPs were laminated with a glossy material which decreased readability.
The current EOPs are laminated with a non-glare plastic which does not inhibit readability.
,
This item is closed.
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Appendix C
7.
Inadequate Writers Guide a.
Inadequate writers guide:
This item discussed the inadequacies in the writers guide which lead to the problems discussed throughout this enclosure.
As discussed elsewhere in this enclosure the EOPs have been significantly improved.
The writers guide has also been significantly improved and now addresses the applicable issues discussed in this enclosure.
This item is closed.
b.
Deviations from the writers guide:
This item discussed several deviations from the writers guide which were noted during the previous inspection.
No deviations from the writers guide were noted during this inspection.
This item is closed.
8.
Miscellaneous I
a.
Lack of approved list of abbreviations and acronyms:
The current writers guide contains an approved list.
This item is closed.
b.
Handwritten changes allowed:
No hand written changes
-
were noted on the COPS.
The writers guide does not provide for a method of hand written changes.
This item is closed.
c.
Inconsistent placement of yes/no exits from decision symbols:
This item has been corrected in the current EOPs.
This item is closed.
d.
Lack of approved list of action verbs:
Verbs and other vocabulary to be used and prohibited from use are discussed in the writers guide.
This item is closed, e.
Inconsistency between EOPs and ONEPs used in training and those used in the control room:
No inconsistencies between the control room procedures and those used in the simulator were observed by the inspectors.
This item is closed.
f.
Inconsistency in methods of describing position on charts (e.g., reference to both "in the shaded area" and "below the curve"):
Current EOPs refer to "in the safe area".
The safe and unsafe areas are clearly indicated on the charts.
This item is closed.
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