ML20012C797
| ML20012C797 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/19/1990 |
| From: | Black S Office of Nuclear Reactor Regulation |
| To: | Kingsley O Tennessee Valley Authority |
| References | |
| NUDOCS 9003230231 | |
| Download: ML20012C797 (8) | |
Text
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I March 19, 1990 Docket Nos. 50-259 50-260 Distribution and 50-296-f53BER"VWe78 BWilson NRC PDR WLittle Local PDR LA i
Mr. Oliver D. Kingsley, Jr.
BFN Reading TRoss Senior Vice President, Nuclear Power ADSP Reading OGC Tennessee Valley Authority
- DCrutchfield BGrimes 6N 38A Lookout Place TQuay EJordan 1101 Market Street-BDLiaw ACRS(10)
Chattanooga, Tennessee 37402-2801 SBlack GPA/CA RPierson GGalletti
Dear Mr. Kingsley:
SUBJECT:
PROVIDES EXAMPLES OF WEAKNESSES IN PROCEDURE DEVELOPMENT GUIDANCE
-AT BROWNS FERRY I
The staff reviewed your procedure improvement program during the Vertical
~ Slice Review conducted in December 1989.
In particular the staff identified certain weaknesses in~your maintenance and surveillance procedure development program.
Enclosed are details of the many examples of inadequate guidance the staff found regarding appropriate develo) ment of procedures at Browns' Ferry.
Further-more, this enclosure illustrates t1at undesirable procedure variations can be due to insufficient guidance and/or lack of conformance to existing guidance.
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These examples are being provided to you for use in strengthening your refer-ence guidance for developing procedures (i.e., Style Guide and Writer's Guides).
I If-you have any questions, please contact the NRC Project Manager, Thierry Ross, i
on(301)492-0767.
Sincerely, l
Original signed by Suzanne C. Black, Assistant Director for Projects i
TVA Projects Division Office of Nuclear Reactor Regulation
Enclosure:
As stated 9.003230231 900319 Tb
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NAME :TRoss
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KINGSLEY r
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Mr. Oliver-D. Kingsley, Jr. j cc:
General Counsel Chairman, Limestone County Commission Tennessee Valley Authority P. O. Box 188 400 West Summit Hill Drive Athens, Alabama 35611 ET llB 33H Knoxville, Tennessee 37902 Claude Earl Fox, M.D.
State Health Officer Mr. F. L. Moreadith State Department of Public Health Vice President, Nuclear Engineering State Office Building Tennessee Valley Authority Montgomery, Alabama 36130 400 West Summit Hill Drive WT 12A 12A Regional Administrator, Region 11 Knoxville, Tennessee 37902 U.S. Nuclear Regulatory Commission 101 Marietta Street, N.W.
Dr. Mark 0. Medford Atlanta, Georgia 30323 Vice President and Nuclear
' Technical Director Mr. Danny Carpenter Tennessee Valley Authority Senior Resident Inspector 6N 38A Lookout Place Browns Ferry Nuclear Plant Chattanooga, Tennessee 37402-2801 U.S. Nuclear Regulatory Commission Route 12, Box 637 Manager, Nuclear Licensing Athens, Alabama 35611 and Regulatory Affairs Tennessee Valley Authority Dr. Henry Myers, Science Advisor SN 1578 Lookout Place Committee on Interior Chattanooga, Tennessee 37402-2801 and Insular Affairs U.S. House of Representatives Mr. O. J.-Zeringue Washington, D.C.
20515 Site Director Browns Ferry Nuclear Plant Tennessee Valley Authority Tennessee _ Valley Authority Rockville Office P. O. Box 2000 11921 Rockville Pike Decatur, Alabama 35602 Suite 402 Rockville, Maryland 20852 Mr. P._Carier Site Licensing Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Decatur, Alabama 35602 Mr. G. Campbell Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P. O. Box 2000 Decatur, Alabama 35602
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ENCLOSURE
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Program Implementation Review I.
Procedure Quality -
Procedure quality was reviewed to ensure adequate incorporation of the proce-dural development guidance.
Results from this review indicate that surveil-lance and maintenance procedures appear adequate to perform required tasks but due to the lack of clearly defined criteria in existing reference guides (PMI-2.3, Style Guide for Writing Instructions Revision 6; PMI-2.5, Surveil-lance Instructions Writer's Guide Revision 9; and PMI-2,20, Format and Writer's Guide for Maintenance Instructions, Revision,1), these procedures contain numerous variations from each other and deviations from established guidance.
The following are examples of procedural weaknesses in the Style Guide and Writer's Guide which could negatively affect the quality and useability of maintenance and surveillance instructions.
A.
PMI-2,3, Style Guide for Writing Instructions, Revision 6 1.
Since craftspersons rely heavily on operator aids while performing maintenance and surveillance tasks, care must be given to ensure that aids are precise, accurate, and convey the necessary information.
Because these procedures are often performed in difficult working environments the quality of drawings, graphs, charts, and other aids will have a large impact on a craftpersons ability to use them effec-tively.
PMI-2.3 does not contain sufficient guidance on the pre-paration of operator aids to ensure consistent development of such aids.
2.
No guidance on the use of placekeeping is provided in the style guide.
Because these procedures are implemented in the field as well as the control room, provisions should be made to ensure operators will be able to maintain their location in the procedure throughout the evolu-tion of the surveillance or maintenance activity.
Some of the procedures are sufficiently lengthy (100+ pages) adding an even greater level of I
complexity in handling and utilizing the procedures.
3.
Section 4.1.1.5 (Action Verbs) should state that action verbs are l
always capitalized to ensure both consistent presentation of written procedures and to provide the procedure user with well defined easily recognized action requirements.
4.
Section 4.2 Note Item (2), instruction step structure should be expli-citly stated in a sufficient detail to ensure all instructional steps will be developed to a predetermined criteria.
Sentence structure (e.g. action verb, device or object being manipulated, location identi-fication, status indication, etc...) should be explicitly stated and examples provided to ensure consistent application of the guidance.
5.
A section should be provided which clearly defines the various step types (e.g. transitional steps, continuous steps, concurrent steps, etc...) including the structure of each of these.
Section 4.6 should I
be expanded to incorporate the required criteria.
l 1
m s
k 2-6.
Section 4.3 (Vocabulary) should be revised to speci/ically define the acceptable terms to be incorporated into the proces. res.
Using descrip-tions " concrete rather than vague, specific rather than ger.crai.
familiar rather than formal" introduce a large subjective factor into procedure preparation that should be avoided.-
7.
Several of the notes contain information which would be more useful incorporated directly into the body of the procedure as a numbered item rather than as supplementary information embedded into a note.
8.
Section 4.5 (Underlines) should be revised to more specifically define the criteria for use in highlight or emphasis.. This is particularly important as the overuse of underlining will' add both increased com-plexity and reduce the overall effectiveness of underlining as an i
emphasis technique.
9.
Section 4.6.8 (Lists) should be expanded to include specific format requirements (e.g. numerical indexing, bullets, etc...) which will be used for list development.
10.
Section 4.6.9 should explicitly state how parameters are to be for-matted and presented.
11.-
Due to the critical nature of decision steps, conditional statements.
need to be emphasized to ensure operators clearly understand the' logic requirements of a procedural step.
Section 4.7 should be expanded to include explicit instruction emphasis of logic statements and examples of the use of logic statements. The examples must be consistent with the criteria defined for the use of conditional statements.
In addition an inclusive list of acceptable logic terms and examples of their. usage should be presented to ensure consistent application of these terms.
i 12.
Section 4.8 should be expanded to include subsections for notes and examples which explicitly define the structure of each and present examples of acceptable usage.
13.
Section 4.9 (Branching) should be expanded to include a list of those referencing term (s) which are acceptable for use in procedures and examples of common usage for each.
14.
Section 4.9.8 requires that a description of a procedure evolution be provided once and subsequent activities requiring the same evolution be referenced to the original section. This method will promote a situa-tion where transitions, referencing, and required placekeeping will be increased and thereby detract from the usefulness of the procedure.
This section should be revised to state specifically when such methods will be acceptable and should indicate that this is not desirable and should be avoided.
15.
Section 4.11 (Verification Provisions) should incorporate a list of each hold point type acceptable and provide and example of the proper fomat for each.
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-16.
Section 4.16.8 on use of special instructions, should be expanded to include a list of all acceptable adverbs for use in the procedures as it relates to control functions.
- 17. Attachment 1 (Action Verbs) should include examples which are consistent with the acceptable format defined in the style guide.
18.
Section 4.21.2, this statement should be clarified and detailed criteric developed to ensure consistent quality charts and graphs. Methods of reproduction and policies to ensure currentness of operator aids should be addressed.
19.
Examples of defined criteria should be incorporated throughout the procedure to ensure users have a complete understanding of the material described.
Some areas where examples should be incorporated are noted here.
This list is not inclusive and many other sections should incor-p(orate examples to ensure consistent understanding of described stand e.g. 4.2.2, 4.6 & 4.8 subsections, 4.9.4,4.10,and4.11).
B.
PMI-2.5, Surveillance Instructions Writer's Guide, and PMI-2,20, Fonnat and Writer's Guide for Maintenance Instructions.
A review of PMI-2.5 and PMI-2.20 has determined that the procedures ace-quately address the guideline requirements for ensuring consistent develop-ment of surveillance and maintenance instructions with the exception of the items listed below.
1.
Several items do not provide adequate detail or examples to ensure consistent application of the instruction (e.g. SI 4.7.1, SI 4.9.2, Maint-4.4.8.2, Maint 4.4.8.9).
These items should be expanded to include criteria which will help ensure the intent of those instruc-tions is easily and consistently carried out.
2.
Section 4.10 (Illustrations) should be expanded to include specific criteria to be used in creating and subsequently evaluating the quality and usability of instruction aids (e.g. typesize and typestyle require-ments, required labels and indications, reproduction controls, legend requirements if provided, etc...).
3.
As indicated above, examples incorporating the requirements specified in the procedure should be incorporated into the appropriate sections to enhance user understanding of these reouirements.
II.
Procedures Reviewed -
Several surveillance and maintenance instructions were reviewed to deter-mine how effectively the guidance on procedure preparation was implemented.
The procedures were reviewed against the guidance provided in PMI-2.5, PMI-2.20, and PMI-2.3.
The procedures generally incorporated the guidance of these references and in most instances where deviations were noted, the lack of clearly defined criteria in the guidance documentation cer-tainly contributed.
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.. Several examples of inadequate implementation of the aforementioned guidelines were identified for each of the procedures listed below. This list in conjunc-I tion with the deviations specified on the next page serves to illustrate
.the presence of widespread procedure variations due to insufficient guidance criteria or lack of adequate verification against the existing guidance.
Procedure Title (1) 2-51-3.2.10.1 Verification of Remote Positior. Indicators for Core Spray System Valves, Revision 3 (2) 2-SI-4.2.B-60FT Core Spray Pump Area Cooler Fan Thermostat Functional, Revision 2 (3) 2-SI-4.10.B Demonstration of Source Range Monitor System Operability During Core Spray Alterations, Revision 4 l
l (4) 2-SI-4.2.B-5(B)
Core Standby Cooling Systems HPCI, LPCI, and Core Spray Initiation Logic Channel B - High Drywell Pressure Cali-bration, Revision 2 (5) 2-SI-4.2.C-3.2FT Instrumentation that Initiates Rod Blocks / Scrams, Inter-mediate Range Monitor (IRM) Functional Test with Reactor Mode Switch in Refuel or Startup, Revision 7 (6) 2-SI-4.5.A.I.c(I) Core Spray MOV Operability Test, Revision 5 (7) 2-SI-4.5.A.1.d(I) Core Spray Flow Rate Loop 1. Revision 7 (8) 2-01-75 Core Spray System, Revision 12 (9)' MMI-51 Maintenance of CSSC/non-CSSC Valves and Flanges, Revision 11 x
(10)LCI-2-F-75-21 Loop Calibration Instruction Core Spray System 1 Flow Indication, Revision 1 (11)ECI-0-075-LUG 001 Electrical Corrective Maintenance Terminating Core Spray l
Pump Motor Leads using Raychem Kits, Revision 3 l
(12) EMI-18 Limit and Torque Switch Adjustment for High Speed CSSC and non-CSSC Valves, Revision 6 (13) MCI-0-075-VLV002 Core Spray Valves 75-537a,75-537b, 75-537c, and 75-537d l
Disassembly, Inspection, Rework, and Reassembly, Revi-sion 3 l
(14)ECI-0-000-M0V002 Electrical Corrective Instruction Limitorque Motor j
Operated Valves Electrical Adjustments, Revision 2 i
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(15)-ECI-0-000-MOV003 Electrical Corrective-Instruction Limitorque Motor Operated Valves Testing Using MOVATS, Revis_ ion 5 (16)2-XA-55-3 Core Spray-Sys I Pump A Start, Revision 7 (17)'2-XA-55-3F Core Spray Sys II Sparger Break, Revision 7 Examples of deviations from the Style Guide and Writer's Guides, as referenced to the procedures above, are as follows:
a.
Inconsistent procedure referencing styles 7.7 note, (3) 1.2 note.-(4) 7.10. (7) 7.44 9.73.1, 9.73.2, (14) 7.5.8 b.
Inconsistent status indication styles (5)7.6.25.1,7.6.3 c.
Action verb usage inconsistent with acceptable action verb list (2) 7.6.1, (4) 7.5, 7.26, (6)7.8.1,(7)7.14,(10)7.18,7.25.3-7.25.4,(11)7.4.3,(14)7.6.3,(17)3 d.
Inconsistent equipment location referencing styles
.(1)7.7.1.6.2,(5)7.5.2,7.6.21.2,(5)7.7.21.3,7.7.41.1,(6)7.6.2, 7.6.4,(10)7.20 e.
Inconsistent illustration styles
- 4) illustration 1, (7) illustration 1, (9) appendix D attachment 1,
- 15) attachment 7 f.
Inconsistent use of capitalization (1) 7.7.1.1, 7.7.1.2, 7.7.1.3, (5) 7.5.6, (7) 7.5 not term, 7.6 record, (7) 7.7, 7.9 action verbs, (9) 8.2.6, (11) 7.2.5.1, (7) 7.3.2, (12) 8.1.16, 8.1.17, (15) 7.2.4, (17) 3 g.
Inconsistent usage of cautions and notes (7) 7.10, 7.15, (9) 8.2.10.2, (12) 8.0, 8.1.4, (12) 8.1.26, (13) 7.0 h.
Inconsistentuseofnotes(incorporationofactionstatements)
(1) 7.7, (11) 7.4.3 o
k..,7
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, t 1.
Inconsistent use of highlighting techniques (2) vs (3) incorporate different use of underlining of references.
Reference, (12)(7) 7.1, 8.1, (9) 3.13.3.14 (11) 4.2 (6) 7.1, 8.1, Reference, 7.8.1 8.1.11 j.
Inconsistent use of equipment identification references (4)-7.2.8,7.2.9.(8) Attachment 2. (11) Inconsistent reference to person-nel,(1)4.2,-(7)4.4 k.
Inconsistent use of logic terms 7.6.2,7.6.2.1,7.6.2.2,7.7.3.4,(3)7.10.2,(4)_7.27.2 7.16, 7.20 (5)7.7.43,7.6.22.1.3,7.6.23.1 (7) 7.15 4.1.2, 8.1.1.4.b (10) 7.11, 7.14 (11)7.2.1,(13)7.3.6,7.3.7 14)7.3.3.7,7.3.3.8 (15) 7.2.2, 7.4.5, (16) 1, 3, 4 (17) 2, 3, 4 1.
Use of punctuation not defined (2) 7.6.2 (3)7.6-7.9 All procedures using ":"
All procedures using "()"
All procedures using "/"
m.
Use of vague terminology in contrast to guidance (3) 7.12, 7.13, 7.14 (4) 7.27.10, 7.27.11 (10) 7.24.5 n.
Term "not" missing underlining (3)7.10.2,(4)5.2 o.
Inconsistent format for hold points (4)7.37.4 p.
Use of actions in precautions in contrast to guidance (7)3.12 q.
Excessively lengthy steps containing multiple actions (9)8.2.5,8.4.2
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Principal Contributor:
G. Galletti
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