ML17261A944
| ML17261A944 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 02/02/1990 |
| From: | Eselgroth P, Norris B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17261A943 | List: |
| References | |
| 50-244-89-80, NUDOCS 9002140184 | |
| Download: ML17261A944 (42) | |
See also: IR 05000244/1989080
Text
U. S.
NUCLEAR REGULATORY COMMISSION
INSPECTION REPORT
FACILITY DOCKET NO ~
INSPECTION REPORT
NO.
FACILITY LICENSE NO'.
LICENSEE:
FACILITY:
INSPECTION DATES:
50-244
50-244/89-80
Rochester
Gas
and Electric Company
49 East= Avenue
Rochester,
14649
Ginna Nuclear Power Station
1503
Lake Road
Ontario,
14519
September
25 - October 4,
1989
INSPECTION TEAM:
Team Leader:
Team Members:
BE
So
F
P ~
L
E ~
G.
W.
CD
M.
BE A.
N
S ~
Norris, Senior Operations
Engineer@
NRC
Bonnett, Operations
Engineer,
NRC
Briggs, Senior Operations
Engineer,
NRC
Lapinsky,
Human Factors Specialist,
NRC
Meeker,
Systems
Engineer,
COMEZ
Paramore,
Human Factors Specialist, SAIC
Perry,
NRC Resident Inspector,
Ginna
SUBMITTED BY:
Barr
S. Norris
Date
Sen
o
Operations
Engineer,
PWR Section
O
APPROVED BY:
Peter
W. Eselgrot
Chief
PWR Section,
Ope
tions Branch
Division of Reac or Safety
Date
Ins ection
Re ort No. 50-244
89-80
TABLE OF CONTENTS
Section
Pacae
1 ~ 0
Executive
Summary ...................................
1
2 '
Basic Comparison of Owners~
Group
~
~
wz.th Facxlxty EOPs ..................................
1
3 '
Independent
Technical Adequacy Review of
the Emergency
Procedures ............................
2
4.0
Review of the Emergency
Procedures
by.
Control
Room and Plant Walkdowns
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2
5 '
Simulator Observation
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6
6.0
On-Going Evaluation of the Emergency
Procedures
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9
7 ~ 0
EOP User. Interval.ews .................................
14
8 '
Management
Meetings .................................
15
9 '
Personnel
Contacted .................................
16
Attachments
Documents
Reviewed ..................................
17
Deficiencies Identified Within
Emergency
Procedures
the
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2 3
3
Deficiencies Identified Within
Writers
6 Users
Guides
the
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3 3
Abbrev'.ations
& Acronyms ............................
37
List of Weaknesses
Identified .................; ......
39
Ins ection
Re ort No. 50-244
89-80
DETAILS
1 '
EXECUTIVE SUMMARY
A special,
announced
team inspection .was conducted of the
Ginna emergency
procedures.
The purpose of the inspection
was to determine if the emergency
procedures
used at Ginna
were technically correct; if their specified actions could be
physically accomplished
using the existing equipment,
controls
and instrumentation;
and if the available procedures
had the usability necessary
to.provide the operators with an
effective operating tool.
For this inspection,
the term
emergency
procedures
included the EOPs,
APs,
ERs,
and all
procedures
referenced,
either explicitly or implicitly,
within the
EOPs,
APs,
and ERs.
The inspection consisted of
reviewing over 150 facility documents,
observing
two
operating
crews in the site specific simulator,
and
interviewing sixteen facility personnel.
The overall assessment
is that the Ginna emergency
procedures
in place at the time of the inspection, with minor
modification as indicated,
are
an example of a well designed
program that has
been properly implemented.
The procedures
were well written and the operators
were able to ut'ilize the
procedures,
during the simulator observations,
to mitigate
the accidents.
At the exit meeting
on October 4,
1989, the
team leader stated that the program for development
and
implementation of the emergency
procedures
was noteworthy.
No violations or deviations
were identified as
a result of
the inspection.
2 '
BASIC COMPARISON OF OWNERSI
GROUP
WITH FACILITY/S EOPs
PURPOSE:
To ensure that the licensee
had developed
sufficient procedures
in the appropriate
areas to cover the
broad spectrum of accidents
and equipment failures.
2.1 The listing of Ginna
was compared to the
Owners~
Group
(WOG) list of Emergency
Response
Guidelines
(ERGs),
Low Pressure
Version,
Revision
1A, to ensure that the licensee
had developed
procedures
in accordance
with the
WOG recommendations.
2.2 It was noted that two of the
ERGs were not listed in the
Table of Contents for the Ginna EOPs.
The team reviewed
the justification and background
documents,
and discussed
the exclusion of the two ERGs with the facility.
Specifically:
Ins ection
Re ort No. 50-244 89-80
The justification for the exclusion of ES-0.4,
Natural Circulation Cooldown with Steam Void in
Vessel
without RVLIS , was based
on the fact that
RVLIS is a recpxirement of the Ginna Technical
Specifications
and
a procedure for operations without
RVLIS, was not necessary.
The justification was not
considered
adecpxate
due to the possibility that RVLIS
could become inoperable.
The facility has agreed to develop
a procedure for
the case
when RVLIS is inoperable.
The weakness
identified above will be tracked
as
Open Item No.
50-244/89-80-01.
b.
The justification for the exclusion of ES-1.4,
Transfer to Hot Le
Recirculation
, was based
on the
fact that the contents of ES-1.4 were included in the
facility~s version of ES-1.3.
The justification was
considered
acceptable
and this item is considered
closed.
3
0
INDEPENDENT TECHNICAL ADE UACY REVIEW OF THE EMERGENCY
PROCEDURES
PURPOSE:
Review the emergency
procedures
to assure that
procedures
are technically adecpxate
and accurately
incorporate
the guidelines of the
ERGs.
The emergency
procedures
listed in Attachment
1 were reviewed
to ensure that the procedures
were technically adequate
and
accurately incorporated
the guidelines of the
as
appropriate.
Each deviation from the
ERGs was reviewed to
ensure that differences warranted
by the plant specific
design were incorporated,
that safety significant deviations
were reported to the
NRC as required,
and that prioritization
of accident mitigation strategies
was correct.
In general,
the
EOPs were technically adecpxate
and accurately
incorporated
the procedural
guidance of the
ERGs.
There were
some instances
where the documented justification was missing
or inadequate.
The specific instances
are considered
minor
and are discussed
in paragraph
4.2.
4 '
REVIEW OF
THE EMERGENCY PROCEDURES
BY CONTROL ROOM AND PLANT
WALKDOWNS
PURPOSE:
To assure that the emergency
procedures
can be
successfully
accomplished.
Ins ection
Re ort No. 50-244
89-80
4.1 Licensed
and non-licensed
operators
were used to walkdown
the procedures listed in Attachment 1.
The walkdowns
were conducted in the control room and in the plant to
ensure that:
actions required by the procedure
could be accomplished
using the installed equipment,
instrumentation
and
controls;
and
- procedures
were easily accessible
and procedural
guidance
was clear and detailed
enough to avoid
operator confusion
and error.
No instances
were identified where the step could not be
performed using the installed equipment,
instrumentation
and controls;
however, three problems associated
with
plant equipment
were identified that could lead to
operator delay or uncertainty during task performance
(see paragraph
4.2).
Also, during the
EOP walkdownsg
several
minor generic deficiencies
were identified and
are discussed
in paragraph
4.3.
All of the deficiencies
identified were considered
minor and did not, in any
identified case,
prevent the operator
from completing the
required action.
4.2 Procedural Deficiencies Identified during the Walkdowns
a.
The CI/CVI Bright-is-Right panel is referenced in
several
as
a verification of valve isolation.
This panel,
and three other panels,
are located
on
the left-center,
upper section of the control panels.
The CI/CVI panel contains
two lights that are not
isolation valves
and eight lights that remain dark
because
the valves are closed
and de-energized.
In
addition, there are seven isolation valves that are
not on the CI/CVI light panel,
but are located either
on one of the other three panels
(which contain
numerous other valves) or, in one case,
on the lower
left-center section of the control panel.
The licensee
had previously identified this problem,
and stated that improvements
had been
made during a
recent modification.
The licensee
agreed to take
further actions to make the CI/CVI valves
more easily
identifiable.
The weakness identified above will be
tracked
as
Open Item No. 50-244/89-80-02.
b. It was noted that most valves that had to be manually
manipulated
when using the emergency
procedures
could
be accessed.
However,
a few valves were identified
where operation of the valve would be difficult
without installation of a ladder or platform:
(1)
Ins ection
Re ort No. 50-244
89-80
the upstream trap isolation valves would require the
operator to stand
on a piece af angle iran (because
the area
was too cramped to use
a ladder)
and
(2) the
isolation valves for the steam- to the turbine driven
pump require climbing over hot
steam piping.
The team noted that these valves could
be operated,
but that the hazardous
conditions might
cause
the
AO to become incapacitated.
The licensee
agreed that these valves,
along with a
few others,
were difficult to reach.
The licensee
agreed to evaluate
the accessibility of in-plant
valves that are required during implemention of the
and to provide the appropriate
improvement to
allow the operator accessibility.
The weakness
identified above will be tracked
as
Open Item No.
50-244/89-80-03.
c.
The Main Steam Line radiation monitors
(R-31/32)
chart recorders
do not function unless
the alarm
point is reached,
although the chart recorders
do
have power.
Thus,
any change in the steam line
radiation cannot
be trended until an alarm condition
has
been reached.
Additionally, the indicator
(recorder
pen) is not visible to the operator,
even
when close up.. This presents
a problem when trying
to monitor the readings
because
the operator, must
wait for the chart paper to advance far enough to be
read,
approximately
5 minutes.
The licensee
agreed that the steam line monitors
presented
a problem during normal and alarm
conditions.
The licensee
committed to evaluating the
monitors
and resolving the problem.
The weakness
identified above will be tracked
as
Open Item No.
50-244/89-80-04
4.3 Deficiencies associated
with the procedures
were divided
into two categories,
generic procedural deficiencies
and
deficiencies related to a specific procedure.
All
procedural deficiencies
were discussed
with the licensee
prior to the exit meeting.
The licensee
committed to
evaluate
and correct
each deficiency, 'as warranted.
In
some cases,
the licensee
had already identified the
deficiency and corrective action had been started.
Those
deficiencies related to a specific procedure
are listed
in Attachment 2, generic deficiencies
are listed below:
Ins ection
Re ort No.
50<<244
89-80
a ~
The level of detail was not consistent
between the
attachments
to the
and the
EOPs themselves.
The
EOPs normally contained valve numbers,
as required by
the writers guide, while the attachments
did not.
The
EOPs normally gave annunciator locations, while
the attachments
did not.
In addition, during the
valkdovns,
most operators
stated that the noun name
of the valve along with the valve number would assist
in locating the component.
h.
When a special
key is required for performance of a
task,
the
and the attachments
do not specify the
need for the key; e.g., to enter the hydrogen monitor
cabinet.
C ~
The deficiencies
associated
with the labeling of
components
were observed to be minor and are divided
into two categories:
(1)
a few components
had no
label,
such
as the
DC power panels in the auxiliary
building; and
(2) there
was
a mismatch between what
the procedure called
a component
and what the
component
was actually labeled.
In most cases,
this
vas considered
a problem vith the procedure,
because
the facility has
an adequate
labeling program in
progress.
Most of the discrepancies
observed
were
outside the control room and associated
with the
attachments
to the procedures.
-The control room has
been almost completely relabeled
and color coded.
d 0
The word >>normal>> is used in the
EOPs to determine if
plant conditions require operator actions;
however,
the >>normal>> conditions that the operator, should
expect are not clearly defined.
Different. answers
vere obtained
from several
operators
vhen asked what
normal meant.
e.
Most of the valves
on the control boards indicate
a
mid-position by both lights lit, but there are
a few
valves that indicate mid-position by both lights
extinguished.
There is no indication on the boards
as to which method is used for the various valves.
The licensee
agreed with all of the above
comments
and
committed to evaluating the deficiencies
and correcting
the deficiencies,
as appropriate.
The weaknesses
identified above
and those listed in Attachment
2 will he
tracked
as
Open Item No. 50-244/89-80-05.
~
Ins ection
Re ort No. 50-244
89-80
4.4 The fare procedures
at Gonna are contained within the
series of Site Contingency procedures.
Although not
directly associated
with the emergency
procedures,
the
stationis fire procedures
were reviewed for possible
impact on the operations staff during emergencies.
The
fire procedure give extensive directions for fighting
fires in specific areas of the plant; but due to the vast
number of procedures
and the complex index, the operators
generally ignore them.
Based
on interviews,
upon receipt
of a fire alarm, the control room operators usually refer
to SC-3.1.1, Fire Alarm Res
onse
Fire Bri ade
determine the specific procedure for a particular
location, the operator then has to refer to SC-3.1, Fire
Emer ehc
General Information.
The procedures
are
divided into two general categories,
one for the fire
brigade response
and one for the control room response.
The procedures
for use by the control room operators
have
information that could be helpful, such
as what equipment
might be affected by the fire in that area.
The
procedures
were not organized to be easily used.
The licensee
acknowledged
the above
comments
and 'stated
that they would evaluate
the current organization of the
procedures.
The weakness identified above will be
tracked
as
Open Item No. 50-244/89-80-06.
5 '
SIMULATOR OBSERVATION
PURPOSE:
To assure that emergency
procedure training
provided the operators with the necessary
information
background
and to ensure that the emergency
procedures
can be
correctly implemented under emergency conditions.
5.1 Utilizing the site-specific simulator,
the team assessed
the adequacy of the training on the emergency
procedures
by observing the actions of two crews of licensed
operators
during unrehearsed
scenarios
designed to
exercise
the crews familiarity with and their ability to
utilize the emergency
procedures.
5.2 The scenarios
were developed with the intent of providing
the team with an opportunity to:
Determine if the procedures
provided the operators with
sufficient guidance to perform their required actions.
- Assess
the licensee~s
operating philosophy with respect
to the emergency
procedures,
especially
where initial
reviews
had identified differences
from the
Ins ection
Re ort No. 50-244
89-80
7
- Assess
the crews ability to use the
and transition
to another
EOP or other procedure,
as required.
- Observe the crews ability to perform-the
emergency
procedures
with the minimum crew manning allowed by
technical specifications
and administrative procedures.
- Assess
the human factors element associated
with the
performance of the procedure in a >>real time>>
situation.
5.3 The scenario
sets
consisted of:
First Crew
lt
Scenario
1: Complete
Loss of Instrument Air, Reactor Trip
with. Three Stuck Control Rods
(E
Op
FR
S ~ 1g
0 ~ 1p
Scenario
2:
Scenario
3:
Scenario
4:
Both Steam Generators
Faulted inside
Containment,
Loss of All AFW Pumps
(E
Og
FR H 1g
1')
Primary Leak into CCW, Fire in >>A<< Diesel
Generator
Room,
Loss of All AC Power
(ECA 0' Og
AP CCWo1~
SC
3 '
')'team
Generator
Tube Rupture,
RCP Seal
Failure.
(E
0~
E
1g
E
3g
FR
C ~ 1~
~ 1g
AP RCPo 1g
AP-CVCS ~ 1)
Second
Crew
Scenario
1:
LOCA Outside Containment
(E
Og
ECA 1'p
ECA 1')
Scenario
2: Faulted
and Ruptured
Loss of
All AC Power
(E
Og
E
1p
E 2g
E
3~
0 'g
ECA 0'~
ECA 3 ~ 1g
FR
Z ~ 1)
Scenario
3: Loss of Vacuum, Fire in the
>>A>> Diesel
Generator
Room,
Loss of All AC Power
(ECA 0 ~ 0~
AP CWo1~
AP TURB 4~
SC
3 ~ 1 ~ 1)
5.4 Obser'vations:
a.
Both crews were able to utilize the emergency
procedures
as required.
There was no hesitancy to
enter the functional recovery procedures
when
required.
Ins ection
I
b.
C ~
d 0
e.
Re ort No. 50-244
89-80
Both crews displayed clear and concise
communication
skills.
This included directions,
repeat
backs
and
acknowledgment that the communication
was understood.
Both crews displayed
good procedural
adherence
throughout the scenarios,
and due to the diagnostic
approach of the emergency
procedures,
they were able
to correctly address
the problem.
This was
especially evident when the operators
were confronted
with a,condition that could have drawn their
attention toward
a suspected
area that was not in
sequence
with the EOPs.
Both crews were required to perform with the minimum
crew allowed, by technical specifications
and
administrative procedures
(i.e.
CRF(
HCO
CO)
2
AOIs, and a communicator).
Both crews performed
satisfactorily.
One scenario
placed
each
crew in the condition of
combating
a fire.
The fire brigade is manned by two
AOIs,=which under minimum manning conditions, results
in the plant being without any qualified operators
readily available for local operations.
The scenario
was then compounded
by a loss of all AC power.
Under'hese
conditions,
the Shift Supervisor
on each shift
made the decision to reduce the manning
on the fire
brigade by re-assigning
one
AO to perform local plant
operations.
f.
The team noted two inconsistencies
in the simulator:
Simulated communications with the
AOs used the page
system
and telephones;
in plant, radios are carried
by the AOs.
The simulator had recently incorporated
the use of
radios
as
a part of training within the last month
and has experienced
some problems.
The use of
radios is planned for subsequent
training cycles.
The operators .stated that they did not believe the
timeliness of the simulated
feedback
from the
was accurate.
go
When an
EOP is revised,
the required operator
training was determined jointly between the
Operations
Manager
and the Training Manager.
However, the criteria used to determine which type of
training was appropriate
(i.e.', required reading,
classroom training, or simulator exercise)
had not
been formally established.
Ins ection
Re ort No. 50-244
89-80
h.
The,use of the
STA du
9
ring training of the shift crews
was not consistent.
Three of the six operating
crews
trained regularly with a qualified STA, the remaining
crews trained with an instructor acting as the
STA.
This method
does not provide for consistent
performance by'the plant crews
and STAs.
i.
The team noted the following simulator differences:
- Two MOV indicator lights on the status
section of
the
MCB are mislabeled.
MOV-825A and MOV-825B are
labeled
>>open>> where in the control room they are
labeled >>closed>>.
The facility has
an an-going
labeling program which corrects discrepancies
, between the control room and the simulator.
- The fire alarm status
panel in the control room has
a white strobe light and an audible alarm
associated
with it that is not simulated.
The
strobe light and audible alarm are-both
new
modifications
added to the control room within the
last year.
The training department
has submitted
the proper requests
to have the simulator upgraded.
The site evacuation
alarm is muted in the
control'oom,
but sounds in the simulator.
A new
modification was added to the control room that
mutes the site evacuation
alarm.
The weaknesses
identified above will be tracked
as
Open
Item No. 50-244/89-80-07.
6 '
ON-GOING EVALUATION OF
THE EMERGENCY PROCEDURES
PURPOSE:
Determine if the licensee
has established
a long
term evaluation program for the emergency
procedures
as
recommended
in Section 6.2.3 of NUREG-0899.
6.1 A review of the Ginna Stationis
system of ongoing
evaluation
and revision of EOPs
was conducted to assess
whether the licenseeis
current system could ensure
high
quality EOPs over time.
The system
was evaluated
on the
basis of a number of elements,
including but not limited
to:
The method for ensuring that changes in plant design,
technical specifications,
technical guidelines,
the
writers guide, referenced plant procedures,
and the
control room are promptly reflected in the EOPs.
The method/procedures
for revising the
E'OPs.
.
Ins ection
Re ort No. 50-244
89-80
10
The timeliness of revisions to the
when incorrect
or incomplete information is identified.
The adequacy of the system for determining necessary
training when procedures
are changed or revised.
- The adequacy of basis
documents,
including technical
guidelines
and writers guide.
- The adequacy of the verification and validation
program.
The effectiveness
of the system of soliciting and
utilizing feedback
from procedure
users
and other
cognizant personnel.
The control over the use of emergency
and abnormal
procedures.
6 '
The team determined that most aspects
of Ginna~s
program
for ongoing evaluation of EOPs were well done.
Positive
program features
included:
r
h
- the quality of the Writers Guide;
- the use of'he Writers Guide for preparation of
abnormal procedures,
as well as
emergency
procedures;
the designation of an Operations staff member with full
time responsibility for ongoing management
of
the'mergency
procedures
program, including coordination of
WOG-ERG revisions, receipt
and response
to all requests
for changes,
and tracking of all changes
from
initiation to final approval
and issuance;
the establishment
of an Emergency
Procedures
Committee,
reporting to the Plant Operations
Review Committee
(PORC), to address
needs for revisions to the emergency
procedures;
and,
the implementation of an administrative procedure that
. defines the requirements for ongoing control of the
preparation
and revision of emergency
and abnormal
procedures.
The team did, however, identify needs for improvement in
several
areas.
The areas of concern are explained in the
following paragraphs.
Ins ection
Re ort No. 50-244
89-80
6.3 Writers Guide and Users
Guide
To assure
the written accuracy
and consistency of the
EOPs over time,. a writers guide should clearly and
explicitly define every aspect of procedure
content
elements,
organization,
format,
and style.
Administrative procedure A-502.1,
Emer enc
and Abnormal
0 eratin
Procedures
Writers Guide,
was found to cover
the relevant procedure
aspects
and, for the most part, to
provide clear, explicit, detailed guidance.
Howeverr
there
was no formalized process
to ensure. that changes
to
the Writers Guide are reflected in the procedures.
Reviews
and revisions to incorporate Writers Guide
changes
are conducted at the discretion of the
coordinator.
Review for conformance to Writers Guide
changes
was not incorporated into the A-601.4, Procedure
Control - Periodic Review,
and A 601 '@ Procedure
Control
of Emer enc
6 Abnormal Procedures.
The users
guide, administrative procedure A-503.1,
Emer enc
and Abnormal 0 eratin
Procedures
Users
Guide
was found, in general,
to contain appropriate,
complete,
and detailed information.
6
4
Specific weaknesses
related to the writers guide and the
users
guide are detailed in Attachment 3.
The weakness
identified above
and those listed in Attachment
3 will be
tracked
as
Open Item No. 50-244/89-80-08.
A variety of design
and operational
changes
can affect
emergency
procedure
requirements.
A systematic
process
ensures
that the emergency
procedures
are kept current
with respect to changes
in plant design,
control room
layout, technical specifications,
and associated
procedures
are promptly and accurately reflected in the
emergency
procedures.
It was concluded that the licensee
has established
appropriate
processes
to ensure that these
types of
changes
are reviewed for impact on the emergency
procedures
and that necessary
procedure
changes
are
incorporated in a timely manner.
There was one exception
to this overall finding, in that, there is no mechanism
to ensure that changes
in >>satellite procedures>> will be
reviewed to determine their impact on the emergency
procedures.
(<<Satellite procedures>>
are procedures
outside the emergency
procedure
set that. may be used in
conjunction with or entered
from an emergency procedure.)
The weakness identified above will be tracked
as
Open
Item No. 50-244/89-80-09.
12
6 '
The processes
for procedure
changes
were defined
appropriately by administrative procedures
(A-601.2
through A-601.4 and A-601.6) with one exception.
Most
station procedures
are issued
and revised in accordance
with A-601.1,
and A-601.2; however, the governing
document for the
and
AOPs is A-601;6, Procedure
Control of Emer enc
& Abnormal Procedures,
was not
referenced in A-601.1 and A-601.2.
The weakness identified above will be tracked
as
Open
Item No. 50-244/89-80-10.
6 ~ 6
6 '
It was determined that Ginna had an effective process for
obtaining feedback
about the emergency
procedures
from
both operations
and training departments; i.e., personnel
submit concerns
and change
recpxests,
in writing, to the
Emergency
Procedure
Coordinator.
If a change is
determined to be necessary,
the Coordinator prepares
the
required
change
forms to initiate the process.
The
process
appeared
to be working smoothly because
of the
present
Emergency
Procedure
Coordinator.
To ensure that
this,
and other established
practices,
are not lost due
to staff changes,
they must be formalized in a written
description of the Coordinator~s
functions
and
responsibilities.
Verification and Validation
(V&V)
Thorough verification and validation of new procedures
and of significant changes will ensure
(1) adherence
to
the basis
documents (i.e., the technical guidelines
and
writers guide);
(2) that the language
and level of
information is appropriate for the users;
(3) that there
is a correspondence
between the procedures
and the plant
hardware;
and
(4) that the procedures will function as
intended.
In general, it was determined that Ginna had
an appropriately defined program to meet these objectives
for the emergency
procedures.
Ongoing V&V requirements
are delineated in A-601.6, Procedure
Control of Emer enc
and Abnormal Procedures.
However,
some weaknesses
were
identified,
as follows:
a.
Satellite procedures
(i.e., Equipment Restoration
Procedures)
and attachments
did not always receive
the
same level of V&V as did the emergency
procedures.
The verification checklists of the
procedure,
Attachments
1 and 2, addressed
both
referenced
procedures
and attachments.
The
validation checklist, Attachment 3, addressed
neither.
A-601.6 does not require that satellite
procedures
and attachments
be included in both
validation and verification.
Ins ection
Re ort No. 50-244
89-80
13
A-601.6
(paragraph
3.2.4) stated that V&V was not
required for ~~minor changes~~ but the procedure did
not explicitly state that
V&V was required for major
changes.
,It w'as noted that V&V was being conducted
for major changes.
c.
A-601.6
(paragraphs
3.4.1.1
and 3.4.4.10)
allowed for
tabletop validation of changes.
A tabletop review is
not an acceptable
alternative to a walkthrough
validation.
The licensee
stated that tabletop
reviews were not used
as
a method of validation.
d.
A-601.6 describes
a scenario-based,
team approach to
validation..
However, there is to provision to ensure
human factors expertise
on the team.
The weaknesses
identified above will be tracked
as
Open
, Item No. 50-244/89-80-11.
6.8 Independent
Quality Group Involvement
In order to ensure
adequate
review of procedures,
an
independent quality review must be incorporated into both
the development
and the ongoing maintenance
of the
procedures.
-It was noted that the
QA organization
audited the initial EOP development
process in 1987.
More recently, in Septemberg
1989@
QA audited .the
process
connected with the incorporation of .changes
resulting from Revision
1A of the Westinghouse'Emergency
Response
Guidelines.
The audit, encompassed
a review of
the technical
changes
and the training associated
with
those
changes.
The results of recent audit indicated
that it was'performance
oriented
and that it identified
valid findings.
Ginna has initiated a pilot program in which a
engineer is dedicated to the surveillance of all aspects
of the Operations organization; i.e., operating
procedures,
training,
and conduct of operations.
If
continued, this will provide a continuing independent
oversight function in a number of areas,
including EOPs.
The
QC engineer
who is presently
assigned is also
a
member of the Emergency
Procedures
Committee
and will be
aware of any proposed
major change.
6.9 Control Over the Use of Emergency
and Abnormal Procedures
a.
Although it was concluded that the standard for
emergency
procedure
adherence
was verbatim
compliance,
except
as allowed by regulation,
the
policy was not included in the controlling procedure,
A-503, Plant Procedure
Adherence
Re uirements.
Ins ection
Re ort No. 50-244
89-80
14
b
A-503-.1,
Emer enc
and Abnormal 0 eratin
Procedures
Users
Guide,
was found to provide adequate
guidance
for the understanding
and use of the
EOP and
format and style conventions,
with one exception.
It
was determined that not all operators
had a clear
understanding
of some of the action verb used in the
and AOPs.
Specifically, the operators
were
unclear about the differences
between
>>ensure,>>
>>verify, >> and>>check. >>
c.
The licensee
had not established sufficient means of
ensuring that only the most current,
approved
revision of a procedure
would be used.
Three
specific concerns
were identified:
There is no positive control of copies of the
procedures
to ensure that they not kept by
individuals and reused.
- There is no way to verify that the most current
revision of attachments
has been obtained.
Although issued
as part of a procedure,
attachments
are maintained
and revised
as separate
documents in
the revision/change
process.
Thus,
attachment
revision numbers
may differ from the main body of
the procedure.
The index of the procedures
does not
state
the revision numbers of attachments.
- The mechanism in place at the time of the
inspection to ensure that the Procedure
Index was
kept up-to-date
needs
improvement.
One instance
was found during the inspection in which a new
revision was in the file but the Index listed the
previous revision.
7 '
USER INTERVIEWS
PURPOSE:
To augment
and clarify findings from other
inspections
tasks
through interviews with procedures
users,
developers,
trainers,
and other appropriate plant staff.
Interviews were conducted with seventeen
Ginna personnel,
including reactor operators,
senior reactor operators,
auxiliary operators,
shift technical advisors, training
instructors,
QA engineers,
and facility management.
The
interviews were used both to corroborate
and augment
inspection findings.
The specific results of the interviews
are reflected in the appropriate
sections of the inspection
report.
Ins ection
Re ort No. 50-244
89-80
8.0 EXIT MEETING
October
4
1989
15
All of the findings had been previously discussed
with
facility management prior to the exit meeting.
The major
inspection findings were reviewed for,the plant management,
and the remainder of the findings were summarized.
The
NRC
team leader
asked the Senior
VP reconfirm the commitments
previously made with respect to the deficiencies
noted.
In addition to the noted weaknesses,,the
NRC summarized
several
areas of strength within the program:
The procedures
were technically correct,
and deviations
were generally well documented;,
The writer guide and users
guide were well written;
The'abnormal
procedures
had been incorporated into the
writers guide;
Use of metal binders to hold the emergency
procedures,
lending to ease in place keeping;
Labeling in the control room and in plant was aggressive;
Personnel
were knowledgeable
and cooperative;
During the simulator observations,
the team observed
good
communications
and procedural
adherence;
and
The training and operations
departments
interacted well
with respect to incorporation of recommended
changes-.
U
Ins ection
Re ort No. 50-244
89-80
9', PERSONNEL
CONTACTED:
~ Licensee
S.
Adams, Technical Manager
R. Carroll, Ginna Training Manager
R. Eliase,
Nuclear Engineering
M. P. Lilley, Nuclear Assurance
Manager
F. L. Maciuska,.Supervisor
License Training
R. A. Marchionda, Director of Outage Planning
R.
C. McCredy, General
Manager,
Nuclear Production
G.
D. Meier, Division Training Manager
T. Schuler,
Operations
Manager
R. E. Smith, Senior VP, Engineering
& Production
S.
M. Spector,
Plant Manager
E. Volpenheim,
Human Factors Consultant,
Volian Enter.
T. A. White,
EOP Coordinator
J. A. Widay, Superintendent,
Ginna Production
NRC
- F ~
- L ~
- G ~
- B ~
P. Bonnett, Operations
Engineer@
DRSg RI
E. Briggs, Senior Operations
Engineer,
DRS, RI
W. Lapinsky,
Human Factors Specialist,
S. Norris, Senior Operations
Engineer,
DRS, RI
S. Perry,
Senior Resident Inspector,
Ginna
A. Yachimiak, Resident Inspector
(Detailed),
Ginna
NRC Contractors.
- C.
M. Meeker,
Systems
Engineer,
COMEZ
- B. A. Paramore,
Human Factors Specialist,
- Attend'ed Exit Meeting on October 4,
1989
Ins ection
Re ort No.
50<<244
89-80
17
ATTACHMENT 1
DOCUMENTS REVIEWED
Document
Document
Number
Title
Rev No./
Date
OWNERS
GROUP
WOG Emergency
Response
Guidelines
1A
EMERGENCY
E-0
E-1
E-2
E-3
OPERATING PROCEDURES:
Reactor Trip or Safety Injection
.Loss of Reactor or Secondary
Coolant
Faulted
Steam Generator Isolation
Tube Rupture
10
8
3
9
EMERGENCY
ECA-0 '
ECA-0 '
ECA-0 '
ECA-F 1
ECA-1.2
ECA-2 '
ECA-3 '
ECA-3 '
ECA-3 '
EMERGENCY
ES-0 '
ES-0 '
ES-0 '
ES-0 '
~ 1
ES-1 '
ES-1 ~ 3
ES-3 '
ES-3 '
ES-3 '
SUB-PROCEDURES:
Rediagnosis
Reactor Trip Response
Natural Circulation Cooldown
Natural Circulation Cooldown with Steam Void
in Vessel
(with RVLIS)
SI Termination
Post
LOCA Cooldown and Depressurization
Transfer to Cold Leg Recirculation
Post-SGTR
Cooldown Using Backfill
Post-SGTR
Cooldown Using Blowdown
Post-SGTR
Cooldown Using Steam
Dumps
4
'
0
0
5
5
10
2
3
3
CONTINGENCY ACTIONS PROCEDURES:
Loss of All AC Power
8
Loss of All AC Power Recovery Without SI Required
3
Loss of All AC Power Recovery With SI Required
5
Loss of Emergency Coolant Recirculation
4
LOCA Outside Containment
1
Uncontrolled Depressurization
of Both
4
SGTR with Loss of Reactor Coolant-Subcooled
Recovery Desired
5
SGTR with Loss of Reactor Coolant-Saturated
Recovery Desired
7
SGTR without Pressurizer
Pressure
Control
3
Ins ection
Re ort No. 50-244
89-80
ATTACHMENT 1 (cont.)
18
DOCUMENTS REVIEWED
~
Document
Number
Document
Title
Rev. No./
Date
CRITICAL SAFETY FUNCTION STATUS TREES
F-0 '
F-0.2
F-0.3
F-0 '
F-0.5
F-0 '
Subcriticality CSFST
Core Cooling CSFST
Heat Sink CSFST
Integrity CSFST
Containment
Inventory CSFST
1
3
1
1
1
2
FUNCTIO
FR-C ~ 1
FR-C ~ 2
FR-CD 3
FR-H. 1
FR-H.2
FR-H~3
FR-H.4
FR-H.5
FR-I ~ 1
FR-I'
FR-I.3
FR-P.1
FR-PE 2
FR-S
1
FR-S.2
FR-Z
1
FR-Z
2
FR-Z.3
NAL RESTORATION GUIDELINES PROCEDURES-
Response
to -Inadequate
Core Cooling
Response
to Degraded
Core Cooling
Response
to Saturated
Core Cooling
Response
to Loss of Secondary
Heat Sink
Response
Overpressure
Response
High Level
Response
to Loss of Normal Steam-
Release
Capabilities
Response
Low Level
Response
to High Pressurizer
Level
Response
to Low Pressurizer
Level
Response
to Voids in Reactor Vessel
Response
to Imminent Pressurized
Thermal
Shock Condition
Response
to Anticipated Pressurized
Thermal
Shock Condition
Response
to Nuclear Power Generation/ATWS
Response
to Loss of Core Shutdown
Response
to High Containment
Pressure
Response
to Containment Flooding
Response
to High Containment Radiation Level
4
3
2
7 '
1
0
2
1
2
2
ABNORMAL PROCEDURES:
AP-CW.1
Loss of a Circ Water
Pump
AP-CCW.1
Leakage into the Component Cooling Loop
AP-CCW.2
Loss of CCW During Power Operation
AP-CCW.3
Loss of
CCW - Plant Shutdown
AP-CR.1
Control
Room Inaccessibility
AP-CVCS. 1
CVCS Leak
AP-CVCS.2 Immediate Boration
1
4
7
6
8
4
6
Ins ection
Re ort No. 50-244
89-80
ATTACHMENT 1 (cont.)
19
DOCUMENTS REVIEWED
Document
Number
Document
Title
Rev. No./
Date
ABNORMAL P
AP-ELECT 1
AP-ELECT 2
AP-FW. 1
AP-IAe 1
AP-PRZR+1
AP-RGB 1
AP-RCC ~ 2
AP-RCP ~ 1
AP-RCS.1
AP-RCS
~ 2
AP-RCS
~ 3
AP-RHR. 1
AP-RHR.2
AP-SW.1
AP-TURB'
AP-TURB.2
AP-TURB.3
AP-TURB.4
ROCEDURES
cont.
Loss of 412
SS Transformer
Safeguards
Busses
Low Voltage or System
Low Frequency
Partial or Complete
Loss of Main Feedwater
Loss of Instrument Air
Abnormal Pressurizer
Pressure
Continuous Control Rod Withdrawal/Insertion
RCC/RPI Malfunction
RCP Seal Malfunction
Reactor Coolant Leak
Loss of Reactor Coolant Flow
High Reactor Coolant Activity
Loss of RHR
Loss of RHR at Low Loop Levels
Loss of Service Water
Turbine Trip without Rx Trip
Automatic Turbine Runback
Turbine Vibrations,
Loss of Condenser
Vacuum
3
3
3
2
2
5
5
4
3
6
1
4
3
6
3
4
E UIPMENT
ER-AFW. 1
ER-BA. 1
ER-CVCS.1
ER-DG ~ 1
ER-DG ~ 2
ER-ELEC ~ 1
ER-ELECT 2
ER-ELEC.3
ER-ELECT 4
ER-ELEC ~ 5
ER-ELECT 6
ER-ELECT 7
ER-INST'
ER-INST.2
RESTORATION PROCEDURES:
Alternate Water Supply to the
AFW Pumps
BAST Temperature
Concerns - Loss of All AC
Reactor
Makeup Control Malfunction
Restoring
D/Gs
Alternate Cooling for Emergency
D/Gs
Restoration of Offsite Power
Cross-Tie
Emergency Offsite Backfeed via Unit
Auxiliary Transformer
TSC D/G Feed to Bus
16 to Supply
Charging
Pumps
Security Diesel Feed to Bus
13
Restoration of Offsite Power using
12B
Transformer to Backfeed
Bus
12A
Installation of the Emergency
3MVA
Transformer to Backfeed
Bus
12A
Reactor Protection Bistable Defeat after
Instrument
Loop Failure
Loss of Annunciator
5
1
0
3
3
3
3
1
& 2
1
Ins ection
Re ort No.- 50-244
89-80
ATTACHMENT 1 (cont.)
20
DOCUMENTS REVIEWED
,Document
Number
Document
Title
Rev. No./
Date
E UIPMENT
ER-NIS ~ 1
ER-NIS ~ 2
ER-NIS ~ 3
ER-PRZR.1
ER-RCC ~ 1
ER-RCC ~ 2
ER-RHRo 1
ER-RMS ~ 1
ER-SFP
~ 1
ER-SWi 1
RESTORATION PROCEDURES
cont.
SR Malfunction
IR Malfunction
PR Malfunction
Restoration of Przr Heaters
during Blackout
Retrieval of a Dropped
Restoring
a Misaligned
RCDT Pump Operation for Core Cooling
Locating Source of High Activity Plant Vent.
Loss of Spent Fuel Pit Cooling
Loss of
SW Return Outside
Aux Building
2
1
5
2
5.
3
3
2
2
ADMINISTRATIVE PROCEDURES:
A-52 ~ 1
A-52 '
A-52 '
A-52.1
A-56 '
A-56 '
A-201 '
A-206
A-50 1
A-502
A-502.1
A-503
A-503.1
A-601
A-601'
A-601 ~ 2
A-601 ~ 3
A-601 '
A-601 '
Shift Organization
& Responsibilities
Operations Written Policies/Practices
Book
Operations
Plan
Conduct of Activities in the Control Room
System
& Component Labeling
& Control of
Operator Aids
Control
Room Panel Labeling
& Demarcation
Operations
Section-Organization
and
Responsibilities
Emergency
Procedures
Committee
Plant Procedures
Preparation
& Classification
'Plant Procedure
Content
& Format Requirements
Emergency
& Abnormal Operating Procedures
Writers Guide
Plant Procedure
Adherence
Requirements
Emergency
& Abnormal Operating Procedures
Users
Guide
Procedure
Control
Procedure
Control-New Procedures
Procedure
Control-Permanent
Changes
Procedure
Control-Temporary
Changes
Procedure
Control-" Periodic Review
Procedure
Control of Emergency
and
Abnormal Procedures
26
10
4
5
6
1
0
10
9
41
3
16
7
34
5
4
4
5
Ins ection
Re ort No. 50-244
89-80
ATTACHMENT 1 (cont.)
R
DOCUMENTS REVIEWED
21
Document
Document
Number
Title.
Rev. No./
Date
OPERATING PROCEDURES:
0-6.10
Plant Operation with Steam Generator
Tube
Leak Indication
0-9
Shift Relief Turnover - Control
Room
12
13
PRECAUTIONS
LIMITATIONS
& SETPOINTS
PROCEDURES:
P-1
Reactor Control
& Protection
System
45
P-2
Reactor Coolant System Precautions
& Limitations 28
P-6
PL
&
S - Nuclear Instrumentation
System
"12
P-7
Safety Injection System
11
P-9
Radiation Monitoring System
55
PRIMARY CHEMISTRY PROCEDURES:
.PC-23.7
Containment
Atmosphere
Hydrogen Monitor.
PC-25.7.11Post
Accident Sampling at the
12
12
SITE CONTINGENCY PROCEDURES:
SC-3
Fire Emergency
Plan
SC-3.1
Fire Emergency
General Information
SC-3.1.1
Fire Alarm Response
(Fire Brigade Activation)
SC-3.4.1
Fire Brigade Captain
& Control Room
Personnel
Responsibility
SC-3.20.51Pre-Fire
Strategy for Turbine Building
Basement
East<<Brigade
Response
SC-3.20.51.1Pre-Fire
Strategy for Turbine Building
Basement
East-Operations
Response
21
12
4
19
TURBINE PROCEDURES:
T-14G
S/G Blowdown Heat Recovery
System
Shutdown
14
Ins ection
Re ort No. 50-244 *89-80
ATTACHMENT 1 (cont.)
22
DOCUMENTS REVIEWED
Document
Document
Number
Title
Rev. No./
Date
TRAINING
GGE05T
GRC057
NEP01C
RECOOS
REC11C
REC21S
RFRI3C
LESSON PLANS:
General
Employee Training-
Administrative/Security Indoctrination
General
Employee Training-
Radiological Protection
Auxiliary Operator Continuing Training-
EOP Tasks
Simulator Training-
ECA-0;0, Loss of All A/C
~ Recpxalification Training-
ECA-1.1, Loss of Emergency Coolant Recirculation
Simulator Training-
ECA-2.1, Multiple S/G Depressurization
Requalification Training-
FR-I.3, Response
to Voids in Reactor Vessel
2
1
OTHER DOCUMENTS:
1.
Ginna Technical Specifications
2.
Operations
Communications
Standards
(02-006,
Rev 0)
3.
Step Difference Evaluation
4.
Procedures
Generation
Package
5.
Attendance
Records of AOs for NEP01C
6.
Training Records for four individuals
7.
Alarm Response
Procedures
(generically)
Ins ection
Re ort No. 50-244
89-80
23
ATTACHMENT 2
DEFICIENC1ES IDENTIR1ED WITHIN THE EMERGENCY PROCEDURES
The deficiencies
noted below were discussed
with the
facility staff prior to the exit meeting.
All comments
were understood
by the facility, and accepted
as valid.
For some of the comments,
specific facility response is
included.
EMERGENCY OPERATING PROCEDURES:
E-0 Reactor Tri
or Safet
In'ection
1.
Step 7, pg
6
The
RNO column does not check the Sodium Hydroxide flow to
verify containment
spray flow.
2.
Attachment:
D/G Stop,
Step
5
Step
does not tell operator to hold voltage shutdown button
in until voltage decreases
to zero or some acceptable
low
lev. If the .button is released
too soon,
the diesel will
restart.
'ttachment:
Letdown,
Step B.9 and C.5
These
steps
have the operator adjust'harging
speed
<<as
necessary<<
without direction as to what the step is trying
to accomplish.
4 ~
Attachment:
RCP Start,
Step B.7.c
Step
does not tell operator
how to determine if RCP No.
1
seal parameters
are normal prior to starting of the pump.
5 ~
Attachment:
DC Loads,
Step B.4
The step cites switch No. 7, actual switch is No.
1
6
Attachment:
CI/CVI, pg
2
SOV-5A and its associated
isolation valve, V-1084A, are
identified as being in the Sample
Hood, actual location is
the Intermediate Building basement,
clean side.
E-1 Loss of Reactor or Secondar
Coolant
1 ~
Step 9.c,
pg
7'tep
is not specific as to whether the service air
compressor is included in the verification.
Zns
I
ection
Re ort No. 50-244
89-80
ATTACHMENT 2 (cont.)
DERZCZENCZES IDENTZFZED WZTHZN THE .EMERGENCY PROCEDURES
E-2 Faulted
Steam Generator Isolation
Step 4.d,
pg
4
The procedure
uses valve numbers of HCV-xxx, but the actual
valves are labeled
as FCV-xxx.
2 ~
Step 4.e,
pg
4
The procedure
does not include the valve numbers;
and .the
valves locally do not include the valve name.
In this case,
'potential exists for the
AO to operate
the wrong valve;
.example,
the valve associated
with the
B MFW pump is the
lower numbered valve.
3 ~
Step 5, 3rd open-bullet,
pg
5
- Zf the valve must be closed locally, consider allowing the
use of the <<knocker<< valve vice requiring local .closure of
the AOV.
- AOV-5737 still has the old valve designator
on it (CV-71).
Step 8. c, pg
6
Expand the step to include placing the mode selector switch
to >>manual<<
and putting HCV-484 in >>auto<<
E-3
Tube
Ru ture
1.
Step B.1, pg
2
Several entry conditions list the wrong step of the
referenced
procedure.
2 ~
Step 7,
RNO b, pg
9
The
ERG step directs the operator
back to step
1 of this
procedure,
but this procedure directs the operator to
transfer to another
procedure~
ECA-3.1~
SGTR WITH LOSS
OF
REACTOR COOLANT SUBCOOLED RECOVERY DESIRED.
3 ~
Step
9. a,
pg
10
The nomenclature is inconsistent
between the step,
which
refers to the
<<CZ reset
key switch,<< the tag on the key
which states
>>C. V. Isolation Reset,<<
and the label on the
locked switch which states
<<CNMT Zsolation Reset.>>
4 ~
Step 22,
RNO,
pg=- 22
The
ERG states
to >>Close
PORV Block Valves<< as the first
step of the
RNO, it was left out of this procedure.
The
justification used to delete this step is based
on operator
training; however, retaining the step in the
RNO to close
the
PORV block valves would be prudent.
Ins ection
Re ort No. 50-244
89-80
~
~
ATTACHMENT 2 (cont.)
'I
DEFICIENCIES IDENTIFIED WITHIN THE EMERGENCY PROCEDURES
25
5 ~
Step
31@
RNO bp pg 29.
The intent of this step is to energize
Instrument
Bus D.
As
written, it assumes
that if MCC B is not energized,
then
A will be energized
(since
MCC A powers the maintenance
bus
for Instrument
Bus D).
To prevent the above,
MCC A must be
energized,
or verified energized, prior to placing
Instrument
Bus
D on the maintenance
supply.
6.
ATTACHMENT N2
PORVS,
(B)(1)(a)
The works
<<AND OPERABLE<< are missing after the .word <<OPEN>>.
7 ~
ATTACHMENT SD-1
- The sequence
in which the valves
and equipment
are listed
in this attachment
does not optimize the efficiency of the
Auxiliary Operator
who will be required to carry out the
actions of this attachment.
A reevaluation of the sequence
could reduce the time required to carry out the actions
and
reduce the chance of missing
a step.
- The secondary
chemical addition pumps
and their controllers
are not labeled clearly.
EMERGENCY CONTINGENCY ACTIONS PROCEDURES:
ECA-1.2
LOCA Outside Containment
1.
Step 2.a,
pg
4
The procedure
has the operator close
a list of isolation
valves but does not provide for re-opening the valves
as is
done in the
RNO.
ECA-2.1 Uncontrolled
De ressurization
of Both Steam Generators
1.
General
The charging
pumps are designated
A/B/C in the procedures
and on the control boards;
however,
on print 433013
1265@
the pumps are designated
as 1/2/3, respectively.
2.
Cautionsg
2nd open-bullet,.pg
3
The caution location is not consistent with other switchover
criteria; i.e. is not located
on the Foldout Page.
3.. Step 3.b,
pg
4
To determine
which bus is supplying the swing SI pump is,
the operator looks at two red lights and must decide which
light is brighter.
During the walkdown, the operator
was
not able to make this determination
due to both lights being
dim
'
Zns ection
Re ort No. 50-244
89-80
ATTACHMENT 2 (cont.)
26
DEFICIENCIES IDENTIFIED WITHIN THE EMERGENCY PROCEDURES
4 ~
Caution,
pg
5
Change the wording to >>... to less than 2335 psig.>>
5.
Step
17. c, pg
13
The operator, was confused
as to how the thermocouple
reading
was to be obtained; i.e.,
computer versus incores,
average
of all or average of five highest or the highest.
6 ~
Step
20.a-RNO,
pg 14
The caution before. step
20 warns of backflow to the BASTs.
Add a second
substep
under the
RNO for step 20.a, >>If at
least
one valve in each flow path cannot
be closed,
go to
step 21. >>
7 ~
Step 25.a,
pg
19
The, value for seal return temperature is not consistent with
the value in AP-RCP.1
ECA-3.1
SGTR with Loss of Reactor Coolant-Subcooled
Recover
Desired
1.
Paragraph
B.1, pg
2
Several entry conditions list the wrong step of the
referenced
procedure.
2 ~
Step
11,
RNO b, pg 11
The
ERG step directs the operator
back to E-3,
STEAM
GENERATOR TUBE RUPTURE~ Step
1, but this step within the
procedure directs the operator to take other actions.
This
comment also applies to ECA 3.2,
Step
4 and
ECA 3.3 Step
6.
3 ~
Step
17, First Note,
pg 14
The justification for this note states
that the selection of
the appropriate
PORV will not noticeably delay subsequent
recovery actions,
because
the status of the block valves is
determined in step
5 of E-3,
STEAM GENERATOR TUBE RUPTURE.
This justification is not completely valid, because this
procedure
can be entered
from step
3 of E-3. In that case,
the block valve status will not have been determined.
4 ~
Step 20. b, pg
17
The
ERG indicates the status of charging
pumps
as either
running or not. This, procedure
only indicates
the
availability of charging
pumps,
which is not the
same
condition as running. This comment also applies to step
21
of this procedure
and similar steps in ECA-3.2.
Ills ection
Re ort No. 50-244
89-80
27
ATTACHMENT 2 (cont.)
DEFICIENCIES IDENT1FIED WITHIN THE EMERGENCY PROCEDURES
5 ~
6.
Step 21.b,
pg 18
The deviation statement for this step states that the
minimum required subcooling for stopping the last SI Pump
was found to be irrespective to charging
pumps status.
This
appears
to conflict with the table in this step which
indicates different subcooling requirements for different
charging
pump availabilities.
FOLDOUT
PAGEOS
3
The phrase
>>unless
needed for RCS cooldown>> is used in the
ERG after the word <<isolated>>,
but it is not used in this
procedure.
This comment is applicable to ESC 3.2 and
3.3 also.
ECA-3.2
SGTR with Loss of Reactor Coolant-Saturated
Recover
Desired
1 ~
Step
4,- RNO b, pg
5
ECA.3.1,
Step
11 has the
same justification and the
same
wording as this step, but refers the operator to Attachment
RUPTURED S/G.
This step refers the operator to Attachment
FAULTED S/G.
Step
11.
RNO b, pg
9
This step is more complicated than the identical step in
ECA-3.1, because
of the added statements
concerning
normal cooling.
This added complication in unnecessary
since
RHR normal cooling would not be established until step
30 of this procedure.
This comment is also applicable to
step
12 and 13.
ECA-3.3
SGTR without Pressurizer
Pressure
Control
1 ~
2 ~
3 ~
Paragraph
B.1, pg
2
The entry condition lists the wrong step of the referenced
procedure.
Step 25,
NOTE, pg 20
The note states
a Pressurizer
level that is different from
the value specified in the
ERG and there is no comment. or
discussion
on this change in the deviation document.
Step
32,
RNO, pg 23
The S/G level specified in this step of the
ERG is the
same
as the level specified in step
1 of the
ERG.
This procedure
uses
90% -in step
1 and
67% in this step,
Ins ection
Re ort No. 50-244
89-80
ATTACHMENT 2 (cont.)
DEFICIENCIES IDENTIFIED WITHIN THE EMERGENCY PROCEDURES
28
EMERGENCY SUB-PROCEDURES:
SI Termination
1.
Step 12.a,
pg 10
clear.,
2 ~
Step 7, pg
2
Deviation Document:
The justification for deleting the
caution
and incorporating it into a following step is
inadequate.
I
3.
Steps
12 - 19,pgs
5,
6
Deviation Document:
The justification statements
for steps
12 through
19 are not in the. proper sequence.
Post<<SGTR
Cooldown Usin
Backfill
1.
Step 4,
RNO b, pg
4
The
ERG step directs the operator back to step
1 of E-3,
STEAM GENERATOR TUBE RUPTURE, but the step directs the
operator to transition to another procedurep
ECA 3 '
WITH LOSS
SUBCOOLED RECOVERY DESIRED~
STEP 1.
2
Step 8.c,
and
RNO c, pg
6
This step
and its
RNO are not in the
ERG and are not
discussed
in the deviation document.
Post-SGTR
Cooldown Vein
Steam
Dum s
1.
Step
6, Caution,
pg
7
This caution is-not contained in the, deviation document.
CRITICAL SAFETY FUNCTION STATUS TREES:
F-0.3 Heat Sink CSFST
1.
Second Block
The flowrate listed applies to AFW system only.
The
conditions
do not consider the
MFW system which indicates in
ibm/hr.
Ins ection
Re ort.No. 50-244
89-80
ATTACHMENT 2 -(cont.)
DEFICIENCIES'DENTIFIED WITHIN THE EMERGENCY PROCEDURES
29
F-0.4 Inte rit
1.
The second question in the
Red path asks <<All RCS
pressure-cold
leg temperature
points to right of limit A on
attached
figure?>>
= The Limit A figure does not label which
of the three lines is the >>Limit A<< curve.
FUNCTIONAL RESTORATION GUIDELINES PROCEDURES:
FR-H.1
Res
onse to Loss of Secondar
Heat Sink
1 ~
Step 12.b,
page
11
The phrase
>>proper
emergency
alignment<< is not. clear.
'The
operator
does not have
any reference
to check the proper
alignment to.
FR-P.1
Res
onse to Imminent Pressurized
Thermal
Shock Condition
1 ~
2 ~
Step
1;
RNO, pg
3
The
ERG step
and the deviation are identical for this step
and step
1 of FR-P2, but the steps
themselves
are different.
Step 2,
RNO b, pg
4
The action required by the last sentence
needs to be more
specific.
All it says is to <<locally check breaker<<.
3.
Step 4,
RNO, pg
5
The step directs the operator to the wrong step.
4.
Step
6, Caution,
pg
6
,The
ERG contains
a caution that is not included in this
procedure.
5.
Step
6,
RNO a,
pg
7
As written, this step would bypass
the next step in the
procedure until the operator reaches
step
18.
The step
needs to be modified to ensure that the next step is
performed
as
soon
as two
SW pumps are available.
6.
Step 16.c,
pg
13
The
ERG contains
a step'o
stop
RCS pressurization.
The
procedure
does not contain this step.
7.
Step 22, pg
17
The,ERG specified the
same Pressurizer
Level for this step
and step 16.b. This step uses
87%, but step 16.b.
uses
75%.
Ins ection
Re ort No. 50-244
89-80
ATTACHMENT 2 (cont.)
DEFICIENCIES IDENTIFIED WITHIN THE EMERGENCY PROCEDURES
30
FR-P.2
Res
onse to Antici ated Pressurized
Thermal Shock
Condition
1.
Paragraph
B. 1. a,
pg
2
The entry condition from F-0.4 is Yellow vice either.
FR-S.1
Res
onse to Nuclear Power Generation
1.
Step 2,
RNO, pg
3
The
ERG step includes direction to manually run back the
turbine,, which is not contained in this procedure.
2.
Step 4,
RNO a,
pg
4
The
ERG step includes. direction to verify containment
ventilation isolation, which is not contained in this
procedure.
3
Step
13, Caution,
pg
9
The caution in step
13 of the
ERG is not included in this
procedure.
~
~
FR-S.2
Res
onse to Loss of Core Shutdown
ABNORMAL PROCEDURES:
Generic to most of the APs:
the first caution listed
needs to be changed to >>If ...
E-0 shall be performed.>>
AP-CCW.2
Loss of
CCW Durin
Power 0 eration
1.
Step 4, pg
5
The. step
does not give any reference
or guidelines to the
operator to specify what the proper valve alignment is.
2.
Step 5.a,
pg
6
The step
does not specify what containment
sump indications
to use nor give guidelines
as to what >>Normal<< is.
3.
Step 9,
pg
7
The step
does not specify that chromate concentration
information is obtained
from the
HP Dept.
AP-CCW.3. Loss of
CCW - Plant Shutdown
1.
Step 5.a,
pg
5
Same
comment
as
number
2 for AP-CCW.2
. Ins ection
Re ort No. 50-244
89-80
ATTACHMENT 2 (cont.)
31
DEFZCZENCIES ZDENTIFZED WITHIN THE EMERGENCY PROCEDURES
I
AP-CR.1 Control
Room Inaccessibilit
1.
Step 3, pg
4
Evaluate making this an immediate action *step, the decision
is made
on whether it is necessary
to enter the'lternate
shutdown procedure for complex fire.
2 ~
Step
11,
RNO, pg
6
Recommend
changing this step to direct the operator back to
step
5 vice step 7.
This will ensure that any actions
missed
when the Local Operating Stations
were established
were accomplished.
AP-IA.1 Loss of Instrument Air
1.
Paragraph
B.1, pg
2
Three entry conditions list the wrong step of the referenced
procedure.
2.
Step 5, pg
6
The nomenclature of the primary IA loads in steps
5, 7,
and
9 is not consistent with that used in Attachment A.
To
avoid confusion,
standard
nomenclature
should be used in
Figure .1 to identify the location of the loads.
3.
Step
10,
RNO c, pg
7
This step should
send the operator to step
15 rather than
step
16.
Since the leak in the IA has not been isolated at
this point in step
10, it is necessary
to establish
isolation of ZA leak (step
15) before restoration of
unaffected portions of the
ZA system
(step 16).
4.
Figure 1, pg
1
Valves
AOV 5251'
5365@
and V-7350 are needed
because
they
are used in the procedure.
AP-RHR.1
Loss of RHR
1.
Step 2, pg
3
Relocate
the Caution to before the step
1 Note.
/
2.
Step
18,
pg
7
The step
does not specify what evaluation is to be completed
by the plants Technical Staff.
Ins ection
Re ort No. 50-244
89-80
ATTACHMENT 2 (cont.)
32
DEFICIENCIES IDENTIFIED WITHIN THE EMERGENCY PROCEDURES
E UIPMENT RESTORATION PROCEDURES:
Generic to most of the ERs:
the format and terminology
used is not consistent
withe the
and APs.
ER-ELEC.4
D
G Feed to Bus
16 to Su l
Char in
Pum
s
1.
Step 4.5
The step directs the operator to remove the normal/emergency
fuse.
The operator
was unable to locate
a control fuse in
the transfer cabinet.
ER-INST.2
Loss of Annunciator
1.
Provide
an Attachment that lists all of the annunciator
alarms for which there is no panel instrumentation to alert
the operator to an alarm condition when the annunciator is
out of service.
If there is an associated
computer alarm,
this can be annotated
on the list.
'SR Malfunction
ER-NIS.1
1.
Step 4. 3. 1, pg
3
Include the valve alignment to re-align the suction of the
charging
pumps to the
RWST.
Ins ection
Re ort, No. 50-244
89-80
33
ATTACHMENT 3
DEFXCXENCIES IDENTXFIED WITHIN THE WRITERS
& USERS
GUIDES
A-502.1
Emer enc
& Abnormal 0 eratin
Procedures
Writers Guide
1 ~
Section 2.2.2
Does not state the difference between
>>Symptoms>>
and >>Entry Conditions>>
and nor when one or both
is required.
Based
on tabletop review of procedures, it
appears
that, for some procedures,
entry conditions only are
used (e.g., the
FR series),
and that they consist of
identification of the other procedure
steps or Status
Tree
conditions
from which the current procedure
may be entered.
2 ~
Section 3.5 and Figure
6 - Does not indicate where figures,
tables,
and automatic action pages
are to be located in the
procedure,
and their order relative to each'ther.
In
practice, it was found that all of these
are treated
as
appendices
to the procedure,
except for tables in some cases
(the location of tables is addressed
in Section 2.4).
3 ~
Sections
4.1.2
and 4.1.3
The required font, pitch, style,
margins,
and other specifications for word processing
are
not stated
(unless
they are stated
elsewhere).
Section 4.1.11 - Does not prohibit the division of a substep
between
two pages.
Although this was found rarely in the
EOPs, it did occur (e.g., in FR-I.1, Step 8).
The division
of a substep
between
two pages
can make it difficult to keep
in mind the relationship
between the Action/Expected
Response
and the
RNO.
5 ~
6 ~
Section 4.3 and Figure
2
Referred to in Section 4.3 but is
incomplete.
It is supposed
to illustrate the format for
page headings,
but it omits the page numbering format.
Sections 4.3.3.1
and 4.3.3.2
Use the term >>preliminary
pages." It would be better to state the specific pages
intended.
Contain
an example,
such
as
>>Page
3 of 15.>>
8
Section 4.5.1.3 - Is not consistent with the procedures;
in
that,
does not state that immediate action steps shall be
identified in a note at the beginning of the procedure.
This is done in the procedures
but is not stated in the
Writers Guide.
9 ~
Section 4.5.1.5 - Examples
are needed of routine tasks for
which it is not necessary
to indicate the expected
response.
10.
Section 4.5.1.6 - The wording is confusing.
1ns ection
Re ort No. 50-244
89-80
ATTACHMENT 3 (cont.)
34
DERXCXENCXES XDENTXFZED WITHIN THE WRXTERS 8 USERS
GUZDE
11 ~ Section 4.5.1.9 - The example of a series of conditional
statements
is poorly formatted.
If a series of conditional
statements
is necessary,
do not lump them together like a
paragraph
block.
Instead,
separate
them by a space,
so that
each is a distinct, individual statement.
12
~ Sections
4.5.2.9
and 4.5.3.6 - What is a >>passive
action
statement'>>
The example provided does not make the meaning
clear.
1 3 ~ Section 4.6 - The List of Appendices
does not include the
current revision number of each appendix.
At present,
there
is no way to ensure
what is- the current revision number of
an appendix.
14
~ Sections
5.2.4
and 5.2.5 - The instructions given in these
sections,
regarding the use of open and closed bullets,
do
not explain that there is an implied >>AND<< between bullets
in a series if no other logic term is specified.
This is
stated in Section 3.3.3.1 of the Users
Guide
(A-503.1) but
is not stated in the Writers Guide.
15 ~ Section 5.5
Procedure
steps
were not always written as
complete,
imperative sentences;
the required action and the
object(s)
of the action were not clear.
In the procedures
reviewed,
complete
sentences
were consistently
used, with
short phrases
that qualify the action (i.e.,
make it more
specific) presented in list format (they are
a grammati'cal
part of the sentence).
However, the Writers Guide statement
would allow writers not to use complete sentences.
16 ~ Section
6.,0 - The format specifications for the
CSFSTs are
incomplete.
If changes
are
made in the Status
Trees,
guidance
may be needed
regarding character style character
size
and spacing,
question block dimensions
and color code.
Figure
7 is supposed
to illustrate the number codes
and
color codes.
The figure was not in color and the number
code
<<3<< was not visible.
A color example
was not provided
in the Writers Guide, nor the complete set of number codes.
17
~ Figures
2 through
5
The page
number
was incomplete.
18. Figure
3
Addition of the column headings
(STEP,
ACTION/EXPECTED RESPONSE,
and
RESPONSE
NOT OBTAINED) would
make the figure easier to understand.
In Step 3, the
expected
response
specific values
are omitted; instead,
the
word >>later>>
appears
in parentheses.
Zns ection
Re ort No. 50-244
89-80
ATTACHMENT 3 (cont.)
35
DERZCXENCXES XDENTZFXED WZTHXN THE WRXTERS
8 USERS
GUZDE
19
~
20
Figure
4 does not.provide
a useful illustration of. the
attachment
page format.
General
comment - A table of contents
would make it easier
to find things in the Writers Guide and also would help
users
understand
the organization of the Guide.
The table
of contents
could be limited to major section headings
and
first level subordinate
headings.
A-503.1
Emer enc
& Abnormal 0 eratin
Procedures
Users
Guide
1 ~
2 ~
Although this is the Users'Guide,
in several places,
the
guidance
seems
to be directed to a procedure writer rather
than to a user.
For example,
Section 2.2.2 states that <<The
symptoms
used should be unique to the procedure.>>
Other
examples of this are -in Sections 2.3.1, 2.3.3,
and 2.3.3.1.
Section 1.4 - Contains definitions of terms.
The verbs used
to specify operator actions
are not included in this
section.
During the inspection,
there were indications that
'he precise
meanings of some of the verbs were not clearly
understood
by all operators.
It appears
desirable to
include verb definitions in the Users
Guide.
3 ~
Section 3.2
Does not require the operator to review
symptoms
and entry conditions,
states
that the operator
~ma
review the purpose/entry
conditions page of the procedure.
4 ~
Section 3.7.2 - Contains
an incorrect reference
to another
section of the Users
Guide
(should be 3.7.3).
5 ~
Sections'.7.3
and 3.7.3.3 - Contain
an incorrect reference
to a preceding section of the Guide
(should be 3.7.1).
6 ~
Section 3.8.1 - Contains
an incorrect figure reference.
There is no figure in -the Users
Guide that shows the binder
layout of the
and APs.
Figure
1 shows the
format.
7 ~
Section 3.10.1
Contains the specific parameter
values that
define adverse
containment,
but they are not included within
the procedures
themselves.
The Inspection
Team found that
the adverse
containment criteria criteria)
have not been
committed to memory by the operators.
XM ection
Re ort No. 50-244
89-80
36
ATTACHMENT 3 (cont.)
DEPICIENCIBS IDENTIPIBD WITHIN THB WRITERS
& USERS'UIDE
8 ~
9 ~
Figure
1 - Is not useful. because
some of the path lines and
priority number codes
were missing.
Attachment
1 - Is not consistent with the current revision
of procedure
E-2.
The attachment
contains incorrect step
references
and action step statements.
In addition, the
discussion of Step
2 is garbled.
Ins ection
Re ort No. 50-244
89-80
ATTACHMENT 4
37
ABBREVIATIONS 6'CRONYMS
AER
BAST
CFR
CI
CO
CRF
DCRDR
F
F/m
GTG
HCO
LCO
NRC
PPDS
PSTG
column of EOPs)
described in RG 1.33)
on of the
EOPs)
ation System
subset of the
EOPs)
ns
Auxiliary Building
Alternating Current
Action/Expected
Response
(left-hand
Auxiliary Operator
Air Operated
Valve
Abnormal Procedures
Alarm Response
Procedure
Atmospheric Relief Valve
Anticipated Transient Without Scram
Boric Acid Storage
Tank
Code of Federal Regulations
Containment Isolation
Control Room Operator
(RO)
Control
Room Foreman
(SRO)
Containment
Spray
Condensate
Storage
Tank
Critical Safety Function Status
Tre
Containment .Ventilation Isolation
Direct Current
Detailed Control Room Design Review
Diesel Generator
(emergency)
Emergency Operating Procedures
(as
Emergency
Procedures
(Ginna~s versi
Emergency
Response
Guidelines
Engineered
Safeguards
Feature
Engineered
Safeguards
Features
Actu
Degrees
Fahrenheit
Degrees
Fahrenheit
per minute
Functional Restoration
Procedure
(a
Generic Technical Guidelines
Head Control
Room Operator
(RO)
Instrumentation
& Control
Institute of Nuclear Power Operatio
Limiting Condition 'of Operation
Loss of Coolant Accident
Motor Operated
Valve
Non-Licensed Operator
Nuclear Regulatory
Commission
Owners<
Group
Procedure
Generation
Package
Power Operated Relief Valve
Plant Parameter
Display System
Plant Specific Technical Guidelines
, Ins ection
Re ort No. 50-244
89-80
~
~
ATTACHMENT 4 (cont.)
38
ABBREVZATIONS & ACRONYMS
PZR
RNO
SFAC
SRO'S
TS
WG
Pressurizer
h
Quality Assurance
Pump
Regulatory Guide
Reactor Operator
Response
Not Obtained
(right-hand column of EOPs)
Reactor Protection
System
Safety Evaluation Report
Safety Function Acceptance'Criteria
Safety Parameter
Display System
Senior Reactor Operator
Shift Supervisor
(SRO)
Technical Basis
Document
Technical Specifications
Validation
& Verification
Writers Guide
Ins ection
Re ort No. 50-244
89-80
39.
ATTACHMENT 5
LIST OF WEAKNESSES
XDENTZFXED AS NEEDXNG CORRECTXON
Xtem
Paragraph
Number
Number
Descri tion
50-244/
2.2.a
89-80-01
h
Development of a Ginna procedure in accordance
with the
WOG ERG'for Natural Circulation
Cooldown with Steam Void in Vessel
without
~RVLZS
50-244/
4.2.a
89-80-02
Resolution of concern with respect to the
'CI/CVZ Bright-is-Right panel.
Several
CZ/CVI
'alves
are not on the panel.
50-244/
4.2.b
89-80-03
Evaluation of accessibility of valves required
to be manipulated during implementation of teh
emergency
procedures,
and installation of
improvements,
as required.
50-244/
4.2.c
89-80-04
50-244/
4
3
89-80-05
Resolution- of concern that the Main Steam Line
radiation monitors
(R-31/32)
do not function
until an alarm condition is reached.
Resolution of generic weaknesses
(Paragraph
4.3)
and specific weaknesses
(Attachment
2)
related to the emergency. procedures.
50-244/
4 '4
89-80-06
Evaluation of Site Contingency procedures
related to fire fighting.
50-244/
5.4
89-80-07
Resolution of weaknesses
observed
during
simulator exercises.
50-244/
6.3
89-80-08
Resolution of generic weaknesses
(Paragraph
6.3)
and specific weaknesses
(Attachment
3)
related to the Writers Guide and the Users
Guide.
50-244/
6.4
89-80-09
50-244/
6.5
89-80-10
50-244/
6.7
89-80-11
Resolution of concern that changes
to
satellite proecures
may not be reviewed for
impact on the emergency
procedures.
Clarification that the emergency
procedures
are controlled by A-601.6 vice A-601.1/2.
Resolution of weaknesses
identified within the
Verification
5: Validation program.