ML20036B110

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Insp Repts 50-338/93-17 & 50-339/93-17 on 930416-23. Violations Noted.Major Areas Inspected:Exam of Events Involving 930416,unit 2 Reactor Trip & Post Trip Operator Intervention Which Defeated Auxiliary Feedwater Sys
ML20036B110
Person / Time
Site: North Anna  Dominion icon.png
Issue date: 05/10/1993
From: Belisle G, Lesser M, Taylor D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20036B108 List:
References
50-338-93-17, 50-339-93-17, NUDOCS 9305180175
Download: ML20036B110 (12)


See also: IR 05000338/1993017

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UNITED ST ATES

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Report Nos.:

50-338/93-17 and 50-339/93-17

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Licensee:

Virginia Electric & Power Company

5000 Dominion Boulevard

Glen Allen, VA 23060

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Docket Nos.: 50-338 and 50-339

License Nos.: NPF-4 and NPF-7

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Facility Name: North Anna 1 and 2

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Inspection Conducted: April 16-23, 1993

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Inspectors:

PA49--t

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Date Signed

M.S.'L sser, Senior Resident Inspector

Sks/F 3

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D.R. Taylor, Resident inspector

Date Signed

Accompanying Inspectors:

John V. Kauffman, NRC, AEOD

Robert A. Spence, NRC, AE0D

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Approved by:

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G.A. Belisfe,N ection Chief

Date Signed

Division of Reactor Projects

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SUMMARY

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Scope:

This special inspection by the resident inspectors was performed to examine

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the events involving the April 16, 1993, Unit 2 reactor trip and the post trip

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operator intervention which defeated the auxiliary feedwater system automatic

start capability for at least 18 minutes.

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Results:

The plant response to the trip was normal with no significant complications or

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equipment problems. All safety systems functioned as designed._

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The operators defeated the ability of the auxiliary feedwater system to

automatically start within 60 seconds when a valid start signal was present.

Corrective action was not immediately initiated for three inoperable AFW pumps

as required by Technical Specification 3.7.1.2.

This is identified as an

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apparent violation, 50-339/93-17-01. A second part of the apparent violation

along with other contributing items in this event are as follows:

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9305100175 930510

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ADOCK 05000338

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Operators failed to follow the procedure 2-ES-0.1, Reactor Trip

Response, requirements in that AFW pumps were secured and AMSAC was

reset prior to steam generator narrow range levels returning to greater

than 20 percent level. This is identified as the second part of the

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apparent violation, 50-339/93-17-01.

Command and control by the Unit 2 Supervisor (Senior Reactor Operator)

was weak, specifically during the recovery from a moderate cooldown.

The Unit 2 Supervisor neither provided adequate direction nor

effectively used alternatives provided by the procedure.

Further, he

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failed to adequately supervise actions taken by the balance of plant

operator.

The balance of plant operator exhibited several misconceptions about the

auxiliary feedwater (AFW) system operation.

He was not aware that

throttling AFW was an option to reduce cooldown or of the limitations

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for operating AFW on recirculation. Additionally, he did not understand

the licensee's nuclear safety policy on defeating an automatic safety

function. He did not recognize that a valid engineered safety feature

signal was present.

Operators interviewed had varied interpretations of how to implement the

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Response Not Obtained column of 2-ES-0.1 step 1, if required later in

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the event, after having previously obtained the expected response.

The licensee has an established policy not to defeat automatic safety

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functions.

The licensee promptly reported the event and initiated an investigation to

determine what causal factors were involved.

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Operators interviewed generally believed that " verify" steps in the procedures

allowed them to initiate actions. This is not consistent with the licensee's

procedure writer's guide and may indicate a weakness in procedure

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impl ementation. This is an Inspector Followup Item number 50-339/93-17-02,

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Use of Verification Steps in E0Ps to Perform Actions, (paragraph 6).

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The licensee believed that it would have been acceptable to shut the auxiliary

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feedwater system valves instead of placing the pumps in Pull-to-Lock. The

licensee had not considered this as another method to potentially bypass the

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safety system. This is an Inspector Followup Item number 50-339/93-17-03,

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Potential for Bypassing Safety System Due to Closed Discharge Valves,

(paragraph 8).

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REPORT DETAILS

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Persons Contacted

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Licensee Employees

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  • M. Bowling, Manager Nuclear Licensing and Programs

L. Edmonds, Superintendent, Nuclear Training

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R. Enfinger, Assistant Station Manager, Operations and Maintenance

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  • J. Hayes, Superintendent of Operations
  • D. Heacock, Superintendent, Station Engineering

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  • G. Kane, Station Manager

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  • P. Kemp, Supervisor, Licensing

W. Matthews, Superintendent, Maintenance

J. O'Hanlon, Vice President, Nuclear Operations

D. Roberts, Supervisor, Station Nuclear Safety

  • R. Saunders, Assistant Vice President, Nuclear Operations

D. Schappell, Superintendent, Site Services

R. Shears, Superintendent, Outage and Planning

  • J. Smith, Manager, Quality Assurance

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A. Stafford, Superintendent, Radiological Protection

J. Stall, Assistant Station Manager, Nuclear Safety and Licensing

Other licensee employees contacted included engineers, technicians,

operators, mechanics, security force members, and office personnel.

NRC Personnel

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  • M. Lesser, Senior Resident Inspector

D. Taylor, Resident Inspector

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  • S. Lee, Resident Inspector
  • M. Sinkule, Branch Chief, NRC Region II

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  • Attended exit interview

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Acronyms and initialisms used throughout this report are listed in the

last paragraph.

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2.

Event Summary

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On April 16, 1993, at 7:17 a.m., Unit 2 experienced an automatic reactor

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trip on turbine trip from 100 percent power due to a generator voltage

regulator failure.

Safety systems responded as designed. Approximately

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9 minutes into the event; however, a reactor operator defeated the

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automatic actuation of AFW in order to reduce the primary plant

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cooldown. A valid AFW start signal- from a low-low SG level' was still

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present. The condition was not recognized as a bypassed safety system

until at least 18 minutes later when other operators identified the

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situation. The AFW system was then returned to automatic standby.

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3.

Sequence of Events

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The following sequence of events was compiled based upon review of post

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trip event printouts and curves, logs and interviews with operators.

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The specific event occurred at approximately the time indicated.

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April 16, 1993

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7:17 a.m.

" Exciter Field Forcing" annunciator received indicating

generator voltage regulator failure

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" Volts / Hertz Relay Actuation" annunciator received

indicating generator overexcitation

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Turbine generator trip

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Reactor trip on turbine trip from 100% power

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AFW automatic start due to SG level shrink.

AFW total flow

rate = 1425 gpm

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Feedwater isolation due to Tave < 554*F with Reactor Trip

7:20 a.m.

Operators verify safety injection is not required and

transition from 2-E-0, Reactor Trip or Safety Injection to

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2-ES-0.1, Reactor Trip Recovery

7:21 a.m.

RCS temperature verified to be at or trending to 547'F

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7:24 a.m.

Primary plant R0 voices concerns to other Control Room

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personnel that RCS temperature is cooling down below 547*F

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7:26 a.m.

BOP R0 starts feeding 2 of 3 SGs with Main Feedwater, places

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MDAFW pumps in PTL and shuts steam supply trip valves to

TDAFW pump.

This defeats automatic start; SG A NR Level =

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5%, SG B NR Level - 12%, SG C NR Level - off-scale-low

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Minimum RCS Tave at 539.5'F; Tave starts trending up towards

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547'F; Minimum pressurizer level at 23%

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7:30 a.m.

With Main Feedwater pumps running, SG B Low-Low Level Alarm

clears

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7:35 a.m.

RCS Temperature stable at 547'F; Pressure stable at 2235

psig

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7:41 a.m.

SG C Low-Low Level Alarm clear

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7:44 a.m.

SG A low-Low Level Alarm clear

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7:45 a.m.

AFW returned to automatic standby

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4.

Event Description

The inspectors reviewed post trip data and conducted discussions with

licensee personnel to assess the plant's and operators' responses.

Following a typical reactor trip, plant systems are designed to bring

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RCS temperature to the no-load Tave value of 547'F and return RCS

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pressure to its normal value of 2235 psig. Normally assigned to Unit 2

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are the 0ATC (Reactor Operator) and the Unit 2 Supervisor (Senior

Reactor Operator).

Following a Unit 2 reactor trip, the 0ATC operates

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primary plant control systems, the TS required third reactor operator

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assumes control over BOP equipment, the Unit 2 Supervisor assumes the

Control Room Command function and the Unit 1 Supervisor acts as the E0P

reader.

The plant's initial response to the trip at t = 0 minutes was

satisfactory.

AFW started automatically due to SG level shrink and

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total AFW flow reacheri 1425 gpm with all throttle valves fully open.

The Main Feedwater R(qulating Valves closed as Tave dropped below 554*F.

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The Main Feedwater Regulating Bypass Valves were closed but available

for feeding SGs.

At about t - 3 minutes, the operators had completed the applicable steps

of procedure 2-E-0, Reactor Trip or Safety Injection, and were

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transitioning to 2-ES-0.1, Reactor Trip Response.

Step 1 of 2-ES-0.1

checks RCS average temperature stable or trending to 547'F and provides

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steps to throttle AFW to 400 gpm if the cooldown continues. As the

downward trend in RCS temperature was not yet evident at that time,

these steps were not implemented.

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In the next few minutes, the high AFW flow rate to the SGs caused RCS

temperature to continue to decrease.

The primary plant R0 voiced

concerns with RCS cooldown rate, in that it was trending below 547*F.

At this point, command and control problems started to occur. Several

equipment problems were being evaluated and dealt with. These included

feedwater relief valves lifting, failed SRNI (N-31), a RCP high

vibration alarm, an IRPI problem, an air ejector radiation monitor alarm

spike and a condensate recirculation valve failure.

The B0P RO

requested permission to " secure AFW" in order to reduce the cooldown.

The procedure reader asked if he could read aloud the RNO steps for RCS

temperature not stable which would have throttled AFW back to 400 gpm.

The Unit 2 Supervisor said, " wait".

The Unit 2 supervisor noted that SG B narrow range level was greater

than 11% (indicating an adequate heat sink), RCS temperature was at

540*F and the procedure allowed AFW flow reduction to below 400 gpm.

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The Unit 2 supervisor gave permission to the B0P operatar to secure AFW

and commence feeding the SGs via the Main Feedwater Regulating Bypass

Valves.

There were no procedural steps to do this for the existing

plant conditions.

Prior to securing AFW, the operators noted that the AMSAC logic had to

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be reset otherwise the AFW pumps would not stop. The operators reset

AMSAC although this was not directed by the procedure. At t = 9

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minutes, the B0P operator secured AFW by placing both MDAFW pumps in PTL

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and closing the steam supply trip valves to the TDAFW pump (2-MS-TV-111A

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and 2-MS-TV-111B). He did not inform control room personnel of this

action.

RCS temperature stopped cooling down and returned to 547*F over

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the next several minutes.

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The B0P R0 also commenced to feed two of the three SGs via the bypass

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valves. At approximately t - 18 minutes primary temperature and

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pressure had stabilized at their desired values and SG B narrow range

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level was in the required band of 20-33%.

Feed was increased to SGs A

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and C to raise level.

All three narrow range levels were clear of the low-low level setpoint

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at t = 27 minutes allowing the AFM pumps to be stopped and placed in

automatic standby. At approximately this point, the procedure reader

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recognized that the AFW pump switches were in PTL and raised a concern

as to how the condition occurred. The Shift Supervisor was notified and

he directed that the switches be placed in Auto.

Since SG levels were

above the low-low setpoint, the pumps did not restart.

It was concluded

that the AFW system remained incapable of automatic actuation for a

duration of at least 18 minutes.

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Summary of Requirements

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Technical Specification 3.7.1.2 requires 3 auxiliary feedwater pumps to

be operable.

With 3 inoperable feedwater pumps, immediately initiate

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corrective action.

Technical Specification 3.3.2.1 requires ESFAS instrumentation channels

associated with AFW pump automatic actuation logic, SG Low-Low Level,

Safety Injection and Station Blackout to be operable with response time

s 60 seconds.

2-ES-0.1, Reactor Trip Response, step 1, checks RCS temperature stable

at or trending to 547'F. The RNO column states that if a cooldown

continues then adjust total AFW flow to 400 gpm until at least one SG

narrow range level is greater than 11%.

2-ES-0.1, step 6, checks SG levels greater than 11%.

The RNO column

states that if all levels are not greater than 11%, maintain total AFW

flow greater than 400 gpm until narrow range level is greater than 11%

in at least one SG.

2-ES-0.1, step 12, requires that all SG narrow range levels are verified

greater than 20% , reset AMSAC, and stop AFW pumps by placing the

switches to auto.

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Assessment of Procedural Implementation

The operators were slow to gain control over RCS temperature as it

cooled below 547'F.

Step 1 of 2-ES-0.1 had already verified RCS

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temperature stable at 547'F; however, a subsequent cooldown trend

developed.

Although this was recognized by the primary plant R0 and

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reported to the Unit 2 Supervisor, command and control of the situation

was inadequate.

Steps were not taken to throttle AFW to 400 gpm when it

became clear that RCS temperature was not stable at 547'F.

Furthermore,

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the BOP R0 believed that AFW could not be throttled to 400 gpm until at

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least one SG narrow range level was greater than 11%.

Therefore, he did

not initially take or recommend any action.

Later discussions with the

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operators indicated confusion on how to implement an RNO step when the

expected response had previously been obtained.

While some believed the

RNO steps could be implemented based upon operator judgement, others

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believed that one must formally return to the step.

At this point, the operators were at step 6 of 2-ES-0.1 and observed

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that B SG was greater than 11%.

This would allow them to reduce AFW to

less than 400 ppm.

Subsequent discussions with the operators revealed

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that each one envisioned a different method to accomplish this. The

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shift supervisor and procedure reader assumed that AFW would be

throttled. The Unit 2 Supervisor understood that the pumps would not

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stop unless AMSAC was reset.

The B0P operator intended to place the

pumps in PTL to ensure they would not restart on the valid low-low SG

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level signal. The B0P R0 stated, in later interviews, that he was

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concerned that fully throttling back on AFW and operating the pumps on

the one inch recirculation line was undesirable and may cause damage.

This concern was apparently a result of previous pump degradation

problems during testing which existed at the plant prior to installing a

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6 inch full-flow recirculation line. The 6 inch line is normally valved

out and is presently used only for pump surveillance testing. The B0P

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R0 apparently did not fully understand that the one inch recirculation

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line was acceptable for short term operation during emergencies. The

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B0P R0 also did not realize tha the Low-Low SG Level signal represented

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an ESF.

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A sense of urgency was being voiced by the primary plant R0.

The Unit 2

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Supervisor did not provide assurance to the primary plant RO that the

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condition was being addressed.

The procedure reader offered to read the

steps to arrest cooldown (thrcttle AFW to 400 gpm) but the Unit 2

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Supervisor rejected the recommendation.

The Unit 2 Supervisor's intent

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was to shift SG feeding from AFW to Main Feedwater via the bypass

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valves; however, the E0P did not provide steps by which to do this at

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this specific point in time.

In essence, the operators improvised to

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accomplish their objective.

Poor communications and non-specific

directions such as " secure AFW", "back off on AFW" and "take off AFW"

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were used which resulted in resetting AMSAC out of procedural sequence

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and turning off the AFW pumps and defeating their automatic start

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capability. At this point, all SG narrow range levels were less than

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the 20% criteria of 2-ES-0.1, step 12, to reset AMSAC and turn off the

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AFW pumps. The SG levels were:

A 5%, B 12%, and C off-scale-low.

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valid SG low-low level setpoint was still present.

This is identified

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as one part of apparent violation 50-339/93-17-01, Failure to Follow

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Procedure 2-ES-0.1 in Securing AFW Following Reactor Trip.

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Main Feedwater was used to feed the SGs; however, this would have been

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unavailable during a loss-of-offsite-power event and AFW pumps would not

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have started automatically within 60 seconds as required.

The action

required of TS 3.7.1.2 with all three auxiliary feedwater pumps

inoperable to immediately initiate corrective action to restore at least

one pump was not taken in that it took a minimum of 18 minutes to return

the system to an operable status.

This is identified as the second part

of apparent violation 50-339/93-17-01, Failure to Immediately Initiate

Corrective Action With Three Inoperable AFW Pumps

Operators interviewed generally interpreted some " verify" steps in the

E0P to allow them to take " action".

Step 2 of 2-ES-0.1 states, " verify

total feed flow to SGs: total AFW flow greater than 400 gpm or Main

Feedwater flow to at least one SG - 0.7E6 lbm/hr." Operators believe

that this step allows them to change feeding from AFW to Main Feed.

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Step 6 checks SG levels greater than 11%.

The RNO column states,

" maintain total AFW flow greater than 400 gpm until narrow range level

is greater than 11% in at least one SG."

Operators interpret this step

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to mean they can take action to reduce AFW to zero once a SG level

exceeds 11%.

These interpretations are not consistent with VPAP-0505,

Writer's Guide for Dual-Column Procedures, which states that

verification steps are used to determine whether an action or condition

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has been successfully performed.

Action verbs are to be used to direct

actions to be taken.

Although this has not been identified as a problem

during simulator training, there may exist a pervasive atmosphere

allowing liberal use of verification steps to perform actions.

Pending

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review by the licensee as to the extent of operator use of verification

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steps to perform actions, this is identified as inspector followup item

50-339/93-17-02, Use of Verification Steps in E0Ps to Perform Actions.

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Safety Significance of the Event

The reactor trip resulted when the generator voltage regulator failed to

an overexcitation state. The licensee had been experiencing periodic

momentary " spikes" of overexcitation over the last several months and

had been unable to perform on-line maintenance. With the exception of

several " nuisance" equipment failures, the trip had no complications.

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Although operators were concerned to varied degrees with RCS

temperature, the cooldown was not severe and typical of previous trips.

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The magnitude of the cooldown was 7.5'F below the no-load value of 547'F

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over a 6 minute period. Minimum pressurizer level was 23%. Minimum

pressure was noted immediately after the trip at 1925 psig. The SGs were

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adequately fed and an adequate heat sink was quickly achieved and

maintained.

Defeating AFW for 18 minutes did not cause any plant response

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complications.

However, the significance of that action is a cause for

serious cancern. Had the system been challenged by a loss-of-offsite-

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power, feed flow would have been lost to the SGs, AFW would not have

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automatically started and feedwater restoration would have depended

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solely on manual action.

In that personnel were continuously monitoring

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the SGs, it is reasonable to assume that the B0P R0 would have

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recognized a loss of feedwater and taken action to restore AFW.

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The inspectors reviewed the licensee's Nuclear Policy on Defeating

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Equipment or System Automatic Safety Functions dated June 8, 1992.

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policy clearly states, " Technical Specification specified automatic

functions w 'l not be replaced with manual actions without prior NRC

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approval...

The policy further provides implementation guidelines and

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examples where automatic control functions may be placed in manual.

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Discussions with operators indicated that they were aware of the policy.

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Licensee Corrective Actions

Once the AFW inoperability was identified to the Shift Supervisor, the

system was returned to automatic standby. Management immediately

recognized the event as a TS violation and promptly reported it to the

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NRC.

The licensee initiated a HPES investigation.

Prior to the end of

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the shift on April 16, the Unit 2 Supervisor and the B0P RO were

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relieved of licensed duties pending results of the investigation. The

licensee's corrective actions appeared to be directed to these two

individuals. The licensee had not considered exploring the possP

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of a pervasiveness in using verification steps to perform activ...

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The licensee considered that fully throttling AFW to zero flow instead

of defeating the automatic start function at step 6 of 2-ES-0.1 would

have been acceptable. The AFW system, feed flow, is designed to be

throttled by the operator for the purpose of controlling SG levels, but

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does not have an automatic ESF open capability.

However, shutting the

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discharge valves for the purpose of removing the system from service

with a valid low-low level signal present may also have constituted a

bypassed safety system.

Further the licensee had not considered the

significance of a valved out system, not actively being controlled, as

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another potential safety system bypass.

Pending determination of when

the AFW system may be removed from service, this is identified as

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inspector followup item

50-339/93-17-03, Potential for Bypassing Safety System Due to Closed

Discharge Valves.

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Exit

The inspection scope and findings were summarized on April 23, 1993,

with those persons indicated in paragraph 1.

The inspectors described

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the areas inspected and discussed in detail the inspection results

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listed below.

The licensee did not identify as proprietary any of the

material provided to or reviewed by the inspectors during this

inspection.

Dissentir,g comments were not received from the licensee.

Item Number

Description and Reference

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50-339/93-17-01

(Apparent Violation) Failure to follow Procedure

2-ES-0.1 in Securing AFW Following Reactor Trip

and Failure to I;nmediately Initiate Corrective

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Action With Three Inoperable AFW Pumps,

paragraph 6.

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50-339/93-17-02

(IFI) Use of Verification Steps in E0Ps to

Perform Actions, paragraph 6.

50-339/93-17-03

(IFI) Potential for Bypassing Safety System Due

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to Closed Discharge Valves, paragraph 8.

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31.

Acronyms and Initialisms

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AFW

Auxiliary Feedwater

AMSAC

ATWS Mitigation System Actuation Circuitry

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B0P

Balance of Plant

E0P

Emergency Operating Procedure

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ESF

Engineered Safety Feature

ESFAS

Engineered Safety Feature Actuation System

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F

Fahrenheit

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GPM

Gallons Per Minute

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HPES

Human Performance Enhancement System

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IRPI

Individual Rod Position Indicator

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MDAFW

Motor-Driven Auxiliary Feedwater

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NR

Narrow Range

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NRC

Nuclear Regulatory Commission

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OATC

Operator at the Controls

PSIG

Pounds Per Square Inch Gage

PTL

Pull-to-Lock

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RCP

Reactor Coolant Pump

RCS

Reactor Coolant System

RNO

Response Not Obtained

R0

Reactor Operator

SG

Steam Generator

SRNI

Source Range Nuclear Instrument

T

Time

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TAVE

Average Temperature

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TDAFW

Turbine-Driven Auxiliary Feedwater

TS

Technical Specification

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ENCLOSURE 2

Fodsunt Esglsest / Ve4. sO6o.1EIFTPeder, July 18, iner / Noenas

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seems .

======== send comments toc The

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Soestery of the - U.S.

Nudeer Ragdesary r**

Washingn== DC sosES. ATTN:

Dedeems and Servies branch.

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Hand deDwer esaments to:One White

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Rint Nenh.11555 Rodrville Pike.

Rockvdle,ndD bonseen y:45 a.m. to 4:15

p.m. Federal workdays,

Copies of commente immy be exammed

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at the NRC puhus h-t Room. 21:0

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L Street.NW.(lawer level).

Washington.DC

ruesaanenseemananom oowraev:

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lames Liebermen. Direcser. Offles of

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Enforceneet. U.S. Nuclear Regulatory

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CAusemien.Wemblegten. DC 20555

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susessumerase espo maaviosa

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The NBC's aurant pahey en

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SeatesV of thelatest seveales to the

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"Gesamt e*=a====e f religy and

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Processe for Emderessmaat Actless."

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(Eninosummapoiky)toGR part 2.

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Febraery ta, tags (gr PR syWikThe

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However,theCommissien has decided

laimpinessa a utalpropam to

l

dessamine whetherto meistain the

carnetpathy wten regard to

l

emieresasst semissemens er to adopt a

i

i

Two VaarTrtalProyeesper

new penny that weeld aHow most

seduseensat emederemmes to be open to

Conessung Open Entersemeent

ste==d==== by au members of the pubhc.

Comterommest poesy genaammas

P8EEyP'=*=====*

assuusvt Nedeer Regulatory

r~ m

*"

The NRCis impleasanting a two year

!

trialpmpuso to auser pubhc

i

ausmaasmho Nedeer Regulatory

observensa of selected enforcement

i

t m===da= dam (NRCI le leseng his potsy centummess.The NRC win monitor the

'

statement en the i==p4====*=Ma= si a

pragma and detenmine whether to

,

two year trial preyam to aHow edscasd escobikh a pausammet pober for

.

emeeroament comieremens to be spes to

M

!

attendemos by su members of the

conferemens

se an assessment of !

general pubhc.This pobey statement

theiuBoutsgasetssim

desathes the two-year rialpropuso

(1)Whs6er esInst that the

andinferens the pubucof how to put

caminemme men openimpacted the

{

informatten en spesemies opse

NRCe shW to esadmet a mesmngful

i

enfer====sme

coalmense endler t=p4====t the NRC'. l

satset This trial prograz ie efective en

8"#'"

i

July 10.195.while commente sa the

(t)Whether the eyes eenforence

preynes are being received.Suban

impassed to Meansee's participation m .

comummens en er before tlw compionsa

the esmisresser

l

of the ertal preyes scheduled for July

(31Whster the fec expended a

1L1sELComments received after this

=ip=8"==8 anseest of resources in

date er6E be comendered if it is praedcol

maid =a the esadoremos public and ,

l

to do so.but thera =auasion is able to

assure camelderation only for c$mments

(4)The meset of pubucinterest m

i

received on or before this date.

opeans the enforceanent conference.

l

i

I

e

.

-

-

_. .-

-

- ._

-. -

,

--

istme For .a stayOpen

three estagertes ofliosamees wee he

rubiest t2 poussemel essemehg.est -

1

e

s, seauseast r h

h

seassmen,

eigen, hemmere, pom sea, met larger

other h wM

6es 1s" he permated, and that

Edorcommet conferenose mu not be

cpen to the peM&s af the amiercossent

comesa of the remnanas types of

disrupthe penness may be rienewed.

licanema.

Each toglemal eEen anil caostnue to

m

~a..a

(1) W

be taken assaset as

II. Ammonedag Opus Emierceanuma

condest the enferoament eenfersace

mdvutaal or if the acnea, though met

Conferemens

proceedtags la escondence with regnomal

procuca. no emissenement assierence

'

talen agamst an mdividual turns on

As sous as it la determined that as

wdl canuses a to a mesang h

whethat an bckvidualhas e-*'M

enforcement conference will be open to

the NRC and es h Whk se

pu e observation, the NRC wdl oraHy

adorcement comierence is ope for

f:) hvolves aiaah parenmal

t

failures where the NRC has requaaned

n uly 8e

eat es enfmement

public observados,it is not open for

confece wtB be open to puhuc

pubine partidpseen.

dat the bdividual(s) involved be

atmo as part M es asenys W

Perenne setendaag open enferoement

"rnent at the conference:

-

(3)1s based on the Radians of an NRC $h Fnwel

oferemens ase remaded that 11) the

8'

,

at

a pparent vielea6 ems diecmened at open

Of5ce of Invesesations (Of) reporn or

g ,P N 88 g3C8R8888 ,g g g g

enforeement semierences are emb,ect to

,

(4) !avolves safeguards infonaat6en.

8""

_ _ _.

8

Pnvsey Act infonna$on, or other

h8"8

further teetser and may be suspect to

.

prw m any reanidag

information which could be considered

so that the NRC

usedule

8"C8 8"E-

atatsman of views

of

Ed

rmterences involytag

{

opint a made by NRC employees at

=edical misadministrations or

State Dakon omcare that en

Pen enforcement conferences er the

crorexposeres will be open assuming

edorosseet conference has b

,

' " " ' '

]

Se confersono can be conducted

scheduled and tantit is open to pubhc

rePresset Sant deterednetese er bellefs.

w:thout <hda==g the arposed

og,.nues,

In addt6en

4

cemen.ts on

individual e naan,a.la addition-

ne NRCinten,ds to announ,ce open se e.mo<e

-

l

ecoa m

.doro.amt.o. menose we .ot be

,do,_

eoss e,s.cas to , e ,

,,

Me se guidamos k him a persons

1

j

open to the public tf the conferenos wm nonnaDy at least to working days k

L

be conducted by telephone or the

advance of the enforcement conference

attending apa h .mafemoces

will be provided as opporteedly to

I

coderance wdl be condeoted at a

6

g, gage,,,,, ph

evbadt writies comments enemyseomaly

J

l

relatively email thands feahty.

(1)

poseed a to Pebas

to the reglemal adEne.These esenments

FbaDy. with the approval of the

par

Romer

'

Execettre Director for Operstions-

(1) TosMus telephone == mama yaa and

wiH embesgesady he forwarded to the

Director of the OSos of Eelsesment fer

i

adorosament conferences wiB not be

(3) Tou-free electronic beurism board

rev6ew end consideretles,

open to the publicin specialcases

mm- .

where good amass has base abows aAer

Pending esenkhk==at of the tolMree

Deled at Baskista, nE thes rik der eljair

baianang the benent of puhuc

messays eyseems,the pabile may can

test

.

l

obenvamos asainst the potenitallapact (smpes-ers:w abtain a rooordsag of

rar du Neelser Rapdatery th-

en the agency's eniercament actica ta a upcondes eyes endureement

Sammeil.Chk.

particular casa.

conferemose.The NRC wtB tease emother secrosary e(the Commenses.

ne NRC will strive to conduct opes

Federal ReWeser eseos efter the tolktree (Ph es-teen Fund FNes W

l

enforcement conferences durtne the

messegn eyeness are --

a ,,,, -

,

  • wo1 ear trial program in accordance

To easiet to NItCla maktag

eth the foHowies three goals:

appropriate arreagements to suppret

D) Appremanaly 25 percent of a2

pubhc oboarvenes of adoresenet

3g

etyph!e enforcement confereadme

omedureesee, andleedmale inessammed ta

I

condated by the NRC wGlbe open for

attendles a pernaaler enforcomment

)

pubae obervae=

conderemos the.id.oe se tedsendaea

COrreCtl0nS

d=8 ***

,

i

(2) At taast cas open enforeement

ideseBed to the mostleg mottoe

vel sr. No. tse

j

eenference en be condessedis ensk of samosesing the eyes enforcement

'

Se res)onal omces: and

condereses no later saa tre >==Maam

Frider.147 U. *

131 Open enforcement conderences

days prier to es endorsement

mu be conducted wrth a vernsty of the

comieremos.

I

avo d po

t6albiasla the

R Cmdes of Open Enfecommet

COtmWSSIGIE

Camdumes

!

selection process and to attempt to meet

.

I

the three pools stated abees, every

be sonoreuses with current proctice.

Twa> Year Tetsi Progress ter

I

fourth eligible amieroament conference

enforceanset coeJerences wdl contrenne

Conshastrig Open Esdoreement

to na-.n be held at the NRC regional

Conferensees Poecy Statement

l

nvolving one of three catesones of

r

j

licensees wdl morumDy be open to the

emers.Meanbare of the public will be

%

public dunes the trial proyesa,

allowed access to the NRC regional

However,in cases where there to en

omens to amend eyes esfera=maae

la notice documet 9318233 beginnma

1

j

ongems adjud6catory proceeding with

conferences in accordamos wrth the

on page 30Pe2 la the leone of Friday,

j

one or sears tutervenors, enforessenet

" Standard Operating Procedures For

ju}y.10. test, as pega alm. in es

conferences nervolvtag issues related to

Prov6dhig Secetty Sepport For NRC

second cohsen, under navn, beginning

4

l

the subject matteraf the ongoing

Heermes And Meetmss pub!Lahed

in the afth lina, y 11.iest" should

edfudica60s mey also be opened.For

November 1.131(35 flt 2231).These

read ~} sly IL 180s .

)

to purposes of tids trialprograan, the

procedures provide that visitors may be

asAsesesse us****

j

4

I

"

--

.

.