IR 05000483/1989024

Insp Rept 50-483/89-24 on 900122-0202.No Violations Noted. Major Areas Inspected:Verification That Emergency Operating Procedures Technically Correct & Usable

ML20012C490
Person / Time
Site:	Callaway
Issue date:	03/13/1990
From:	Charles Brown, Hasse R, Hopkins J, Phillips M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20012C489	List: IR 05000483/1989024 ML20012C488
References
50-483-89-24, NUDOCS 9003220066
Download: ML20012C490 (27)

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION III

Report No. 50-483/89024(DRS)

Docket No. 50-483 License No. NPF-30 Licensee:

Union Electric Company Post Office Box I49 - Mail Code 400

St. Louis, MO 63166 Facility Name: Callaway Nuclear Plant Inspection At: Steedman, MO 65077 Inspection C ted: January 22 through February 2,1990 L

Inspectors:

3[f8 R. A. HassefR I Date Te m Leader 0 Ys 3//3/90 g

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n, RITI Date J. R. Sears, Consultant (COMEX)

B. Paramore, Consultant (SAIC)

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_ Approved By:

M. P. Phiflips, Chief Date Operational Programs Section Inspection' Summary-Inspection on January 22 through February 2.1990 (Report No. 50-483/89024(DRS))

Areas Inspected:

Special announced safety inspection to verify that the Callaway Emergency Operating Procedures (EOPs) were technically correct and usable.

The inspection was conducted in accordance with TI 2515/92(SIMS No. - HF. 4.1).

Results:.No violations were identified. The licensee showed strength in providing useful information to the operator without encumbering the procedures.

Training weaknesses for both licensed and non-licensed operators were identified.

A weakness in equipment labelling was also identified.

This weakness was being addressed by the licensee.

9003220066 900324 DR ADOCK 05000483 PDC L_

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persons Contacted'

Union Electric Company i

• D. Schnell, Senior Vice President, Nuclear

• J. Blosser, Callaway Plant Manager J. Baker, Operating Supervisor

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D..Heinlein, Assistant Superintendent, Operations G. Hughes, Supervisor, ISEG

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M. Konya, Engineer, Quality Assurance

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H. Bono, Supervisory Engineer, Quality' Assurance

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S. Petzel, Engineer, Quality Assurance J. Laux, Manager, Quality Assurance J. Gearhart, Superintendent, Quality Assurance

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W. Campbell, Manager,~ Nuclear Engineering i

J. Peevey, Assistant Manager, Operations and Maintenance

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C. Naslund,. Manager, Operations Support M. Evans, Superintendent, Training U.S. NRC M. Phillips, Chief, Operational Programs Section, RIII

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B. Little, Senior Resident Inspector, RIII

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Other licensee personnel were contacted / interviewed during the

inspection.

• With these exceptions, all othe personnel listed attended the exit

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interview conducted on February 2,1990.

2.

Licensee Action on Previous Inspection Findings

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(Closed) Open Item (483/87019-01):

Inadequate documentation of E0P i

setpoints.

This item is closed based on the discussion in

-Paragraph 3.c.(1)(b) of this report.

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Emergency Operating Procedures

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a.

Background Emergency Operating Procedures (EOPs) have undergone significant changes due to the 1979 accident at the Three Mile Island (TMI)

facility. The post-TMI procedures are symptom-oriented rather than event-oriented.

Symptom-oriented E0Ps provide the operator guidance on how to verify the adequacy of critical safety functione and how to restore and maintain these functions when they are

degraded.

Symptom-oriented E0Ps are written in a manner that the operator need not diagnose an event to maintain the plant in a safe shutdown condition for all accidents that are within the scope of the E0Ps.

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The purpose of this inspection was to verify that the Callaway E0Ps are technically correct; prepared in accordance with the writer's

guide; that their specified actions can be accomplished using existing equipment, controls, and instrumentation; and that the

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available procedures have the usability necessary to provide the operator with an effective operating tool.

b.

Inspection Methodology The inspection consisted of a desk top review of 25 Optimal Recovery Procedures and 18 Function Restoration Procedures; an in plant walkdown of local actions specified in 10 Recovery. Procedures and

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L one Abnormal Procedure; exercises of five scenarios on the plant I

L simulator, which tested the use of 13 procedures; and a human factors review of the procedures, plant walkdowns, and simulator exercises.

In addition, users and developers of the E0Ps were interviewed. A detailed listing of these activities is given in Appendix A.

c.

Inspection Results The inspectors concluded that the Callaway E0Ps were adequate to

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mitigate accidents within the scope of the Westinghouse Owners Group Emergency Response Guidelines (ERGS) and could be implemented by the plant staff.

The Callaway E0Ps reflected a conscientious effort to provide the reactor operators with relevant information beyond that provided in the skeletal guidelines in the ERGS without encumbering the procedure. An example was the highlighting of continuous action steps. The lack of such guidance has tended to be a generic concern expressed by operators during other E0P inspections.

In contrast, the inspectors identified a number of concerns during the inspection.

Principal among these was licensed and non-licensed operator training and plant labelling.

These and other concerns are discussed in the following paragraphs and in Appendix B of this' report.

(1) Desktop Review

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The desktop review consisted of a detalled comparison of the E0Ps to the ERGS. Where technical deviations from the ERGS occurred, the written justification for the deviation was reviewed for adequacy.

The setpoint documentation was also reviewed.

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(a) Deviations From The ERGS g

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Deviations.from the. ERGS were minimal since Ca'11away was I

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basically the reference plant; however, one technical-i

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deviation was made which was not adequately justified-i and-in fact deviated from the mitigative strategy of

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the ERGS.

In four E0Ps involving a LOCA or steam generator

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tube rupture, the licensee inserted _a step limiting the

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cooldown~ rate of the RCS to < 50 F per hour if no reactor

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coolant pumps (RCPs) were running.

The ERGS specified a cooldown rate of < 100 F per hour regardless of RCP status.

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/p The licensee's justification for this deviation was that it was consistent with the background information for

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other E0Ps where natural -circulation cooldown was in

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E progress. and it was desirable to minimize void formation.

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The inspectors questioned this strategy where loss of

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primary coolant was involved. The licensee contacted the i

Westinghouse Owners Group (WOG) and confirmed that in

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these cases, a maximum cooldown rate consistent with

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thermal stress limits (ie, <100 F per hour) was appropriate.

The licensee immediately issued temporary change notices to these E0Ps correcting this deficiency.

In addition,

the licensee was submitting a maintenance item to the WOG to clarify this issue in the background documents.

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In another case, the licensee aowd an unjustified note

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to E-0, " Reactor Trip or Safety Injection," allowing the

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operators to use the ES-0.0, "Rediagnosis," procedure l

prior to exiting E-0.

The licensee. stated that the intent

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of the note was to give-the operator the option to go to ES-0.0 after the Immediate Actions (steps 1-14) of E-0 were completed.

(The remaining steps in E-0 were mostly diagnostic.) In interviews, some operators stated that-they could use ES-0.0 as soon as the Note appeared

(step 5); others, after the Immediate Actions were completed; others, after the diagnostic steps were completed (steps 22-24); and still others, only after E-0 had been exited. Upon~ questioning by the inspectors the

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licensee contacted WOG to determine if the note was l

consistent with the intent for using ES-0.0.

The WOG stated that the Note does not conform with the intent of the Background documents for using ES-0.0.

The licensee

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issued a Night Order stating the ES-0.0 was not to be entered unless Safety injection had occurred and E-0 had been exited. The licensee intended to discuss this issue further with the WOG.

There were a few cases where unjustified additions had been made to the E0Ps that were not technical deviations but the

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rationale was not clear.

For example, a note had been

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added to E-3, " Steam Generator Tube Rupture" that it was perferable to not run an RCP in a loop with a ruptured steam generator.

The ERGS do not address this issue. The

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inspectors noted that a documented justification in such cases would allow the reviewers to assess the author's rationale. The licensee agreed to address this issue.

(b) Setpoint Documentation The setpoints used in the E0Ps were documented as engineering calculations. The inspectors reviewed a sample of these calculations.

No concerns were identified. One

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discrepancy was identified between the setpoint calculation and the value used in the E0Ps.

The E0Ps used an RCS temperature of 350 F for isolating the accumulators. The setpoint calculation indicated a value of 385 F should be used.

This was apparently a result of the revised method for calculating this setpoint in revision 1A of the ERGS; however, it was not incorporated into the E0Ps. The safety significance was minor.

The licensee issued a temporary change notice during the inspection incorporating the correct value into the E0Ps.

(2) E0P Walkdowns Walkdowns of selected E0Ps were conducted with licensed and non-licensed operators who would normally perform these tasks.

Particular emphasis was given to local actions in the plant.

The objective-of' these walkdowns was to determine if these a

actions could be performed in a timely manner with a minimum

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potential for error.

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In general, the operators were able to implement the E0Ps as written. However, some concerns were noted. Additional-details are given in Appendix B.

In the E0Ps, equipment that cannot be controlled from the main control board (MCB) must be locally operated. Some of this equipment is in poorly lighted areas (even with normal lighting available) and requires climbing on piping and other components to operate.

Two examples are local operation of the Turbine Driven Auxiliary Feedwater Pump and the Main Steamline Isolation Valves. The licensee agreed to review the need for platforms and additionti lighting in these areas.

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The E0Ps reference normal and special operating procedures in order to perform local tasks to mitigate specific events.

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=The Equipment Operators (E0s) could not find several of the valves identitied in the referenced procedures.

The EOs used u

valve locator sheets, system piping diagrams and control room operators to help. locate the valves.

Poor lighting and small

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valve tags contributed to the E0s difficulty in locating the valves.

The. licensee agreed to incorporate additional valve location information in the referenced procedures, provide additional E0P training for the EOs, and to review the need for additional lighting.

Further, the licensee has started a valve relabelling program with larger, more visible labels.

Completion of this

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labelling program will be tracked as an open item-(50-483/89024-01).

The training issue is discussed further in Paragraph 4.

(3) Simulator Exercises l

Five scenarios exercising 13 procedures were conducted on the Callaway simulator to verify that the procedures provided the operator with an effective tool to place the plant in a safe shutdown condition for accidents and transients within the scope of the ERGS.

The. scenarios were run utilizing two.

different operating crews consisting of a-Shift Supervisor (SS),

an Operating Supervisor (OPS), two licensed operators acting as Primary Plant Operator (RO) and Balance of Plant Operator (BOP),

and a Shift Technical Assistant (STA). (One of the crews had

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three licensed operators.)

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In general, the specified actions detailed in the selected E0Ps j

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-were technically correct and could be accomplished using existing equipment, controls and instrumentation. The procedures led the operators through the transition points without much confusion. However, some concerns were noted.

The inspectors identified a need for additional training in I

correctly transitioning to other procedures. -One example

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occurred during scenarios with the Design Basis Accident (DBA)

l Loss of Coolant Accident (LOCA). The initial symptoms that the Steam _ Generator (SG) display during a LOCA or a large ' steam break are similar.

Using the diagnostic steps in E-0, the crews had difficulty distinguishing between a LOCA and a large steam break.

In one case the crew transitioned to the faulted SG procedure.

It should be noted that the difficulty in distinguishing between the DBA LOCA and a large steam break has been observed on all of the W E0P inspections.

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~Another example occurred while E-3, " Steam Generator Tube

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. Rupture,'! (SGTR) was being performed.

The RCS was being cooled down (step 14, E-3)'when the operators incorrectly used the Safety Injection (SI) Reinitiation criteria on the Foldout Page to transition to ECA-3.1. The Background document for the Foldout Page stated that the transition to ECA-3.1,

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based on the Reinitiation criteria, only applied when SI

equipment must be restarted to maintain safe RCS conditions.

(Up to this step in E-3 none of the SI equipment had been stopped.) The licensee has agreed to place more emphasis on transitions ia their future E0P training.

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The inspectors identified a need for additional training in timely completion of E0p steps.

The Background documents

state that if an action or its contingency action cannot be completed or is not successful, and no further action is provided, the operator should continue with the next step of the procedure. Additionally, the Background documents state that unless otherwise specified, a required task need not be fully completed before proceeding to the next step.

These two general rules of procedure usage ensure efficient implementation of the E0Ps where steps are time consuming.

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The crews inconsistently applied these rules of usage during 3.

. the simula *.or exercises.

One example occurred during a loss of all-AC power scenario. The crew used ECA-0.0, " Loss of'

Al1 AC Power," to restore power to one of the safety busses.

The crew then spent 14 minutes attempting to restore the other safety bus vice continuing with ECA-0.0.

This left the plant in a degraded condition which would have been corrected by continuing-with ECA-0.0.

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Another example occurred in scenarios with SGTRs when the operators were at the diagnostic steps (22-24) of E-0.

Step 23.c of E-0 has a Note stating that approximately 15 minutes is required-_for a representative SG radiation reading or sample. The operators got initial SG sample results

-in approximately five minutes.

These results were less than the SGTR transition parameters. The crews were hesitant to continue with E-0.

The licensee has agreed to concentrate on timely implementation of the E0Ps in their future training.

d.

Human Factors Review The human factors review addressed the written adequacy and usability of the Callaway (E0Ps) and the feasibility of performing the E0P steps as written in relation to control room and plant design

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,e, characteristics. The. human factors review also addressed the

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Callaway program for ongoing evaluation, development, and revision of E0Ps. The methods used included desktop review, walkthroughs of a sample of the E0P set in the control' room and plant; observation of E0P use during simulator exercises; review of E0P program and

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related documentation; and interviews with operating shift and

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training personnel and with the E0P coordinator.

(1) Findings From E0P Review In general, the E0Ps updated to Revision 1A of the ERGS were adequately written in accordance with the Callaway Emergency Operating Procedure Writer's Guide (APA-ZZ-00102, Revision 2).

It was evident that attention had been given to providing

enough detail to facilitate operator tasks.

Although the overall finding was that the Callaway E0Ps are adequately written, three areas were identified which the licensee should evaluate in the ongoing E0P program. These areas are discussed in the following subsections.

Specific examples are given in Appendix B.

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(a) Continuing Steps The Background Document for the Westinghouse ERGS identifies

" continuing steps," as steps the operator must continuously perform during the procedure. Although operators interviewed said that these steps were not always evident in the Callaway E0Ps, a sample check made by the inspectors found no case where a continuing step was not evident.

Callaway generally highlights continuing action steps in cautions.

This practice is not in conformance with accepted principles of procedural information presentation, V

since steps in cautions and notes can easily be missed; however, it does represent a conscientious effort by the licensee to address a generic problem. The licensee should make sure that there are no " Hidden" continuing steps in the E0Ps.

(b) Plant Component Identification and Location During the performance of walkthroughs Equipment Operators had difficulty finding some of the components they may be required to operate while implementing the E0Ps. This indicated a training need rather than a deficiency in the E0Ps.

The practice in the E0Ps was as follows: When an " Action / Expected Response" step must be performed locally, the component was identified by both noun name and component

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number, and location information was provided either in the E

step or in an attachment. This was also true when the

" Response Not-Obtained" step was expected to be performed locally.

Plant component numbers and location information were omitted when it was expected that control room action-would be sufficient to ensure that the step was completed.-

Difficulties in finding components were observed primarily when Equipment Operators were asked to walk through steps which they might be required to perform if control room

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In some cases components could not be c

found on the equipment lists available to the E0s. The licensee should review this issue and take action to ensure-

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that Equipment Operators can.in a timely manner, locate all components that may have to be checked or operated locally.

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(c) Consistency of Terminology Between Procedures and Component Labeling Walkthroughs in the control room indicated satisfactory consistency of terminology between procedure wording and control room component labeling.

Instances were found of mismatches between in plant component labeling and procedure terms.

Examples of this are given in Appendix B.

In addition, in plant labeling was found to be poor.

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licensee had initiated a. program to upgrade in plant labeling.

In relation to this program, the licensee should ensure consistency of nomenclature across procedures, control _ room component identification,. and in plant component-identification.

(2) E0P Writer's Guide The Callaway Emergency Operating Procedure Writer's Guide, APA-ZZ-00102, Revision 2, was reviewed for adequacy against the guidance provided in NUREG-0899 and NUREG-1358. Overall,-

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the Callaway Writer's Guide was found to be clear and comprehensive in covering-the topics that should be included.

However, some omissions and items for improvement were identified

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as discussed below.

The licensee should evaluate these needs t

and revise the Writer's Guide accordingly before the next E0P revision cycle.

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Section 3.2.3 inappropriately permitted a Deficiency List.

The E0P Coordinator stated that in practice Deficiency Lists were not permitted and that this section would be removed from the Writer's Guide.

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Section 3.2.4 should more clearly explain what information the

E0P writer was supposed to include on the " Purpose and Symptoms or Entry Conditions" page.

A Section 3.2.6 should state how immediate actions were to be identified as such. The current practice was to identify immediate action steps in a note at the beginning of each procedure in which they occurred. However, the Writer's Guide did not state this.

Section 4.0 provided guidance on writing instructional steps.

Needs for additional guidance in this area were identified.

There was no clear statement that steps should be written as imperative sentences._ Also, no specific guidance was provided concerning major /high level ("1" level) steps and substeps.

Section 4.1.3 stated that " complex evolutions should be prescribed in a series of steps,...." Examples of step format were needed.

It is potentially confusing to make the subordinate items a mix of complete sentences and verbless phrases. The operators should not have to adjust to changing-syntax within a step instruction. Mixed syntax occurred in many steps in the E0P set. Although this was not found to cause confusion, it is desirable to provide better guidance on step format in the Writer's Guide and work toward consistent syntax within steps in future revisions of the E0Ps.

Guidance should be added to Section 4.1 (or to another section as judged to be most appropriate) concerning identification of local actions. Review of the E0Ps indicated that this had been done by use of the word " locally" or other wording such as

" Send Equipment Operator to...." However, the Writer's Guide did not mention this. The Writer's Guide should require identification of local actions and provide examples of how it should be done.

Another, related need was to define the use of " manually."

Review of the E0Ps indicated that this term had been used to indicate implementation in the control room of conditions that should have occurred automatically, or were otherwise expected to exist. This usage seemed to be consistent, although an exhaustive check could not be made during the inspection.

If

" manually" was to have this meaning, it should ne', be used to describe a local action. The use of " manually" should be defined in the Writer's Guide.

As an alternative, the need for this term could be evaluated. There may be less potential for procedural inaccuracy if actions could be presumed to be i

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performed in the control room unless they were specified as

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local actions. The distinction between correction of failed-j/

automatic actions and other control actions performed in the control room may not be particularly helpful to the operators.

Section 4.1.5 allows as many as three direct objects in a string. This was not done in the E0Ps and the Writer's Guide should not allow it.

No more than twe direct objects should be permitted in a string; if there are more than two., they should be listed.

Examples of. acceptable logic statements should be provided in Sect. ion 4.4.

Particularly needed are:

an example of the acceptable use of "AND" and "0R" together (section 4.4.1);

an example of list format for combinations of multiple conditions (Section 4.2.2.1); and an example of the use of

"IF NOT" (Section 4.4.2.5).

Section 4.4.2.1 allows up to three conditions connected by

" AND."

The limit should be two. Any more than two should be presented in a list format.

An example of this is needed.

Section 4.5 addresses cautions and notes. This section did not clearly define the content of a caution. Also, the-inclusion of step instructions in a caution was not prohibited.

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Guidance on these points should be added.

Section 4.5.2 states that a note should be placed after a step if the note " pertains to the results of the performance of a step." This statement should be deleted from the. Writer's Guide.

The intent of the statement was unclear, and inconsistent with standard principles of procedure writing.

No examples of a note after the step to which it applies were found in the E0Ps.

The Writer's Guide should state that each caution and note should address only one topic.

The Guide should also state that notes and cautions were not to be typed in all caps.

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text capitalization should be used.

Problems in these areas were not found in the E0Ps, but guidance on these points could prevent future problems.

Section 5.2.2.1 should be omitted since numbers above 9 should be shown in numerals, not compound words.

Section 5.6 on abbreviations, symbols, and acronyms should refer to and require conformance with a definitive, controlled list.

A' SNUPPS Abbreviation List, Controlled Drawing No.10466x-j-2 4018,

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had been issued to govern nameplates on the main control board and the auxiliary shutdown panel, annuciator tile legends, and B0P computer point descriptions. APA-ZZ-00300 was the procedure

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that controlled identification of plant equipment.

These

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documents were fairly consistent, but there were differences between them in abbreviations and acronyms. One controlled

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list should govern the nomenclature used in the control room and in the plant, and the E0P Writer's Guide should refer to

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and require use of that list for component identification in E0Ps(andotherprocedures).. The Writer's Guide referenced APA-ZZ-00300, Attachment 1 in a note, but did not require

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conformance with this list. -The Writer's Guide did not mention

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the SNVPPS Abbreviation List, which was said to govern control room labeling, Discrepancies between it and the E0Ps could potentially cause confusion.

.t Section 6.0 provided guidance on the typing format for the E0Ps.

It would be helpful to add to this section guidance on the breaking of steps and substeps, and guidance prohibiting the breaking of cautions and notes, and guidance on the separation of cautions and notes from the steps to which they apply.

The indentions used in typing the E0Ps sometimes resulted in very limited line space for step instructions, especially in RNO substeps. This lead to the need to split RNO actions between pages. This may be particularly undesirable when a substep is split between two pages or when an-RNO action is separated from the Expected Response it is intended to achieve.

Consideration should be given to changing the indention format to reduce the need to carry over steps and substeps.

Attachment 3 illustrated the format for the " Purpose and Symptoms or Entry Conditions" page. There was an error in the illustration; it indicated that Attachments were listed on that page.

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Attachments 2 through 6 would be more useful to a procedure writer if they were completed examples, showing content.

In their present form, these attachments were primarily useful for word processing.

(3) Ongoing Evaluation of the Emergency Operating Procedures A review of the Callaway system for ongoing evaluation and revision of the E0Ps was conducted to assess whether the

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licensee's current system could ensure high quality E0Ps over time. This review addressed the following elements of

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an effective program for continuing E0P management:

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Adequate documentation of the bases for procedure

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technical content, kept current as changes and revisions-e

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to the E0Ps were made.

An E0P Writer's Guide to ensure the written adequacy

and consistency of revision, and changes to the E0Ps.

• Processes for ensuring that changes in plant and control room design, technical criteria and guidelines, referenced procedures, and job aids were evaluated for impact'on E0Ps and that the necessary E0P changes were made in a timely manner.

• A verification program to ensure that E0P revisions and changes were consistent with (1) current technical guidance and criteria; (2) Writer's Guide requirements; and (3) plant and control room design characteristics.

• A validation program to ensure that revised E0Ps could be performed effectively by the operating shift teams to respond to emergency conditions.

Sufficient, timely training as appropriate for.all members of the operating shift teams.

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a process for feedback and resolution of E0P questions, problems and recommendations for improvement based on E0P use in training and operating experience.

g Most of the elements-of an effective program for ongoing

- evaluation of the E0Ps were found to be in place at Callaway, Corrective actions were found to be completed or in progress for several program weaknesses identified in a previous NRC audit and an internal E0P. audit conducted by Callaway QA in July 1989 (see Paragraph 5).

(a) Control Over the E0P Revision and Change Process One of the previously identified problems was a deficiency in the control of the Procedure Generation Package (PGP).

To correct this deficiency, the licensee was preparing a new Emergency Operating Procedure Generation Package. The licensee stated that Tehe licensee stated that the new PGP would be issued as an administrative procedure, which was

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expected to be completed by June 30, 1990. This document would define the requirements for all revisions to the E0Ps. The draft document was reviewed by the inspectors to verify that it adequately specified the processes for E0P revision.

The following needs for improvement in the January 1990 draft PGP were identified:

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.The most significant omission in the draft PGP had to do with the requirement for control room and plant walkdowns of E0P revisions. Any significant revision should be walked down in the control room, the plant, or both as applicable. Criteria for when a walkdown would be required should be stated. Many of the discrepancies. identified in the Callaway QA audit and in the E0P inspection could have been corrected before Revision IA was approved and issued if thorough walkdowns had been conducted.

It was also imperative-that referenced procedures-be included in the verification and validation program,

The draft PGP permitted tabletop review as a method of validation.

Since the objective of validation was to ensure the performance effectiveness of the E0Ps, tabletop reviews did not appear to be appropriate.

• The guidance on both verification and validation needed to be made more explicit. Checklists should be provided to ensure that the reviewers who participate in these tasks consistently cover the issues that-should be addressed in verification and validation.

This should include an assessment of potential impact of post-accident environmental conditions on operations.

• The new PGP would be used in conjunction with several

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existing administrative procedures, including:

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APA-ZZ-00101, " Preparation, Review, Approval and

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Control of Procedures"; and APA-ZZ-00102, Emergency

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Operating Procedures Writer's Guide." There was

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potential for gaps and' ambiguity because the applicable -

guidance was distributed in three primary documents.

The licensee should ensure that all of these procedures

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refer to each other as necessary; that they do not i

contain conflicting guidance; and that together they-provide clear and complete guidance for E0P revision.

This need was particularly important for the

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relationship between APA-ZZ-00101 and the new PGP.

APA-ZZ-00101 did not make clear that there were special requirements for emergency operating procedures (for example, in Sections 4.1 through 4.4).

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the draft PGP did not mention certain requirements specified in APA-ZZ-00101, Section 5.1, that would

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seem to be applicable to preparation of an E0P revision as well as any other procedure revision.

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The draft PGP stated only that E0P revisions would

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be' reviewed according to APA-ZZ-00101. As'another example of inconsistency, APA-00-00100 stated a

(Section 4.2.1) that " Procedures will be approved...

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in accordance with APA-ZZ-00101 or APA-ZZ-00102,...

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prior to implementation." APA-ZZ-00102 did not say anything about the approval process.

Further, the guidance in APA'ZZ-00101 was inadequate for E0P review and approval because it did not mention the special-verification, validation, and documentation requirements associated with E0P revisions.

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Section Four of the draft PGP discussed

. verification / review of E0P revisions without mentioning the Qualified Reviewer Program. The licensee should

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ensure that PGP Section;Four be consistent with the'

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guidance in Section 5.2 of APA-ZZ-00101 or that the exception for E0Ps be noted in APA-ZZ-00101 and reference made to the source of complete guidance for'

s E0Ps. The administrative procedure on Qualified Reviewer Training also did not mention'the:special requirements for review of E0Ps. The licensee should evaluate the need for this and the need to address.

E0P review specifically in Qualified Reviewer. Training.

• The draft.PGP did not contain a section that defined responsibilities for E0P revisions and changes.

This should be added.

In preparing this'section, the licensee should consider the. possibility that the E0P-Coordinator and the E0P writer may not always be the same person.

Responsibilities-for verification and i

validation should be included in this section.

Issuance of the PGP as a controlled document addressing these concerns will be tracked as an open item

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(483/89024-02).

(b) Documentation of Technical Bases The draft PGP required that documentation be maintained of any " technical deviation" from the Westinghouse Emergency Response Guidelines (i.e., any deviation which

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changed _the intent of an ERG step). The PGP also required

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that documentation be maintained to identify the sources of plant specific values used in the E0Ps, including those which were asked for by the ERGS and other specific values in the E0Ps.

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. (c) Processes for Ensuring that Changes in Design, Technical Criteria, and Referenced Procedures are Reflected in the E0PS F

Procedurally controlled processes existed to ensure that-r; changes which could affect E0P requirements would be

evaluated and that the necessary E0P changes would be made in a timely manner.

For design modifications, these processes were specified in Engineering Department Procedures. APA-ZZ-00108,

. Revision 4,-provided for review'of procedure impacts of changes / revisions to " primary licensing documents"

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(e.g., FSAR, Technical Specifications, etc.). A Reference Tracking System had been established to ensure that changes to procedures were tracked and references among procedures were kept accurate, which was governed by APA-ZZ-00106.

(d) Training The interviews conducted with control room personnel and equipment operators indicated that improvements were made in E0P training during the past year.

However, both.

groups indicated that they-felt more in-depth training was required.

Control room personnel indicated that requalification training had not been sufficient to become thoroughly familiar with all procedures in the E0P set, especially the ECA, FR and ES_ series.

Equipment operators wanted more training time in general (they may be assigned to other tasks during allotted training time) as well as more-familiarization with the E0P strategy / concepts and task requirements specific to E0Ps.

The equipment operators who were interviewed and participated in walkthroughs considered the recently introduced Job Performance Measures valuable.

Several said that they would like

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opportunities to observe E0P exercises on the-simulator.

(e)

F_eedback and Resolution on Questions, Problems, Suggestions Concerning the E0Ps Formal and informal methods were found to exist for Operations and Training personnel to ask questions, identify problems, and suggest improvements to the E0Ps. These methods were concluded to be working adequately.

4.

Training and Qualification Effectiveness Naining issues identified during this inspection are discussed in bragraphs 3.c.(2), 3.c.(3), and 3.d.(3)(d).

In summary, the inspectors

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The resolution of'the training issues will be tracked as an open item (483/89024-03).

5.

Quality Verification Effectiveness Prior to July 1989 only one limited scope surveillance of the E0P program had been performed. This surveillance was restricted to determining if aa open item resulting from a NRC inspection (Inspection Report 50-483/87019(DRS)) was being effectively addressed.

In July 1989, the licensee's QA organization performed a' comprehensive audit of the E0P program. This audit was based on NUREG-1358,

" Lessons Learned from the Special Inspection Program For Emergency Operating Procedures," and NRC Temporary Inspection Procedure 2515/92

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(which was.used during this inspection).

The findings of this audit generally paralleled those of this inspection. Principal among these were:

-The Procedures Generation Package was not under formal control.

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Some plant specific parameters used in the E0Ps were not traceable to source documents.

No formal E0P training program existed for equipment operators.

Equipment designators used in the E0Ps and the equipment labels were not always consistent. Also, some location information was in error.

• Plant equipment needed more visable labelling.

Corrective actions were planned or in progress for all findings. The

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inspectors concluded that this audit had been very effective in i

identifying existing problems with the E0P program; however, considering the importance of the E0ps, more frequent independent assessment may appropriate.

6.

Open Items l

Open items are matters which have been discussed with the license which will be reviewed further by the inspectors or which involve some actions on the part of the NRC or licensee or both. The open items disclosed during this inspection are discussed in Paragraphs 3.c.(2),

3.d.(2)(a), and 4.

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Exit Interview-h The' inspectors met with licensee. representatives (denoted in:

Paragraph I) on February 2, 1990.

The inspectors summarized the purpose, scope,.and findings of the-inspection and the'likely r

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informational' content of the inspection report. The licensee- -

L acknowledged this 'information and. did not. identify any proprietary LF information.

Attachments:

Appendix A:

Description of Inspection Activities

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Appendix B:. Additional Comments from the E0p Inspection at Callaway

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Appendix A

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Description of Inspection Activities

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PROCEDURE NUMBER TITLE (1)

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(2)(3)-

E-0 Reactor Trip Or Safety injection (2)(3)

E-1 Loss Of Reactor Or Secondary Coolant s

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E-2 Faulted-Steam Generator. Isolation (2)(3)

E-3-Steam Generator Tube Rupture (3)

.ES-0.0 Rediagnosis ES-0.1 Reactor Trip Response (3)

ES-0.2 Natural Circulation Cooldown r

(2)

ES-0.3 Natural Circulation Cooldown With Steam Void In Vessel (with RVLIS)

ES-0.4 Natural Circulation Cooldown With Steam Void In Vessel (W/0 RVLIS)

ES-1.1 SI Termination ES-1.2 Post LOCA Cooldown And Depressurization (2)(3)

ES-1.3 Transfer To Cold Leg Recirculation ES-1.4 Transfer To Hot Leg Recirculation ES-3.1 Post-SGTR Cooldown Using Backfill

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ES-3.2 Post-SGTR Cooldown Using Blowdown ES-3.3 Post-SGTR Cooldown Using Steam Dump (2)(3)

ECA-0.0 Loss Of All AC Power ECA-0.1 Loss Of All AC Power Recovery Without SI Required

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ECA-0.21 Loss'0f A11 AC Power Recovery With

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SI Required

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(3)

ECA-1,1 Loss Of Emergency Coolant Recirculation ECA-1.2'

LOCA Dutside Containment (2)(3)

ECA-2.1 Uncontrolled Depressurization Of All-Steam

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Generators

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(3)

ECA-3.1-'

SGTR With Loss Of Reactor

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Coolant - Subcooled Recovery Desired

k ECA-3.2 SGTR With Loss Of Reactor

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Coo'lant - Saturated Recovery Desired

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ECA-3.3 SGTR Without Pressurizer Pressure Control

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FR-C.1 Response To Inadequate Core Ceoling FR-C.2 Response To Degraded Core Cooling FR-C.3 Response To Saturated' Core Cooling M

FR-H.1 Response To Loss Of Secondary Heat Sink FR-H.2'

Response To Steam Generator Overpressure

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FR-H.3 Response To Steam Generator High Level FR-H.4 Response To Loss Of Normal Steam Release Capabilities FR-H.5 Response-To Steam

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FR-I.1 Response To High, Pressurizer Level FR-I.2 Response To Low Pressurizer Level.

FR-I.3 Response To Voids In Reactor Vessel

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FR-P.1 Response To Imminent Pressurized Thermal Shock Condition FR-P.2 Response To Anticipated. Pressurized Thermal

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Shock Condition (2)(3)

FR-S.1 Response To Nuclear Power Generation l

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FR-S.2 Response To Loss Of Core Shutdown l

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FR-Z.1L Response To_High'

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FR-Z.2?

Response To High Containment Recire Sump' Level:

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1FR-Z.3 Response To High Containment Radiat1on Level'

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(2)i 0TO-ZZ-00001, Control-Room' Inaccessibility.

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Notes:

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' All E0Ps were reviewed during the desktop review describedLin Paragraph'3.c.(1).

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.(2) 'These'; procedures were walked down as described in

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1 sti Paragraph 3.c.(2),

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(3) lThese' procedures were exercised during the simulator

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scenar.ios' described in Paragraph 3.c.(3).

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Appendix B Additional Comments From The E0P Inspection at Callaway h

1.

Procedures

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E-2 - Faulted Steam Generator Isolation.

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Steps 1 and 4, RNO instructions-These instructions contained examples of potentially confusing and inconsistent use~of the term " manually." All local actions should be clearly and consistently identified as such, with plant component identification and location-information provided as required.

In the Callaway E0Ps, " manually" was typically used to describe control room actions to implement conditions that should have occurred automatically or were otherd se expected to exist.

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Step 3 RNO-A question was raised during the walkthrough about the intent'

of this step.

It was not c)nar what was to be done with the findings from substeps (1) - (8). Whatever the findings, you go to Step 5.

The

. assisting RO felt that the need/ reason for this RNO was unclear if there was no faulted steam generator and the MSIVs have been closed.

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Step 4.6-During the plant walkdown, the assisting E0 was uncertain of the' location of the.feedwater chemical injection valves.

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Step 5 RNO-During the control room walkdown, the assisting RO raised the question why it was necessary to manually switch to the alternate AFW

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supply when there was an automatic swapover on low suction pressure to the AFW pumps and an AFW actuation signal.

I Step 6.c-In substeps (1) and (2), the verb "open" should not be

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capitalized and underscored; it is not a logic term. Also, Table I was

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out of place; it should follow substep (2).

ES-0.2 - Natural Circulation Cooldown a

Note (4) preceding Step 1-This note was continuing /nonsequential step.

i Consider making it Step 2.

For example:

Monitor conditions for starting a Reactor Coolant Pump while continuing in this procedure.

IF conditions for starting an RCP can be established, THEN repeat Step 1.

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Step 11-This step required the use of Core Exit Thermocouple (CET) data.

The CET monitor was on a back panel of the control room. Operators stated

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.that the monitor was not working entirely properly; they said that there

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was' a-CRT display which did not work, but a printout of the temperatures could be obtained.

The update frequency for the data on the printout was

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questioned.

Operators also stated that this monitor was mostly used by engineering.

Instructions for use were observed to be written in marker pen inside the cabinet' door. CET data were available on the plant computer, but operations personnel stated that when a trip occurs, the computer could be-expected to lock up. Therefore, Step 11 tells the control room personnel to do something that they may not be able to do, at least not efficiently. The licensee should evaluate the'need to provide more reliable and convenient CET data, and resolve the problem of an E0P instruction-that may not be possible to follow.

ECA-0.0 - Lc5s of All AC Power

Step 5 of Attachment 9 - Reword to clarify that the reference to sections 5.1 and 5,2 refer to the NE procedure rather than the NB procedure.

(The current wording caused some confusion during the simulator scenarios.)

ERG step 22 checking containment radiation level was deleted because of power loss and online instruments would not be available. This step should be incorporated using an HP Tech and portable survey instrument to monitor the radiation level at the air lock door or equipment batch.

Step 23 - Consideration should be given to the alternative of filling the spent fuel pool via the ESW system as noted in Callaway's self-initiated " Safety System Functional Assessment."

Step 4-If an Equipment Operator had to locally start the turbine-driven AFW pump, some of the actions would be difficult to accomplish (especially step 4.a(2) because the valves were high and the equipment layout in the room was congested.

No battery pack emergency lighting was in the area. The licensee should evaluate needs to facilitate a local start of the pump.

• Step 8-Problems were identified with the molded case breakers listed in Table 1.

No indication of breaker position was provided locally. The assisting E0 said that there have been problems with these breakers not opening, and also some problems with them closing. The E0 said that the design concept was that breater position and movement could be indicated by feel; however, thf t -did not work very well.

The licensee was evaluating this problem and EOs have had training on operation of molded case breakers. However, the evaluation should consider needs for modification of the controls and addition of local indication.

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Attachment 5, Step 2-During the plant walkthrough the open and closed p

positions on the mechanical indicator on the valve for ESW Train B to VHS

_[ Step 2.a(1)] were not labeled. This was also the case for the valves identified in Steps 2.b(1) and 2.b(2).

The descriptive names for the valves identified in Steps 2.a(3) through 2.a(6) were insufficient. The assisting E0 said that at a minimum the valves in. items (4) and (6)'

should be identified as inner containment.-

E-ECA-1.2 - LOCA Outside Containment

Note Preceding Step 2-This note was not well placed; it applied to substep 2.b, which appeared on the next page. Also, the note contained

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step instructions. Some of the information in the note (the first two sentences) was redundant with information in substep 2.b.

The logic-l statement _(the last sentence in the note) could be added to substep 2.b..

i FR-H2 - Response to Steam Generator Overpressure i

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Step'3 - The wording of this step was awkward and could be confusing.

The wording should be simplified if possible. The term "affected SG(s)"

might be used to simplify the wording of this and subsequent steps unless this term could be misconstrued.

If the use of "affected" is not appropriate, consider the term "overpressurized SG(s)."

Caution Preceding Step 4-This was an example of a continuing step

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treated.as a caution. The caution did not fully specify what was to be done if the SG 1evel criterion was exceeded. One possible way of correcting this was to replace the caution with a monitoring step. The following illustrates one possible way to do this by inserting a new Step 4.

(The present Step 4 would become Step 5.)

4.

Monitor Narrow Range Level in the Affected SG(s) While Continuing with Step 5:

IF level increases to greater than 97% (86% FOR ADVERSE CONTAINMENT), THEN secure steam release path AND

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GO TO...,

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Step 4.d-Consider the need for a valve list. The assisting R0 said that there were approximately 10 valves for the steamline lowpoint drains to the condenser.

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ECA-0.1 - Loss Of All AC Power Recovery Without SI Required

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'The note preceding step 4b of attachment 6 should be a caution since it warns of potential equipment damage.

E,S-1.3 - Transfer To Cold Leo Recirculation

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Step 5 - The criteria for aligning containment spray should be given

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rather than state "if necessary."

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OTO-ZZ-00001 - Control Room Inaccessibility

The following discrepancies between procedure designators and component labelling were identified:

Component Procedure Breaker Load Label Designator NG03C AL-HV-36 Supply from.

CST to EF4 Condensate TDAFP valve NG04C-BG-HV-8105 PDP Discharge PDP Discharge EF4

.to RCS Valve to Regen HX

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e NG04C-BB-HV-835]A Seal Water Seal Water DFS Injection to RCP A Isv NG01B EJ-HV-8809A RHR to RHR to-CR1 Cold Leg Isv Acc Inj Loop

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1&2 NG01B EJ-HV-8716A RHR cross RHR Train A ERI Connection Hot Leg Valve Recirc V NG01B BB-HS-8000A BB-HS-8000C BR3 NG02B BB-HS-80008 BB-HS-8000D DF1 Attachment 3, Step '1.3.6.1-The instruction was to " Verify the yellow CHGD indicator is present at position window," It did not say what to do if the CHGD indicator was not present. The assisting RO said that this step was not necessary because the breaker closing springs must be charged to

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close the breaker (cover in Step 9) but not to open it.

The assisting RO thought Step 1.6.3.1 could be confusing.

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' Attachment 3 StepsLI.11 and l'.12-These steps instructed the RO to ensure a

that NG02 and NG04 feeder breakers were closed.

The assisting R0 said

.that if'those. breakers were not closed, the person performing this

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attachment should' call the Shift Supervisor for authorization to close them: The need to state this should be evaluated.

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Attachment 3, Step 1.13-This step instructed the R0 to position three valves.

There were no lights on the panels to indicate valve position.

The need for valve position indication on NG02A, HF2, HF3, and FF4 should.

be evaluated.

• Attachment 3, Step 3.1-Instead of saying " perform the following" for the breakers listed below, it would be better to state the steps to.be

. performed (3.1.1 through 3.1.3.3).

The present wording is vague.

Attachment 3, Step-3.1.3.1-The need for this step should be evaluated.

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The same comments apply to this step as stated for Step 1.3.6.1 above, except that in this case there was an instruction about what to do if the yellow CHGD indicator is not present.

Attachment 3, Step 4.1.3-The note preceding the list of breakers told

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the operator to " Allow time for BN-LCV-112E and BB-LVC-112C to stroke to

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the desired position prior to opening breaker." There was no indication of the position of those two valves.

The need for position indication or information about stroke time should be evaluated. Also, the note should precede Step 4.1.3 instead of being inserted in the middle of the step instructions; and the last phrase should read " prior to opening the breakers listed in Step 4.1.3."

One other comment was that this note should perhaps be a caution.

Attachment 3 General-This attachment required operation of molded case breakers. There was-no indication of breaker position or power to the breakers. As discussed in the comments on ECA-0.0, problems have been experienced with the operation of these breakers.

• The organization / format of Attachment 3 could be confusing.

In particular, there was a need to evaluate step 4.1.3.1 and its relationship with Steps.6,0 and 7.0.

Attachment 10 - the operator may have to climb over the top of the diesel generator to reach the second manual air start control valve.

A. handle was needed to use this valve to start the diesel.

The attachment (Step 1.2.4.2) implied that a handle was attached to the side of the valve, but there was none. The operator would have to get the handle attached to the first manual air start control valve and take it with him. A handle at the second valve should be provided if possible.

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A question was' raised about why Step 1.2.5 would not be performed as the first

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alternative before Step 1.2.3 or Step 1.2.4.

The reasons for this should be made clear in-training.

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2, Valve Location e

The equipment operators had difficulty in locating the following valves (location information was not given in the procedure).

c Procedure Valve ECA-2.1 BIT Outlet Iso

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Step 18 Valves:

EM-HIS-8801A

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EM-HIS-8801B.

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BIT Inlet Iso valves:

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EM-HIS-8803A EM-HIS-8803B ES-1.3 SI Pump Recirc to Step 13 RWST valves:

EM-HIS-8814A EM-HIS-88148 RHR Hot Leg Recirc_ Valves:

EJ-HIS-8716A EJrHIS-8716B FR-S.1 Reactor MV WTR BA Step 7a Blending Tee:

BG-FCV-111A

- E-1 RHR to SI Pump Attachment 5 B Suction:

Step 3 EJ-HIS-8804B 3.

Emergency Lighting

No battery powered emergency lighting could be identified in the SI and

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CCP pump rooms 1113 and 1114 or in the BTRS valve room.

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