ML100150069

Supplemental Information Related to the January 6, 2010 Braidwood Station Regulatory Conference

ML100150069
Person / Time
Site:	Braidwood
Issue date:	01/14/2010
From:	Shahkarami A Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
BW100007, EA-09-259, IR-09-007
Download: ML100150069 (62)

Text

January 14, 2010 BW100007 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Unit 1 Facility Operating License No. NPF-72 NRC Docket No. STN 50-456

Subject:

Supplemental Information Related to the January 6, 2010 Braidwood Station Regulatory Conference

References:

1) Letter from Steven West (U. S. NRC) to Charles G. Pardee (Exelon Generation Company, LLC), "Braidwood Station, Unit 1, NRC Follow-up Inspection Report 05000456/2009007; Preliminar/ Yellow Finding," dated November 30,2009

2) Letter from Amir Shahkarami (Exelon Generation Company, LLC) to U. S.

NRC, "Response to NRC Follow-Up Inspection Report 05000456/2009007,"

dated December 10, 2009

3) Letter from David Gullott (Exelon Generation Company, LLC) to U. S. NRC, "Submittal of Supporting Documentation for January 6, 2010 RegUlatory Conference," dated December 30,2009 In Reference 1, the NRC issued a preliminary Yellow finding for the June 24, 2009 failure of the B Train Containment Sump Suction Valve (Le., 1S18811 B) to stroke full open during surveillance testing.

In Reference 2, Exelon Generation Company, LLC (EGC) requested a Regulatory Conference to present facts and assumptions used to assess the finding and its significance. As a result, a Regulatory Conference was held on January 6, 2010, at the NRC Region III Office. Information from Reference 3 was presented and discussed. During the Regulatory Conference, the NRC requested additional information by January 15, 2010, to support their review. In addition, EGC is providing information to further clarify material presented during the Regulatory Conference.

Attachments 1 through 4 to this letter provide the NRC with the supplemental information.

In preparing the information for this submittal, EGC identified an error in the calculation of the fire contribution to the core damage frequency (CDF) presented at the RegUlatory Conference.

The error was introduced by the software used to calculate the fire risk. The software vendor has been informed, and this issue has been entered into the EGC corrective action program. In a telephone call between Amir Shahkarami (EGC) and Steve West (U. S. NRC) on January 14, 2010, it was concluded that the NRC will not need the values for the change in CDF to support their review.

January 14, 2010 U. S. Nuclear Regulatory Commission Page 2 The attached information pertaining to local valve operation does not impact the evaluation results previously submitted for NRC review in Reference 3 and supports the information EGC presented during the Regulatory Conference. Specifically, Operations personnel have the required training and procedures to respond in a timely manner to a failure of an Sl8811 valve to fUlly open. Credit for local operator action is appropriate since the valve is accessible under the postulated conditions and sufficient time is available to take the required actions, which are procedurally directed.

During the Regulatory Conference, it was implied that EGC was selectively using less conservative alpha factor data for the Braidwood 1SI8811B SDP evaluation. As stated in the response to NRC Request 6 in Attachment 1, all data used was consistent with the PRA model of record to ensure the validity of the SDP (I.e., no data was selectively used to favorably influence the SDP evaluation).

There are no regulatory commitments contained in this letter.

Should you have any questions concerning this letter, please contact Mr. David Gullott, Regulatory Assurance Manager, at (815) 417-2800.

Respectfully, Amir Shahkarami Site Vice President Braidwood Station Attachments:

1. Supplemental Information Related to January 6, 2010 Braidwood Station Regulatory Conference

2. BwAP 340-1, "Use of Procedures for Operating Department"

3. "Effects of Hot and Cold Temperature Exposure on Performance: A Meta-Analytic Review"

4. Excerpt from NRC Letter Dated October 31, 2007 cc: NRC Regional Administrator, Region III NRC Project Manager, NRR - Braidwood Station NRC Senior Resident Inspector - Braidwood Station

ATTACHMENT 1 Supplemental Information Related to January 6,2010 Braidwood Station Regulatory Conference During the Regulatory Conference held January 6, 2010, the NRC requested that Exelon Generation Company, LLC (EGC) provide additional information to support their review. In addition, EGC is providing information to further clarify material presented during the Regulatory Conference.

NRC Request 1:

When the 1S18811B valve was manually opened and timed on November 3,2009, what impact did the previous June cycling and maintenance have on the time recorded? What is being credited or what assumptions are made for maintenance activity impact? What was the condition of the 1SI8811 B valve during the exposure time?

Response 1:

1. When the 1SI8811 B valve was manually opened and timed on November 3, 2009, what impact did the previous June cycling and maintenance have on the time recorded?

When the 1SI8811 B valve was manually opened by an operator on November 3, 2009, the impact of the water intrusion and preconditioning from the June maintenance activity on the opening time would be minimal. Degradation of the valve stem or actuator stem nut due to the presence of water would not be expected due to the corrosion resistance of the component materials. Degradation of the valve stem grease would also not be expected due to the water resistance of the grease on the valve stem and actuator stem nut.

Stem grease condition (grade) and opening forces determine the required actuator (handwheel) torque to open the valve. The valve stem for valve 1SI8811 B is lubricated on a 36 month frequency. The valve stem of valve 1SI8811 B was lubricated in accordance with Work Order (WO) #804743 on May 17, 2006. Following the failure to open on June 24,2009, the stem was again lubricated in accordance with WO #1084024. In accordance with this WO and procedure MA-AA-723-301, "Periodic Inspection of Limitorque Model 5MB/SB/SBD-OOO through 5 Motor Operated Valves," the as-found stem lubrication was graded prior to cleaning and relubrication.

The WO documents that the as-found grease grade was 2 on a scale of 1-5 (I.e., grade 1 being stem clean, well lubricated, no recommended actions and grade 5 being stem dry, wear particles visible, actions required). In accordance with the grading scale, a grease grade of 2 indicates that the stem thread area is clean and the lubricant appears to be aged but retains lUbricating properties. The valve was manually stroked with the handwheel during the stem lubrication process with no anomalies being noted. FollOWing stem lubrication, the valve was diagnostically tested during electrical operation and all parameters were acceptable. The stem coefficient of friction was measured during testing and was in the normal range indicating no degradation of the stem or stem nut.

2. What is being credited or what assumptions are made for maintenance actiVity impact?

An analysis of Diagnostic Testing data for the 1(2)SI8811A1B valves was performed utilizing the MOV Integrated Data Acquisition System (MIDAS) testing database. Table 1 provides a summary of the analysis for data collected between 2006 and 2009.

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ATTACHMENT 1 Supplemental Information Related to January 6,2010 Braidwood Station Regulatory Conference Table 1: MIDAS Analysis of 1(2)SI8811A1B Diagnostic Testing Data Measured Avg.

I

}

Measured Handwheel Valve Diagnostic Avg. Open Test Date Open Run Torque '*

EPN Test Type Run Torque Force (ft-Ibs)

(ft-Ibs)

(Ibs) 1818811A

• As-Found 11/02/2007 3444 91 13.6 1818811A 1818811B As-Left As-Left

= 11/02/2007 06/25/2009 3388 4507 91 101 13.6 15.1 1818811B As-Left 05/17/2006 4444 97 14.5 2818811A As-Found 11/17/2006 4123 114 17.0 2818811A As-Left 11117/2006 3992 86 12.9 2818811B As-Left 05/04/2008 3932 83 12.4 2818811B As-Found 11/15/2006 2958 80 12.0 2818811B As-Left 11/15/2006 3348 81 12.1 Average As- Found 3508 95 14.2 Average As-Left I 3935 90 13.4 Average All Tests 3793 92 13.7

• Determined using run torque and Limitorque standard handwheel equation The above data incorporates as-found (pre-lubricated stem) and as-left (post-lubricated stem) diagnostic testing data during electrical operation. The as-found data indicates that for the group, the 2818811A valve exhibited the highest opening torque of 114 ft-Ibs (17 ft-Ibs handwheel torque) and was only slightly greater than the opening torque measured during the June 25, 2009 diagnostic test of the 1818811 B valve of 101 ft-Ibs (15.1 ft-Ibs handwheel torque).

The measured opening torque during the diagnostic test would be similar to the opening torque during the manual opening time test performed on November 3,2009. The 2818811A valve also exhibited the greatest change in torque between as-found and as-left tests. This change was 28 ft-Ibs (Le., 114 ft-Ibs - 86 ft-Ibs) of actuator opening torque or 4.1 ft-Ibs (Le., 17 ft-Ibs - 12.9 ft-Ibs) of handwheel torque. This data indicates that the handwheel torque change for both extreme cases is very small. This small change is due to the mechanical advantage of this actuator's handwheel assembly. These small changes in handwheel torque would have a minimal effect, and would not significantly alter the manual opening time measured on November 3, 2009.

3. What was the condition of the 1818811 B valve during the exposure time?

The design of the 1(2)818811A1B valves is that the torque switch is bypassed for the first 30 to 40 percent of open travel. The 1818811 B valve would have traveled to approXimately 34 percent open prior to the torque switch affecting the open electrical stroke logic and stopping valve travel.

Following the1818811B valve failure to open on June 24,2009, further stroking of the valve was not attempted in the degraded condition. Additional stroke attempts following failure to fully stroke can lead to loss of critical data when attempting to determine the failure cause. In this case, the torque switch and upper and lower limit switch finger bases were replaced. Both of these components are reliable and would not affect the valve or actuator performance in the Page 2

ATTACHMENT 1 Supplemental Information Related to January 6, 2010 Braidwood Station Regulatory Conference electrical or manual modes of operation. During this maintenance activity a stem lubrication was also performed based on the frequency of this activity coming due. The valve was stroked with the handwheel during the stem lubrication process with no anomalies being noted. An as-left diagnostic test was performed in accordance with WO #1245941 following this maintenance.

The results indicated that there were no performance changes with the valve or actuator, and all acceptance criteria were met.

NRC Request 2:

Under emergency conditions, would the operators attempt to cycle the 1Sl8811 B valve closed using the Control Room handswitch based on seeing dual indication?

Response 2:

Under emergency conditions, the operators would not use the Control Room handswitch to cycle an S18811A1B valve closed. The action to open an S18811A1B valve is clearly written in procedures; therefore, operators would not attempt to cycle the valve to the closed position.

In addition, none of the operators interviewed determined that procedure guidance allows closing a valve that should be open, and no crew attempted to close a failed 1S18811A1B during the training scenarios. None of the operators interviewed thought that trying to close a valve that should be open would be allowed by procedures, or should be attempted by the crew.

Operators interviewed thought that a crew would be within procedural guidance to take the Control Room handswitch for a failed valve to the open position to attempt to place an automatic valve in the required position; however, no simulator crews attempted to open the failed 1S18811A1B valve from the Control Room until directed by the 1BwEP ES-1.3 procedure.

Applicable procedure guidance is provided in Attachment 2, BwAP 340-1, "Use of Procedures for Operating Department," Step C.3:

C. 3. Prudent Operator Actions

a. Prudent Operator Actions are actions taken during a transient or emergency condition without explicit procedure guidance including

3) Performing necessary actions to manually duplicate an automatic actuation that has failed to automatically occur.

b. In deciding if taking prudent action is appropriate, the following elements should be considered as a whole:

3) SRO concurrence should be obtained prior to performing the action, with the exception of time critical actions such as isolating a failed open pressurizer PORV or taking manual control of a FW Reg valve to restore Page 3

ATTACHMENT 1 Supplemental Information Related to January 6,2010 Braidwood Station Regulatory Conference steam generator level. This will give the Control Room team a chance to determine if the proposed action is appropriate.

The procedural gUidance noted above is utilized and reinforced in training to ensure actions taken are consistent with the intent of the emergency operating procedures. There are only procedure steps to get an S18811A1B valve open and taking an S18811A1B Control Room handswitch to the close position would not be an allowed operator action.

Additionally, when the 1SI8811 B valve failed at the 34% open position, the valve could not have been manually repositioned using the Control Room handswitch until the 1SI8812B had been closed due to the electrical circuit design. This system interlock, however, does not prevent local manual operation. As noted from previously run simulator scenarios, no crew attempted to close an S18811A1B or open it until directed by procedure.

At the Regulatory Conference, it was noted that Joseph M. Farley Nuclear Plant (Farley) recovery actions involved repeated attempts at cycling the valve, closed to open, by use of the Control Room handswitch. At Braidwood, this action is prohibited by procedural guidance and as demonstrated by crew scenario performance, is not expected to occur. In addition, due to the S18811A1B valve electrical circuit design, the valve would not respond to the Control Room handswitch while in mid-stroke (Le., dual indication). Braidwood has procedural guidance for locally opening the SI8811 AlB valve in accordance with 1BwCA-1.1, "Loss of Emergency Coolant Recirculation," whereas local operation of the valve was not possible at Farley.

NRC Request 3:

What is the correlation for Refueling Water Storage Tank (RWST) level in feet to RWST level in percentage?

Response 3:

RWST Alarm Setpoint Levels in Percentage HIGH Level Alarm =96.0%

LOW Level Alarm =90.0%

LO-2 Level Alarm =46.7%

LO-3 Level Alarm =12.0%

Empty Level on Indicator =9%

Bottom of RWST Tank = 401.667 feet

=

Ratio of feet I % level 0.54833 ft I %

RWST Alarm Setpoint Levels in Feet {Reference to Plant Elevation}

HIGH Level Alarm =454.31 feet LOW Level Alarm =451.02 feet LO-2 Level Alarm =427.27 feet LO-3 Level Alarm =408.25 feet Empty Level on Indicator =406.60 feet Tank Bottom =401.67 feet Page 4

ATTACHMENT 1 Supplemental Information Related to January 6, 2010 Braidwood Station Regulatory Conference RWSTAlarm Setpoint Levels in Feet (Reference to Tank Bottom)

HIGH Level Alarm  :::: 52.64 feet LOW Level Alarm  :::: 49.35 feet LO-2 Level Alarm  :::: 25.61 feet LO-3 Level Alarm  :::: 6.58 feet Empty Level on Indicator  :::: 4.93 feet Tank Bottom  :::: 0.0 feet NRC Request 4:

Provide reference(s) to the published literature that support minimal temperature effects on valve manipulation.

Response 4:

NUREG/CR-5680, "The Impact of Environmental Conditions on Human Performance,"

September 1994, was pUblished as a reference handbook to be used by NRC inspectors to aid in determining the impact of specific environmental conditions on licensee personnel performance. The information provided in this document examines the effects of heat on mental and perceptual/motor tasks (e.g., the effects of heat exposure on physical tasks such as reading a gauge, calculating data, and making decisions). This reference document examines the effects on various populations of workers, including acclimated workers. Nuclear plant operators are in the category of acclimated workers.

The specific sections of this NUREG/CR evaluated in the EGC review of the impacts of heat on performance include Volume 1, Section 4.3, "Effects of Heat," Volume 2, Sections 5.5, "The Effects of Heat on Performance of Tasks," and Volume 5.6, "The Effects of Heat on Performance of Tasks in Nuclear Power Plants."

Additionally, NUREG-1852 "Demonstrating the Feasibility and Reliability of Operator Manual Actions in Response to Fire," October 2007, was reviewed. Section 3.2.3 of this NUREG references, "Effects of Hot and Cold Temperature Exposure on Performance: A Meta-Analytic Review," which is prOVided in Attachment 3.

These references support the conclusion that the local temperatures at the SI8811 valves during the dominant risk scenarios, combined with the duration of the actiVity, will not have a significant effect on the operator's ability to manually open a containment sump suction valve.

Therefore, EGC considers it reasonable that manual valve operation can successfully be performed and credited in the Significance Determination Process (SOP) evaluation.

NRC Request 5:

Provide fire contributions to the core damage frequency (CDF) for the dominant sequences.

Response 5:

Table 2 prOVides a list of the important fire areas and associated scenarios.

Table 2: Dominant Fire Scenarios Page 5

ATTACHMENT 1 Supplemental Information Related to January 6, 2010 Braidwood Station Regulatory Conference Zone Zone Description Scenario Initiator(s) 11.3-1 nit 1 Containment Pipe Penetration Area 1AP21 E (Bus 131 X1)

Division 11 Miscellaneous Electric Equipment Room 5.6-1 1DC05E And Battery Room 1AP1 OE (LVSG) and 5.2-1 Division 11 ESF Switchgear Room 1AP11 E (LCXFMR) 11.6-0 Auxiliary Building General Area, Elev. 426 1AP32E (Bus 132X5) 11.6-1 Division 12 Containment Electrical Penetrations Area 1AP28E (Bus 132X4) 1-1 Unit 1 Containment Bounding Fire 11.6-0 I Auxiliary Building General Area, Elev. 426 1AP16E (Bus 134X)

NRC Request 6:

Provide the basis for using 2003 data for the alpha factor in the Braidwood 1S18811 B SOP evaluation as opposed to 2007 data.

Response 6:

As provided prior to the Regulatory Conference, EGC performed a sensitivity evaluation, at the NRC's request, to selectively apply the NRC SPAR model "pooled MOV" alpha factor for the SI8811 valves. This is documented in Appendix J of BW-SDP-003. It was also noted in that Appendix that use of the current RH MOV values in the model is considered appropriate.

Selective use of a different data set (I.e., the 2007 CCF Parameter Estimates) challenges the validity of the SOP by changing both the Base COF and SOP evaluation results. This is particularly true if only one parameter (e.g., the alpha factor for the SI8811 valves) is changed.

In order to properly account for the 2007 CCF parameters, as noted in the ASME PRA Standard, a complete update of the PRA model would be required. EGC has an established PRA update process which includes an extensive update of PRA model data using the latest available information. This update process requires considerable effort (I.e., on the order of 500 to 700 person-hours) to ensure the model reflects the as-built, as-operated plant. This update would include all of the appropriate 2007 CCF parameters as well as an update to the single component failure probabilities, maintenance unavailabilities and initiating event frequencies. A sample of differences between the 2003 CCF information (published in May 2006) and 2007 CCF information (pUblished in September 2008) is provided in Table 3 below. It is observed that use of one value from the 2007 information would inappropriately bias the conclusion compared to the result if the entire model were updated to the new generic values.

Page 6

ATTACHMENT 1 Supplemental Information Related to January 6, 2010 Braidwood Station Regulatory Conference Table 3: Sample of 2003 Versus 2007 Alpha Factors tmrameter 2003 alpha factor d007 alpha factor Difference 1.58E-02 .05E-02 +93%

2/2 Sl MOVs 5.56E-02 2.83E-02 -49%

2/2 Pooled MOVs 3.55E-02 2.28E-02 -36%

2/2 AF Pumps FTS 5.43E-02 5.50E-02 +1%

2/2 AF Pumps FTR 1.59E-02 7.34E-03 -54%

2/4 EOGs FTS 1.09E-02 7.83E-03 -28%

2/4 EOGs FTR 1.65E-02 8.25E-03 -50%

4/4 EOGs FTS 1.65E-03 1.51E-03 -8%

4/4 EOGs FTR 3.62E-03 2.18E-03 -40%

2/2 pzr PORVs 5.52E-02 6.04E-02 +9%

As the Braidwood PRA model of record 60 is based on data available in 2006, use of the published CCF 2003 data for the SOP evaluation is the appropriate data set to use, as it is consistent with the other data parameters used in the model. Identification of the CCF readjustment was identified prior to use of the model for this application. Fidelity in the application of data within the model was the reason that the 2003 CCF factor was used in the base model prior to incorporation of the 1Sl8811 B boundary conditions.

Supplemental Information:

What is the impact on timing for local manual SI8811 valve operation from Radiation Protection (RP) requirements?

Response

EGC has performed a review of the Radiation Protection (RP) protocols under emergency conditions where expeditious manipulation of the 1SI8811 AlB valve is necessary. The actions are governed by procedures RP-AA-403, "Administration of the Radiation Work Permit Program," section 4.4 and EP-AA-113, "Personnel Protective Actions," section 4.2. These procedures require an RP technician to prescribe radiological controls (e.g., protective clothing and other measures) as described in section 4.2.1 of EP-AA-113. As stated in EP-AA-113, "The decision to utilize radiological controls that differ from standard Radiation Protection practices shall be documented in position logs." The review concluded that this guidance could be subject to interpretation for whether radiological controls are required for Operations personnel during an emergency. This issue has been entered into the EGC corrective action program.

Additional timing was performed by an operator who dressed out in cloth booties, outer shoe covers, cotton liners, and gloves. The total time, including stopping at 401 ft. elevation for dress out, from the Control Room to the SI8811 B valve local hand wheel was six minutes. The 7.5 minutes assumed in the original SOP evaluation was based on the timing of an RP escorted individual who had never been to Braidwood Station. Therefore, the original timing of 7.5 minutes is conservative and remains valid.

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ATTACHMENT 1 Supplemental Information Related to January 6,2010 Braidwood Station Regulatory Conference Supplemental Information:

Provide a comparison of the Braidwood 1SI8811 B issue to the 2007 residual heat removal (RH) containment sump suction valve Yellow finding at the Farley Nuclear Plant.

Response

In Reference 1, the NRC issued a preliminary Yellow finding to the Farley Nuclear Plant for a failure of the Farley Unit 2 SI8811A (Le., RH containment sump suction valve) to fully stroke open. In Reference 2, the NRC provided the final significance determination and Notice of Violation for the same event. EGC has reviewed the design, failure, and evaluations of the 2007 event described in References 1 and 2 and noted considerable differences compared to the event described in Reference 3 and as presented during the Regulatory Conference held January 6, 2010. The comparison of aspects and the differences between Farley and Braidwood are presented in Table 4.

Page 8

ATTACHMENT 1 Supplemental Information Related to January 6,2010 Braidwood Station Regulatory Conference Table 4: Comparison of Farley and Braidwood RH Containment Sump Suction Valve Issues Aspect I Farley Braidwood Impact on Braidwood Issue Valve Entire valve including Valve body Local manual operation accessibility handwheel encapsulated encapsulated only; available and credible (see schematic in motor operator and Attachment 4) handwheel accessible RH pump }:dequate NPSH with Sufficient NPSH with RH pump able to perform operation Ive 20% open valve 34% open function Exposure time 85.5 days 323.5 days Greater period of nonfunctionality Valve failure High humidity Water intrusion into Valve failed to stroke full mode environment within valve MOV torque switch open encapsulation; MOV compartment operational characteristic Common cause Licensee excluded; NRC Included by licensee Modeled using 2003 data failure included and NRC consistent with remainder of Braidwood PRA model Procedures for No EOP steps to restart No EOP steps to RH pump restart not credited RH pump RH pump restart RH pump if SI8811 not full open operation with dual SI8811 indication Procedures for No EOP steps for local EOPs direct operators SI8811 fully open with RH local valve valve operation to locally open valve if pump restarted operation valve fails to fully open Credit recovery No procedures for local Time available to Sufficient time and local of valve by local valve operation locally open 1SI8811 environment supports operation valve exceeds time recovery of valve by location required to perform the operation manual action and environmental conditions allow access to valve.

Actions performed by qualified operators are included in periodic training program, and have been validated by operator performance.

Use of Control Operators would perform Procedures direct use Higher reliability of valve Room mUltiple attempts to of Control Room being opened in expected handswitch to close/open valve using LilY open valve Control Room handswitch handswitch in open direction only and to dispatch an operator to timeframe locally open valve Page 9

ATTACHMENT 1 Supplemental Information Related to January 6, 2010 Braidwood Station Regulatory Conference Differences in operator actions associated with the failure of 1SI8811 B to open fully are discussed in further detail in Response 2. Contrary to Farley operator actions, Braidwood operators would not attempt to close the valve.

The circumstances surrounding the NRC enforcement decision taken in 2007 related to the failure of an SI8811 valve to stroke for Farley were reviewed for applicability to Braidwood.

While there are some similarities with the overall issue (Le., an SI8811 valve failed to stroke fUlly open upon demand) there are some key differences. These key differences, outlined in Table 4, are significant with respect to the likely outcome of an event in which an SI8811 valve fails to fUlly open and the corresponding SDP results. Specifically, Farley was given no credit for local manual operation of an SI8811 valve primarily due to total valve encapsulation (Le., the valve is not physically accessible). Whereas, the Braidwood SI8811 valves, are physically and environmentally accessible and, are procedurally directed to be manually operated, either by the Control Room handswitch or locally, by trained operators until fully opened.

References:

1) Letter from Joseph W. Shea (U. S. NRC) to Mr. J. Randy Johnson (Southern Nuclear Operating Company, Inc.), "Joseph M. Farley Nuclear Plant - NRC Special Inspection Report 05000348/2007009 and 05000364/2007009; Preliminary Yellow Finding," dated August 2,2007

2) Letter from William D. Travers (U. S. NRC) to Mr. J. Randy Johnson (Southern Nuclear Operating Company, Inc.), "Final Significance Determination for a Yellow Finding and Notice of Violation (NRC Inspection Report Nos. 05000348/2007011 and 05000364/2007001, Joseph M. Farley Nuclear Plant)," dated October 31,2007

3) Letter from Steven West (U. S. NRC) to Mr. Charles G. Pardee (Exelon Generation Company, LLC), "Braidwood Station, Unit 1, NRC FOllow-up Inspection Report 05000456/2009007; Preliminary Yellow Finding," dated November 30,2009 Summary:

The information provided during the January 6, 2010, RegUlatory Conference and further discussed in this letter demonstrates that sufficient time exists and that the plant design and local environment supports operator access; therefore, the recovery of the 518811 AlB by local manual operation should be credited in the NRC's SDP evaluation for Braidwood.

Page 10

ATTACHMENT 2 BwAP 340-1 Use of Procedures for Operating Department

BwAP 340-1 Revision 24 Information Use USE OF PROCEDURES FOR OPERATING DEPARTMENT A. STATEMENT Of APPLI{.fABILITY The purpose of this procedure is to provide operators with general information on how to use Operating procedures and detailed information on how to use the Emergency/Abnormal procedures.

B. REFERENCES

1. Braidwood Procedure Generation Package - Abnormal and Emergency Operating Procedure Writers Guide.

2. SwAP 340-1T1, SwST Log.

3. Westinghouse Owner's Group Emergency Response Guidelines.

4. ANSI 18.7 (1976).

5. NUREG 0899, (1982).

6. HU-AA-104-101, Procedure Use and Adherence.

7. OP-AA-108-108, Unit Restart Review.

1

BwAP 340-1 Revision 24 Information Use

c. MAlNBQ~

1. General Information NOTE It is recognized that procedures cannot (and should not) be specifically written for every contingency. If an approved plant procedure does not exist which applies to the current situation, personnel are instructed to take action so as to minimize personnel injury, damage to the facility, and to protect health and safety of the general public and the personnel onsite.

a. Due to the large number of procedures, which vary widely in compleXity and impact, it is recognized that their content must be retrieved on differing bases:

1) Immediate Operator Actions as designated in the procedure, must be committed to memory by all licensed operators.

2) _BwGPs must be immediately present as they are used, and the steps signed off on the flow chart as the steps are performed.

3) Other procedures will be used as directed by the designated level of use following the guidance in HU-AA-1 04-1 01.

b. BwOPs are written to support all other plant procedures. BwOPs are generally not written to be UNIT specific, although on occasion due to system modifications it may be necessary to make them so. When a BwOP needs to be UNIT specific the BwOP procedure number will remain the same but will have an a or b added immediately to the right of the number.

EXAMPLE: BwOP XX-1a, Startup of UNIT 1 Equipment BwOP XX-1b, Startup of UNIT 2 Equipment The UNIT number will be placed in the title and all references in the main body of the procedure will be made UNIT specific when a UNIT specific procedure is needed.

c. In the event a BwOP is entered from a BwEPIES, BwOA. BwCA. or BwFR, and the BwOPs PrereqUisites, Precautions, Umitations and Actions, and/or procedural steps cannot be performed as written or verified in a timely manner, the Shift Manager or designee SHALL have discretion as to what actions may be bypassed to achieve the purpose of the procedure in an expeditious manner.

2

BwAP 340~1 Revision 24 Information Use

c. 1. d. BwARs are used to assist the operator In responding to an alarm condition. They Include both specific and general inputs as to all possible causes of the off~normal condition.

2. Definitions:

a. Word Usage - Key words and definition

1) AT - "at a value" means closer to that value than to any other that can be reasonably read from the applicable scale.

2) CHECK - Note the condition of.

3) DISPATCH - Send an operator out to perform a task without waiting for completion of the task. The procedure Is continued.

4) FAULTED - i6fers to a steam generator that has a secondary break.

5) INTACT - Refers to a steam generator that Is not faulted, ruptured, or leaking and Is available as a heat sink.

6) LOCALLY - Operator action required In the plant, usually at the specific location.

7) MAINTAIN - Control a given plant parameter within the range specified. The use of the word MAINTAIN denotes a continuous action and Is not intended to create a hold point In the procedure.

Once the direction is given to MAINTAIN the specified parameter, performance of the procedure may continue.

8) MANUALLY - Operator action required, usually at the Main Control Board.

9) MAY - Denotes optional action.

10) MONITOR - Watch or observe a specified parameter at intervals designated or determined by the operator.

11) RUPTURED - Refers to a steam generator that has a primary to secondary break (SGTR), requiring safety injection.

12) SHALL - The action must be performed.

13) SHOULD - Denotes a management expectation.

3

BwAP 340-1 Revision 24 Information Use C. 2. a. 14) STABLE - To be within the normal control band OR within some desired range.

15) STEAM GENERATOR TUBE LEAK (SGTL) - Refers to a steam generator that has a primary to secondary break that does not require a safety injection.

16) UNCONTROLLED - Not under the control of the operator, and incapable of controlled by the operator using available equipment.

17) VERIFY - Confirm that an expected condition exists. If the condition does not exist, then perform actions to establish the condition.

18) GO TO or RETURN TO - Used to direct movement to different steps.

b. Various symbols used throughout operating procedures identify special situations. The symbol key is as follows:

1) 'III Placed in left hand margin or by a procedure title indicates a station commitment. The document to which the commitment was written can normally be found in the reference section of the procedure.

2) ¢ Placed in the margin or by a procedure step sign-off to indicate acceptance criteria (data or step that is required to be acceptable for the successful completion of the procedure).

3) Placed in the margin or by a procedure step to indicate administrative acceptance criteria. Administrative acceptance criteria is not required to successfully complete the surveillance, but does require corrective action. The corrective may include the initiation of an Issue or WR.

4) The low-level steps shall be designated by numbers or letters when their sequence of performance is important V\lhen the sequence of events is not important, the low level step shall be proceeded by one of the following bullets:

a)

• "Closed Bullet" indicates the step(s) MUST be performed (in any order).

b) o "Open Bullet" indicates the step(s) MAY (if applicable) be performed (in any order).

4

BwAP 340~1 Revision 24 Information Use

c. 3. Prudent Operator ActIons

a. Prudent Operator Actions are actions taken during a transient or emergency condition without explicit procedure guidance including:

1) Performing necessary actions where no procedure exists. If unforeseen circumstances arise that present Imminent personal injury, equipment damage, injury to the public or similar consequence, then actions outside of procedures may be taken, provided those actions are approved by the Shift Manager. The exception to the requirement for Shift Manager approval is action to prevent personal injury or to save a life.

2) During transients, actions required to place the plant in a stable condition may be performed from memory.

3) Performing necessary actions to manually duplicate an automatic actuation that has failed to automatically occur.

4) Performing manual action prior to an automatic Reactor Trip System actuation.

5) Performing manual action prior to an automatic Engineered Safety Feature actuation with SRO approval. (Exceptions: CS actuation and Manual SI actuation during an ATWS)

b. In deciding if taking prudent action is appropriate, the following elements should be considered as a whole:

1) Plant safety status should be maintained or enhanced. Prudent mitigative or preemptive action should not degrade plant status or put the plant in a less safe state or challenge it more than the initiating event It should not cause a RED or ORANGE path critical safety function condition.

2) Prudent operator actions should not interfere with the performance of Immediate ActIons.

3) SRO concurrence should be obtained prior to performing the action, with the exception of time critical actions such as isolating a failed open pressurizer PORV or taking manual control of a FW Reg valve to restore steam generator level. This will give the Control Room team a chance to determine if the proposed action is appropriate.

4) Any prudent operator action taken should be verified once the specific procedure is implemented.

5

SwAP 340-1 Revision 24 Information Use C. 3. b. 5) The licensee may take reasonable actions that departs from a license condition or a Technical Specification in an emergency when:

a) The action is immediately needed to protect the public health and safety, and b) No action consistent with the license condition and Technical Specifications that can provide adequate or equivalent protection is immediately apparent, and c) As a minimum a licensed Senior Reactor Operator has approved the licensee action prior to taking the action.

6) When an action departs from a license condition or a Technical Specification, initiate NRC notification.

BwAP 340-1 Revision 24 Information Use C. 4. Detailed Information (Emergency/Abnormal Procedures)

a. Definitions:

1) Emergency Operating Procedures (BwEfj

_BwEPs are a four procedure set that initiate operator action based upon either a reactor trip or safety injection. They provide for the diagnosis and mitigation of design basis events such as loss of coolant accidents (LOCA), steam generator tube ruptures (SGTR) and loss of secondary coolant (LOSC). The first BwEP LBwEP-O),

REACTOR TRIP OR SAFETY INJECTION is the entry point to all emergency procedures.

2) Event SPeCific SybDrocedures (BwEP ES)

If certain conditions are met or exceeded in the _BwEPs, the

_BwEP ES will direct actions to accomplish the given objective or supply new actions based on observed conditions. The _BwEP ES subprocedures are grouped under the appropriate _BwEPs.

3) Emergency Contingency Actions eBwCA}

_BwCAs are procedures which supplement both the _BwEPs and

_BwEP ES subprocedures by providing recovery actions for low probability or unique event sequences which can not be easily addressed in the _BwEPs and _BwEP ES subprocedures.

4) Abnormal OPerating ProcedUreS eBwOAl

_BwOAs provide guidance to the operator when important parameters or systems are in jeopardy, but a reactor trip or SI has not actuated.

5) Status Trees eBwST}

The _BwSTs are a set of six decision trees that evaluate the six critical safety functions to determine if the function is intact or being challenged. If challenged it will reference the restoration procedure for restoring the function.

6) Functional Restoration Pro<;§dures (BwER}

The _BwFRs direct operator actions to recover/restore the degraded safety function dependent on which CSF is challenged and the extent of degradation.

7) Critical safety Fynction (CSEl One of six functions necessary to ensure the integrity of the three "barriers" preventing the release of radiation. The six critical safety functions are monitored by the status trees and include sub criticality, core cooling, heat sink, integrity, containment, and inventory.

7

SwAP 340-1 Revision 24 Information Use C. 4. b. Two Column Format Use:

1) General The left hand column contains the "action" the operator is to perform, or the "expected response" the operator should see. This "action/expected response" column, contains both high level and low level actions. The high level steps describe 'what to do",

whereas the low level steps present the "how to do" information.

Most procedures have a "klck-ouf', which directs the operator to go to another procedure as conditions require, or as re-dlagnosls directs. The words "go to" will be used to direct the operator to leave one procedure and transition to another. This same mechanism will be used to direct movement to different steps In the same procedure, except when directed to retum to a step that has already been performed or passed over; the words "return to" may be used.

If an "action" in the 1111 hand column cannot be performed or an "expected response" cannot be obtained, the operator should go to the "response not obtained" column on the right hand side to get the required response or conditional action. The conditional action statements contain certain criteria which, If met, require execution of the "response not obtained" action statement. If the criteria is not met, the operator should return to the next step in the 1111 column unless directed otherwise. Unless otherwise specified, a required task need not be fully completed before proceeding to the next instruction; It is sufficient to begin a task and have assurance that it is progressing satisfactorily. This ensures efficient Implementation where steps are very time consuming. In certain cases, where local operator actions are required (outside the Control Roam), a NOTE may be added to reinforce this rule of procedure usage.

If a particular task myst be comPlete prior to proceeding, the step containing the task or an associated NOTE will explicitly state that requirement Transitions to other guidelines or to different steps in the same guideline may be made from either column.

8

BwAP 340-1 Revision 24 Information Use ACTION/EXPECTED RESPONSE NOT OBTAiNED

RESPONSE

Verify Reactor Trip: (Action) Manually trip the reactor (Contingency Action)

• Rod bottom lights - .L.!I (Expected Response) !E the Reactor will .t!QI trip, (Conditional ActIon Criteria)

• Reactor trip and bypass breakers - OpeN ltieN GO TO _BwFR-S.1, RESPONSE TO NUCLEAR (Expected Response) POWER GENERATION/ATWS, Step 1. (Conditional Action)

• Neutron Flux -

DROPPING (Expected Response)

C. 4. b. 2) Logic Terms The logic terms AND, OR, HQI, !E. THeN and WeN, are used to logically construct conditional statements and express complex combinations of conditions and actions. These terms are written Into the procedure to clearly identify the conditions that must be satisfied prior to taking the reqUired actions.

When action steps are contingent upon certain conditions or combination of conditions, the step SHALL begin with the words !E or WeN followed by a description of the reqUired condition. The conditional action that follows SHALL begin with the word TtieN.

EXAMPLE: !E pressurizer level is stili dropping, IHeN manually initiate SI and go to _BwEP-O REACTOR TRIP OR SI.

weN RCS pressure Is below 1000 psig, THeN isolate all accumulators.

3) Operator ActIon Summaries Operator Action Summary pages contain Information that must be monitored throughout the procedure. For example, RCP trip criteria, or inadequate core cooling criteria. The Operator ActIon Summary is located on the backside of each page of the reqUired

_BwEP, _BwEP ES and _BwCA procedure.

9

BwAP 340-1 Revision 24 Information Use C. 4. b. 4) Continuous Action Summary Pages Once the procedure has been implemented, the SRO is responsible for monitoring the status of the Continuous Action Summary (CAS) page steps. A step indicated on the CAS becomes applicable after proceeding past that step in the main body of the procedure.

CAS steps are provided as a prompt to the crew of incomplete steps or expected conditions that may require further action. Any action taken is to be performed using the referenced procedure step, not directly from the CAS. A diamond around the step number will annotate high level steps. The portions of a step that are continuous actions are summarized on the Continuous Action Summary page.

A continuous action is an action that is applicable from the point at which it is first encountered until superceded by alternate guidance or stated to be inapplicable. A continuous action generally remains applicable throughout its associated procedure unless otherwise stated, and may apply after a transition has been made to another procedure if it does not contain any actions that are inappropriate for the subsequent procedure. Certain continuous action steps are only applicable to the current procedure in effect. These steps will be identified with "while in this procedure" or similar wording on the CAS page to designate that the action only applies while the associated procedure is in effect. A Continuous Action may also be implied through the use of WHEN, THEN statements, and the action verbs "control", "monitor", "maintain", and "try".

Any BwEP or BwCA continuous action in progress is suspended if either a RED or ORANGE condition is detected on a Status Tree.

Optimal Recovery Guideline (BwEPs, BwCAs) actions are not to be performed while a Critical Safety Function is being restored from a RED or ORANGE condition. The continuous actions of the Optimal Recovery Guidelines are still applicable if a YEllOW path condition is detected and the YEllOW FRG is implemented.

5) Remote Shutdown Panel Activation of the Remote Shutdown Panel authorizes direct entry into applicable emergency or abnormal procedures, as determined by the SRO.

10

BwAP 340-1 Revision 24 Information Use C. 4. b. 6) Convenience (Contrgl Room. T§C. Remote §hutdown panel)

Each procedure will have a tab on the outside edge identifying it for easy reference. _BwEPs, _BwEP ES and _BwCAs will be in red binders. _BwFRs and _BwSTs will be in orange binders, while

_BwOAs will be in yellow binders.

c. Procedure Compliance Normally procedures shall be followed as written. It is recognized that circumstances may arise that were not foreseen in the preparation of the emergency procedures. If a combination of events occurs that is not specifically addressed by the emergency procedures and immediate action is reqUired to protect the health and safety of the public, then 10CFR50.54(x) and (y) allows, with a Senior Reactor Operator's approval, whatever action(s) is/are necessary to place the plant in a safe condition.

Prudence may require actions outside of the emergency procedure in situations to protect:

• The health and safety of the public/plant personnel or,

• Important equipment for safe operation of the plant.

This should be done only when necessary to solve an immediate problem and only after careful consideration and approval from the Shift Manager (or SRO designee). Appropriate log entries describing the situation and the resolution actions shall be subsequently made. Invoking 10CFR50.54(x) and (y) requires an ENS notification.

d. Critical Safety Functions:

1) Barrier Concept In order to have procedures that address symptoms, instead of events, the critical safety functions were developed. The critical safety functions protect the integrity of the fuel, RCS, and containment (three barriers) to prevent the release of radiation.

The six critical safety functions each have a status tree LBwSn, which determines if the function is satisfied, and restoration procedures LBwFRs). which restore the function if it is challenged.

The block and branch format SHALL be used, as well as a black and white branch/end point design convention which allows the operator to distinguish red. orange, yellow and green paths when they are not presented in color.

11

SwAP 34Q..1 Revision 24 Information Use C. 4. d. 2) Status Tree Priority The prioritization of Critical Safety Functions is consistent with the defense*in-depth concept of multiple barriers to radiation release. It stresses the importance of maintaining as many barriers as possible at all times in order to insure the "health and safety" of the general public. Monitoring of Critical Safety Function status trees is always done in order of priority:

a) Sub criticality (S) b) Core Cooling (C) c) Heat Sink (H) d) Integrity (P) e) Containment (Z) f) Inventory (I)

The Status Trees will always be arranged and numbered in this order.

3) Color Definition and Priority GREEN - The Critical Safety Function is satisfied - no operator action is called for YELLOW - The Critical Safety Function is not fully satisfied* operator action may eventually be needed ORANGE

• The Critical Safety Function is under severe challenge

• prompt operator action is necessary RED - The Critical Safety Function is in jeopardy

• immediate operator action is required The six critical safety function status trees are arranged in order of priority. The importance of any non-green end point relative to any other end point of the same color is indicated by the order of the trees.

The STA should continue to monitor the status trees. If a RED or higher priority is encountered then lower priority BwFRs should be suspended, and the higher level RED path implemented unless otherwise directed by an emergency procedure.

12

BwAP 340-1 Revision 24 Information Use C. 4. d. 4) Usage Rules The priority of operator action is fixed by the physical arrangement of the trees. Both the ordering of the trees and color coding of the end points serve to define priorities. For the entire set of trees, priority of operator action is given to:

RED paths, in tree order ORANGE paths, in tree order YELLOW paths, in tree order As an example, a RED in Core Cooling is more important than a RED in Heat Sink (order of the trees). However, the RED in Heat Sink is more important than any ORANGE (order of the colors).

The initial scan of the Status Trees is to be performed after departing the _BwEP-o procedure unless specifically directed to do so within _BwEP-O.

The Status Trees are entered in succession in the sequence:

a) Sub criticality (S) b) Core Cooling (C) c) Heat Sink (H) d) Integrity (P) e) Containment (Z) f) Inventory (I)

Entry into a tree is always at a point indicated by the arrow at the left side of the tree. The user then works through the tree, choosing at each branch point that branch which represents the actual condition existing in the plant and defining, by the path taken through the tree, the status of the plant in terms of the Critical Safety Function in question.

Exit from the tree is always by way of a branch end point, which shows either satisfaction of the Critical Safety Function or the failure that currently exists. If a failure is indicated, the end point shows the coIor-coded priority of response to the failure to maintain the Critical Safety Function, and the Function Restoration Procedure, which should be used to reestablish the faulted Critical safety Function.

The status of each Critical safety Function should be logged during each scan of the trees using SwAP 340-1T1.

13

BwAP34Q..1 Revision 24 Information Use C. 4. d. 4) Both Red and Orange conditions require departure from any other (non _BwFR) procedure, with the exception of _BwCA 0.0,

_BwES 1.3, and BwFR C.2. _BwCA-O.O instructs the operator to monitor the _BwSTs for information only, and to implement _BwFRs only when instructed. _BwES 1.3 has the operators establish Cold Leg Recirculation in order to supply water to the ECCS pumps and return to or implement the BwFRs only when instructed. _BwFR C.2 performs an action that will cause a Red Path in another CSF, but instructs the operators to complete _BwFR C.2 prior to implementing the higher priority Red Path.

In all other cases. a Red condition requires implementation of the designated _BwFR immediately upon detection. Any other procedure remains in suspension until the _BwFR is complete. Generally the

_BwFR requires actions, which will clear a Red or Orange condition before returning the operator to whichever procedure was in effect.

An Orange condition does not require immediate action. The current pass through the status trees is to be completed, with the status of each Critical Safety Function noted. If no Red condition is encountered during the scan, then the highest priority Orange is addressed first, requiring departure from the procedure in effect.

Once the actions of the _BwFR are completed assuming no Red condition has appeared, the next highest priority Orange can be addressed.

If, during the execution of any Red condition _BwFR. a Red-condition of higher priority arises. then the higher priority condition should be addressed first, and the lower-priority Red _BwFR suspended.

If. during the execution of any Orange _BwFR, any Red condition arises. the Red condition is to be addressed first, and the Orange

_BwFR suspended.

After completion of any Red-condition _BwFR, the status trees should be scanned again, if scanning was suspended by reqUired operator actions.

Tree scanning should be continuous if any condition coded higher than Yellow is found to exist. Operators should be familiar with those conditions associated with Red paths. If no condition coded higher than Yellow is encountered, the tree scanning frequency may be reduced to 1Q..20 minutes unless some significant change in plant status occurs. Also if a Red or Orange Path condition exists for which the BwFR has already been performed and exited, and the Emergency Director concurs, the tree scanning frequency may be reduced to 1Q..20 minutes unless some significant change in plant status occurs. Tree scanning JIlI¥ be terminated when deemed appropriate by the Emergency Director.

14

SwAP 340-1 Revision 24 Information Use C. 4. d. 4) 'MIen the initial scan of the status trees is performed, an entry for each tree should be made on SwAP 34Q...1T1, SwST Log Sheet.

'MIen scanning frequency has been reduced, logging of the status trees should then continue to be performed once every 20 minutes thereafter or if there is a change in color for one of the trees. 'MIen logging the status of the trees on SwAP 340-1T1, SwST Log Sheet, the color for the path should be logged in the upper left hand comer of the box. The _SwFR number should be logged in the bottom right hand comer of the box. The date, time, and initial blanks should also be filled in by the individual performing the status trees.

'MIen the log sheet is completed as necessary it should be routed to the Operating Clerks for retention.

A YELLOW end point does not require immediate operator action.

Frequently, it is indicative of an off-normal or temporary condition, which will be restored to normal status by actions already In progress. In these instances, the operator may choose to delay entry into the referenced _SwFR, and allow the function status to return to GREEN by Itself. For example, following reactor trip, nuclear flux remains In the intermediate range with a negative startup rate for more than 15 minutes - a YELLOW condition. However, the flux normally continues to decay into the source range - a GREEN condition. Similarly following reactor trip, steam generator water levels may shrink out of the narrow range of Indication - a YELLOW condition. Normal AF flow will recover level to the no-load value over a period of time, thereby restoring a GREEN condition.

Operator discretion is required in use of the status trees. It Is possible that certain accidents might produce non-green status conditions, which are not expected to be corrected. For example, the proper operator action for a steam line break Is to allow the faulted generator to dry out, resulting In an unsatisfied heat sink condition. A 1088-0f-ooolant accident will produce an unsatisfied RCS Inventory condition, which may never be satisfied. The operator should realize, and the trees should reflect, that these concerns are of low priority as long as other safety functions are satisfied. In these instances, repeated attempts to restore the affected safety function are not necessary. It Is sufficient to note the status condition on each pass through the trees.

15

BwAP 340-1 Revision 24 Information Use C. 4. e. Procedure Interface:

NOTE Activation of the Remote Shutdown Panel authorizes direct entry into applicable emergency or abnormal procedures, as determined by the SRO.

_BwEP-O must be entered on either a reactor trip from criticality or SI, unless the reactor is manually tripped during the performance of

_BwOA PRI-5 or _BwGP 100-5. There are no provisions for entering

_BwEP-O unless there is a reactor trip or SI. The LOCAILOSC, Faulted SIG Isolation and SGTR procedures LBwEP-1, _BwEP-2, _BwEP-3) are all entered from _BwEP-o. It is not possible to go directly to _BwEP 1, 2, or 3 without a reactor trip or SI even though a LOCA, LOSC, or SGTR may be suspected. In the event of a small primary leak, without a reactor trip or SI, proper action would be to go to _BwOA PRI-1 EXCESSIVE PRIMARY PLANT LEAKAGE which may lead to _BwEP-O if the condition is serious enough. It should be noted that if the primary leakage is small enough normal shutdown procedures may be adequate even though it would be classified as an actual LOCA.

Status trees are normally used only after a reactor trip or SI, however, this does not preclUde the monitoring of these trees during a normal cooldown, or at any other point where the operator deems necessary. It should be recognized that if the trees were monitored at a point other than after a reactor trip or SI, some trees may not be satisfied and are not expected to be. For example, sub criticality would never be satisfied during normal power operations, if the tree was monitored.

16

SwAP 340-1 Revision 24 Information Use

c. 5. Detailed Information (General Operating Procedures. _BwGP-1oo series)

a. The _BwGP-1oo series contains:

1) Operating procedures. _BwGP 100 series.

2) Operating flowcharts. which correspond to each procedure.

3) Operating appendices.

4) Operating tables.

b. The operating procedures are used to describe the steps necessary for plant operation:

1) The procedures will be visible and followed during those evolutions described within.

2) The procedures are used in conjunction with the flowcharts and are not permanent records. The flowcharts are the permanent records as described below.

3) The procedures will be used in conjunction with other procedures as referenced (BwOP or _BwGP).

c. The _BwGP flowcharts are referenced in the applicable procedures.

1) The flowcharts are to be followed from left to right as described by the black arrows.

2) The flowchart will be initiated by the Shift manager and he will place his initials. time and date at the enter arrow (upper left, sheet 1).

3) Exceptions to steps should be noted on the Flowchart Exception Sheet, _BwGP 1OQ.1T26. The person excepting the step should place the circled "exception number" at the excepted step location on the flowchart. The "exception number" should also be placed just prior to the resolution step, (the step in the "resolve prior to step Ir column), if applicable.

17

SwAP 340-1 Revision 24 Information Use C. 5. c. 4) The flowchart will contain three basic step designations:

a) The large circle signifies major steps in the procedure and will contain within it either a small circle or a box for initials.

b) The circle signifies a step to be completed and initialed by the NSO.

c) The box signifies a step that is to be approved prior to starting and initialed after completion by an SRO.

5) Prior to performing any actions directed by the GP the Prerequisite, Precaution, and Limitations and Actions section (C, 0, E) will be read by the NSO and any subsequent relief NSO prior to continuing the procedure. All NSOs will signify this by initialing the circles (C, 0, E).

6) Dotted lines around a step signify an option to either do the step or bypass the step.

7) The procedure will be done in accordance with the flowchart. It will move from the left to right of the flowchart. The steps are placed on the flowchart to show apprOXimate times to do the step. Steps that have no line before them may be started at the discretion of the RO/SRO.

8) The flowcharts that contain more than 1 sheet will have black arrows for leaving that sheet and black arrows for entering the following sheet

9) Included on the flowcharts will be pertinent information:

a) Data tables for noting specific parameters.

b) Plant conditions.

c) Information pertinent to operation that may not be included in the procedures.

10) The Shift Manager will initial completion of each flowchart and the Exit time and date.

11) Flowcharts and aU other forms (ECC, etc.) will be routed to the Operating Clerks for retention.

18

BwAP 340-1 Revision 24 Information Use C. 5. d. The _BwGP Appendices will cover necessary checklists and information sheets for proper use and completion of the applicable procedure.

1) The appendices are referenced in the procedures.

2) The appendices contain the MODE CHECKLISTS which ensure all Tech Spec requirements are met prior to changing MODES.

3) The System lineup Checklist AppendiX will be generated by the appropriate Operating Engineer signifying which systems he requests lineups on (M and E lineups).

4) Contained within the appendices are the ECC and RRD.

NOTE The governing document for the plant mode changes is the BwGP main procedure and associated flow chart. The attachments/checklists are tools for support of these governing documents.

e. The use of the BwGP Mode Change Checklists are as follows:

1) Mode Change Checklists are In place to ensure all Tech Spec limiting Conditions for Operation and surveillance requirements are met before the mode change occurs.

2) Mode Change Checklists are referenced at the appropriate steps of the BwGP procedures and shall be completed prior to the mode change.

3) The Shift Manager (or SRO designee) is responsible for initiating the Mode Change Checklist, per the BwGP flowchart, and monitoring its progress.

19

BwAP 340-1 Revision 24 Information Use C. 5. f. The Mode Change Checklist will be completed as follows:

1) An SRO shall review all sections of the Checklist.

2) Log any discrepancies in the appropriate section of the Checklist.

3) Initiall11me/Date each step of the Checklist after the review has been made.

4) The Shift Manager (or SRO designee) shall initiate the appropriate review of the Clearance Order Report and MCB walkdown as required prior to the Mode Change.

5) The Shift Manager (or SRO designee) and Unit Supervisor shall thoroughly review the Mode Change Checklist. any discrepancies.

and Clearance Orders that may affect the Mode Change. \lVhen the information has been determined to be acceptable for the Mode Change. the Shift Manager (or SRO designee) and Unit Supervisor shall sign or initial, time and date the checklist signifying permission to make the mode change.

6. Tech Spec Limiting Conditions for Operation/Administrative Action Requirements (LCOARlAAR)

The LCOAR procedures track actions taken in the event any Tech Spec LCO is not met. These procedures assist In complying with the Tech Specs by providing documentation that the UNIT is maintained in the required MODE of operation for safe operability until the LCO is restored. The LCOAR procedures are also used to implement Safety Function Determination Program (SFDP) Requirements of ITS section 5.5-15. The LCOAR procedures are intended to be used in conjunction with the Tech Specs and not by themselves. The AAR procedures track actions taken In the event any Administrative condition/commitment etc. Is not met.

a. Multiple Action Charts (Applicable Tech Spec Action number) may be selected provided the actions apply to only one event Perform and document all steps using the more conservative time requirements when applicable.

b. LooAR procedures are initiated when the Shift Manager or Unit Supervisor determines it necessary for tracking reqUired action Item completion.

c. All completed or addressed steps SHAlL be signed by the supervisor that completes them.

20

BwAP 34CJ..1 Revision 24 Information Use C. 6. d. If a LCOARIAAR contains required ACTIONS that must be accomplished PROMPTLY or IMMEDIATELY, or in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or less, this will be highlighted in the space following the tiUe on the first page. Upon initiating a LCOARIAAR, enter the NOTIFICATION time and proceed directly to the ACTION REQUIREMENTS to ensure compliance within the specified time. If entry into the LCOARlAAR establishes a reporting or special action requirement, this will also be highlighted in the space following the tiUe on the first page. The first page will not reftect the fact that Section B of the LCOAR shall be performed immediately since this section applies to all Tech Spec LCOARs.

e. LCOARIAAR procedures will remain in effect until all operability/administrative requirements are met excluding reports or special actions tracked by applicable department

f. While in progress, the lCOARlAAR, when not directly being used, will be maintained by the Unit Supervisor.

g. The SRO SHALL determine any additional surveillances that must be performed to declare the eqUipment operable. If the inoperable component or system is made operable within the time specified by the LCOARlAAR, the applicable surveillance test(s) are performed and reviewed for acceptability. In addition, the SRO will indicate the restoration of the eqUipment to operable status by signing the applicable section of the action chart, including the time and date the equipment was deelared operable. It is not required to perform additional surveillances on inoperable SUPPORTED SYSTEMS that were being tracked under LCO 3.0.6. Once the SUPPORT SYSTEM has been restored, the SUPPORTED SYSTEM is also restored.

h. The Shift Manager or designee SHALL be responsible for the initial notification of each department involved in maintaining a LCOARlAAR.

i. Once contacted by the Shift Manager or designee, each Department SHALL be responsible for ensuring that all actions applicable to that Department (i.e. Grab Samples, inspections, reporting requirements, any additional Surveillance Requirements, etc.) are met

j. Unused Action Charts and Attachments may be discarded if desired.

k. Completed LCOARIAAR procedures will be forwarded after review to the Operating Clerks for retention.

21

BwAP 340-1 Revision 24 Information Use C. 6. I. The initial section on page 1 of the LCOARJAAR procedure will contain:

1) The title of the procedure.

2) The LCO number _BwOL 3._._._ or administrative requirement reference.

3) Any time constraints of 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or less and/or reporting/special actions highlighted in BOLD type.

m. SECTION A NOTIFICATION

1) The plant MODE at the time of notification.

2) AU applicable MODES.

3) The initiating conditions.

a) These may include but are not limited to:

o SURVEILLANCES o LCOARS/AARs o EQUIPMENT FAILURES o BwARs

4) Safety Function Determination

5) Specification 3.0.3 and Mode Change Applicability (LCOARs only).

6) separate Condition Entry: Time Extension Allowances

7) The name of the Shift Manager on duty that was notified.

8) Issues, associated Work Requests, and, if desired, related Clearance Orders.

9) Name of SRO initiating the LCOAR.

10) Name of Unit NSO on duty.

22

SwAP 340-1 Revision 24 Information Use C. 6. n. SECTION S SAFETY FUNCTION DETERMINATION PROGRAM REQUIREMENTS (LCOARs only)

NOTE Refer to Technical Requirements Manual Appendix 0, Safety Function Determination Program (SFDP) for detailed explanation of SFDP performance.

1) Loss of Safety Function (LOSF) Evaluation a) A step is included which will provide for a Safety Function Determination Evaluation. Any time LCO Required Action entry Is being delayed as allowed by LCO 3.0.6 or multiple LCOARs are in effect on a unit, the following question must be answered:

Assuming no concurrent single failure, and assuming no concurrent loss of offsite power or loss of emergency diesel generator(s), can all the required redundant SUPPORT and SUPPORTED SYSTEMS perform their Intended Safety Function(s) as assumed in the Accident Analysis?

b) If the answer to the above question is NO, then a Loss of Safety Function exists. The LCOAR for the sse in which the LOSF exists must be entered and the Required Actions performed for the Condition(s) that exist.

2) LCO 3.0.6 DELAYED LCOAR ENTRY a) A step is included which allows for delaying LCOAR entry for SUPPORTED SYSTEMS, which are determined to be inoperable SOlely due to an Inoperable Tech Spec related SUPPORT SYSTEM. This is an option to directly cascading Tech Specs. An evaluation to determine BOTH of the following is required:

• Entry into LCO 3.0.6 is applicable.

• No Loss of Safety Function (LOSF) exists.

23

BwAP340..1 Revision 24 Information Use C. 6. n. 2) b) To delay SUPPORTED SYSTEM LCOAR entry as allowed by LCO 3.0.6, ALL of the following apply:

• The SUPPORTED SYSTEM is addressed In Tech Specs.

• The SUPPORT SYSTEM that Is Inoperable Is addressed In Tech Specs and the LCO Required Actions are being addressed.

• The SUPPORTED SYSTEM Is Inoperable solely due to the SUPPORT SYSTEM Inoperability.

• The SUPPORT SYSTEM LCO or Required Actions do not direct entry into the SUPPORTED SYSTEM LCO and Required Actions.

c) If delayed LCOAR entry is desired and allowed, record in Table 1 and Table 2 all SUPPORTED SYSTEMS, which are Inoperable.

(1) Record in Table 1 the Time and Date all dlrectiy supported SSCs became inoperable. Review all active LCOARs to determine exactly whenlhow long this SSC has been inoperable.

(2) Using Completion Time extension rules for SUPPORTED SYSTEMS, record the Time and Date the LCOAR must be entered for each inoperable SUPPORTED SYSTEM.

(3) Record in Table 2 all SUPPORTED SSCs, which are inoperable as a result of any inoperable SUPPORTED SSC(s) identified in Table 1. Record Time and Date for inoperability and required LCOAR entry in the same manner as performed in step 1) above.

24

BwAP 340-1 Revision 24 Information Use C. 6. o. SECTION C ACTIONS

1) A step checking for possible Specification 3.0.3 Applicability (lCOARs only).

a) If it is found that Specification 3.0.3 actions are applicable, initiate _BwOl 3.0.3 and perform those specific actions.

2) lCOARslAARs with multiple ACTION CHARTS under the same lCO/Administrative requirement may contain an INDEX as the second page to assist in determining the most restrictive action.

Generally, lCOARslAARs with 2 or more separate action charts will have an index.

3) Other specific actions reqUired by the situation (not necessarily Tech Spec Related) including partial performance of applicable surveillances to maintain frequency of other operable equipment.

4) A reference to Emergency Plan on applicability (lCOARs only).

5) Information required to help determine applicable actions requirements.

p. lCOARlAAR ACTION CHART

1) Enter the NOTIFICATION time and date.

2) Determine the applicable action chart from Tech Specs/Administrative requirement. check the appropriate box and sign.

3) A large asterisk (*) preceding the text of the Action on the left represents a required IMMEDIATE action and must be performed immediately/as soon as possible upon initiation of the lCOARlAAR (time of notification).

4) Upon satisfactory completion of the required action, an SRO should enter the time, date and signature adjacent to the action performed.

Steps without signature spaces next to the action are documented elsewhere in the procedure.

5) With the appropriate action box checked or chart signed on the index, the actions within the chart must all be completed and signed off with the following exceptions:

• Restoration of the LCO prior to expiration of the required time interval, OR

• An alternative action is taken. (An altemative action SHALL be designated by use of the term OR).

25

BwAP 34Q..1 Revision 24 Information Use C. 6. p. 6) VVhen the LCOARIAAR ACTION CHART indicates a report or special action is required, the Shift Manager/designee SHALL initiate notification of the Regulatory Assurance Department and/or other designated responsible group by completing the NOTIFICATION OF LCOARlAAR REPORT1NG OR SPECIAL ACTION REQUIREMENT form at the end of the LCOAR procedure. A copy of the NOTIFICATION OF LCOARIAAR REPORTING OR SPECIAL ACTION REQUIREMENT should then be sent to the Regulatory Assurance Department or other designated responsible group as soon as practical (normally S 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />) to allow for processing. The original is maintained in the LCOARlAAR procedure affected.

7) Actions to be taken as written on the chart may occasionally paraphrase the action in Tech Spec/Administrative requirement.

For complete understanding of the action, and the steps required, the Tech Spec/Administrative requirement action must be read.

q. SECTION 0 RESTORATION

1) A step is included which will prOVide for evaluation and listing of selected surveillances, plant conditions, or other actions necessary to prove component/system operability. This list will be based on the initiating conditions as specified in Section A and ACTIONS in Section B. The SRO SHALL review the surveillance schedule to determine any surveillances out of frequency as a result of being in the LCOARIAAR.

2) Some LCOARslAARs will contain steps for restoration unique to the particular specification.

3) A statement will be made when the LCO/Administrative requirement has been met and when the action requirements may stop. Included will be references to any report requirements that are still applicable even though the LCO/Administrative requirement has been mel

4) Once all requirements have been satisfactorily completed the SRO will sign. The review of the LCOAR is completed by the Unit NSO and Shift Manager.

5) The Regulatory Assurance Supervisor SHALL receive and review only the LCOARslAARs with reporting requirements and/or special action requirements.

r. ATTACHMENTS This will contain any information, logs, reporting/special action notifications or steps, which will aid in meeting action or restoration requirements. It may also contain an Instrument Condition Tracking Log if any system bistables were tripped.

(Final) 26

ATTACHMENT 3 Effects of Hot and Cold Temperature Exposure on Performance:

A Meta-Analytic Review

VOL. 45, NO. to, 682~698 Q

~

Taylor & Frands llIykwli._llRIup Effects of hot and cold temperature exposure on performance:

a meta-analytic review JUNE J. 'A'.JL.C:K.j. and CAROLINE BusCH§ tDepartment of Psychology, Clemson University, Clemson, SC 29634, USA

~John A. Volpe National Transportation Systems Center, Cambridge, MA 02142, USA

§Supporting Science and Technology, US Army Soldier Center, Natrick, MA 01760, USA Keywords: Temperature; Performance; Environmental conditions; Meta-analysis.

A meta-analysis to mathematically summarize the effect of hot and cold temperature exposure on performance was completed The results from 515 effect sizes calculated from 22 original studies suggest that hot and cold temperatures negatively impact performance on a wide of cognitive-related tasks. More specifically, hot temperatures of 9O"F Web Bulb Globe Temperature Index or above and cold temperatures of (lOGC) or less resulted in the greatest decrement in performance in comparison to neutral temperature conditions (14.88% decrement and 13.91 % decrement, respectively).

Furthermore, the duration of exposure to the experimental temperature, the duration of exposure to the experimental temperature prior to the task onset, the type of task and the duration of the task had differential effects on performance.

The current results indicate that hot and cold temperature exposure have a negative impact on performance and that other variables (e.g., length of exposure to the temperature or task duration) may modify this relationship.

1. Introduction Adjusting to and working under hot or cold temperatures has long been a ehallenge for people living under immoderate weather conditions. In spite of the ability in industrialized societies to control indoor temperatures, a similar challenge continues for many people who are regularly exposed to extreme temperatures while working.

Concern about the effects of temperature on work-related performance has prompted the National Institute for Occupational Safety and Health (NIOSH) to attempt to establish upper limits for occupational exposure (1972). However, in their revised criteria of 1986, NIOSH did not include upper limits for heat exposure under the that there was not a well-established relationship between performance and heat (NIOSH, 1980).

Although a number of governing bodies have attempted to use the available literature to establish guidelines for on-the-job extreme temperature conditions, they

'"Author for correspondence. e-mail: jpilche@c1emson.edn

Tei?1/JenltUl'e and performance 683 have met with limited success. This has been largely due to the conflicting nature of the primary studies the effect of extremes on performance.

For some studies have reported little, if any, performance loss under extreme temperature exposure (Chiles Pepler 1959, Colquhoun 1969, Grether, et al. 1971, Ramsey and Pai et al. 1983), whereas other studies have reported performance decrements (Mackworth 1947, Fraser Pepler 1960, Bell, et al. 1964, Azer, et al. 1972, Fine and Kobrick 1978).

Perhaps not surprisingly, narrative summaries have also had limited success with drawing conclusions from the available data on the effects of temperature extremes on performance (Ramsey 1995). Although there have been numerous narrative attempts to summarize the data (Bell and Provins 1962, Grether 1973, Ramsey and Morrissey 1978, Bell 1981, Kobrick and Fine 1983, Ramsey 1983, Kobrick and Johnson 1991, Ramsey and Kwon 1992), a clear picture of the results has yet to be presented. One possible reason for the confusion in the original data and summaries is the variety of experimental conditions that are used across different studies. For example, the specific type of task, the severity of the temperature exposure, and the duration of the temperature exposure may have differential effects on pcrformance under extreme temperature conditions (Wilkinson 1969, Hancock 1984).

A quantitative approach to summarizing the data would allow an examination of the effects of temperature extremes on performance and an assessment of the effects of variables that may differentially impact performance. A type of quantitative summary examining the relationships among type of task, degree of temperature exposure, and duration of temperature exposure was recently completed (Ramsey and Kwon 1992, Ramsey 1995). In these reviews, figures were used to plot the intersection points of the parameters of interest for each study. Although this approach provided a visual means of summarizing across the studies, it did not permit strong quantitative conclusions.

A meta-analysis (Hunter, et al. 1982, Hunter and Schmidt 1990) of the data on temperature exposure and performance should provide much more quantitative results than any of the previous summary studies. The meta-analytic technique has been successfully used to quantitatively summarize research studies in a variety of other fields, such as clinical psychology, educational psychology, industrial-organizationa I psychology, physiological psychology, and social psy-chology (Goyder and McCutcheon 1995, Huffcutt, et al. 1996, Hyman, et al.

1989, Klawansky, et aI. 1995, Paus, et al. 1998, Peers and M 1994, Pilcher, et al.

2000, Svartberg and Stiles 1991). Meta-analytic reviews, because of their mathematical nature, tend to be objective and consistent. Furthermore, they have several statistical advantages over the more common narrative review. A potential problem with every study that uses a sample of a larger population is that the sample chosen may not actually match the population of interest (i.e., a sampling Because it mathematically averages across studies, a meta-analysis actually minimizes the influence of sampling error. Moreover, some original studies may be based on a relatively small sample size, thus problems with low power. A meta-analysis avoids this potential problem by not performing significance testing at the individual study level. Effectively, in a meta-analysis, all individual samples are combined into one large sample, which should be largely representative of the general population of interest. An additional advantage of the meta-analytic technique is that it allows an easier definition of the variables (called moderator variables) that may affect the dependent variable

684 J. J. Pilcher et al.

of interest. For example, the length of time that each participant is exposed to an extreme temperature condition is a potential moderator variable.

The purpose of the current study was to use the meta-analytic technique to provide a comprehensive, quantitative analysis of the effects of temperature exposure on performance. To better quantify how temperature exposure may influence performance, the of temperature exposure, duration of the experimental session, duration of temperature exposure prior to task onset, type of task, and task duration were defined as potential moderator variables.

Because of the conflicting nature of the original studies and the previous narrative reviews, it was difficult to make predictions on the outcome of the meta-analysis. In general, more extreme tempcratures were expected to result in a greater performance decrement than moderate temperatures. Predictions on the potential effects of the other moderator variables on performance were not possible.

2. Method 2.1. Location of study data A thorough data search was completed for the current meta-analysis. The American Psychological Association's Psychlnfo database was queried for keywords 'thennal',

'temperature', 'hot', 'cold', and 'heat'. The names of the authors that were retrieved from Psychlnfo were also submitted as keyword queries. In addition, recent volumes of the journals Ergonomics and Human Factors were revi.ewed for relevant articles published too recently to appear in the database. The data search identified 527 articles, reports, and dissertations published between 1922 and 1997. Of these, 226 primary studies examining the effect of environmental temperature conditions on performance were identified. These studies represented a wide range of experimental conditions including many different types of dependent measures, hot and cold temperature exposure, cold water exposure, partial body exposure to temperature conditions, temperature exposure under laboratory conditions, and temperature exposure under field conditions.

2.2. Decision rules The purpose of completing a meta-analysis is to combine the mathematical difference between experimental and control groups across primary studies. To ensure that combining across studies results in meaningful data, decisions must be made in advance for selecting studies for inclusion in the meta-analysis. The following criteria were used for selecting primary studies for inclusion in the current meta-analysis.

First, each study had to report hot or cold environmental temperature exposure as an experimental condition. Enough information had to be provided about hot environmental temperature conditions to calculate a Web Bulb Globe Temperature (WBGT) index (described below), if one was not provided. Air temperature had to be provided for cold environmental temperature conditions. Cold water exposure studies and studies where temperature exposure was brought about by clothing or head gear were excluded from the analysis. Second, the neutral temperatures used in the primary studies had to meet the criteria shown in the top portion of table 1.

Because the experimental results are compared with the neutral temperature results, it was important to control for this factor by limiting the neutral temperature range that would be allowed in the meta-analysis. The neutral temperature ranges were chosen after reviewing the primary studies to determine what temperatures were

Temperature and pefjormance 685 ch aracterist ics.

Neutral TeimpereltUile A. 6O~ (l5.56~2L06cC) WBaT: hot eXfler:iml:nt:al temperature conditions B. 65 75°F (18.33 temperature conditions WBaT)

WBaT)

Duration of Experimental Session A. Short 120 mins)

B. Long 120 mins)

Duration of Pre-task Temperature Exposure A. None B. Short (I 59 mins)

C. Long 60 mins)

Type of Performance Task A. Reaction time B. Attention/Perceptual C. Mathematical processing D. Reasoning, learning, memory Duration of Task Battery A. Short ( 60 mins)

B. (60 mins) most often used as neutral conditions for comparison to hot and cold exposure. For the current meta-analysis, studies using hot temperature conditions had to use a neutral temperature condition between 60 69.9°F (l5.56~2L06°C). WBGT and studies using cold temperature conditions had to use a neutral temperature eondition between 65 75°F (18.33 23.89°C). Third, each study had to report on at least one type of performance measure reaction time, tracking, memory tasks). Studies using only motor-specific self-report tasks, or physiological measures were excluded from the analysis. Last, enough reliable information had to be provided in the study to allow computation of an effect size statistic for each performance measure. In the case of the current set of data, this usually meant a direct reporting of means and standard deviations or a clear graph such that the data could be estimated. Based on these four criteria, 23 of the 226 primary studies could be used in the meta-analysis (Pepler 1953, Bursill 1958, Pepler 1958, Givoni and Rim 1962, Dean and McGlothlen 1964, Youngling 1965, Reilly and Parker Jr. 1968, Griffiths and Boyce 1971, Colquhoun and Goldman 1972, Reddy 1974, Bell 1978, Langki1de 1979, Epstein, et al. 1980, Beshir, et al. 1981, Lewis, et al. 1983, Enander 1987, Sharma and Panwar 1987, Thomas, et al. 1989, Armstrong and Thomas 1990, Razmjou and Kjellberg I Shurtleff, et al. 1994, Razmjou 1996, van Orden and Benoit 1996).

686 J. J. Pilcher et aL It is important to note that numerous primary studies in a meta-analysis is a common occurrence. In only those articles that meet specific criteria is the primary means of insuring that the studies used are valid for the meta-analysis conducted. The purpose of strict criteria for inclusion is to ensure that mathematically combining across the studies that meet the criteria results in meaningful data.

2.3. Temperature calculation Studies that used high temperatures as the experimental condition had to report the environmental condition either as the WBGT heat index or provide enough information to calculate the WBGT. Some studies reported the environmental temperature in the form of the Effective Temperature (ET) index. In this case, the ET was converted to WBGT using equation I (Brief and Confer 1971):

WBGT (ET-13.l)(0.823 (I)

Other studies reported the environmental temperature in the form of dry bulb (DB) and wet bulb (WB) temperatures. For these cases, it was assumed that air temperature was approximately equal to globe temperature when air movement was negligible or unreported in experiments conducted indoors (Ramsey 1995). Thus, assuming that the natural and psychrometric wet bulb temperatures were equivalent, DB and WB temperatures were converted to WBGT using equation 2 (Parsons 1995):

WBGT 0.7 WB + 0.3 DB (2) 2.4. Coding of study information A special coding form was developed to record pertinent information from each of the primary studies that met the criteria for inclusion. Potential moderator variables were identified by the literature related to environmental conditions and performance. The categories chosen for the current analysis are listed in the bottom portion of table I. First, all primary studies were coded for the type of environmental temperature exposure: hot or cold. Hot temperature conditions were defined as experimental temperatures of 70"F (21.11°C) WBGT or above and were further eategorized as Hotl (70~79.9 OF [21.11 26.61°C] WBGT), Hot2 (80 89.9°F

[26.67 32.1 TC] WBGT), or Hot3 ( 90°F [32.22°C] WBGT). Cold temperature conditions were defined as experimental temperatures of less than 6Y'F (l8.33°C) and were further categorized as Coldl (50~64.9°F [10~ 18.28°C]) and Cold2 ( 50°F

[10°C]). The endpoints for the hot and cold categories were determined by the range of temperatures used in the 23 primary studies that met the decision rules for inclusion in the current meta-analysis. The endpoints for the hot and cold sul>eateg.oriles (Hotl, Hot2, Hot3, Coldl, Cold2) were determined after thoroughly reviewing the temperature ranges in the primary studies used in the current analysis and were chosen to equalize, as much as possible, the number of studies in each temperature subcategory. Second, the duration of the complete experimental session was coded as either short << 120 mins) or long ( 120 mins). The experimental session included any pre-task exposure to the temperature as well as the duration of all task trials and all tasks that were completed under temperature conditions. Third, the time that participants were exposed to the temperature conditions prior to working on the task (pre-task exposure) was categorized as noue, short (l 59 mins),

Temperature and vel'!OJ"mllI1C'e 687 or long ( 6Omins), Fourth, the type of task was defined as reaction time attcntional or perceptl11al tasks or mathema-tical tasks multiplication or adding identifying lower versus higher or memory tasks word recall task duration was as short ( 60 mins) or long ( 60 mins).

The criteria for the potential modifier variables listed above were determined after reviewing the primary studies being used in the current analysis and examining natural cutoff points for the duration and logical task categories for collapsing across the primary studies. This is commonly done when choosing categories for a meta-analysis (Pilcher and Huffcutt 1996).

An effect size statistic, which indicates how many standard deviations the mean of the experimental group differed from the mean of the control group, was computed for each study using the technique described by Hunter and Schmidt (1990). The effect size statistic, d, was calculated using equation 3 where XE is the mean of the experimental group, is the mean of the control group, and Sp is the standard deviation pooled across both groups.

d (3)

Equation 4 is the formula for computing the pooled standard deviation, where N E and SE represent the sample size and standard deviation for the experimental group and N c and Sc represent the sample size and standard deviation for the control group.

(4)

In calculating effect sizes, careful attention was paid to the sign of the effect size statistic to insure that a positive d-score represented better performance in the experimental group than in the control group, whereas a negative d-score indicated worse performance.

It is important to note that most of the studies used in the current analysis used more than one of the conditions being coded, thus resulting in multiple d-scores for the majority of studies. For example, studies often used more than one experimental temperature condition or more than one type of performance task. A total of 517 d-scores were calculated from the 23 primary studies. However, the results presented here are based on 515 d-scores from 22 primary studies. One study (Beshir et al.

1981) which met the criteria for inclusion was removed from the meta-analysi s following the calculation of the individual d-scores. The d-scores calculated from this study ( 12.2 and 14.53) were excluded as outliers. For comparison, the d-scores resulting from the 22 studies used in the current meta-analysis ranged from 4.39 to 1.86.

The 22 primary studies used in the current included data from 317 experimental participants. Because the data from each participant were usually included in more than one coding condition, the current results are based on a total of 7044 data points. In addition, most studies exposed their participants to both the neutral and experimental temperature conditions. Therefore, not only were multiple d-scores computed for many of the primary studies, the d-scores were not entirely independent. This commonly occurs in the meta-analytic technique. In the case of the current study, this had a minimal impact on the over-all d-score results. The repeated-measures within most of the studies would have underestimated the variance associated with the d-scores but would not have affected the d-scores

688 J. J. Pilcher et at themselves. Thus, the pattern and strength of the d-scores reported here were unaffected The reliability of the coding process was assessed by having two independent researchers code each of the primary studies that met the criteria for inclusion. The correlations for the d-scores and for each of the coded on the coding form were very high (ranging from 0.98 to 1.00). The few between the two raters were investigated and resolved. The high correlations between the two raters indicate that the necessary information could be coded reliably from the studies.

2.5. lvfeta-analytic methodology All meta-analyses were completed using an SAS (SAS Institute INC, Cary, N.C.)

computer program (Huffcutt, et at. 1992) that mathematically combines d-scores across primary studies. The result is an estimate of the mean effect size across the studies (i.e., the average number of standard deviations the experimental group distribution was offset from the control group distribution) and the variability observed around this average. All computations were weighted by sample since studies based on a larger sample are more stable than those based on a smaller sample (Hunter, et al. 1982, Hunter and Schmidt 1990).

It should be noted that the SAS program does not provide any tests of statistical significance. Significance testing is not typically done in the meta-analytic procedure as these procedures were developed to avoid the problems and limitations intrinsic to significance testing (Hunter, et aI. 1982, Hunter and Schmidt 1990). Furthermore, because sampling errors tend to average out when combining across primary studies, average effect sizes from a meta-analysis represent direct estimates of the overall strength of a relationship in the population. Finally, the variability around the mean reflects the to which other variables moderated the relationship. Therefore, the variability does not represent a lack of consistency within the data, but, instead, provides an indication of how other variables may affect the specific variable of interest.

The overall goal of the current study was to examine the effects of hot and cold temperature exposure on performance. As a first step, a meta-analysis that collapsed across all temperature and performance task conditions was completed. This provided an overall estimate of the effect of temperature exposure on performance.

Second, a separate meta-analysis for each of the major categories was completed.

This included an analysis of the effect of hot and cold temperature exposure on performance, the effect of duration of temperature exposure on performance, the effect of pre-task temperature exposure on performance, the effect of the type of task on performance, and the effect of task duration on performance. The third level of the meta-analysis collapsed across the temperature subcategories and examined each of the major coding separately for the hot and cold conditions. Finally, an additional analysis was completed for the hot temperature condition for temperatures 80°F (26.67°C) WBGT and higher (collapsing across Hot2 and Hot3 temperature subcategories).

The mean d-scores calculated in each of the analyses represent the mean numbcr of standard deviations the experimental temperature group differed from the neutral temperature group for the particular variable being examined. The variance for each of the d-seores reflects the extent to which other experimental variables affected the magnitude of the difference between the experimental and control groups. These analyses were designed to follow a hierarchical strategy as is typically done in meta-

Temperature and performance 689 analytic procedures (Hunter and Schmidt 1990). In general, the current meta-split up the data into smaller chunks based on the characteristics, thus making the analyses more and more specific. By dividing the data into smaller the number of studies and the number of d-scores analysed at anyone time became smaller and smaller. Naturally, the smaller the number of studies and d-scores in any the more tentative the results.

3. Results The results from the first stage of the analyses are presented in the top line of table 2.

Combining across all coding categories, including hot and cold temperature conditions, resulted in an overall effect size of ~O.l92. This indicates that the mean performance of the experimental group (those participants exposed to either hot or cold temperature conditions) was 0.192 standard deviations less than the average performance of the control group (the neutral temperature group). More practically, as shown in the percentage difference column in table 2, hot and cold temperature exposure resulted in a 7.61 % decrement in performance in comparison to the neutral temperature condition. Note that all percentiles presented in the tables assume that the d-scores approximate a normal distribution and can be obtained from standard z-score tables.

Table 2. Meta-analysis results for each

\ill %DiW Var(\i)C N(tt)d N(Stt N(Ptf Overall ~0.192 7.61 0.429 515 22 7044 Hot exposure ~0.150 5.96 0.363 315 16 4229 Hotl ~0.020 ~0.80 0.193 148 2342 Hot2 ~0.189 7.50 0.548 60 8 685 Hot3 0.382 ~ 14.88 0.503 107 9 1202 Cold exposure ~0.255 10.06 0.522 200 9 2815 Coldl ~O.l97 7.81 0.381 104 4 1788 Cold2 ~0.356 13.91 0.750 96 6 1027 Short experimental session ~0.410 15.91 0.709 189 11 1900 Long experimental session 0.147 5.84 0.298 264 10 4536 No pre-task temp duration ~0.101 4.02 0.143 185 8 3277 Short pre-task temp duration ~O.l27 5.05 0.362 103 7 1090 pre-task temp duration ~0.472 18.15 0.842 165 9 2069 Reaction time tasks ~0.OO5 0.20 0.151 37 5 Attention/Perceptual tasks ~O.l95 7.73 0.379 285 16 4310 Mathematical tasks ~0.033 ~ 1.32 0.259 94 962 Reasoning/Learning/Memory tasks ~0.469 ~ 18.05 0.881 99 8 1020 Short task duration ~0.513 ~19.60 0.850 225 12 2227 task duration ~0.072 2.87 0.147 228 9 4209 "Mean effect size; difference between neutral and temperature conditions; "variance around the mean effect dnumber of effect "number of studies;

'number of data points in experimental groups.

690 J. J. Pilcher et aL The remainder of table 2 contains the results from the second of the As can be seen, cold exposure resulted in worse (l 0.06 %

decrement) than hot exposure (5.96% decrement). In both hot and cold exposure cOlrlditions, the nearer the temperature was to the neutral range the less effect it had on performance. Within hot Hotl temperatures rcsulted in a 0.80%

decrement in performance, Hot2 temperatures resulted in a 7.50% decrement, and Hot3 temperatures resulted in a 14.88% decrement. For cold environments, Cold1 temperatures resulted in a 7.81 % decrement in performance and Cold2 temperatures resulted in a 13.91 % decrement.

The length of the experimenta I session also had an effect on performance. Short experimental sessions had a stronger negative effect on performance (15.91 %

decrement) than long experimental sessions (5.84% decrement). However, the longer the person was exposed to the temperature prior to task performance (pre-task temperature duration), the worse the performance. For example, long pre-task temperature duration resulted in a 18.15% decrement in performance while no pre-task temperature duration resulted in a 4.02% decrement in performance.

Performance was also affected by the type of task and task duration.

Performance under environmental temperature exposure conditions was least affected for reaction time tasks (0.20% decrement) and most affected for reasoning, learning, or memory tasks (18.05% decrement). A 7.73% decrement in performance was observed in attention or perception tasks and a 1.32% decrement was observed in mathematical processing tasks. In addition, performance was more affected by short task durations (19.60% decrement) than long task durations (2.87%

decrement).

The meta-analytic results from the third level of analyses examining each of the coding variables for hot and cold experimental conditions are reported in tables 3, 4, and 5. The top line in tables 3 and 4 indicate the over-all d-score for hot and cold Table 3. Meta-analysis results for the hot environments.

a N(tl)d tl %DiW Var(l.1t N(St)C N(PtY Hot exposure ~0.150 5.96 0.363 315 16 4229 Short experimental session ~0.385 14.99 0.512 108 6 1248 session ~0.068 2.71 0.264 181 9 2733 No temp duration ~0.054 2.15 0.096 89 5 1692 Short temp duration ~0.186 7.38 0.411 76 5 790 Long temp duration ~0.286 11.26 0.612 124 7 1499 Reaction time tasks ~0.060 2.39 0.241 24 4 440 Attention/Perceptual tasks ~0.194 7.69 0.416 207 13 2885 Mathematical tasks ~0.098 3.90 0.406 56 5 500 Reasoning/Learning/Memory tasks ~0.OO4 0.16 0.024 28 3 404 Short task duration ~0.385 14.99 0.670 130 6 1257 task duration ~0.067 2.67 0.190 159 9 2724 a mean effect size; difference between neutral and experimental tempreature conditions; "variance around the mean effect size; dnum ber of effect sizes; cnumber of studies; fnumber of data points in experimental groups.

and performance 691 Table 4. results for cold environments.

u lI N(Ptf Cold exposure ~0.255 10.06 0.522 200 9 2815 Short session ~0.456 17.58 1.084 81 652 experimental session ~0.268 10.57 0.326 83 3 1803 No temp duration ~0.151 6.0 0.188 96 5 1585 Short pre-task temp duration 0.027 1.08 0.202 27 2 300 Long temp duration ~0.963 33.22 I 118 41 3 570 Reaction time tasks 0.072 2.87 0.013 13 2 312 Attentio!1iPerceptuai tasks ~0.197 7.81 0.305 78 6 1425 Mathematical tasks 0.037 1,48 0.091 38 4 462 Reasoning/Learning/Memory tasks ~0.774 28.05 1.209 71 6 616

~0.679 25.14 1.034 95 6 970

~0.082 3.27 0.068 69 1485 "mean effect difference between neutral and experimental temperature conditions; cvariance around the luean effect dnumber of effect sizes; cnumber of studies; fnumber of data points in experimental groups.

Table 5. Meta-analysis results for the Hot2 and Hot3 ,,,,,,"r;m"nt,,1 11" %Diff'>

Hot2/3 exposure ~0.312 12.25 0.528 167 12 1887 Short experimental session ~0.462 17.80 0.504 90 6 1040 Long experimental session ~0.128 5.09 0.498 75 6 839 No pre-task temp duration ~0.279 10.99 0.264 19 2 338 Short pre-task temp duration ~0.252 9.95 0.409 58 5 582 pre-task temp duration ~0.362 ~14.13 0.691 88 6 959 Reaction time tasks ~0.064 2.55 0.373 16 3 240 Attentio!1iPerceptuai tasks ~0.359 ~14.02 0.494 121 9 1483 Mathematical tasks ~0.358 13.98 1.234 26 2 120 Reasoning/Learning/Memory tasks 0.044 1.75 0.071 4 2 44

~0.462 17.80 0.695 112 6 1049

~O.l25 4.97 0.257 53 6 830 U mean effect difference between neutral and eXj>eriim,:ntal temperature conditions; cvariance around mean effect dnumber of effect cnumber of fnumber of data points in experimental groups.

exposure, respectively, as reported initially in table 2. As shown in tables 3 and 4, the general pattern for hot and cold environmental temperature exposure effects on performance was similar to the over-all results, with cold exposure resulting in a nelmtive effect on performance than hot exposure. However, when examining hot temperature exposure of 80°F (26.67 "C) WBGT or above (table 5), hot exposure

692 J. J. Pilcher et al.

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Cold2 Cold1 Hot1 Hot2 Hot3 Temperature Subcategories Figure 1. The mean percent difference in performance between the neutral temperature groups and the five temperature Cold2: 50 G F (IO G C): Cold I: 50 ~

64.9°F (IO~ 1 Hotl: 70~79.9°F WBGT; Hot2: 80-89.9c F (26.67~32.1 WBGT; Hot3: ;?:90"F had a slightly greater negative effect on performance than cold exposure. When comparing the cold (table 4) and the Hot2 and Hot3 temperature subcategories (table 5), the general pattern remained similar to the over-all results reported in table

2. Performance was worse under short temperature exposure conditions than under long temperature exposure conditions. Long pre-task temperature durations resulted in worse performance than either no pre-task temperature duration or short pre-task temperature duration for both hot and cold. Finally, worse performance was observed in short task durations than in long task durations. The biggest difference between hot and cold temperature exposure was seen in the mathematical and the reasoning, learning and memory tasks. Performance on mathematical-related tasks was worse under hot than cold environmental conditions. In contrast, performance on reasoning, learning, and memory tasks was more negatively impacted by cold exposure than hot exposure.

Finally, to emphasize the general effect of temperature extremes on performance, figure I presents the mean percentage difference for each temperature subcategory (the complete data for each of the temperature subcategories are presented in table As shown, the overall pattern of results is an inverted V-shape function bctween performance and the of temperature exposure. When across all moderator variables within each temperature , the inverted V-shape becomes almost perfectly symmetrical between the cold subcategories and the Hot2 and Hot3 subcategories. While the Hot I condition had very little effect on performance, the Cold2 and Hot3 temperature conditions resulted in the overall greatest decrement in performance.

4. Discussion The current results indicate that both hot and cold temperature exposure had a negative effect on performance in a variety of different types of tasks. As expected,

TeJ'J1{Jerurtw'e and performance 693 the detriment in perfonnance occurred under the coldest conditions ( 50 of

[lOOC]) and the hottest conditions ( 90 F D WBGT) a I3.9! % and a 14.88% average decrement, respectively. The Cold! (50~64.9DF [10 !8.28°C]) and Hot2 (80~89.9°F 32.1 WBGT) conditions resulted in a smaller decrement in performance, whereas the Hotl (70 79.9°F [21.11 WBGT) temperature condition had little effect on performance.

Furthermore, the effects of temperature exposure on performance varied by the type of task. Cold exposure ( 65°F [18.33°C]) resulted in a large negative effect on performance on reasoning, learning, and memory tasks whereas exposure to hot environments of 80°F (26.6TC) WBGT or above on average resulted in a small improvement in performance on these types of tasks. In contrast, attentional and perceptual tasks were more negatively affected by hot exposure ( 80°F [26.6TC]

WBGT) than by cold exposure. Similarly, performance on mathematical tasks and on reaction time tasks was negatively affected by hot exposure ( 80°F [26.67°C]

WBGT) but not by cold exposure. Although these data may seem confusing when attempting to break them down as was done in tables 4 and 5, figure 1 provides an easy way to estimate the effect of temperature exposure on performance. This inverted- U shaped function may be especially useful when examining a typical work environment where the employee may be involved in a variety of tasks and a variety of environmental conditions, such as length of task duration or length of temperature exposure, simultaneously. In this type of real world setting, figure 1 prOvides the best estimate of the effect of temperature exposure on performance.

Although the current results do not completely agree with previous narrative summaries, there is some degree of overlap. For example, in his recent reviews, Ramsey (Ramsey and Kwon 1992, Ramsey 1995) concluded that environmental temperatures of 86 to 92°F (30 WBGT had a negative effect on perfonnance of complex perceptual motor tasks but no consistent effect on mental/cognitive tasks or very simple perceptual motor tasks. With the exception of the mathematical tasks in thc current study, these results are generally in agreement with the current results. As Ramsey did not separate mathematical processing tasks as an independent task category, it is impossible to compare the current results with Ramsey's results on those type of tasks. Another review found that mental tasks are not affected by hot exposure in the range of 86 to 92°F (30 WBGT but monitoring, tracking and vigilance tasks are (Echeverria, et al.

1991). Again, these conclusions closely match the current data with the exception of the mathematical processing tasks category. Also similar to the current results, other narrative summaries have concluded that high temperatures resulted in more severe perfonnance decrements than more moderate temperatures (Grether 1973, Bell 1981 ,

Hancock 1984).

In contrast to the number of reviews on the effects of hot temperature exposure, few efforts have been made to summarize the effects of cold exposure on perfonn.ance. Earlier reviews examining the effects of cold exposure on performance found that more extreme cold exposure impairs perfonnance more than moderate temperatures (Fox 1967, Hancock 1984, Enander 1987). In general, the current meta-analytic results agree with these conclusions.

One of the advantages of the current quantitative review over the previous reviews is the ability to clearly examine the effects of different moderator variables on performance. Of the variables investigated in the current study, only the duration of the experimental session has been examined in narrative reviews. In his recent

694 J. J. Pilcher et al.

Ramsey (Ramsey and Kwon 1992, Ramsey 1995) concluded that the duration of exposure to heat was not related to . In contrast, the current results indicate that experimental sessions of less than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> had a stronger tlPtt,VP impact on performance than longer durations. Similarly, tasks durations of less than 60 minutes resulted in poorer than longer tasks. One possible explanation for these data is that people adjust to some extent to working under extreme temperature conditions and may actually improve their performance over time when the necessary task continues throughou t the temperature exposure time.

This would indicate that in working environments that involve extreme temperature exposure, worse performance would be expected at the beginning of the working day than later in the day.

However, the current data also suggest that performance after a pre-task temperature duration of at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> was substantially worse than performance either immediately upon exposure to the temperature or performance within one hour of exposure to the temperature. These results would suggest that exposure to extreme temperatures prior to a specific task onset would likely bring about substantially worse performance on the new task. This would indicate that workers may need to perform the task in the temperature condition in order to adapt to the working environment and improve performance. This could be especially problematical in industrial environments where workers may be performing relatively routine tasks for a period of time under an extreme temperature condition, but after a period of exposure would not be able to completely apprehend and respond to changing parameters and performance criteria on the job.

The current results suggest that to better understand the effects of temperature exposure on performance it is necessary to better document the effects of moderator variables on performance, especially variables concerning temperature and task duration. There are also other variables that may impact performance under extreme temperature conditions such as level of acclimatization to the temperature, level of personal arousal, amount of body temperature ehange brought about by temperature exposure, and level of training on the task. The current study could not investigate these potential moderator variables because most studies either did not report these types of data or did not report the data in enough detail for a meta-analysis. More comprehensive meta-analyses can be completed when more studies have been published with full descriptive data.

Perhaps the major limitation of the current investigation was that many primary studies that may have been used in narrative summaries were rejected from the current meta-analysis. As explained in the methods section, rejecting many primary studies is a common occurrence in a meta-analysis. Although it is not necessary to include all possible primary articles in a meta-analytic review, it is important that a bias not be introduced inadvertently into the data. Because the studies rejected in the current meta-analysi s were rejected according to rules designed to result in a scientifically sound meta-analysis, there is no a priori reason to assume that the articles rejected were systematically different in their results from the ones that were included. In addition, where they are comparable, the current overall results agree with many recent narrative summaries, indicating that the current data base was similar to the ones examined in the narrative summaries. The best way to solve this limitation is for future primary studies to include full descriptive data. This would allow for more studies to be included in a future meta-analysis and more moderator variables to be examined.

Temperature and performance 695 In summary, the curren t meta-analyti c review on the effects of hot and cold temperature exposure on performance supports four major conclusions. First, the effect of cold and hot temperature exposure resulted in an inverted U-shape function with cold exposure of 50°F (lODC) or less and hot exposure of 90°F WBOT or more in the worse performance. In contrast, between 70 and 79.9°F (21.11 26.61°C) WBOT resulted in very little effect on performance.

Second, temperature exposure had a differential effect on different types of tasks with hot exposure of over 80°F (26.67°C) WBOT having the most negative effect on attentional and perceptual type tasks and mathematical processing tasks whereas cold exposure of less than 65°F (l8.33°C) had the most negative effect on reasoning, learning, and memory tasks. Third, short exposure to temperature conditions and short task durations resulted in worse performance than longer durations. Last, pre-task temperature exposure of more than 60 minutes resulted in a substantial decrement in performance. These data that industries requiring workers to perform under either hot or cold temperature conditions should be aware of the potential negative effects of temperature exposure on performance.

Acknowledgements This paper was supported by the Federal Railroad Administration's Office of Research and Development. The views of the authors do not purport to reflect the position of the Federal Railroad Administration or the Department of Transporta-tion. We thank Dr. Thomas Raslear for his valuable comments on the data and the manuscript.

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ATTACHMENT 4 Excerpt from NRC Letter Dated October 31,2007

UNl'1'KD STATJES NUCLB.U UGULATORY COMMISSION RSOIONU SAM NtJNN A'ILANTA FBDBRAL CBNTBR 61 :flOR$YI1I S'l'UBT. sw. SurrB 2311S A11..ANTA. 0I0R0lA 30303-8931 EA..()7..173 Southem Nuclear Operating Company, Inc.

Joseph M. Farley Nuclear Plant ,~

ATTN: Mr. J. Randy Johneon VIce President .. Fartey 7388 Narth State Highway 96

'Columbia. AL 38319

SUBJECT:

FINAL SIGNIFICANCE DETERMINATION FOR A YEll.OW FINDING AND NOnCE OF VIOLAnON (NRC INSPECTION REPORT NOS.

05000348I2001011 AND 05000SfW200101', JOSEPH M. FARLEY NUCLEAR PlANT)

Dear Mr. Johneon:

The purpoee of th. letter. to provide you the final reeulta of our 81gniffcance determination of the preliminary Yellow ffrdng identified In NRC Inspection Report 05000348,3&412007009, a.

issued on AuguIt 2007. The In8peotlon finding W88 _8888d using the Significance Determination PraceIe end . . preliminarily char8cterized .. Yellow, a ffndng with 8Ub8tantlal 1mp0rtanc8 to I8fety that could result In adc:ItIonaI NRC InepectJone and potentially other NRC action. Thill preliminary Yellow finding Invofved the faIIU... to promptly identify and correct a significant condition adverse to quality which resulted In the Unit 2 Relldu81 Heat Removal (RHR) train A contannent lUmp suction valve failing to stroke fuI open on AprtI29. 2008. and January 5. 2007.

a.

At yoUr requeet, a Regulatory COnference W88 held on September 1 2007, with Southem Nuclear Operating Company, Inc. (SNC). to bther dl8OlJ88 yoar vfewa on this 1a8ue. A copy of SNe's p.... entatlon material and

• listing of attendeel at the con1erence .... enclosed. During the meeting SNC described Ita 88lllement of the 8Igniffcance of the finding. Ita root cause evaJuaUon of the wive fatIIJr8I, and detailed correctfw actions to preclude l'BCUrrence.

, At the Regulatory Conference. SNC provided Ita p8I8peCIIv8 qn aaveraI 88p8Ct8 of the

, preliminary significance determination. SpeclflcaIIy. SHe maintained that:

An adjuslment In the riIk 88888811'18nt U to commo.n C8IJI8 of the motor operated valve (MOV) faIu... WIll not jU8tffted baled on new information and anaIy&ia developed from the llcen888's contInt*lg root C8U88 8Y81uat1cn. the orfgNI equipment manufacturer's EMIIuatIon of the PlDY torque switch. an off..8lte Motor Repair Facilly motor 1n8peotlon.

and a thJrd.party ~ conadI8nt technical nrvI8W of the common 08U88 EMIIuatIon. Bued on .... SNC concluded that the opposite AHR train IUCtfoR MaY would not be 8ffeated by a common cause faIIu.... thereby reduoing the overall ch8ngeln

• core damage frequency (CDF).

SNe 4 Pracdee.* a copy of thlB letter, Its enctosu..... and your response, If you choose to provide orle, wI. be made avaUabIe electronically for public inspection In the NRC Public Document Room or from the NRC'. document ayBtem (AOAMS), 8CC881ib1e from the NRC Web site at ymw.nrc.goylreac:lng=rrnlAdr.btml www.nrp.gaylrwlng-nnladlms.html. To the extent poeaIbJe, your response should not include any personal prfvacy, proprietary, or safeguards ilformation so that It can be made availeble to the Public without redaction.

Docket Nos.: 60-848, 50-384

~ Noe.: NPF-~, NPF-8 EncIoeuree:

1. lJcenaee presentation material

2. U8t of Attendees S. NotIce of Violation ccwJenc18:

B. O. Mct<Jnney, Ucenslng SsrvICIJI Manager, 8-031 Southern Nuclear Operating Compeny, Ino.

42 Invem. . Center Parkway Blrrnlnghem, At SI5201-1296 General Manager, Farley Plant Southern NucIe8r OperatIng Compeny, Ina.

P. O. Box 1296 Binnln~ At SI5201-1296 J. T.Gaeaer ExecutIve VIce Pre8kIent Southern Nuclear OperatIng Company, Ina.

P. O. Box 1296 Binnlnghun. At 36201-129t5 MoanIca CutDn Southern Nuctear 0pendIng Company, lno.

Bin B-022 P, O. Box 1296 Birmlngh8m, At S8201-1295 (co wJencI ccnt'd - see Page 5)

Farley Nuclear Plant Regulatory Conference Unit 2 RHR MOV8811A Preliminary

.Yellow Finding September 12, 2007 sovntlERNA COMPANY Iillngy til Sttrr. Jiur """,.lJ":

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