ML17286A566
| ML17286A566 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 01/30/1991 |
| From: | Meadows T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| TAC-77486, NUDOCS 9102050061 | |
| Download: ML17286A566 (36) | |
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UNITED STATES NUCLEAR REGULATORY COMMlSSlON REGION V 1450 MARIAI.ANE,SUITE 210 WALNUTCREEK, CALIFORNIA04596 January 30, 1991 MEMORANDUM FOR:
Docket File Washington Public Power Supply System (WPPSS)
WPPSS Nuclear Unit No.
2 (WNP-2), Docket No. 50-397 FROM:
SUBJECT:
REFERENCES:
Thomas R. Meadows Licensing Examiner MEETING
SUMMARY
- JANUARY 25, 1991 MEETING TO DISCUSS WNP-2
RESPONSE
TO NRC EOP INSPECTION TEAM ISSUES (a)
NRC Inspection Report 50-397/90-20 (b)
Response
- Letter, G. Sorensen, dated November 25, 1990 On January 24,
- 1991, members of the NRC staff met with representatives of WPPSS (the licensee) to discuss the issues presented in reference (a) as requested by reference (b).
A list of the attendees is provided in Enclosure 1.
A copy of the licensee's initial corrective action analysis
- summary, presented at this meeting, is provided in Enclosure 2.
The licensee stated that the three deviations from the BWROG EPGs, of concern:
Primary Containment Venting Steam Cooling Termination, and Primary Containment Flooding were referred to HRR for guidance.
The NRC staff (NRC) acknowledged that that these deviations were designated as open items, and were assigned to the Division of Systems Technology, Reactor Systems and Plant Systems
These items remain open.
The licensee stated that the resolution of Open Item 90-20-05 (Implementation of EOP Caution 1 - RPV Level Instrumentation) involves the completion of their situation based evaluation of the credible.events (fire and unisolated high energy line break in the reactor building), that would require RPV level instrumentation to be considered inoperable.
The licensee stated that the evaluation and corresponding procedural development activities are expected to be completed by March 1991.
The licensee also stated that EOP Caution 1 will be updated accordingly, and committed to forward the details of this effort to the NRC by March 1991.
This item remains open.
The licensee stated that the EOP graph errors (Open Item 90-20-06, Calculational Errors in EOP Graphs) were corrected.
An LER (90-019) was issued with a root cause evaluation and supplemental review of all graphed information.
The licensee stated that the cause of this event was personnel error during the procedure revision process.
The licensee committed to correcting their revision process encompassing the writers guide.
the process for calculation incorporation into technical basis documents, and EOP verification and validation, in order to prevent a recurt ing event.
The licensee stated that an expanded report of follow-up corrective actions, based on their current review of all EOP calculations will be forwarded via a revised LER by the end of January
)991.
This item remains open.
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<<1 January 30, 1991 The licensee addressed the remaining issues, primarily Open Item 90-20-04 (Development and Verification and Validation of EOP's and EOP support procedures),
in an analysis summary (Enclosure 2), which details their initial position on these issues.
The licensee clarified that the Completion Status Code 3, "Will Not Be Implemented,"
meant that these items were not of immediate
- concern, in that they had minor safety significance, had little effect on adequate procedure
- guidance, or were not valid.
Furthermore, the licensee stated that all of these issues will be reevaluated during their scheduled revalidation of the entire population of EOPs, Emergency Support Procedures, and associated flow charts.
This effort would begin after the hiring of a Human Factors
- Engineer, and a review of the EOP writers guide and associated changes to the EOPs by this individual.
The licensee stated that a detailed completion schedule (supplementing Enclosure
- 2) will be forwarded based on this review, by the end of April 1991.
After a detailed review, the NRC personnel present agreed that Completion Status Code 3 items were properly classified, and stressed the necessity for the licensee to complete the commitment f'r an expanded action plan.
The NRC stressed that timely resolution to all of these issues is expected.
The licensee acknowledged this concern.
Enclosures:
As Stated Thomas R.
Meadows Licensing Examiner cc w/enclosures:
See Attached List Docket File C. Sorensen, SRI K. Perkins, RV R. Zimmerman, RV P. Johnson, RV P.,Eng, NRR J. Wermeil, NRR J. Dyer, NRR J. Kudrick, NRR
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Enclosure 1
LIST OF ATTENDEES NRC T. Meadows L. Miller G. Galletti WPPSS T. Messersmith J.
Baker S.
McKay G. Sorensen
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ENCLOSURE 2
1990 EOP INSPECTION REPORT ANALYSIS
SUMMARY
COMPLETION STATUS I=
64 (60.4%)
2=
10
( 9.4%)
3=
32 (30.2%)
1990 EOP INSPECTION REPORT ANALYSISTOTALS WRITERS GUIDE (I OR 2 IMPACI)=
7
( 6.6%)
VERIFICATION(1OR2 IMPACT)=
32 (30.2%)
'l VALIDATION(I OR 2 IMPACT)=
17 (16.0%)
OTHER (INCLUDINGNO IMPACT~ 50 (47.2%)
TOTAL TOTAL COMPLETION STATUS I
CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY 2
WILLAWAITHUMANFACTOR EVALUATION BEFORE DECIDING ON ACTION 3
WILLNOT BE IMPLEMENTED
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
2 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDING ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIFI'ION)
PPM 1.2.3:
Deviation procedure not adequate for EOP's.
PPM 1.3.51:
Independent verification of safety related component labels desired.
WRITER' GUIDE VERIF.
ADMIN VERIF.
TECH.
VALIDATION CLOSURE DATE COMP.
STATUS COMMENTS Evaluating deviations with procedure control.
POC prior to deviation; EOP Coordinator Review.
Non EOP issue.
Label Coordinator to change label PPM.
PPM 2.3.1:
Confusing steps.
PPM 2.3.1:
Confusing controller setting (5% above).
PPM 2.3.1:
No labeling on BD Rad 22 (23) recorders.
PPM 2.3.1:
Valves not in the MEL.
PPM 2.3.3:
Board designation alternates between P827 and K 1(K2).
PPM 2.3.1:
Incorrect switch designation.
PPM 2.3.3:
Switches not keylock.
PPM 2.10.1:
REA-FlC-3A Setpoint not adjustable externally by operator.
1 To bc resolved in biennial review.
Several attempts have been previously made to correct.
Present'uidance to be validated ASAP.
Recorders are due to be changed out.
R-6.
Valves are in MEL. Because of software requirements last - must bc entered as I.
Hard copy of MEL must bc consulted.
GE board designation willbc used.
Biennial Review.
Writer's Guide to bc changed.
1 Rev. 8 Fixed.
1 To be resolved ASAP.
Willprovide morc specific guidance.
I
1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDINO ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY g)ESCRIPI'ION)
WRITER' GUIDE VERIF.
ADMIN VERIF.
TECEI.
VALIDATION CLOSURE COMP.
DATE STATUS COMMENTS PPM 2.10.1:
Building controller thumbwheel -.6 versus
+.6.
PPM 2.10.1:
Controller setting incorrect.
PPM 2.10.1:
No auto position, not enough detail for operators to function. More training required.
'PM
- 2. 10.1: Platform for Operations.
PPM 2.10.1:
ROA-TIC-3 had no label.
PPM 2.10.1:
Shifung damper control to auto not fully described and locations of fans not accurate.
PPM 3.3.1:
Contains reference to RWP PPM.
PPM 3.3.1:
Duplicated step on two pages.
PPM 3.3.1:
GDS verses Graphic display system.
PPM 3.3.1:
Group Isolation attachment does not say where to check.
PPM 3.3.1:
Implicitreference to PPM 4.12.4.6.
PPM 3.3.1:
Incorrect punctuation in a step-Use of AND/OR.
To be resolved ASAP.
1 o be resolved ASAP o be resolved in biennial review. Normal after Start/Stop is commonly referred to as Auto.
TER willbe issued to install permanent scaffold.
1 Label request Issued.
Validation willbe performed and any necessary corrective action taken.
Plant management directed inclusion of this PPM.
3 PPM is correct as written.
2 Not agarnst present wnters procedure.
Checking of~ is important.
Format acceptable.
Plant writers PPM not violated.
Human factors willlook at this.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
s CORRECTIVE ACfIONWILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDINO ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPTION)
PPM 3.3.1:
Indicates using printout when the operators use the screen.
PPM 3.3.1:
Note placed after step to which it applies.
PPM 3.3.1:
Pagination incorrect.
PPM 3.3.1:
Panel C verses Board C.
PPM 3.3.1:
Procedure deviation system sometimes results in poor print quality deviations.
PPM 3.3.1:
Referenced section of another PPM incorrect (RCIC).
WRITER' GUIDE VERIF.
ADMIN VERIF.
TECH.
VALIDATION CLOSURE COMPe DATE STATUS COMMEN'IS e printouts are available-will be an option to use either the screen or the printout.
Note placed~ substcp to which it applies.
Correct as written.
Pagination has been corrected.
Writer's Guide willbe revised.
Process for Pdf's willevolve with procedure upgrade.
Present guidance adequate.
Referenced PPM was revised removing section number.
Willbe corrected.
PPM 3.3.1:
Referenced section of another PPM incorrect (HPCS).
PPM 3.3.1:
RHR-V-123A and B cannot be closed from control room.
PPM 3.3.1:
Use ofall caps to indicate position and not as labeled.
PPM 3.3.1:
Use of PSI/Sec instead of PSIG/Sec.
PPM $.0.0:
EOP Caution I wording was non-conservative in that the case of temperature equal to the saturation temperature was not cautioned.
Referenced PPM was revised removing section number.
Will be corrected.
Caution tag controls valves.
Should not be caps.
To be corrected ASAP.
To be corrected ASAP.
Proposed PPM mark-up complete.
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1990 EOP iNSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDING ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPI'ION)
PPM 5.0.0 The placement of cautions in a separate procedure makes it difficultfor operators to usc the information.
Operators should not be required to transition to another location to read cautions.
PPM 5.0.1:.
HCTL and PSPL curves contained non-conservative errors rclativc to their associated calculations.
PPM 5.0.4:
EOP Flowchart Validation only requires that validation for revisions to procedures
"...need only encompasses the changes made to the previously approved procedure PPM 5.0.6:
Add the tools required for PPM 5.6.1, SBO to list.
PPM 5.1.1:
Contingency callouts not used for ~v transition to RPV Flooding or Emergency RPV Dcpressurization.
WRITER' GUIDE X
~
'ERIF.
ADMIN VERIF.
TECH.
VALIDATION CLOSURE COMP.
DATE STATUS COMMENTS Corrected PPM deviation in place.
Verification of all calculations number's will be conducted.
Results willbc forwarded via LER supplement.
PPM 5 0 4 specifies the minimum requiremcnL The Operations Procedure Coordinator willdetermine ifany further increase in validation efforts are required when EOP flowcharts arc rcviscd. Will evaluate current guidance for adequacy.
proposed PPM mark up complete.
Proposed PPM mark-up complete.
PPM 5;1.1:
PPM step, IF the continuous SRV nitrogen supply is or becomes unavailable...", should be structured as an override but isn'.
(Inadequate verification.)
PPM is correct as written relative to W.G.
criteria.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDING ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY g)ESCRIPHON)
PPM 5.1.1:
References to ESP's are formatted with the procedure number alone, without the required title. inadequate verification.)
PPM 5.1.1:
The procedure does not usc directives in active voice to direct action for a high level task.
inadequate verification.)
PPM 5.1.1:
The qualifier other than is used vice the term except".
gnadequatcverification.)
PPM 5.1.1:
The transition to Primary Containment Flooding on low RPV level is confusing.
PPM 5.1.2:
A flowchart structure is used that is not specifically allowed by the Writers Guide.
WRITER' GUIDE VERIF.
ADMIN VERIF.
TECH.
VALIDATION CLOSURE COMP.
DATE STATUS COMMENTS Proposed PPM mark-up complete.
Verification checklist to be changed.
Procedure is correct as written.
Proposed PPM mark-up complete.
PPM 5.1.2 does not contain any of the unauthorized flowchart s~aucture rclativc to this deficiency.
PPM 5.1.2:
A particular step contains four qualifying terms.
PPM 5.1.2:
At IIEE place in the PPM thc abbreviation S.P." was used vice SP.
PPM 5.1.2:
Contingency callouts missing (one for RPV Flooding and one for Emergency RPV Depress).
PPM 5.1.2:
Inconsistent terminology used.
Similar steps should bc wriucn using the same terminology.
Proposed PPM mark-up complete.
Simplified structure willbc used.
Proposed PPM mark-up complete.
Note: Allconungency callouts willbe changed to "NOTES".
Proposed PPM mark-up complete.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDINO ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPHON)
PPM 5.1.2:
Location information for P609 and P611 was given in a format other than specified in thc W.G.
PPM 5.1.2:
Periods used in the abbreviation chg. hdr. isol. valve.
PPM 5.1.2:
PPM contains additional information not specifically required.
PPM 5.1.2:
PPM uses "ATWS/ARI"vice"ATWS-ARI" PPM 5.1.2:
The step "Terminate boron injection if initiated" is a conditional step structured in a manner that violates W.G.
requirements.
Onadcquate verification.)
WRITER' GUIDE UERIF.
ADMIN UERIF.
TECH.
UALIDATION CLOS~
CO DATE STATUS COMMENTS Proposed PPM mark-up complete.
Proposed PPM mark-up complete.
Validation caused this note to be added and has since proven beneficial to PPM users when dealing with ATWS.
Proposed PPM mark-up complete.
Proposed PPM mark-up complete.
PPM 5.1.2:
Wording for the step which asks, "ls morc than one control rod not fully inserted?", is confusing.
PPM 5.1.3:
Wait Until" symbol inconsistently used (i.e., IEIr, of the symbols included the words then proceed ).
PPM 5.1.3:
Suggested working change to a step to eliminate the use of the word "until.
Proposed PPM mark-up complete.
Usage of the Wait Until symbol will bc eliminated.
Proposed PPM mark-up complete.
Suggested fit is technically incorrect and doesn't fitcorrect word usage.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMAN FACTOR EVALUATIONBEFORE DECIDING ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPI'ION)
PPM 5.1.4:
A step concerning MARFP was confusing to operators duc to complex logic and branching.
PPM 5.2.1:
A symbol was used with a slight deviation to Writers Guide criteria (i.e., contained a dotted linc).
PPM 5.2.1:
At IEII;location in the PPM the abbreviation DSIP" is used vice DSIL (typo)
PPM 5.2.1:
At IEII; location in the PPM the phrase "refer to" is used vice pcr".
PPM 5.2.1:
Brackets are used to identify concentration" per W.G. approved abbreviation/acronym list, while at another location in the W.G. direction is given to EIII usc brackets.
WRITER' GUIDE VERIF.
ADMIN VERIF.
TECH.
VALIDATION CLOSURE DATE COMP.
STATUS COMMENTS Proposed PPM mark-up complete.
Human factor willevaluate.
Proposed PPM mark-up complete.
Proposed PPM mark-up complete.
Writers Guide to bc corrected.
Proposed PPM mark-up complete.
PPM 5.2.1:
BWROG EPG criteria for drywcll spray initiation due to high P.C. pressure not mct.
PPM 5.2.1:
At ~n location of this PPM, the N~
contains a superscript vice subscript.
This is part of one of the three WNP-2 deviations at NRR. Additionally, the Supply System is persuing this issue with the BWROG EPC.
Proposed PPM marL-up complete.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDING ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIFI'ION)
PPM 5.3.1:
Decision blocks use the word "area" when referring to Table 1, while Table 1 was labelled using the word room" (relative to locations within the Reactor Building).
PPM 5.5.1; Ifthe entire procedure is performed, the step sequence of steps 1, 2, 3, 4, and 5 requires the operator to alternate back and forth between div 1 and div 2 panels.
(PPM did not fullymeet W.G.
requirements.)
PPM 5.5.1:
The PPM specified 'relay numbers in steps 1,2, 3,4, and 5 and did not use noun names for relays.
PPM 5.5.3:
Fire lockers near hydrant and FP-HT-1F werc in poor condition.
VYRITER'S GUIDE VERIF.
ADMIN VERIF.
TECH.
VALIDATION DATE COMP.
STATUS COMMITS Proposed PPM mark-up complete;-
PPM is correct as written.
Rational for step sequence was explained during inspection.
Corrective Action complete.
New fire lockers installed.
PPM 5.5.3:
Gate valve installation not specified in pfocedufco PPM 5.5.3:
PPM does not contain a note or caution concerning adverse conditions prior to the step which require opening the T.B.
rollup door.
Added during POC review but missed in retyping prior to issuance.
The change is complete.
Corrective action complete.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDINO ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPTION)
PPM 5.5.3:
Prcstaged dedicated tools were not available to perform step 2 which required closure of 3 condensate system valves.
PPM 5.5.5:
Step 2 in this procedure is different in format from identical steps I, 2, 3, and 4 of PPM 5.5.1.
WRITER' GUIDE VERIF.
ADMIN VERIF.
TECH.
VALIDATION DATE STATUS COMlvGMIS esc valves must be closed manually, via their handwheels.
This procedure would only be performed during times where no air or electrical power arc available for power assisted valve operators.
Steps are not identical.
Different format used due to differing scope requirements.
Inspection report error.
PPM 5.5.8:
Hose adapter used to connect hose to SLC flange not specified as a required tool in the PPM.
PPM 5.5.8:
PPM specified the use and prestaging of crescent wrenches vice box-end or socket drive wrenches.
PPM 5.5.8:
PPM uses valve numbers without a noun dcscriptor.
PPM 5.5.8:
Routing of several hundred feet of rubber hose from the SLC relief valves to RCIC pump suction would bc difficultfor one operator.
Consider installing a hose reel or additional operators.
This adapter is permanently connected to one end of the hose and was therefore not listed separately.
Proposed PPM mark-up complete.
Proposed PPM mark-up complete.
ER submitted requesting hose reel installation.
1990 EOP INSPECTION REPORT ANALYSIS COMPLZ1'ION STATUS I CORRECTIvE ACTION WILLBE IMPLEMENTEDAS NECESSARY 2
WILLAWAII'UMANFACTOR EvALUATIONBEFORE DECIDING ON ACTION 2
WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPI'ION)
PPM 5.5.9:
Dyno tape label found on RWCU-Mx-5.
"Dyno tape is temporary and uncontrolled and should not be found on any plant cquipmcnt.
PPM 5.5.9:
Note preceding step 16 appears to be inappropriate at this point in the sequence of actions.
WRITER' GUIDE VERIF.
ADMIN VERIF.
TECH.
VALIDATION CLOSURE COMP.
DATE STATUS COMMEYIS Not an EOP issue.
is note is in thc correct location.
PPM 5.5.9:
Step 14.g contains a wording error (i.e.,
should usc ensure" vice "confirm').
PPM 5.5.9:
Steps 13.e and 1 l.e are similar but use slightly different format.
PPM 5.5.9:
The word FILTER is shown in all capital letters (step 10.e) indicating it is exact plant labeling when in fact it should read "LOW FLOW RESET VESSEL A."
PPM 5.5.9:
Two different terms used to refer to thc same panel.
PPM 5.5.9:
Valve operators for manual RWCU valves listed is step ll.b are on the floor at the valves, however; they are not dedicated for EOP/ESP use.
PPM 5.5.11:
PPM includes d note prior to step 2 that attributes thc human cognitive process of thinking to the RSCS.
1 Proposed PPM mark-up complete.
1 Proposed PPM mark-up complete.
is is an error in the inspection report.
Proposed PPM mark-up complete.
Valve operators arc used for normal operations.
Proposed PPM mark-up complete.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDINO ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPTION)
PPM 5.5. 17:
Panel H13422 had penciled terminal layout marhngs on thc inside of the panel door.
PPM 5.5.17:
Step 5a is not clear on instruction to flood containmcnt.
PPM 5.5. 17: Steps 2 and 3 are 'ifstatements that require the Shift Manager and CRS to concurrently recheck entry conditions while executing all other EOP flowcharts.
These ifstatements" should be on the flowcharts.
PPM 5.5.18:
Step 3 should be integrated into step 4 as they arc not separate actions.
PPM 5.5.19: A white tag (dated 1983) was attached to RHR-V-67 noting the valve had a packing leak.
WRITER' GUIDE VERIF.
ADMIN VERIP.
TECH.
VALIDATION CLOSURE DATE COMP.
STATUS COMMIUVIS Not an EOP issue. Marhngs had nothing to do with PPM 5.5. 17. Marhngs have been removed.
Existing guidance is clear and adequate.
Separate ovemdcs exist for the conditions of the "ifstatements" in thc appropriate flowcharted EOP's.
These ifstatements are relative to PPM 5.5. 17 specifically.
PPM is correct as written.
Corrective action complete.
Old outdated tag was removed.
Not an EOP issue.
PPM 5.5.19:
Specilied a 15 ft. step ladder to reach a valve required to be operated.
The prestagcd ladder was only 8 ft.
PPM 5:5.19:
Steps 4h and 4i spccificd valve numbers without using noun names.
A 10 ft. ladder was immediately installed and PPM 5.5.19 will be changed to specify a 10 ft. ladder.
Proposed PPM mark-up complete.
Proposed PPM mart;-up complete.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION STATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDINO ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPTION)
PPM 5.6.1:
(SBO), lists no tools or equipment necessary to perform it.
PPM 5.6.1:
Dyno tape is used to label the open/dose lights for PI-VX-262, 263, 264, and 265 as well as E-CP-DG-RP/3 (D/G droop switch).
PPM 5.6.1:
Step 12b should be evaluated and revised as it incorrectly isolates RCIC high exhaust pressure isolation switches.
PPM 5.6.1:
Step 5.13 fails to indicate which HPCS and RCIC room doors to open.
(Inadequate verification.)
PPM 5.6.1:
Step 5. 19 requires operator to move upstairs to read hydrogen pressure.
Operator believed that he could also read this information on a local gauge without moving upstairs.
PPM 5.6.1:
Step 5.22 contains a second action that should be located after 5.23.
(Inadequate verification.)
WRITER' GUIDE VERIF.
TECH.
VALIDATION CLOSURE COMP.
DATE STATUS COMMENTS While not listed in the PPM, these tools (2 crescent wrenches) were and are prcstaged.
PPM willbe changed.
Proposed PPM mark-up complete.
Label request issued.
Willbe installed.
RFTS submitted to determine necessity of cap removal.
Existing direction is prescriptive and very adequate.
Operator was mcorrect.
This pressure cannot be read without moving upstairs.
PPM is correct as wnttcn.
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1990 EOP INSPECTION REPORT ANALYSIS COMPLETION SfATUS I 2
3 CORRECTIVE ACTION WILLBE IMPLEMENTEDAS NECESSARY WILLAWAITHUMANFACTOR EVALUATIONBEFORE DECIDINO ON ACTION WILLNOT BE IMPLEMENTED DISCREPANCY (DESCRIPI'ION)
The writers guide allows the use of qualifiers (i.e., except).
The position of the qualifier clause may cause it to be read after the action is begun.
The writers guide design for "continuation condition'teps splits the condition form in contingent action.
The condition is attached to the previous action symbol, suggesting a relationship that may not exist.
The writers guide directions on referencing and branching is unclear.
Definitions of referencing and branching provides no clear distinction.
WRITER' GUIDE X
VERIF.
ADMIN VERIF.
TECH.
VALIDATION CLOSURE COMPo DATE
. STATUS COMMI2iTS Only gtIB qualifier is allowed to be used
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(singular).
Human factors willlook into this.
t I
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