ML18033B135
| ML18033B135 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 01/18/1990 |
| From: | Crutchfield D Office of Nuclear Reactor Regulation |
| To: | Kingsley O Tennessee Valley Authority |
| References | |
| NUDOCS 9001260265 | |
| Download: ML18033B135 (16) | |
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Docket No. 50-260 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 January 18, 1990 Mr. Oliver D. Kingsley, Jr.
Senior Vice Pr es ident, Nuclear Power Tennessee Valley Authority 6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801
Dear Mr. Kingsley:
SUBJECT:
BROWNS FERRY'S EMERGENCY OPERATING PROCEDURES/INSTRUCTIONS An NRC inspection performed during the period of August 8-19, 1988 (NRC Inspection 50-260/88-200) determined that the Browns Ferry Nuclear Plant (BFN) emergency operating instructions (EOIs), when used by trained operators, would function to mitigate the consequences of an accident.
- However, numerous weaknesses involving the development of the EOIs were found.
On May 31, 1989, you forwarded your response to Inspection Report 88-200.
In this letter you committed to fix a limited number of identified weaknesses in the BFN EOIs which were based upon Revision 3 of the NRC approved Emergency Procedures Guidelines (EPGs).
The NRC staff revisited the BFN site on October 17-18, 1989 to review the status of the BFN EOIs for restart.
The staff confirmed that the BFN EOIs were nearly equivalent to Revision 3 of
= the EPGs.
This audit identified several issues involving the current Revi-sion 3 EOIs requiring TVA's attention prior to Unit 2 restart.
These issues are identified in Enclosure 1 and were discussed with your staff during the October audit.
Resolution of these concerns will result in making the current BFN EOIs fully equivalent to Revision 3 at restat t.
To verify the staff's previous conclusion in Inspection Report 88-200 concerning the acceptability of the BFN EOIs, when used by trained operators, we will evaluate operator perfor-mance using Revision 3 EOIs as part of the requalification examinations.
Pend-ing our successful verification of operator action using Revision 3 of the
Our audit also identified a longer-term problem requiring your attention after restart.
You previously committed to have the BFN operators fully trained in Revision 4 of the EOIs prior to the end of 1990, which is after the scheduled May 1990 Unit 2 restart date.
Our October audit has identified weaknesses in the current Writer's Guide which were previously discussed in Inspection Report 88-200.
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January 18, 1990 The current Writer's Guide should be rewritten to eliminate potential problems in the development of the EOIs, especially with respect to logic statement'eaknesses and referencing problems.
The problems with the Revision 3 EOIs should be eliminated in the Revision 4 EOIs through the use of a good Writer' Guide.
Although the current EOIs could benefit from a similar effort, you should not undertake major revisions to the Revision 3 EOIs unless sufficient time is available to retrain the operators prior to restart, to ensure safety is not adversely impacted.
Enclosure 2 provides comments TVA should consider in developing the new Writer's Guide and the Revision 4 EOIs.
In light of the substantial effort required to develop the Writer's Guide and Revision 4 EOIs, we believe you should reevaluate your Revision 4 implementation schedule.
We expect that you will keep us informed on the progress of your Revision 4
upgrade program.
In summary, the staff concludes that with the comprehensive training undergone by the plant operators, the plant can be restarted and safely operated using the Revision 3 based procedures.
Furthermore, it is our understanding that TVA will undertake a review of the current Writer's Guide to incorporate the staff's comments identified in Inspection Report 88-200 and amplified in.
A revised Writer's Guide will be used to develop the Revision 4
EOIs.
A schedule for the full implementation of Revision 4 will be the subject of further discussions.
t If you have any questions, please call the NRC Project Manager, Gerald E. Gears, at 301-492-0767.
S incere ly, ennis H. Crutchfield, A
ociate Director for Special Projects Office of Nuclear Reactor Regulation
Enclosure:
1.
Staff Comments-on the Draft Emergency Operating Instructions on October 17-18, 1989 2.
Staff Comments for Incorporation in Browns Ferry Revision 4
Emergency Operating Instructions cc w/enclosu'res:
See next page
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Br.. Oliver D. Kingsley, Jr. January 18, 1990 The current Writer's Guide should be rewritten to eliminate potential problems in the development of the EOIs, especially with respect to logic statement weaknesses and referencing problems.
The problems with the Revision 3 EOIs should be eliminated in the Revision 4 EOIs through the use of a good Writer' Guide.
Although the current EOIs could benefit from a similar effort,,you should not under take major revisions to the Revision 3 EOIs unless sufficient time is available to retrain the operators prior to restart, to ensure safety is not adversely impacted.
Enclosure 2 provides comments TVA should consider in developing the new Writer's Guide and the Revision 4 EOIs.
In light of the substantial effort required to develop the Writer's Guide and Revision 4 EOIs, we believe you should reevaluate your Revision 4 implementation schedule.
We expect that you will keep us informed on the progress of your Revision 4
upgrade program.
In summary, the staff concludes that with the comprehensive training undergone by the plant operators, the plant can be restarted and safely operated using the Revision 3 based procedures.
Furthermore, it is our understanding that TVA will undertake a review of the current Writer's Guide to incorporate the staff's comments identified in Inspection Report 88-200 and amplified in Enclosure 2.
A revised Writer's Guide will be used to develop the Revision 4
EOIs.
A schedule for the full implementation of Revision 4 will be the subject of further discussions.
If you have any questions, please call the NRC Project Manager, Gerald E. Gears, at 301-492-0767.
Sincerely, Dennis M. Crutchfield, Associate Director for Special Projects Office of Nuclear Reactor Regulation I
Enclosure:
1.
Staff Comments on the Draft Emergency Operating Instructions on October 17-18, 1989 2.
Staff Comments for Incorporation in Browns Ferry Revision 4
Emergency Operating Instructions cc w/enclosures:
See next page NRR:TVA/PM*
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Letter dated January 18, 1990 to Tennessee Valley Authority BROWNS FERRY'S EMERGENCY OPERATING PROCEDURES/INSTRUCTIONS DISTRIBUTION:
Docket File NRC PDR Local PDR BFN Reading ADSP Reading TEMurley/JSniezek DCrutchfield FMiraglia JRoe SShankman AThandani GThomas JKudrick BDLiaw SBlack Rpierson BWilson, Region II WLittle, Region II Licensing Assistant GGearst DMoran AMasciantonio OGC
GAP/CA
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Mr. Oliver D. Kingsley, Jr.
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January 18, 1990 cc w/enclosures:
General Counsel Tennessee Valley Authority 400 Mest Summit Hill Drive ET 11B 33H Knoxville, Tennessee 37902 Nr. F. L. Moreadi th Vice President, Nuclear Engineering Tennessee Valley Authority 400 West Summit Hill Drive WT 12A 12A Knoxville, Tennessee 37902 Dr. Nark 0. Medford Vice President and Nuclear Technical Director Tennessee Valley Authority 6N 38A Lookout Place Chattanooga, Tennessee 37402-2801
- Manager, Nuclear Licensing and Regulatory Affairs Tennessee Valley Authority 5N 157B Lookout Place Chattanooga, Tennessee 37402-2801 Mr. 0. J. Zeringue Site Director Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.
Box 2000
- Decatur, Alabama 35602 Mr. P. Carier Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. 0.
Box 2000
- Decatur, Alabama 35602 Mr. G. Campbell Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P, 0.
Box 2000
- Decatur, Alabama 35602
- Chairman, Limestone County Commission P. 0.
Box 188
- Athens, Alabama 35611 Claude Earl Fox, M.D.
State Health Officer State Department of Public Health State Office Building Montgomery, Alabama 36130 Regional Administr ator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street, N.M.
Atlanta, Georgia 30323 Mr. Danny Carpenter Senior Resident Inspector Browns Ferry Nuclear Plant U.S. Nuclear Regulatory Comission Route 12, Box 637
- Athens, Alabama 35611 Dr. Henry Ayers, Science Advisor Committee on Interior and Insular Affairs U.S.
House of Representatives Washington, D.C.
20515 Tennessee Valley Authority Rockville Office 11921 Rockville Pike Suite 402 Roc kvi 1 le, Maryland 20852
ENCLOSURE 1
STAFF COtOENTS -ON-THE-DRAFT BIERGENCY.
VISION-3.
PC/P-6.1 is intended to prevent actuation of the wetwell sprays if the nozzles are submerged.
Spray actuation would result in water from the nozzles entering directly into the suppression pool.
The EOIs have taken "this action when the level instrumentation is at the maximum value.
For Browns Ferry, this limit is 20 feet while the nozzles are at 26.4 feet.
This results in a space of 6.4 feet where the sprays could possibly be eff'ective, but are not actuated due to limitations of instrumentation.
Discussion revealed that there may be alternate methods which could be used to determine the water level beyond 20 feet.
In light of the fact that spray actuation is the last remaining action that could save the containment, all possible means should be taken to assure that the sprays are available.
TVA should review the-alternate procedures to determine level, rather than simply limiting the action aue to primary level instrumentation limits.
In general, the reason for the action which is normally'iven in the EPGs in parentheses is the basis for the action.
However, the EOIs have also triggered the action due to instrument limitation as indicated in 1.0 above; If the action is based on instrument limits, it should be so stated rather than the rationale provided in the EPGs..
The draft that the staff reviewed had several inconsistent referrals.
For example, suppression pool water level was given in negative inches from normal as well as a measurement in feet from an absolute reference.
Also, the wetwell is referred to as the primary containment as well as the wetwell.
Vhi le we recognize that the EOIs which the staff reviewed were in draft, special note should be taken to eliminate these types of inconsistencies.
-The actions indicate that there is no manual action to initiate either the RHR or CS room coolers.
This limitation is not normal for a clark I design.
Therefore, this limitation should be verified before this important option is discarded.
Several actions within the Secondary Containment Section are based on the operator being able to determine whether the pipe rupture is within the primary or secondary system.
However, there is no guidance provided to the operator in determining which system is affected.
First of all, this is a deviation of the symptom based EOIs.
It requires an evaluation by the operator.
Secondly, there is no direction given to the operator.
The EOIs should as a minimum provide some guidance relative to how the operator should determine the break location.
Otherwise, the operator is left to his judgment as to how the location is determined.
6.
In the EOIs, Contingency No.
2 (Emergency Reactor Depressurization) is entered if reactor water level cannot be determined.
However, in the BWR Owners'roup.(BWROG)
Revision 3 of the Emergency Operating Procedures, the appropriate action is flooding the reactor pressure vessel (RPV) when reactor water level cannot be determined.
Emergency depressurization may complicate efforts to restore and maintain RPV water level.
TVA has com-mitted to revise this procedure to reflect the BWROG guidance.
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ENCLOSURE 2 STAFF COMMENTS FOR INCORPORATION IN BROWNS FERR R
V I
4 EM CY OP RATING I STRUCTIONS Major weaknesses were identified in the BFN EOI program during both the 1988 EOP inspection and the staff's October 1989 review.
These program weaknesses generally relate to the Writer's Guide and to the verification of the procedures.
In order to develop procedures that clear ly and consistently present informa-tion to operators in a way that will minimize error, a complete and restrictive Writer's Guide is necessary.
A complete Writer's Guide addresses every aspect of the procedures, and is restrictive in that it defines the precise methods and format to be used when writing procedures.
Writer's Guides that fail to address important aspects of a facility's procedures or fail to precisely define the structure of a facility's procedures will lead to inconsistent and unclear procedures that may increase, rather than minimize, human error.
Prior to upgrading the BFN EOIs to'evision 4 of the NRC approved Emergency Procedures Guidelines, the Writer's Guide should be revised to correct the weaknesses, taking the following into consideration.
In order to present procedural information in a way that will minimize error potential and support operator performance, three main points should be emphasized.
1.
Oesign a simple and distinct format for important types of procedure steps.
By keeping the format simple, the steps will be easy for operators to read and understand.
By selecting a distinct format for each type of important step, operators will be able to identify the action required of them by the format of a step, as well as its content (e.g.,
"GO TO step X"
means to leave the step in process and perform the step or procedure indicated, whereas "REFERENCE step X" means to perform the step indicated ly Ith e p
p
).
Th di i
i F11 id operator use of the procedure and increase the likelihood that the steps will be performed correctly.
2.
Use a clear emphasis method for each type of important step format.
For example, capitalization and underlining may be used to draw operator attention to the format that identifies the type of step to be performed (e.g.,
"GO TO Step 24 of this procedure" ).
Logic terms, transition terms, and cant>unary information are especially in need of clear emphasis.
3.
Consistently apply the format and emphasis methods.
When operators are trained and thus expect different types of procedure steps to be dis-tinctly presented and emphasized, deviation from their expectations can slow information processing and interfere with use of the procedure.
Inconsistency in procedure format can potentially lead to operator error (e.g.,
"GO TO" used to indicate a transition in another part of the pro-cedure; conversely, "GO TO" used to mean concurrent execution of steps in one place in the pro'censure and moveiaent from one step to another elsewhere in the procedure).
Consistent application of format can only be assured through the use of a complete and restrictive Writer's Guide, and verifi-cation against the Writer's Guide.
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