ML20042F772
| ML20042F772 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 04/17/1990 |
| From: | Lawyer L, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20042F767 | List: |
| References | |
| 50-348-90-02, 50-348-90-2, 50-364-90-02, 50-364-90-2, NUDOCS 9005090373 | |
| Download: ML20042F772 (95) | |
See also: IR 05000348/1990002
Text
{{#Wiki_filter:7 , - ! =4 - 'c ' [ , $a htop UNITE)$TATES - -[ 'o NUCLEAR REGULATORY COMMISSION
[ REGION 11 , < 0 101 MARIETTA STREET.N.W. f ATLANT A, GioRot A 30323 E
k...../ Li'
Report Nos.: 50-348/90-02 and 50-364/90-02 Licensee:. Alabama Power Company 600 North 18th Street Birmingham, AL 35291-0400 Docket Nos.: .50-348 and 50-364 License Nos.: NPF-2 and NPF-8 Facility Name: Farley 1 and 2 Inspection Conducted: March 5 thru March 16, 1990 Inspection at eysitenearp Alabama /7 70 Inspector: M ' Li Lawyer, Team Leader V Date Signed NRC Team Members: D. Desaulniers G. Maxwell L. Mellen M. Morgan B. Schin Contractors: G. Bryan, Jr. COMEX A. Sutthoff, SAIC Approved by: / 7/74 T. A. Peebles, Chief Date Signed Operations Branch ' Division of Reactor Safety SUMMARY L -Scope: This 'was a special announced Emergency Operating Procedure (EOP) team
inspection. Its purpose was to verify that the Farley E0Ps were technically accurate and that their specified actions could be accomplished using existing equipment, controls and instrumentation. The inspection evaluated the adequacy of the licensee's E0Ps (including Abnormal Operating Procedures [A0Ps]), conformance of these procedures to the Westinghouse Owners' Group (WOG) Emergency Response Guidelines (ERGS) and conformance to the approved writer's , guide, The inspection included a technical adequacy review of the procedures, ! control-. room and in plant walkthroughs, simulator evaluation of selected 4 procedures, a. review of on going control of these procedures and interviews of l operators who use the procedures. ! ' P005090373 900402 PDR ADOCK 05000348 g PDC s
l .-
- .
2 Results: The overall assessment concluded that the E0Ps adequately covered the broad range of accidents and equipment failures necessary for safe shutdown of the plant. The team identified weaknesses in the licensee's verification and validation program as evidenced by: an inadequate steam generator tube leak procedure and control room design inadequacies, (paragraph 4). A second weakness was 'in plant fire procedures, including: 1) hot shutdown panel labeling inadequacies, 2) shutdown margin calculation problems, 3) containment entry after head venting and, 4) location of emergency equipment in a fire zone (paragraph 4). The third weakness identified was that the writer's guides for E0Ps and their implementation were inadequate, (f.ppendices C & D). The team identified a strength in room labeling in radit^,non areas and the basement of the auxiliary building, (paragraph 4) and a second strength in accurate E0P references to control room panel labeling, (paragraph 4). The team reviewed the draft Safety Evaluation Report (SER) on the licensee's Procedures Generation Package (PGP) commitments and determined that, when the Inspector Followup Items (IFIs) in this report are completed, all licensee actions necessary in response to the SER will be completed. Violations or deviations were not identified in this report. F 3
, , , , [ su > U l f- p gj .
REPORT DETAILS F . I. 'Pers'ons contacted 1. Licensee employees p . t G. Armstrong, Reactor Operator - Operations ' ! C. Batherson, Plant Operator - Operations. '
- E. Carmack, Unit Supervisor - Operations Support
o ', ' A. Danberry, . Reactor Operator - Operations - ' p A. Dansby, Shift Foreman - Operations [, J.-Exum, Reactor Operator - Operations T. Ford, Reactor Operator - Operations R. Forrester, Senior Reactor Operator - Operations
- S. Fulmer,' Supervisor.- SABR
g , ~ M. Galle, Shift Foreman - Operations L. Grimes, Systems Operator.- Operations .. R. Hayes, Senior Engineer - SAER !
- R. Hill, Assistant General Manager - Plant Operations
. C. Hurst, Senior Reactor Operator - Operations J. Isler, Operations Planner J. Laska, Reactor Operator - Operations W. Lee, Senior Plant Instructor - Nuclear Operations P C. McLean, Senior Plant Instructor - Nuclear Operations
- D. Morey, General Manager - Farley Nuclear Plant
T. Nesbit, Generating Plant Engineer. R. 0 dom.. Plant Operator - Operations .. B. Oldfield, Shift Foreman - Operations "J Osterholtz, Manager - Operations C._Plotz, Reactor Operator - Operations J. Powell, Unit' Supervisor - Operations J.'Ryan, Senior Reactor Operator - Operations p .M.' Sanders, Reactor. Operator - Operations 'T. Stowe, Plant Operator - Operations R. Swift, Senior Plant Instructor - Nuclear Operations B. Vanderbye, Plant Instructor - Nuclear Operations K. Vines, Reactor 0perator - Operations J. Wall, Reactor Operator - Operations , G. Waymire, Shift Foreman - Operations
- L. Williams', Manager - Training
P. Willis, Nuclear Technician
- J. Woodard, Vice President - Nuclear
Other licensee employees contacted included engineers, technicians, y' operators and office personnel. 2. NRC Personnel
- E, Adensam, Project Director, PD II-I, NRR
- T. Peebles,
Operations Branch Chief - RII
- S. Shankman, Chief, Procedures & Training - NRR/DLPQ/HFAB
- D. Verre111, Project Branch #1 Chief, DRp - RII
' - - a }
, _ _ - - - - ___ - - __ - _ - _ .- e 2 3. NRC Resident Inspectors ' 'G. Maxwell, Senior Resident Inspector - Farley Nuclear Plant
- W. Miller, Resident Inspector - Farley Nuclear Plant
r
- Attended exit interview on March 16, 1990.
Procedures reviewed during this inspection are listed in Appendix A. A list of abbreviations used in this report is contained in Appendix E. 2. E0P/GTG Comparison i The team compared the index of Farley E0Ps and AOPs against the the index of WOG ERGS nd the list of emergency procecures recommended in Regulatory Guide 1.33. The team confirmed that the licensee had developed sufficient procedures to cover the spectrum of accidents and equipment failures addressed by the ERGS and Reg. Guide 1.33. In addition, the team evaluated deviations from the ERGS incident to the E0P walkthroughs. Findings concerning these deviations are listed in appendix B, The team compared the FNP E0Ps to the ERGS and found that the accident mitigation sequence of the ERGS was generally followed. Those cases where step deviations existed without adequate justification are identified in appendix B by the term "PSTG DEV". The team met with the licensee to discuss the development and implemen- tation of the as found PSTG. The licensee described this PSTG as "the Farley PSTG consists of the WOG ERG-HP revision IA plus the E0P step deviation Justification of Differences documents". A review of the various E0Ps indicated that the Farley operations department developed revision 0 of the Farley E0Ps directly from rev.1 of the WOG ERG. The E0Ps were produced by application of the principles in the Farley writer's guide to the technical information in the ERG, the Farley setpoint document, and other sources. The licensee submitted an E0P procedure generation package (PGP) to the NRC for review and approval in 1983. The licensee conducted verifi:ation and validation of the E0Ps during May - July,1984, using the Farley simulator. The licensee implemented these E0Ps in July 1984. The licensee revalidated a limited number of the E0Ps again in 1989. For those not validated on the Farley simulator, licensed plant operators conducted validation of those E0Ps in 1989 through table top reviews. Review of the E0Ps and AOPs against the requirements of their respective writer's guide identified a number of deviations. These deviations disclosed inadequate verification of the procedures against the writer's guides. An NRC SER on the Farley procedures generation package was issued on l February 5,1990. The licensee had not completed the SER review at the I time of this inspection. The team reviewed the SER and documented "open" items in this report (paragraphs 4 & 5) in order to permit SER closure. . '
hD - . . ,
- - ) .
' , !. 3 L ! . .s . . . i 3, independent technical adequacy review of the E0Ps J ' The team reviewed the procedures listed in Appendix A and found.that they ! ' either followed the vendor recommended accident mitigation strategy and action sequence or deviated from them with acceptable justified , E deviations, except as noted in Appendix B.- The principal deficiencies , P were failure to specify E0P mode applicability and deletion of the ERG. ) , L . i caution to transfer to EEP-0 upon SI actuation. L
Rules of use for the E0Ps are not adequately defined. The writer's guide.
did not address use of the procedures. There is no user's guide for. !
Farley E0Ps. A number of operators were unclear about the meaning of some , < ' aspects of procedure structure, rules for performance of RNO actions, and , the meaning of some procedure steps. The many inconsistencies in- structure within the.EOPs contribute to the lack of clarity. t. bout the I< meaning of procedure elements. Consequently, operators vary in the ways they interpret and perform the E0Ps as evidenced by operator interviews t and procedure walkthrcughs. See Appendices B and C for specifies L examples. Place keeping aids were used rarely although the procedures generally contained more than adequate provision for place keeping. Many problems were identified with E0P cautions and notes. Some were due; to violation of writer's guide requirements while others wer9 caused by writer's guide insufficiency. See Appendix B for specific examples, Many of the E0P steps contained action-substeps that lacked verbs or step numbers. This left the operator to infer the desired action verbs and any required step sequences. In most cases, the expected operator actions would have been obvious to the least qualified operator. In other cases, p .these steps led experienced operators to state that they 'would take ' / actions that were not described in any procedures or that were undesirable - such as releasing radioactive liquid to the outside atmosphere (Appendix- ' B,. paragraph 11.4). . Quality of many of the operator aids was poor. Copy quality was poor and , far too many of the aids were handwritten. Some reproductions-had lost- '.' their clarity-due to excessive photocopying. See Appendix B for details, e Inspection of control room drawings verified that E0P specified components- were accurately presented. No discrepancies-were noted, " pf No violations or deviations were noted in this area. 4. .. Review of the E0Ps and AOPs by inplant and control room walkthroughs The team conducted control room and plant walkthroughs on the E0Ps ! and AOPs listed in appendix A. The walkthroughs were conducted to: confi rm that the_ pron dures could be accomplished; verify tha( instrumentation and controls were consistent with installed plant equipment; and ensure that i ndi ca tors', annunciators, and controls were -available to the operators, d l m
p , - ra n . p % [ , , - '4 l: + , i h, -g ._ During the walkthroughs the team also evaluated the location of-the E0Ps ,, , in the control room and verified that they were current revisions and were 9- easily-accessible to operators. To aid the operators in quick recognition of the E0Ps and other operations procedures, the licensee required unit 1 procedures to be printed on yellow paper and unit 2 on green paper. Three P sets of. emergency and abnormal procedures were maintained in the control [ room for each of the units. V E ' Indicators, annunciators and controls referenced in the E0Ps were found ! to be available to the operators except as noted in Appendix B. F, " Inside the control room, the E0P nomenclature appeared to be generally- consistent with installed equipment and outside the control room it was , L not. The tea'n enumerated noted discrepancies in Appendix 0. .The licensee committed to review these and make changes. as appropriate. Resolution of this issue was identified as IFl 50-348/364/90-02-01. L While the results of the walkthroughs were generally acceptable, many ' discrepancies in the areas of technical adequacy, writer's guide , E adherence, and human f actors were noted. Technical and human f actors discrepancies are noted in Appendix B while writer's guide discrepancies are noted in Appendix C as IFls 50-348,364/90-02-02 and 03 respectively. The NRC found numerous control room design inadequacies. Equipment and annunciator nomenclature in the E0Ps matched the labeling on the main control board in nearly every instance. However, there were numerous labels which were difficult to read due to wear or excess accumulations of tape gum, dust and overspray. There were many instances of missing or handwritten position indication labels, or dymotape labels - that could easily fall off or be removed. Several gauges on the main control board could 'not- be read to the level of the accuracy required by the .EOPs.- Engineering units were also lacking on some pressure and flow indicators. Several control room design items were identified in which the placement or labeling of controls, instruments, or indicators was inconsistent. Nuclear radiation monitors were labeled by number but were not arranged in the racks in order. Controls were arranged on the board inconsistently. For example, the switch for CCW pump IB was positioned to the lef t of pump 1A. The pen color coding for the steam generator level recorders was also inccasistent. The narrow range level recorder had red, green, and blue pens corresponding to steam generators one, two and three. The wide range level recorder had reversed pen colors for steam generators two and three. Contrary to the guidance in NUREG 0700, Farley annunciator panels were designated numerically both horizontally and vertically. Recorders also had handwritten scales and scales that were difficult to read due to felt -tip pen markings obscuring the scales. Appendix B contains additional details. The procedure for steam generator tube leakage, AOP-2.0, did not provide adequate guidance for operators. In this AOP, primary coolant -leakage from the RCS could be as much as 200 gallons per minute. For that size leak, the AOP required the operators to place the plant in h(ot standby within three hours and to continue to cold shutdown. L . h j
W c [
- _g 5 ! t. L /o It did not give. guidance on rate of power reduction, isolation of the - F S/G, rate of cooldown, reduction of RCS pressure to stop the leak, or L other guidance similar to that given in the E0P for SGTR. It also did [ i not caution operators about overfilling a S/G. In addition, neither ' this procedure nor the site emergency plan and its implementing procedures j I. clearly reauired the declaration of a NOVE, contrary to NRC guidance in ' NUREG 0654. The V & V weaknesses in control room design and the steam ' generator tube leak procedure are identified as IFl 50-348,364/90-02-04.
The team reviewed the AOPs related to fires in various plant areas. . AOP 3 28.1 and AOP 28.2 involved recovery f rom fi re . These procedures both ! 1[ - required operations from the hot shutdown panel, where there were multiple examples of panel and procedural nomenclature differences. Both L procedures required the calculation of shutdown margin, but failed to ' provide adequate instructions on all of the required action to complete. ! < j the calculations. Both of the procedures require containment entry af ter ' ' the Vessel Head vents have been opened. Finally, the instructions and i equipment required to manually determine CST level were not adequate, and ' L in the case of A0P-28.2 the required equipment was stored in the fire . area. . Inadequacies in fire protection procedures are identified as IFI '" ' 50-348,364/90-02-05. 4 ! The Farley E0P verification and validation program established in the i' administrative procedure for development and maintenance of emergency response procedures did not apply to the A0Ps, but was limited to the j" EEP, ESP, ECP, FRP, and CSFSTs. New or revised E0Ps and AOPs were to be written by a procedure writer, who was typically a licensed SRO with ' an engineering degree, The prucedures were then reviewed by an authorized. reviewer, typically a licensed SRO, The E0P and AOP verifi- cation process for new or revised procedures did not include: i Required walkthroughs in the plant by the writer or reviewer. .; . Review by a human factors specialist. ! . ! , Review by a system engineer, in most cases. , ,
Review by other disciplines that may have. action steps assigned in 3 , the E0P or A0P, in most cases. The team found that one V&V item from the recently issued SER on the PGP required further work. That item was "The verification and validation programs should be~ expanded to include the following objective - ERPs . should be usable; that is, operators be able to follow ERPs with a minimum
of , delays, confusion and errors. This item was identified as - IFI 348,364/90-02-06. > There were no violations or deviations noted in this area. . L :._ _ : _j
eg , 4 {p 'M c p w U 6 m 5.- Simulater observation r The team observed two crews performing'the following scenarios on the FNP- '! Simulator. ( (1) ATWT (2) Small break LOCA - RCP seal -' reduced SI capacity (3) Stuck open PORV - PORV block valve fails to close- f (4) Main-steam break in containment - reduced CS capacity '(5) RHR suction valve closure - large break LOCA in Mode 4 s a (6) Loss of CCW, loose parts alarm, plant trip & NC cooldown (7) S/G tube leak, degradation to SGTR & backfill operations The simulator performed satisfactorily during observations of the above scenarios, The E0Ps did not cause interference between board operators nor was-there any significant, unnecessary duplication of operator effort, Although the E0Ps provided lines for place keeping to the lowest substep- and component detail point, the procedure place keeping blanks were not used. No' method of place keeping was apparent except that the procedure . files were laid aside, open upside down on the control operator's desk. In particular,- when transfers were- made from one E0P or. AOP to another E0P or AOP, little effort was made to ensure that' "open" conditional statements ("when" items) - contained within the original. E0P guidance to the' opert. tor - were also transferred to the new E0P, The staff's February 5,1990 SER on the' PGP identified the following concern: "The training program states that training on major revisions will be conducted in the classroom if ooth the plant and the simulator are'- unavailable,- Classroom training is appropriate as a alternative for
- simulator _or walkthrough training only as a temporary measure.
The- . training program should be revised to state that classroom training will be used as a substitute only when the introduction of new. procedures would otherwise be delayed due to simulator or control room unavailability, Retraining on the simulator or in the control room thould occur as soon as possible." This item was identified as IFI 348,364/90-02-07. e There were no violations or deviations noted in this area, .
n, m j o u - 7 , e 6. Management Control of E0Ps and ADPs The . team reviewed the licensee's procedures for management control and' ! ongoing maintenance of E0Ps and AOPs. The management review and approval- process for.new or revised E0Ps.and AOPs required PORC review'of any that involved ar unreviewed safety question as defined in 10 CFR 50.59. The authorized procedure reviewer was required to make this determination by ' + completing a nuclear safety evaluation checklist, including a: written 10' r CFR 50.59 safety evaluation when a change to the procedures as described F in the FSAR was involved. In general, new or revised E0Ps and AOF$ were approved for use ay the- manager. of operations without PORC review. 'The ' licensee's approval process required the manager of operations to also approve related changes to the E0P verification and validation and the step change document. which included the written justifications of any E0P step deviations.from the ERG. The licensee's administrative procedures required a periodic . review of . operating procedures; at least every two years for ' safety related. L procedures, including E0PS and ADPs. These reviews were to bc done by an authorized reviewer, typically a licensed SRO. In addition, the .SAER group conducted an audit of the E0P program in October 1988. The audit g included comparing the E0Ps against the ERGS to verify proper justification F of the differences. The. audit identified a need for improvement in the verification and justification documents. A followup audit. in . December-1989, noted improvements in the E0P program. The licensee stated ' that additional annual audits of the E0Ps are currently planned. SAER ' 'also ha$' conducted audits that-compare-the existing plant procedures to the- list-of Reg. Guide 1.33 required procedures. Training'to be done on new or revised E0Ps and ADPs was determined by the procedure writer and reviewer. The training for operators typically included a night order entry, which would be read 'by the SS and SF 'and . presented to operators at crew pre-shift briefings. In some cases, a training change notice would be sent to the training. department for further dissemination to _ operators as required reading or classroom training. Training for other disciplines (such as H.P., chemistry, or I&C) on their E0P actions was not adequate. During the procedure walkthroughs, the team found that in general ' other disciplines were not trained-in or even aware of their E0P required actions. In some cases.- they might have been unable to perform these actions in a ~ correct or timely manner. (Such as chemistry of f site dose calculations af ter lifting - an atmospheric relief on a ruptured S/G, HP. use of a portable radiation 4 monitor on main steam lines to identify a ruptured S/G, or. I&C jumpering instrument air and operating RHR HX flow control valves). Appendix B contains specific examples. \\ i L
p .-. - _- _ _ _ . L 6 o- j ! 8 I i t . b A summary description of all plant modifications was received by the F manager of operations for review and incorporation by procedure writers , -into the E0Ps and ADPs -as applicable. However, information on plant labeling changes was- not generally received- by the procedure writers, There was no requirement for such feedback on revised labels in the t applicable procedure: AP-25. Equipment Idea.tification.
I
- -
Operating experience reports, such as NRC information notices and industry reports. were routinely reviewed onsite and routed to the operations , ' prockdure writers as applicable for review and incorporation into the E0Ps - and AOPs. Feedback from the training department, on training department ' forms, was also routinely received by the procedure writers. - Feedback from operators was accomplished by phone calls or handwritten notes to the [ procedure writers. The operator feedback was not formalized - no fornis were used, no numbering or tracking system was used to account for the ' feedback items, and no formalized response was sent back to the originator of the suggested procedure change. While there were some good elements of management control, . the licensee lacked some parts of a strong comprehensive program that would assure the- ongoing maintenance of the E0Ps and AOPs. There were no violations or deviations noted in this area. 7. E0P user interviews k The team conducted interviews with 10 licensed operators. The operators believed that~ the E0P5 were free of technical discrepancies and were confident that the procedures would be usable and effective _in mitigating the consequences of an actual event. The procedure use problems.most frequently cited by the opicators concerned their ability to follow the logic of the procedures, Specific concerns identified by the operators included ' dif ficulties in identifying decision points, understanding- ' ! complex action steps, understanding the intent of sections of the procedures, and the potential for failing to notice transition _ points. It was also
, stated that cautions and notes were sometimes overlooked. l p The interviews revealed weaknesses in the operators' knowledge of rules of usage for the E0Ps. Of the 10 operators interviewed, oniy two individuals
knew that black dots preceding substeps indicated that the substeps could be performed in any order. Operators also had difficulty in clearly stating the rules that applied regarding when-it was permissible to return from the response not obtained column to the left hand column of the EOPs. 'The interviews also revealed-other weaknesses in operator knowledge. Event mitigation strategies were incorrectly described by a number of operators. L Several operators were unable to explain proper usage of Figure 1 of ESP-1.1. -Operators were generally satisfied with the adequacy of training they ' received on the EOPs. Some limited concern was expressed by experienced operators with the quality of training provided to new operators, i C:')
- .. .. . . - - - l ! 9 i h " t Comments regarding the performance of local actions required by the E0Ps i j' revealed the following operator concerns. They felt emergency lighting
may not: be adequate in some areas and therefore the tasks could not be [il accomplished without a flashlight. Similarly, ladders were not readily. '
available.for access to valves on elevated piping on some occasions, Some
felt that steam eaks could prevent local actions in the main steam valve l i- 3 , room. Although -all of -the operators recognized that considerable , 1 l improvements had been made in the labeling of local control stations, it~ ! wa a, a common belief that much work' was still to be done in the labeling !' . L upgrade effort..
i There were no violations or deviations noted in this area. it L 8. Exit Interview l The; inspection scope and findings were summarized on March 16, 1990, with those persons indicated in paragraph 1. The NRC described the areas inspected and discussed in detail .the inspection findings listed below. No proprietary material is contained in this report. No. dissenting comments were received from the licensee. Item Number Description, Paragraph IFI 348,364/90-02-01 E0P nomenclature and labeling deficiencies, paragraph 4 and appendix D IF1-348,364/90-02-02 E0P technical and human factors deficiencies, paragraph 4 and Appendix B IFI 348,364/90-02-03 E0P writer's guide deficiencies, p.aragraph 4 and Appendix C , IFI 348,364/90-02-04 V&V weaknesses in control room design and the- SGTL procedure, paragraph 4 IFI 348,364/90-02-05 Fire protection procedure deficiencies, paragraph 4 .IFI 548,364/90-02-06 SER V&V deficiencies, paragraph-4 IFI 348,364/90-02-07 SER- training deficiencies . par: 'raph 5 ' g r .; - -_
= , y . , s N l APPENDIX A
' , PROCEDURES REVIEWED ' CFS-0 Critical Safety Function Status Trees REV 6 s EEP-0 Reactor Trip or Safety Injection REV 11 i EEP-1 Loss _ of Reactor or Secondary Coolant .REV 10 EEP-2' Faulted Steam Generator Isolation REV 6. EEP-3 Steam Generator Tube Rupture REV 8 ., ESP-0.0- Rediagnosis- REV 5 l ESP-0-1 Reactor Trip Response REV 10 i L ESP-0-2 Natural Circulation Cooldown to Prevent Reactor REV 6-
it Vessel Head Steam Voiding REV 7 i ESP-0-3 Natural Circulation Cooldown With Allowance for REV 0 Reactor Vessel Head Steam-Voiding (With RVLIS) -! ESP-0-4 Natural Circulation Cooldown With Allowance for REV 7 <l Reactor Vessel Head Steam Voiding (Without RVLIS) L ESP-1,3 . SI Termination REV 7
' - ESP-1.2 Post LOCA Cooldown and Depressurization REV 7_ t L ESP-1,3 Transfer to Cold Leg Recirculation REV 7 , ESP-1.4 Transfer to Hot Leg Recirculation REV 3 4 ESP-1.S Transfer from Hot Leg to Cold Leg Recirculation REV 0 , ' ESP-3.1 Post-SGTR Cooldown Using Backfill' REV 8
ESP-3.2 Post-SGTR Cooldown Using Blowdown. REV 7 , ESP-3.3 Post-SGTR Cooldown Using Steam Dump REV 7 ! .ECP-0.0 ' Loss of All AC Power REV 7
! ECP-0.1 Loss of All AC Power Recovery Without SI Required REV 7 ' ECP-0.2 Loss of All AC Power Recovery With SI Required REV 7 t ECP-1.1 Loss of Emergency Coolant Recirculation AEV 9 1 ECP-1.2 LOCA Dutside Containment REV 2 i ECP-2.1 Uncontrolled Depressurization of All Steam REV 7 i Generators REV 7 ECP-3.1 -SGTR With Loss of Reactor Coolant Subcooled REV 8
. Recovery Desired REV 6 . ECP-3.2 SGTR With Loss of Reactor Coolant Saturated
Recovery Desired. REV 6' . ECP-3.3 SGTR Without Pressurizer Pressure Control REV 7. ' FRP-S.1 Response to Nuclear Power Generation /ATWT REV 0 FRP-S.2 Response to Loss of Core Shutdown REV 3 FRP-C.1 Response to Inadequate Core Cooling REV.7 , FRP-C.2 Response to Degraded Core Cooling REV 6 FRP-C.3 Response to Saturated Core Cooling REV 7 FRP-h.1 Response to Loss of Secondary Heat Sink REV 8 FRP-H.2 Response to Steam Generator Overpressure REV 4
FRP-H.1 Response to Steam Generator High Level REV 4 'FRP-H.4' Resoonse to Loss of Normal Steam Release REV 5 . Capabilities i kJ
o o .. I ! 2 FRP-H.S Response to Steam Generator Low Level REV 6 FRP-1,1 Response to High Pressurizer Level REV 5 FRP-].2 Response to Low Pressurizer Level REV 7 FRP-1.3 Response to Voids in Reactor Vessel REV 7 FRP-P.1 Response to Imminent Pressurized Thermal Shock REV 6 Condition FRP-P-2 Response to Anticipated Pressurized Thermal Shock REV 6 Condition FRP-Z.1 Response to High Containment Pressure REV 6 FRP-Z.2 Response to Containment Flooding REV 2 FRP-Z.3 Response to High Containment Radiation Level REV 2 AOP-1.0 Excessive RCS Leakage REV 4 AOP-2.0 Steam Generator Tube Leakage REV 10 A0P-3.0 Turbine Trip S P-9 Setpoint REV 5 A0P-4.0 Loss of Reactor Coolant Flow REV 3 A0P-5.0 Loss of Electrical Train A and/or B REV 9 AOP-6.0 Loss of Instrument Air REV 13 A0P-7.0 Loss of Turbine Building Service Water REV 3 A0P-8.0 Partial Loss of Condenser Vacuum REV 8 A0P-9.0 Loss of the On Service Train of Component REV 4 Cooling Water A0P-10.0 Loss of Train A or B Service Water REV 4 A0P-11.0 Loss of River Water REV 7 A0P-12.0 Residual Heat Removal System Malfunction REV 3 A0P-13.0 Loss of Main Feedwater REV 6 A0P-14.0 Penetration Room High Pressure REV 4 A0P-15.0 Chlorine Tank Leakage REV 3 AOP-16.0 CVCS Malfunction REV 5 A0P-17.0 Malfunction of RCS Pressure Control System REV 3 AOP-18.0 Nuclear Instrumentation Malfunction REV 9 A0P-19.0 Malfunction of Rod Control System REV 9 AOP-20.3 Seismic Event REV 4 A0P-21.0 Severe Weather REV 3 AOP 22.0 Flooding of the kiver Water Structure REV 3 A0P-23.0 Plant Computer Malfunction (SPDS) REV 1 AOP-24.0 Loss of RCS Flow With Solid Plant Condition REV 2 ADP-25.0 Condenser Tube Leakage REV 3 A0P-26.0 Main Turbine DEH System Malfunction REV 4 AOP-27.0 Emergency Boration REV 2 AOP-28.0 Control Room Inaccessibility REV 2 A0P-28.1 Fire or Inadvertent Fire Protection System REV 9 Actuation in the Cable Spreading Room AOP-28.2 Fire in the Control Room REV 6 AOP-29.0 Plant Fire REV 10 AOP-29.1 Plant Stabilization in Hot Standby and Cooldown REV 3 Without "A" Train AC or DC Power A0P-29.2 Plant Stabilization in Hot Standby and Cooldown REV 3 Without "B" Train AC or DC Power A0P-30.0 Refueling Accident REV 3 A0P-31.0 Loss of Service Water Pond REV 5 A0P-32.0 High Reactor Coolant Activity REV 1 !
L. ,
u- , , . ' - , ,' ,. ibf?
- "
~ a 1 . 4 m" y, g y; ,3 :. . ' s. ' ' . - , - MR: . . , , ' s 1 _-' q . -p ' 3- . w,',. m = -l , -l j i'f h[ t 4 l' e f ? AOP_-33. 0 ' 1High Activity -' Radiation Monitoring System _ .REV-6 ' ' ' LM, ?AOP-34.0 ! Malfunction.;of RCS Wide' Range Pressure In'dic2 tion REV 0- i LAOP-35.0( .t.oss of Main Control Board'AnnunciatorsL ' REV 01 ' ~ n , , .,. , ,. . 'FNP-0-SOP-0.'2' Development and Maintenance of Non-Emergency, REV?l- ' , @i. Response Operations-Group Procedure 5j , ' ~ , W, . . .
. . < .. g,3 iFNP-0-AP-74'
- Development'and Maintenance of Emergency.'
REV 3 - - Response' Procedures ,' 3 a- , , c'?; 1 ( ) , k' p ~ o t ,
, ) _- l {I ,'g I ".,y '.'u l! ? ,
o :P , - .. b i e ! L .a is k. , L.'- s ? -t. , % c %1 < l k i,. e .. - s D [ < k -T- _ .7 -, k!? .
r s -y , 5 .',-[ , .. -6 . > s + , , , 2 l_ a ; r. .< ? 8 h,);]d ;n?- , Qii - - r s t s
- _ - _ - _ - _ _ - _ - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _. _ , . ! = APPENDIX B TECHNICAL AND HUMAN FACTORS COMMENTS This appendix contains technical and human f actors comments and observations. Unless specifically stated, these comments are not regulatory requirements. However, the licensee acknowledged that the f actual content of each of these comments was correct as stated. The licensee further committed to evaluate each comment, to take appropriate action and to document that action. These items will be reviewed during a future NRC inspection. I. General comments: Within approximately the past year, rarley installed a CE heated junction thermocouple reactor vessel level monitoring system. CE letter AP-86-038 of March 21, 1986 documented the results of a joint CE/ Westinghouse review of the use of the CE thermocouple system in the "RVLIS" application in the Westinghouse ERGS. The review authortred the use of the CE system in RVLIS applications within the ERGS, with three restrictions: ECA-3.2 (set point change was required); FR-I.3 (step Ba revision required); and CSF-0.2 (tree was modified to eliminate "RVLIS"). Farley has implemented these unique revisions to the ERGS, However, the NRC found the quality of FNP E0P justification document statements f or E0Ps involving use of RVLIS was often poor and inaccurate (e.g. RVLIS not installed; RVLIS operational but excluded from E0P use). PSTG DEV: Although the ERGS were mode dependent, Farley mode applicability was not specified nor were there deviations which eliminated mode dependency. To test Farley E0P mode dependency, one of the simulator scenarios consisted of a mode 4 LOCA with SI available and without a loss of AC power (e.g. E0P entry via ECP-0.0 was not applicable). .The simulator crew manually tripped the reactor and initiated SI, entered EEP-0 and continued in the E0Ps. This would not have been possible under the ERG usage rules. There were no Farley usage rules. The basic problem stemmed from the mode applicability limitations of the ERGS. The original ERGS were designed for modes 1 & 2 and then extended selectively to modes 3 or 4, subject to specific per procedure restrictions. ERG E-0 was mode 1-3 limited. Further, since the ERG scheme prohibited transfer to other subordinate ERGS without initial entry via E-0 (or ECA-0.0), transfer to subordinate procedures would have also been blocked. Although the team concurred with the SS judgement to use the E0Ps, lacking any other option, it was not apparent that he was aware of the mode limitation nor did the E0Ps themselves acknowledge any mode dependency. _ _ - - - - _ --__- _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ . _ _ _ _ _ - . _ _ - _ _ ___-- _ _ _ _ _ _ _ -
. . . I 2 PSTG DEV, foldout pages: The red path summary on the foldout pages routed the operators directly to the FRPs. The ERG red path summary routed the operator to the CSFSTs. The fold out page is reprinted on the facing page of the symptoms section of each E0P. It fails to provide any needed information at that location. Logic terms are applied inconsistently throughout the E0Ps and AOPs. Transition terms other than those indicated in the writer's guide are used throughout the AOPs. Substeps are structured inconsistently throughout the E0Ps. In some cases component lists include action steps, in other cases, action verbs are omitted and the operator action indicated implicitly rather than directly. The page numbering method used in the E0Ps does not provide the user of the procedure or its attachments with an indication of their location relative to the end of the procedure body or the beginning or end of the attachment. II. EEP comments: 1. EEP-0 Reactor trip or safety injection a. Section B.I: This section was a list of symptoms that required a reactor trip. Item 21, Manual, was not an item that required a reactor trip, b. Section B.III: The label for PB-496A on the main control board was incorrectly written as FB-496A. c. Section B.III: This section was a list of symptoms that require safety injection. Item 5, Manual, was not an item that required safety injection. d. Step 1 note 2. This note indicated that the foldout page should be monitored continuously. This information was basic to use of the procedures and its inclusion here only served to add clutter to the page, e. Step 1 note 4: This note was a continuous action step that was not placed within the sequence of steps in the procedure, f. Step 1 note 5: This note was incorrectly structured as a conditional logic step. The information it contained constituted a continuous action step that was not placed within the sequence of steps in the procedure.
_. - - - - - - ' ' , , 3 - g. Step 1: This step was stated " Check if reactor tripped." The use of "if" following " check" was elimir.ated from other steps in the FNP E0Ps, for example, step 24 of EEP-1. Justification for that elimination was stated as foliews: " Deleted use of the term 'if' since its usage has been restricted mainly as a logic term." h. Step 1.1 RNO: This conditional step sequence stcted the consequent action " manually trip the reacter" prior to listing of the required conditions. 1. Step 1.1 RNO: This step used the term " continue with step 1.2" rather than " proceed to step 1.2," contrary to the writer's guide. J. Step 2.1 RNO: The first component in the list following this step included the expected response "to TRIP position" and the action step " hold for approximately 5 seconds." This structure was contrary to the writer's guide requirements for the structure of action steps. k. Step 4: This step was stated " Check if SI actuated." The use of "if" following " check" was eliminated from other steps in the FNP E0Ps, for example, step 24 of EEP-1. Justification for that elimination was stated as follows: " Deleted use of the term 'if' since its usage has been restricted mainly as a logic term." 1. Step 4.1 RNO: This step used the term " continue with Step 5," rather than " proceed to Step 5," contrary to the writer's guide. The word " Step" was capitalized, in contrast to other references, such as in step 1.1 ,RNO of this procedure. m. Step 5.1 RNO: item 12 in the component list following this step, "CHG PMP 1A (B or C) at least one pump breaker closed" included an additional action to check amps greater than 0. Inclusion of an action within parentheses was inconsistent with the structure of the rest of this component list, as well as others found in the E0Ps. The action also lacked an action verb, and due to its placement and structure was likely to be overlooked by operators, n. Step 7.1 RNO: Item 1 in the component list following this step, "MDAFW PMP 1A (B or C) at least one started" included an additional action to check amps greater than 0. Inclusion of an action within parentheses was inconsistent with the structure of the rest of this component list, as well as others found in the E0Ps. The action also lacked an action verb, and due to its placement and structure was likely to be overlooked by operators. l
f : ,- . v s '
4 q i p, L ' o. Step 7.2 RNO table: Headings in the "SG" column of this table [ were too long to fit in the designated table column and extended
into the column headed "IA." i e , p. Step 9: The component list following this step included I conditional' actions that were not structured in conformance with p writer's guide requirements, q, . Step.11.1 table: Headings in the "SG" column of this table were too long.to fit in the designated table-column and extended into F the column headed "IA." In addition, the FK-499 label - for [ " closed" was broken. < a !- r.. Step 11.1 RNO: The component list following this step included i the qualifier "if required" following expected ' responses. This term referred to .the possibility that the valves were already closed. Because the step directed operators to " verify" the
valves closed, these qualifiers wen unnecessary. If the valves - were 'already closed, the action verb " verify" would require no - further action. ! s. Step 14 RNO table: This table included a conditional logic step , in the "SG" column that is structured and located contrary to writer's guide requirements. - t. Step 15.1 RN0: The second item in the component list following H this step included a conditional logic step structured contrary to writer's guide requirements, f u. Step 15.3 RNO: This step directed the operator to use Attachment 2. The page number of Attachment 2 was not provided making the attachment more difficult to find in the procedure. e v. Step 15.4 RNO: This step included a conditional logic step , structured in violation of- writer's guide requirements. In [ addition, the use of the adverb " manually" did not alter the
meaning of the step and was contrary to writer's guide > requirements to avoid using adverbs and adjectives, w, Step 17.1.1: The label for the 1-2A Diesel used very small type and was difficult to read. x. Step 17.2 note: This note included two conditional logic steps, including one that had continuous applicability. These steps were located outside of the step sequence, and no method to remind operators of the continuously applicable conditional step , was included in the procedure, y. Step 17.2: Items 3 and 4 in the component list following this step included an additional action to check flow of service water through containment coolers greater than 0. Items 7 through 12 in the component list included an additional action to check , amps greater than O. ~
[x. <j.) , 3 1 > x ' L A 5 4 , . 3 E 4 Inclusion of an action within parentheses was in:cnsistent with. e , " the structure of the rest of this component . list, 'as t well as , ^- others found in Lthe - EOPs. The action also lacked an action .< verb,_and due to it: platoment and structure was 'likely to be ! -overlooked by_ operators. . . z, Step 18.1: Item 5 in the component list following this step - , ' O' included-a conditional logic step structured contrary to writer's. guide. requirements. . aa. Step 18.1 RNO: This step included- the adjective "still" which .! did Lnot change the meaning of 'he~ step and- was contrary to l writer's _ guide requirements to avoid: using adjectives and " > adverbs.
As _ au. Step: 18.?: 51s step included a con'tinuously applicable 7 -conditiomS4 14.e p that was structured contrary to writer's l guide recg/ runents. , .i ac. Step 18.3: See comment on step 18.2.above. 1 ad. Step 16.4.1: This step included the qualifier "as required."'
This qualifier could be easily retaitten as "to maintain S/G ' - narrow range level greater than 6%." ae. . Step 20: This ' step required operators to check the RCSD
- !
temperature trend, however, the instrumentation listed for use was not capable of' trending. - ~ af. Step 20 RNO: This step and its first substep included the terms- "as follows" and "by performing the' following."- Because the_ l system for procedure use requires -that' the user proceed to the- { following steps, this information was-unnecessary." l ag. Step 20.1.1 RNO table: Headings in the 'first . column of this table were. too long to fit in the designated table. column and extended.into the-adjacent column heading. In addition, the label for main steam drain valves used plastic tape to label " reset," " auto" and "open." j y , > ah. - Step 20.1.1 RNO: Item 5 -in the component list following ' this " step included a conditional step wnere structure was contrary to writer's guide requirements. _ a ai. . Step 20.1.2 RNO: This conditional step was structured contrary -to writer's guide reauirements. In addition, item 5 in the component list following this step included a conditional step structured contrary to writer's guide requirements. s aj. Step 20.1.3 RNO: The label for main steam isolation valves ' lacked an " auto" position on the label. ,o , . 4 p
g, g , h(1 .
- . . ,
1 ,- . n m> + 2 ~
- ,
3 6 ' _ . - I- a k'. Step 20.2 RNO: This step included the term "by performing the
f following." Because the. system for -procedure use requires that , the user proceed to the- following steps, this information was _ unnecessary." s , , al. St'ep 20.2.2: This step -used the term "using in a form that ' conflicted with writer's guide _ requirements for transition terms. In addition, the table following this step included Unit 4 --2 nomenclature.in a Unit 1.piocedure. ~ ~ q am. Step 21.1 caution: This caution ' included - an improperly ' structured conditional step that^had continuous applicability. ' an. Steo . 23.1: This step uses the term "per" in a form that conflicted with writer's guide requirements for - transition- 3 terms. In ' addition, the table following this step repeats. information'found.on. the foldout.page, j ~_ ao. Step 25.2: The label for LR-476 was chipped, making- the numeral- "7"-appear to be the numeral;"1."
ap. Step 27: This step was- statad " Check' if SI should be- terminated." The use of if" following: " check" was ~ eliminated - from other steps in the FNP .EOPs, for example, step -24 of EEP-1. Justification for that elimination was stated as follows: n " Deleted use of the term 'if' since its usage has been restricted mainly as a logic term, aq. Step 27 RNO: Substeps 1 through .3 included two' actions in one ] sentence, contrary to writer's " guide- requirements. Substop; ] 4 i.ncluded three actions _ in one step, contrary to writer's ' 4 guide requirements. A - ar. Step 28 RNO: This conditional step - was unnecessary. )The condition was already confirmed by the need to. move into the RNO
column.
- j
as. Step 30 caution: This caution included a conditional. logic step l incorrectly placed outside of the step; sequence. In addition, 'f it included an embedded reference to an SOP. at. Step 30.1 RNO: This step contained a- continuously applicable l conditional step. Item 5 of the component list following'tne i step included a conditional step. Both were structured' contrary i to writer's guide requirements. b au. Step 31 RNO: Substeps 1 through 3 included more than one action i contrary to writer's guide requirements. 1 av. Step 31.4: This step was a continuously applicable conditional l logic step structured contrary to writer's guide requirements. ' In addition, it lacked a method for reminding users of the continuous applicability of the step. ' 0 g j , s [ k _
7 - -_ -- _ - uy ,
, . , , q. :. .J > ., ,, . \\ 7~ .- i ,
- t
. -i w ' aw .~ !. Step 31.4 RNO: This wasl a conditional logic step structured
contrary to _ writer's guide requirements. j
ax. Step 33 RNO: This was a' conditional logic step structured l ' contrary to writer's guide. requirements. '
- <
J ay t Step 37.2 caution: This caution was a conditional logic' step ! structured contrary to writer's guide requirements andi 1 incorrectly placed out of the action step sequence. . - E L az.: = Step 38.2: Identifiers for breakers DA07, DB05, DC01 and-DD03
were obscured by'the switch handles;
- -; I .ba. St'ep 38.2',1 RNO: This Ltep was a conditional " logic step , structuredL contrary to writer's guide requirements. In [ addition, items-.1 and 6 of the component list following this - ~ n _ step were '~ action steps,, rather than: components and expected: q - responses as ' found in thei rest of the list and' in' other j component lists throughout the procedures. ' L bb. Step 38.2.5 RNO: The-label for DH01 was difficult.to read. ! . a be. Step 39.5 cautioni This caution included actions that were y' incorrectly located out of the action step' sequence- . 't bd, Step _40: This step included two actions,- contrary to writer's guide' requirements. be. _ Attachments'1,2 and 3: The -type s'ize -used on the representation ' - of light boards was . small and the' component numbers were. difficult to read. In addition, step 1 RNO was anL incorrectly structured conditional logic step. , bf. Attachment 5 notes 1 and 2: These notes are conditional.~ logic- statements structured contrary to writer's guide requirements, bg. Figure 2: The legibility of the print.on this figure was less
than that used in the procedure steps. j -i 2. EEP-1 Loss of reactcc or secandary coolant .a . ' Step 3.1: This~ item referred to steam generator level indicators. j LI-474, LI-484 and LI-494. Even though these indicators had ! scale divisions similar to adjacent level gauges; they were not = t marked with units of measure. b. Step 4.1: This step listed six radiation monitoring drawers ! ' which were poorly identified; R-15, R-ISB, R-15C, R-19, R-23A, and R-23B. These drawers had name plate identification tags which more accurately identified them. .i jo ' U , . , - , i
, - L@b ,y
, s u - i L '8 , v 4 9 - ' c. Step 5.1 caution: This caution contained a - statement which - a y appeared to beLproviding a specific - direction for operator
- ,
. action.
4 L -d. Step 5.1: This step identifled. two circuit breakers; FUK4' and - " i FVW4. The~ switch for these breakers covered the' numbers (FUK4 } ' and FVW4), on the nameplate tags making it difficult to read 3 them..
e .- PSTG DEV' Step 5.3 RNO: This step used the word " stuck." The d ERG, E-l' used the word "opon" in reference -to the PORV- block' -i L valve. This, difference was not explained in the justification- N document, , ' f. Step 7.2: This step referred to steam generator level: indicators . LI-474, ; LI-484 ' and . LI-494. Even though these indicators .had
' -scale divisions similar to adjacent gauges; they were not marked
with units of measure, r g. Step 9.3: - This - step listed four ' radiation monitoring drawers which were poorly identified; R-02, .R-07, R-27A, - and R-27B. .These drawers had nameplate identification tags whichi more -f accurately identified them, h. Step 13cl.5: The mimic bus 1G for the emergency diesel. gener eter 3 . had lettering which was faded. } , - 1. Step 13.2: This step identified circuit break'e'r DA07.- The switch for this breaker covered:this-number on the' nameplate tag -making it difficult to read.
p j. Step 16.1: This step directed the operator to ascertain that RCS y pressure was less than 265 psig.' However, it did .not specify. 1 the gauge or instrument. k. Step 18.3 does not address that ~this step is -for the the "SI accumulators, as shown in the ERG, E-1.= 1. Step 19.1: This step listed ten radiation monitoring drawers; - R-15, R-15B, ~R-15C, F 2 9, R-23A, R-23B, R-60A, R-608, R-60C and R-600. The nameplata identification tags more- accurately < identify them. . -t m. Attachment 2: This attachment was inconsistent with the justification document FNP-1-M-40, FNP-1-EEP-1, Attachment 2. i n. Figure 1 required rotating the page in order to use it. i o. The foldout page was inconsistent with the justification - document FN0-1-M-40, FNP-1-EEP-1, Sheet 64 of 68. > . e +
aypp i e p g .
- <
~ .9 - o i W 3. EEP-2- Faulted steam generator isolation a.u Step 1 RNO: Use of IF/THEN logic, .at the start of the RNO action.was not necessary and was redundant. The followup statement, " .to assist in valve closure" explained the function of the . TEST position and was not necessary. : Both~ items were confusing ' .and misleading. The remaining statement, " place the associated ~ c' = test switch in the TEST position.." would have sufficed as an: RNO item. > ' b. S_tep 3.1:- The ~ sentence structure in this step -and "other" procedure steps; e.g., 3.2 and 3.3, was' inconsistent, , , c._ Step 3.1 RN0: The verb " locally unlock" did not appear in the - approved facility action verb list, Table 1, FNP writer's ! guide. d. Step 3.4: This step did . not state what parameters to use- to confirm if S/G IC continued to be faulted, e, Step 3.4.1 RNO: The verb " locally unlock".did not appear in the- facility action verb list, Table 1 of the FNP writer's guide, f,- Step 3.5: This step did not state what parameters to use 'to confirm if S/G 1B continued to be:fau'ted, g. Step 3.5.1 RNO: The verb " locally unlock did not appear in th'e - approved facil.ity action verb list, Table 1 of the FNP writer's .. guide. 'I 'h. . ' Step 4.1: The instruments listed for " trending data" would not provide a -trend- unless -the operator took-note- of the listed S/G pressure instrument readouts.on at least two different occasions or " points in time", j 1 1. Step 7.2: The listed radiation monitors did not use the facility assigned names associated with each monitor. The term " normal" was not definitive as an indication of monitor stat u s ~. Operators displayed inconsistency in their determinations of what monitor -levels were considered normal" or " abnormal". - -I 4. EEP-3 Steam generator tube rupture ] a. Step.2 RNO: This step stated: " Proceed to step 5 and isolate. ] . ruptured S/G(s) per step 3 when identified." -The wording of i this step _was-improper, in that the transition out of the step "! preceded the conditional when statement. In addition, the when 1 statement was not phrased in the when, then logic as required by
the writer's guide.
) ) R f l . . a
E .. . ' ~ i pg w . , . i . h . 2 10 ' s o
- y ( , f,'$ ,ih- b "' b. ' Step 2.2.1: .This . action substep- containe'd no verb. .In I 1 addition,s it- gave no . guidance on how to get S/G sample-- 3 p radioactivity results. j y , c. Step '. 2. 2. 2 : . This action substep- contained ' no verb; In- J{ addition, it gave .no guidance on how - to get S/G steam line portable radiation monitor results. , - , . ~ ' n d. Step - 2.2.3: This' action substep. contained no verb. LIn. . ' ' addition, it gave no guidance on 'howito -get ~R-19 readings with7 an individual 5/G blowdown aligned. Some -licensed operators 1
- ..
I' - would go to the B0P panel and : operate individual 5/G blowdown sample isolation valves, a process for 'which no- operations < procedure' exists. '
a e. Step 2.2.4:- This action substep contained no verb.- .I n ' l addition, . it gave no guidance on how to get R-60 radiation ! readings ~ from S/G main steam atmospheric. relief - lines. Some 1 licensed operators would manually open S/G atmospheric reliefJ l valves; others.would not. -Intentionally releasing l contaminated, " ' water to-the atmosphere would be undesirable, -{ f. Step 2.2.4: Labels 'on the R-60A, B,. and C' meters were: handwritten.in ink, Js g. Step 3.1: .The table information "1A (B,C)" was? located in the .; -wrong. column. } h. ' Step 3.4.1 RNO: This step was erroneously numbered 3.3.1. Et
i. Step 3.5 RNO: In the table, -.the words :"(B,C)' blowdown valve" ] ~ were located in the wrong column.
j. Step 3.6.5 RNO: This step contained two action substeps.that .i - ' lacked verbs'and step numbers. -i k. Step-3.6.6 RNO: Tnis- step contained two action substeps. that:
lacked verbs and step numbers. In addition, the labels on the - l MOV controller / indicators in the turbine building were difficult- j to see. They were located on the side' of the ' control- button ' boxes, which were in turn-inside a plexiglass cover box. { 1. Step 8.3.2 RNO: This step included five action substeps; that - ' lacked verbs and . step' numbers. In addition, -the third and fourth substeps required HS 3825 and HS 3885 handswitches to be ( in the START position. The switches had no START position;.they' j had only CLOSE and OPEN positions.
m. Steps 9.1.3, 9.1.5, and 9.1.6: Breaker switches DF13, DG15, and i DG13 had labels that were difficult to see, because they were j blocked by plastic switch covers. t i
- j2*
- r - .
_ _ _ _ - - . _ . . . . . . . _ _ . . . _ < , 11 ! n. Step 9.2: This step included a list of five breakers. The control board labels for all of them were difficult to see, because they were located under the switch handles, o. Step 9.2.1 RNO: The third and fourth substeps required HS3825 and. HS3885 to be in the START position. The switches.had no STAR.T notition; they had only CLOSE and OPEN positiotis. Also, the lasu substep stated " proceed to step 9.2.7.", but there was no step 9.2.7. There was a step 9.2.7 RNO. p. Step 9.2.4 RNO: Breaker DF13 switch label was difficult to read, because it was obscured by a plastic cover, q. Step 9.2.5 RNO: The table contained local actions for which the plant location was not stated, r. Step 9.2.8 RNO: This step contained five action substeps that lacked verbs or step numbers. s. Step 12.2 note: This note was located in the middle of step 12.2, but it applied to step 12.3, t. Step 12.3: This step contained five action substeps that lacked verbs and step numbers. Also, the third and fourth substeps used the term "when required", and did nut state the applicable condition or setpoint. u. Step 12.3.2 RNO: This step required the operators to notify the countir.g room to perform FNP-0-CCP-645, which was titled " Main steam abnormal radiological release". This step was referred to in step 12.3 RNO as an alternate method for cooldown, which it was not. Step 12.3.3, another alternate method for cooldown, conditionally dumped steam from a faulted S/G using its atmospheric relief, but required no subsequent performance- of FNP-0-CCP-645. Also, procedure FNP-0-CCP-645 did not give adequate guidance to chemistry personnel to perform offsite dose calculations. It referenced EIP-9, which in turn contained a form (figure F of EIP-9.4) for calculating offsite dose. Figure F was not sufficiently legible; it. was printed in a type size too small for use in emergency procedures. Neither Figure F - nor EIP-9.4 described how to determine the source term (microcuries per milliliter) required by Figure F. Some guidance was contained in FNP-0-CCP-1300, but that procedure was not referenced by the other procedures. No guidance was given in step 12.3.2 RNO or the other procedures about information that operators needed to give to chemistry personnel, such as: which PORV was opened and for how long, that the related MSIV was closed, and to use the R-60 radiation monitor for the source term determination. In addition, chemistry personnel on shift were not familiar with these procedures. v. Step 15.1: This step stated " Check normal pressurizer spray available." It did not state that the determination of availability was based on RCP A or B running. _
. i , 12 l w. Step 22.2: This step required the operator to check containment radiation normal on four meters. No guidance was provided as to ' what reading was normal. x. Step 15.1 RNO: This step contained a transition preceding an observe caution statement. ~ y. Steps 22.2 RNO . and 22.3: These steps contain a transition , preceding _ a conditional when statement. In addition, the conditional when statement required reading the following two steps to determine the when applicability. Those were the only steps bypassed by the transition. . III. ESP comments: '1. ESP-0.0 Rediagnosis a. Foldout: The term " monitor" was used with each step. It was not included in the writer's guide action verb list, b. SPD sect. A: During a search of the SPD, the inspector noted that page -15 item 3 incorrectly referenced table 12 for SCM; table 12 (on pg. 35) was RWST vs sump level. ! c. Step 1.1: The 50 psig ~ S/G pressure was not contained in the SPD. d. Step 2.1: Since LR 477 was seismically qualified and'LR 476 was- not, it appeared LR 477 should have preceded 476, e. Unit 1 CST level train A and unit 2 CST level, both trains: Engineering unit numbers . did not correspond to the scaling marks, f. During the walkthrough, the NRC noted there was no noun name identification on six radiation meters on the BOP instrument auxiliary relay rack. 2. ESP-0.1 Reactor trip response a. Step 1 caution: This caution is a conditional logic step structured in conflict with writer's guide requirements and placed outside of the step sequence, b. Step 1.1.2 RNO: Items 3 and 4 of the component list following this step are conditional logic steps structured in conflict with the writer's guide requirements, c. Step 1.1.3 RNO: This step directed the operator to throttle auxiliary feedwater but maintain greater than 395 gpm total flow. The required level of accuracy was not available from FI-3229A,'FI-3229B and FI-3229C.
y - - - q -{ 7: p
r; 13' p C P These indicators were listed before the indicators which did > provide the required level of accuracy; digital meter FI-3229. In addition, this step was a continuously applicable conditional ' ' step and item 5 of the following component list was a conditional logic step, both structured contrary to writer's guide require- -t ments. In addition, both tables located within this step included headings that extended from the lef t column into the . adjacent column. , i d. Step 1.2.2 RNO: MN STM ATMOS PRESS REL VLVs were presented in table format. This format was inconsistent with the list format used in other procedures (e.g. , FNP-1-ECP-1.1, Step 30.3). In s addition, the table headings extended from the left column.into- . the adjacent column. e, Step 2 RNO: This step included a reference to boration tables embedded in parentheses and- lacking specific: location information for the boration tables.
- f
f. Step 2.4 RN0: This step directed the operator to check emergency borate -flow and charging flow greater than 30 gpm. . The increments on flow indicator FI-122 did not provide the required level of accuracy to make this determination. g. Step 2.4.1 RNO: This step directed the operator to verify an operable flow path established using Attachment 1. The page- number of Attachment I was not provided making the attachment more difficult to find in the procedure. , " b. Step 3: This step viol'ated writer's guide requirements for use of the term "then." i. Step 5.1 RN0: This step was a continuously applicable conditional l step structured contrary to writer's guide requirements. The procedure did not provide a reminder to ensure that the operator return to Step 5. J. Step 5.2 RNO: The component l'.st following this step included conditional logic structured contrary to writer's guide requirements. k. Step 6.1.1 RNO: This step lacked the required valve position for ' valves Q1P16V540, Q1P16V542, Q1P16V541, and Q1P16V543. 1. Step 6.1.4 RNO: This step lacked the desired valve position for valves 01P16V540, Q1P16V542, Q1P16V541, and Q1P16V543. In addition, the term "0R" was formatted in a manner contrary to writer's guide requirements, m. Step 6.2.1 RNO: This step was a conditional logic step structured contrary to writer's guide requirements. I
"agy , , hjt/ _ , k ,
- g.
' y ' i , g -?A N '\\- + - 3 ' a .v . . . _ ' ~ Step- 7.h 4 RN0: The component list following-this step included. . n. -actions to check -amps greater - than 0. - These actions' were 1 structured in contrary to writer's guide requirements. a'nd' their + 4 inclusion was inconsistent with. component lists' found elsewhere t in the procedures'. - o. Step- .7~ 2 note: This note was structuredfincorrectly as a- .i ' ' conditional action step. 1 . p. Step 7.3 caution: This caution was anditional.- action step . O structured in conflict with writer's guiue require.nents and
' incorrectly =placed outside'of the sequence of steps. - ! q. Step 8.1 RNO: The component listed following this ' conditional- action - step was structured in . conflict with writer's guide. 4 . requirements. 4 . r. Step' 8.2 caution: This caution was a continuously applicable conditional logic step that wasi structured in ! conflict with writer's guide requirements and-incorrectly placed outside of '} the-step. sequence of the procedure; In addition, no reminder of ! the step was provided for the procedure user. 1 . . 1 s. P ep 8.2: Items-3, 4 and 5 of-the. component list following this a m g included complex expected responses that were difficult to interpret and use. 'i t.
- Step 8.3.2 RNO
- This- step required the operator to choose
- -
between two alternative actions. The logic structure of - this , , step' allowed more than one interpretation as to which conditions ~ j applied to the two alternative actions. . In addition, the ' logic 4 structure of the step and .the cot <H.;1onal logic included in the "t y" component list were contrary to writer's guide requirements.
.
- t
u. Step 8.4: The format for - 'li sting pressurizer heaters was inconsistent with the format used to list pressurizer heaters in Step 7.1.1-RNO. , v. Step 9.1: This step directed 'the operator to maintain greater than 395 gpm -total auxiliary feedwater - flow. - This level of -t accuracy was not available from FI-3229A, FI-3229B and F1-32?9C. These indicators were listed before the indicator which did
provide the required level of accuracy; digital meter FI-3229.
a In addition, this step was a continuous by applicable conditional i step structured in conflict with writer's guide requirements, ' w. Step 9.2: The - spacing used in the expression of S/G narrow range percent levels was irconsistent with similar expressions used in other steps '(e.g. , Step 7.3) and was less legible due to the lack of spacing, , ! . '
f4 I [ ' i 7 , y fcr u . h) i > m - 15 ' > p M -; < p , Step 9.3: This step was a' continuous by applicable conditional a
. . . '~ x.- i, -logic step structured in conflict with writer's guide
> requirements and. lacked a: reminder of the step for-users, y. Step 10: A space was missing between the hyphen and the second-
element of the temperature range expression.: . ' O . . ' ' z. . Step 11.1 RN0: This step violated writer's guide requirements ' - for. transition terms and no reminder of continuousiapplicabilityL s was,provided for the user. i o aa. Step 12.4:- This step' directed the operator to shift to only one- l steam jet air ejector in service, "If desired". The step did- 4 ' not . define the conditions, under which this action was l appropriate. In addition, the procedure to be used to shift to only one steam jet air ejector was not referenced in this step. a b'. - Step 13.4.2: This step was contrary to writer's guide require- - ments for transitions and failed to provide a page number for ., locating Figure 1. "! - ac. Step 13.5:RNO: This step was not a contingency action for step ' ' .13.5.. i ad. Step 13.6 RNO: .This step was not a contingency action for 13.6. j ae. -Step 13.7: This step was contrary to writer's guide requirements - for the use of:"then."
af. Step 14: The ^. spacing in the pressure, level, and temperature' l ranges was inconsistent with spacing used in similar~ expressions - within this procedure (e.g., Step 13.7.6 RN0). n' f ag. Attachment 1: This step directed the operator.to use Table 1 or ~ Table 2 as appropriate. It is not clear that "as appropriate"
- 1
refers to whether CVC-MOV-8104 or CVC-MOV-8439 was~ open. In addition, the step was contrary to writer's guide requirements for the use of logic terms. =3. ESP-0.2 Natural circulation cooldown to prevent reactor i vessel head steam voiding {
a. PSTG DEV, Step 1 caution: The following ERG caution item did ! not appear in the facility document: j "If SI actuation occurs during this (guideline), E-0, -! Reactor Trip / Safety Injection, should be performed." j The ERG stated that the purpose of the caution " cues" the operator into the transfer & subsequent performance of E-0 items. Such action would have addressed conditions and operator ' actions which were not covered in ES-0.2. Facility justification stated that the caution was elfminated "due to being within the scope of operator knowledge and training". , '4
<,
- ,;
r . 16 <- This lack of. detail was inoppropriate for" a newly trained / licensed operator or an operator who is under accident stress. 'b. Step 1 RNO: By proceeding to step ' 2 "until an RCP can be started", implied that-the operator would need to remember to return to step 1 when power and support conditions for the RCP were restored - or met. The rest ' of the procedure f ailed to provide some method of reminding the operators to return to step 1. c. Step 1.1 RNO: This step provided information. It did not provide alternative actions nor directions to move ' to another area of the procedure, d. Step 1.3 RNO: See step 1.1 above, e. Step 1.4 RNO: See step 1.1 above, f. Step 1.5 RMD: See step 1.1 above. g. Step 1.6 RNO: See step 1.1 above, h. Step 1.7: Use of "IF"/"AND"/"THEN" logic, at the start of the action was not necessary and was redundant. Use of the verb " establish" was not appropriate for the context of the action statement. 1. Step 1.7 (RCP bearing oil lift pump items): Statements of white ~ oil pressure indicating lights and lift pump operation after RCP operation, were not included in a note preceding step 1.7. J. Step 2.1.1: In determining required boron addition, this step states 2 rather than only 1 "most preferred" method of determination, k. Step 6.1: This step used the action verb " maintain" rather than " establish". 1. Step 6.2 RNO: The follow-up list of controllers did not state " adjusted" but rather " adjusted as required", m. Step 7 RNO: This step' may be incorrectly used as part of the listed items in step 6.4 RNO. n. Step 8.1 RN0: This follow-up list consisted of both actions and indications of placing letdown in service, o. Step 8.2: The "when needed" statement within the follow-up verifications list was not necessary.
hs ' '
- . (
~. . o pv = Q: ' , ' J 17 , . ..' ' ' p.- - Step;8.2- RNO (PZR PORV items): The statements;of.not using both r PORVs for reducing pressure were not included .in a note
" - proceeding. step 8 2.
g, ' q. -Step 9.1: Two separate actions inappropriately. appeared in this step - " blocking of the low steam line' pressure SI/ main . steam 'line isolation" and '" verification -that . blocking had 6ccurred". .! r. Step 9.2: Two separate actions inappropriately. appeared in this' ! . step " blocking of the low PZR pressure SI" 'and " checking that= g blocking had occurred". Also .TSLB 7-1, 7-2, and '7-3. lacked descriptors. '.. s.- Step 11: Instruments listed for " trending data" would not
' . provide a trend unless the operator took note of the listed S/G - pressure instrument readouts on at least two different occasions ' y " ' ' or.- points.in time". t. Step 12 caution: This statement -was not clear. The phrase, "must icontinue exceeding" implied that the bounds of this , procedure had alr'eady been exceeded and that transfer to ESP-0.3' ! or 0.4 shou'id'have occurred.
t u. Step 12.1: An explanation that the RCS PRZR AUX .SPR was "used .for pressure control" did not note desired val've position = nor . .did it provide' "end- result" valve positioning as presented for other listed -1tems within this procedure. 3 v. <StepE12.1-RNO (PZR PORV items): See step 8.2 RNO above. ,f -w. Step 12.2.2 RNO: .Two separate actions inappropriately appeared '
in-this step - " continued cooldown of the RCS" and " reduction of -! RCS-pressure". - , x. -Step 13.2: Two unique actions inappropriately appeared in ~this step " monitoring of condensate-. requirements" and " continuance , of RCS.cooldown using this procedure". . . . ! y. Step 14.2: This step lacked conditional logic and it 0 inappropriately contained -two unique conditional areas "IF ' both CRDM fans running..." and "IF any CRDM fan NOT running...". z. Step 15 RN0: This step contained two separate RNO actions - "repressurf zation of the. RCS" AND possible " transfer to other' ,'! procedures". The action verb "repressurize" did not appear in Table 1 of the' FNP writer's guide. t aa. Step 15.1: The term "large variations" was not definitive as an indication of PZR level . - Operators displayed inconsistency in determinations and explanations of what "large variations" meant, 4 Vi {: $
_ x. . s L 18- .. ab. Step 16.1 RNO: By proceeding-to step 17 until "RCS pressure is less than 1000 psig", implied that the operator would need to remember to return to steps 16.2 and 16.3 when pressure dropped below 1000 psig. The rest of the , procedure failed to provide some method of reminding the operators to return to steps 16.2 & 16.3. ac. Step 21.1: Three separate actions appeared in this step - " maintaining RCS pressure greater than 350 psi", " opening of the S/G atmospheric relief valves" and " visual observation of any steam f rom the S/Gs". ad. Step 21.1 RNO: This step contained - rather than a note - the statement, "approximately 29 hours af ter initiation of RHR system", ae. Step 22.1: This step lacked an action verb such as " check". af. Step 22.2: This step lacked a reierence to a specific mechanism or instrument in which to check for all S/Gs not steaming. 4. ESP-0,3 Natural circulation cooldown with allowance- for reactor vessel head voiding (with RVLIS) ~ a. PSTG DEV: Foldout page: This red path summary illustrates the problem discussed above, that -of incorrect routing directly to the FRPs. The EF,G red path summary routed the operator to the CSFSTs. b. Paragraph BI and the identical wording in step 12 caution of ESP-0.2: The portion "... when the limits of FNP-1-ESP-0.2 must " be exceeded; from the following: ... -was inconsistent with the WOG equivalent and was confusing. c. Step I caution: Farley deleted the ERG caution to transfer to E-0 (EEP-0) given SI. The justification was based upon operator knowledge. Although the team agreed that SI initiation transfer to EEP-0 was within-the purview of operator knowledge, this was the only identified instance where an ERG transfer was undocumented and lef t -to operator knowledge. Since transfers were significant to the mitigation strategy, the-team concluded the deviation was inadequate, d. This procedure did not implement the ERG ES-0.3 and ES-0.4 background document statements prohibiting transfer to FR-I.3 while in ES-0.3 or ES-0.4. The ERG considered the matter a training item; however during walkthroughs, the operators were not aware of the limit. --
-- . . - a f.i; f J j. 1 6 % ; ,y ! Yv (l > , .t 19' ,s I f E ' The S/G= A-C atmospheric pressure relief valve controllers had- e. , embossed tape labels added to indicate close> position-. .The tape 9 obscured the paper _ slide in labels. The _ upper- and lower l '
' instrument' paper slide _ in labels were inconsistentu between . ' , ' instruments. " f.- PSTG-DEV: Step 1.1.2 RNO: The ERG step did notc use-the _ _ , -atmospheric. reliefs although-use of the atmospherics was?infe.rred in.the WOG background instrument and controls list. The team. .; concluded the Farley step was a proper but undocumented deviation i from the ERG step. , s - - - g. . Step 2:. -This step was not flow oriented to. the board layout. _ ' r h. Step 4.4: This step omitted closure of HV 8146 and HV-8147 and 1 , positioning of the charging controller FK 122. With these valves open, alternate _ spray would short' circuit back >to the loops. -! 1. _ ERG basis, step . 4 : The basis - stated the operator should =be = i
aware that pressurizer. would not respond in the normal = manner if a head- void were present and -noted that letdown in excess of charging would result in increased pressurizer level,,.the
x opposite: of normal . single bubble expectations, This was? not' l
covered in the procedure but was considered part of Farley- operator knowledge. Since the walkthrough operator was. unaware
of' the : unusual pressurizer behavior, the team concluded'that a- note.or caution was required- before step 5 of the licensee!s
' procedure. 4 .j . Step 5 was incompatible with auxiliary spray.. operations. ,;; k. Step 7: Contrary to the norm,- this- step did not. remove power
-following accumulator isolation. l 1 ' l 1. Step 12 presumed the atmospheric relief valves were open. If. condenser . steam dump cooling were. available, the _ atmospherics- , .- would'be closed. ' , m. Step 13.1: This process was complex and- infrequently ' accomplished and required reference to the supporting pro u dure. Procedure FNP-X-68.0, -ICC Monitoring System, was not referenced in the EOP. 1 n. -St'ep 13.3: Since this procedure assumed "no accident in progress" . the TSC may not be activated. 4 o. Step 7.3: The equivalent step 'in ESP-0.4, step 10, had an RNO _ vent the accumulators if the discharge valves were not closed. This step did not. - 5. ESP-0.4 Natural circulation cooldown with allowance for reactor. _ vessel" head-steam voiding (without RVLIS) , , x .a .. . .
pn- -:l Q4 . -- 20 p: , a. This procedure did not implement the ERG background document statement prohibiting- transfer . to FR-I.3 while in ES-0.3 or ES-0.4. The ERG considered the matter a_ training item; however' , during walkthroughs, the operators were not aware of the limit. , b. Step 1 caution: Farley deleted the ERG caution to transfer' to E-0 (EEP-0) given SI. The justification was based upon b operator knowledge. Although the NRC agreed that SI initiation transfer to EEP-0 was within the purview of operator knowledge, ' this (and in ESP 0.3) was the only identified instance where an ERG transfer was undocumented and lef t to operator knowledge. Since E0P transfers were significant to the mitigation strategy, the team concluded the deviation was unjustified. c. PSTG DEV, Step 1.7 RNO: ERG RNO lb was omitted (establish SCM), d. ERG basis: 'This reference stated the operator should be aware the pressurizer would not respond in the normal manner if a head void were present and noted that letdown in excess of charging- would result in increased pressurizer level, the opposite of normal single bubble expectations. This was not covered in the procedure but was considered part of- Farley operator knowledge. Since the walkthrough operator was unaware of the unusual , pressurizer behavior, the NRC concluded that a note or caution was required before step 5 of the licensee's procedure, e. Step 21.2: This step presumed the-atmospheric relief. valves were open. If condenser steam dump cooling were available, the atmospherics would be closed, f. Step 22.1: This process was complex and infrequently accomplished and required reference to the supporting procedure. Procedure FNP-X-68.0, ICC Monitoring' System, was not referenced in the E0P. g. Step 22.3: Since this procedure assumed "no accident in progress", the TSC may not be activated, b. Figure 1: The meaning of the dashed lines was not clear. 6. ESP-1.1 Post SGTR cooldown using blowdown a. Step 4.1.5: The mimic bus 1G for the emergency diesel generator > lettering wa: faded, b. Step 4.2.1 RNO: This step used the word consider. This was not an action word utilized in AP-74, Attachment 1, Table 1. c. Step 8.3: This step listed four radiation monitoring drawers; R-02,'R-07, R-27A and R-278. The nameplate identification tags more accurately identified them, 7
r 21 . , ' Step 18.8: This step required resetting sequencers B1f and BIG. d. . The nameplates on the reset push buttons were inccrrectly labeled "Ess Stop Reset." This confused the operator conducting the walkthrough. i e. Figure 1: In this figure the page must be rotated for use. .Also,_the divisions for pressure did not clearly indicate if the values are in psi, psig or psid. i 7. ESP-1.2 Post LOCA cooldown and depressurization a. Step 2.2.1 RNO: The verb " consider" was used without qualification for an RNO step. j b. . Step 2.2.8 caution RNO: The caution required the operator to -assure there was sufficient diesel capacity prior to energizing the pressurizer heaters; however, the gauge cannot be read to the precision required in the caution (0.27 Mw), ! c. Step 11,9: The pump identification was written RCP BEARING- ! d (BRG) OIL LIFT PUMP (PMP) in the procedure. The switches were labeled RCP BRG OIL LIFT PMP on the B pump and RCP BEARING OIL LIFT PUMP on the A and C pumps. The labeling was not consistent l between identical instruments, j d. Figure .1: The horizontal scale of the graph had units of PSI, ! PSID, and PSIA, depending upon the position along the axis. The j graph was difficult to interpret in the positions around 400 and l 2250. l l e. Page 19 JD change 4: This change stated that the digital total i AFW flow was not seismically qualified. The interviewed operators stated that the instrument was seismically qualified, t The instrument was determined to be .not seismically qualified, Step 5.2 RNO JD: This step JD stated " check" RCS average _j ' . temperature. The procedure stated " verify" RCS average J temperature. i , 8. ESP-1,3 Transfer to cold leg recirculation 3 a. ERG step 1 caution 1: The caution to maintain SI recirculation ] flow was deleted. The justification stated subcooling was j handled in the foldout page. The justifit.ation was inadequate, s b. Step 2: The procedure nomenclature corresponded to the board labeling. However, the NRC noted nomenclature differences between board labels for the two isolation valves (e.g. 3538A, i "penent room" and "HV" vs. 3538B "pene RM" and "SFP-HV"). l s , 1 3
A 3. . , 22 c. Step 4 caution: The annunciator set point was -incorrectly identified. The alarm response procedure indicated the set point was'4.7 ft., plus or minus one inch, not 4.6 ft, d. Step 5: Contrary to the ERG, FNP left the SI pumps running through the suction shif t. SI flow verification should be required on conclusion of step 5. e. -Justification, pg. 17 item 2: The citation of step 6.3 was incorrect; step 6.4.was the proper reference, f. Step'l caution: There were 2 cautions in one caution statement. g. Attachment 2, step 1.2 RNO: If ph were less than 8.5, 'the operator was directed to verify only one spray pump running. There was no check that containment pressure allowed reduction to one spray pump (e.g. S16psig). 9. ESP-1.4: Transfer to hot leg recirculation a. Step 1.1: This step contained five action substeps that lacked verbs and step numbers, b. Step 1.3: This step contained four action substeps that lacked verbs and step numbers. c. Step 1.5: This step required charging pump 1B train A amps greater than zero. There were two charging pump ammeters labeled IB - they were not identified as train A or train B. 10. ESP-l.5 Transfer from hot leg'to cold leg recirculation a. Step 1.3: This step used the " isolate" action verb rather than "close". Also, this step lacked an RNO for manual operation of the valve if the valve could not be closed from the MCB. b. Step 1.4: This step lacked an RNO for alternative flowpath or manual operation of valves in the event the valves cannot be opened from the MCB. c. Step 1.5: The statement of not starting 1A & IB train "A" charging pumps was not in a " caution" preceding the step. Also, this step lacked a verification of system flow. d, Step 1.7: This step lacked an RNO for manual operation of the valve in the event the valve could not be closed from the MCB. e. Step 1.8: This step lacked an RNO for alternative flowpath or manual operation of the valve if the valve could not be opened from the MCB. 1 - _ - _ _ _ - _ _ _ _ _ - - -
pm - ~ , b 4 , s .w y < , 23- 1 6 bs f.. Step 1.9: This statement of not starting both IC and IB train _ ."B" charging pumps was not in 'a " caution" preceding the s.tep. i " - ,This step lacked a verification item to ensure system flow. . 11. ESP-3.1-Post-SGTR cooldown using backfill a.- Step 4.1: The ' power history chart had ~not been updated for 5 - ' days, b. Step a 6.4.1 RNO:- The use of FNP-l'-SOP-62.0 by the , system- operator was not clearly indicated. This was inconsistent with other ESP. procedures, c. Step 6. caution JD: The justification for this step did not- include the' actual reason for the dif ferences between -100. H degrees /HR per the WOG and the actual cool down rate of 100' degrees in.60 minutes per this procedure. < - 12 . ESP-3.2 Post-SGTR cooldown using blowdown a.- Page 1,. Paragraph B.I: The hyphenation was missing between the- words post and SGTR. ~b. Steps 5.1, 5.2, 9, and 9.2 RNO: These steps referred to steam generator le' vel indicators LI-474, LI-484 and ' LI-494. The se -- indicator gauges were not marked with units of measure.
J c. Step 6.1, 15.1, ano the foldout page-Step 2.4: These steps used- the words "cooldown rate less than 100 F in ' any 60 minute . period." The justification document ~ did -not clearly show that- this -was acceptable in place of the requirements'specified in - the ERG. d. Step.10.2: This step discussed manually closing condensate dump valve N1N21V927. This valve was located in the lower.- level turbine building about 12 ' feet from the floor., The valve . handwheel was;found to be chained and locked into. position. The 1 valve nameplate could not be seen from the floor. Step 10.2 did . not warn the operator-about the above circumstances. .; ~ .I e. Step 10.1: This step discussed a hotwell level at 22 inches, l The gauge for hotwell level was divided-into 0.to 5 feet. .Also, the alarm (K-15) was not listed in . this step as an aid in s . promptly identifying its location'on the MCB, l f. Step 10.4.2: This step identified a manually operated valve l (N1G24V501) which was located above the main condenser. The ' valve was found to be virtually inaccessible. This required the- operator to place himself in a position where he could fall or otherwise hurt himself. Step 10.4.2 contains no provisions to alert the operator about this condition.
! j' . - , & a
- _ _ _ _ _ _ _ _ . . _ . _ _ _ _ _ . . . . . .9 e -, . 24 . ~ g. Step-15.3.1 RNO: The last section of this step took the operator into procedure FNP-1-SOP-62, which did not direct the operator back into ESP-3.2. h. _ Figure 1: This page had to be rotated for - use. Also,- the- divisions for pressure did not clearly indicate whether the values were in psi, psig or psid. 13. ESP-3.3 Post SGTR cooldown using steam dump a. Page 1, Paragraph B.1: The hyphenation was missing between the words post and SGTR. b. Steps 5.1, 5.2, 9, and 9.2 RNO: These steps referred to steam generator level indicators LI-474, LI-484 and LI-494. These indicator gauges were not marked with units of measure. c. Step 6.1, 15.1, and the foldout page Step 2.4: These steps used the words "cooldown rate less than 100 F in any 60 minute period." The justification document did not cleariy show that this was acceptable in place of the requirements specified in the ERG. d. Step 10.2: This step discussed manually closing condensate dump valve N1N21V927. This valve was located in the- lower level turbine building about 12 feet from the floor. The valve handwheel was found to be chained and locked into position. The valve nameplate could not be seen from the floor. Step 10.2 did not warn the operator about the above circumstances, e. Step 10.1: This step discussed a hotwell level at- 22 inches. The gauge for hotwell level was divided into O to 5 feet. Also, the elarm (K-15) was not listed in this step as an aid in promptly identifying its location on the MCB, ~ f. Step 10.4.2: This step identified a manually operated valve (N1G24V501) which was located above the main condenser. The valve was found to be virtually inaccessible. To gain access to the valve would require the operator to place himself in a position where he could fall or otherwise hurt himself. Step 10.4.2 contains no provisions to alert the operator about this condition, g. Step 15.3.1 RN0: The last section of this step took the operator into procedure FNP-1-SOP-62, which did not direct the operator back into ESP-3.3. h. Figure 1: This page had to be rotated for use. Also, the divisions for pressure did not clearly indicate whether the values were in psi, psig or psid. l
p. , < , - - - p , gy
- ,.
- _ K I + s ! 25- , , . o ': ,
G .
- -
V. ~ECP comments:- p [ 1. ,ECP-0.0 Loss.of all AC power
h ' a ;- During the walkthrough, the NRC noted that the hallway labeling ' on-unit 2 channel II and IV NI ~ cabinets was incorrectly color im c oded ~. The small: TPNS label plates were blue andL white, -not 't ' green- and silver. Unit 1- NI cabinets- had _no 'back panel; TPNS L labels.
b. Paragraph B,- entry: The FNP . entry was inconsistent with the e ERG, - The team . considered the FNP entry = and the supporting
deviation inadequate. At Farley, two_particular busses must be'- O. energized to provide power to 'a single train-(e.g. F & K or G & . , L).- Specific _ power configuration requirements should be' ' provided in lieu of " operator judgement". c.. . Step 16: S/G-pressure was displayed on instruments with 20 psi.
- h
per division. It was not possible to read 203 psig.
d. The; spent fuel pool local level indicator read only a few feet above and below normal level and.was difficult to read without- .- entering a contaminated - area. The scale did not extend deep . - enough _to _show the technical specification level, 23' above the- top of'sto' red fuel. _ - 2. .ECP-0.1 Loss of all AC power recovery 'without SI required a,
- Steps 2.5'and'2.6: These steps. required resetting sequencers'B1F
and B1G. The nameplates on the reset-push buttons were labeled a Ess . Stop Reset." This confused the operator -conducting- the. d .
- "
walkthrough. g . b. Step 7.1...7.2 and 15: These steps. referred to steam generator- ' . level ' indicators LI-474, LI-484, and LI-494. Even though these ' indicators had. scale divisions similar to adjacent level gages they were not' marked with units of measure. g c. Step _7.1.1 RNO: The size of the letters on the nameplates for ~ valves AFW-MOV-3350C, 3764E and 3764F were approximately two- times as large as similar nameplate letters. ' v s 3. ECP-0.2 Loss of all AC power recovery with SI required , a. Step 1.3 RN0: Performance of this step would have required the operator to climb up piping on the wall to reach the Q1P17V107 CCW return valve. b. Step 3.2 table: The plant label for CCW pump 1C was difficult to read with the result that "1C" appeared to be the numeral "10." j ' > ' .( j
p ., , , ,: c. Step 4 caution: ' This caution incorrectly used a- conditional logic statement = structure.. l ! ~d. Step 4.2 RN0: No page numbers were provided for. easy access to the referenced attachments. e. Step 4.5 caution: This caution failed to identify the potential . hazard, f. Step 6 caution: This caution did not comply with writer's .; guide requirements for a conditional logic step, incorrectly .i placed the conditional step out of the action step sequence, i ' and included a' reference to an S0P embedded in parentheses. g. Step 6.1 RN0: . Item 5 of the component list was contrary to writer's guide requirements for conditional' logic statements, j ! h. Step 6.1.1 RNO table: Headings in the " Intact SG"' column of the N I . table extended into the adjacent column, adding clutter and reducing legibility. , i. Step 6.2: This step was not a substep to step 6. f. Attachment 1: Steps 1 and-2 were the same as those found in. i ' ESP-1.3,-however, the order was reversed with no operational or- . technical basis. k, Attachment 1, step 3 caution: This caution failed to identify the potential hazard. 1. Attachment 2: The sequence of disconnects listed in this 3 -attachment had no technical nor operational basis. Within each ' train, the disconnects were sequenced i n an order' that was inconsi si.ent with physical location .and placement of the equipment, reducing efficiency and' increasing the amount-of - time and effort required to complete the task. In addition, the- emergency. lighting provided near the B- train disconnects was obscured by pipes. -. 4. ECP-1.1 Loss of emergency coolant recirculation ! t a. Step 1 caution 2: This caution included a conditional logic step structured contrary to writer's guide requirements and. incorrectly placed out of the action step sequence of the _ procedure. b. Step 1: This step failed to identify the conditions under which , step 2 or 3 or both were to be performed. c. Step 2.3: This step directed the operator to check RWST level greater than or equal to 4.6 feet. The level indicators referenced, LI-4075A and LI-4075B, had gauges with I foot increments'and therefore did not provide the required increments to allow accurate reading of the 4.6 foot level.
,; .. 27 d. Step 2.3 RNO: This step was not a contingency - action to step 2.3. e. Step 2.5: lhis step directed- the operator to. backflush ~ ' approximately 1/2 foot from the RWST. The step listed LI-4075A and LI-4075B prior to SPDS points LT0501 and LT0502. The SPDS- points allowed easier and more accurate reading of small changes- in RWST level. f. Step 3.2: This step- directed the operator to check RWST level greater than or equal to 4.6 feet. .The level indicators referenced, LI-4075A and LI-4075B, had gauges with I foot increments and therefore did ntt allow 4.6 feet to be read accurately, g. Step 3.2 RNO: This step was not a contingency action to Step 3.2. h. Step 5.1: The term "as necessary" was superfluous and did not add needed information to this step. 1. Steo 6.2 caution: This caution was incorrectly structured as a conditional logic step. j. Step 6.2: This step was a continuously- applicable conditional step. No reminder of the step was provided to the procedure user, k. Step 6.3. RNO: MN STM- ATMOS PRESS REL VLVs were presented in ' list format. This format was inconsistent with the table format -used in other procedures (e.g. , FNP-1-ESP-0,1, Step 1.2.2 RNO). 1. . Step 10.2: Item 3 in the component list following this step included a conditional logic step structured in violation of writer's guide requirements. In addition, this conflicted with the structure of component lists included elsewhere throughout the ERPs. m. Step 10.2 RNO: This step was contrary to writer's guide requirements for transition terms. In addition, no reminder of the continuous applicability of the step was provided to procedure users, n. Step 13: The step directed operators to check that no RWST to ECCS sump backflow path was open. The accompanying ' table checked that the related valves were open. This inconsistency could lead to confusion and error. o. Step 14.3: This step was stated " Check if one RCP should be started." The use of "if" following " check" was eliminated from other steps in the FNP ERPs, for example, step 24 of EEP-1. Justification for that elimination was stated as follows: " Deleted use of the term 'if' since its usage has been restricted mainly as a logic term." i
- . ; -
. , V: . '_ 28 . p. ' Step 14.3.1 RNO: This step was not a contingency action to step. 14.3.1. , Step 14.3.3-RN0Same as on comment step 14.3.1 RNO above. q.
r. Step 14.3.4 RN0: Same comment as on step 14.3.1 RNO above, s. Step 14.3.4: This step directed the operator to check FR-1548 - and FR-154A to determine if seal leakoff flow was within. Figure .j 1 limits. There was no indication on the chart paper that it ] was incremented in gpm. .! k t. Step 14 3.5 RNO: Same comment as on step 14.3.1 RNO. {t u. -Step 14.3.6: This step directed the operator to check RCS i within Figure 2 limits. The step failed to provide a page 4 number for easy reference to the required figure. ' -i v. Step 15.1.4 RN0: This step directed the operator to-control SI l flow by opening or closing appropriate SI velves to maintain- + core exit thermocouple temperatures stable or trending down. The step did not provide the relationship between valve position f ~ and core exit thermocouple temperature, w. Step 17.1.1 RNO: This step included action steps within the ,l format of a component list. This was inconsistent with other ! component lists used throughout the E0Ps. , i ' x. Step 20.1 RN0: This step included .the term "as required " ' Inclusion of the term did not add any information- or alter the 3 action. .! ! y. Step 21.1 RN0: This step was ' contrary to writer's guide d requirements for conditional logic statements, z. Step 22: Same comment as on step 14.3 above. aa. Step 22.2: Same comment as on step 22 above. ab. Step 23: Same comment as on step 22 above, j ac. Step 23.1 RNO: This step was contrary to writer's guide j requirements for transition terms, In addition, no reminder j of continuous applicability was provided for procedure users. -l ad. Step 27 caution: This caution failed to identify precisely to which steps it applied. ac. Step 28: This step included two related actions incorrectly linked by the term "while" rather than the conjunction "and " This was contrary to writer's guide requirements. ..
4h.e--. nee-.'....--....'. . . . . , , - , -r . - 29- , af. Step 29.2 RNO: This step included a conditional action step structured contrary to writer's guide requirements. ag. Step 29.4: MN STM ATMOS PRESS REL VLVs were presented in list format. This format was inconsistent with the table format used in other procedures (e.g. , FNP-1-ESP-0.1, Step 1.2.2 RNO). ah. Step 30.1 RNO: This step included a conditional action step structured contrary to writer's guide requirements. ai. Step 30.2: This step included a conditional logic step structured contrary to writer's guide requirements, , aj. Step 30.2 RNO: This step was a continuously applicable conditional logic step structured contrary to writer's guide requirements. In addition, no reminder of the step was provided to procedure users, ak. Step 31: Same comment as on step 14.-3 above, al. Step 31.1 RN0: Thi s step was contrary to writer's guide requirements for transition terms. In addition, the procedure failed to provide a reminder of continuous applicability for users to ensure that the operator returns to steps 31.2 and 31.3, am. Step 33 RNO: Bulleted item. 2 wes contrary to writer's guide requirements for conditional logic steps, an. Step 34: Same comment as on step 31 above. .ao. Step 34.1 RNO: This was not a contingency action to step 34.1. ap. Step 35.1: This step was contrary to writer's guide requirements for conditional logic steps, aq. Step 35.2 RNO: Same comment as on step 35.1 above. ar. Figure 2: Reduced type size and poor reproduction have resulted in reduced legibility. 5. ECP-1.2 LOCA outside containment a. PSTG DEV, Step 1.1 RNO: This step stated: "If normal RHR system in service, then perform the following." A similar step was not in the ERG. The licensee did not have an- E0P user's guide, and the ERG user's guide stated that the guideline procedures were applicable for use only in modes 1, 2, or 3 with the RHR system not in service. This E0P step deviation from the ERG was not justified in the JD. - . , .. . 4 .,,,. w
p L# , , 30 b. Step 1.1.2 RNO: This step contained three action substeps that lacked action verbs. They also lacked step numbers and associated required sec.uence. Performance of the steps out of sequence - closing the RHR pump suction valve before stopping the.oump - would be undesirable. c. Step 1.1.4 RNO: This step contained an IF, THEN, OTHERWISE logic statement not defined in the writer's guide. d. Steps 1.1.5 RNO and 1.1.6 RN0: These_ steps each contained three , action substeps that lacked action: verbs and step numbers. As in substep-1.1.2, performance of the steps out of sequence would; be undesirable, e. Step 1.1.8 RNO: Same comment as on step 1.1.4 RNO above, f. Step 3.1: This step contained two' action substeps that lacked ' verbs and step numbers. ,g. Step 3.8: This step contained a typo: verify. 6. ECP-2.1 Uncontrolled depressurization of < all steam generators . a. Steps 3.2 and 20: These steps refered to steam generator level indicators LI-474, LI-484 and LI-494. Even. though these indicators had scale divisions similar to adjacent level gages they were not marked with units of measure. b. Step 5: The scale division numbers on level gauge LI-4132A did not align properly-with the marks on the scale, c. Step 7.2: This step listed ten radiation monitoring drawers; R-15, R-15B, R-15C, R-19, R-23A, R-23B, R-60A, R-60B, R-60C and R-60D. These drawers had nameplate identification tags which more accurately identified them, d. Step 37.2: This step did' not specify the gauge- to. be used to verify maintaining steam generator level, ' e. Figure 1: This page had to be rotated to be used.. Also, the divisions for pressure did not clearly indicate whether the values were in psi, psig or psid. '7. ECP-3.1 SGTR with loss of reactor coolant subcooled recovery desired a. Step 1.1: MLB1 1-1 and MLE1 11-1 lacked descriptors, b. Step 1.1 RNO: This step lacked an indication of SI being reset. 1 c. Step 1.2: MLB2 1-1 and MLB2 11-1 lacked descriptors. -._
. f e ' [ -31 d. Step 1.2 RNO: This step lacked an indication of Phase'A- being reset,
e. . Step 1.3: MLB3 1-1 and MLB3 6-1. lacked descriptors. f. Step 1.3.1 RNO: This step lacked an indication of Phase B and CS being reset, g. Step 1.3.2 RNO: The follow-up items listed in this step were action steps rather than confirmation items, h. Step l'3.3 RNO: The statements of not stopping both 1A & IB recirc fans and not stopping both 1A & IB exhaust fans were not included in a note preceding step 1.3.3. 1. Step 2.2 RNO: This step inappropriately contained two separate actions. J. Step 2.2.1 RNO: The phrase " consider aligning" did not appear. ~ as an action verb in Table 1 of the FNP writer's guide. k. Step 2.2.2 RN0: Same comment as on step 1.1 above. 1. Step 2.2,6 RNO: Same comment as on step 1,3.2 RNO above. m. Step 2.2.8 RNO caution: The indication for determining precisely "0.27 Mw" was not available, n. Step 3.2: Listed radiation monitors did not use the facility assigned names associated with each monitor. The term " normal" was not definitive as an indication of monitor status. Operators displayed inconsistency in their determinations of- - what monitor levels were considered " normal" or " abnormal". o. Step 3.2 RNO: By proceeding to step' 4 until " spray add tk level falls to less than 10%" and "when containment pressure -is less than 16 psig",. implied that operators would need to remember'to return to' steps 3.3.1 and 3.3.2. The. remainder of the procedure did not provide reminders to return to steps 3.3.1 and 3.3.2, p. Step 5.2: Same comment as on step 3.2 above. q. Step 5.2 RNO: Same comment as on step 2.2 RNO above. r. Step 7.1: This step lacked an FNP wr. iter's guide action verb, s. Step 8.3: The statement that RHR flow was to be " adjusted when required", was not necessary. Other lists in the procadure simply stated ' adjusted". . . . .. . . - . . . . . . . . . . _ . _ . . _ . . . . . . . _ . . _ . . . . . . _ . . -
_ _ _ _ _ _ . . . . _ . . . _ . . . . . . Os l4 ' 32 i t. . Step 8.4.1 RNO: In this step, steam .was to - be dumped "in accordance with"-SOP-62.0, not, "by using" SOP-62. u. Step 8.4.2 RNO: Same comment as on step 8.3 above, v. Step 8.4.3 RN0: Same comment as on step 8.3 above. w. Step 10.2 RNO: In this step, the word " consult" did not appear in' Table 1 of the FNP writer's guide. x. Step 13.1 RNO: Same comment as step 2.2 RNO above, y. Step 13.1 RNO (PORV Items): The statements in this step of "not using both PORVs" and "to use auxiliary spray if the PORVs are unavailable" was not included in a note preceding step 13.1. z. Step 14.2: The statement in this step of " establishing only one RCP running (preferably 1B, lA, then IC)", was.not included in a- note preceding step 14.2. aa. Step 15.5 RN0: This step provided information. It.did not provide alternative actions nor directions to move to another area of the procedure, ab. Step 15.6 RNO: Same comment as on step 15.5 RNO above, ac. Step 15.7 RNO: Same comment as on step 15.5 RNO above. ad. Step 15.9: Use of "IF"/"AND"/"THEN" logic, at the start of the action was not necessary and was redundant. Use of the verb " establish" was not appropriate, ae. Step 15.9 (RCP bearing oil lift pump-items): Statements of white oil pressure indicating lights and lift pump operation after RCP operation were not included in a note preceding this step, af. S tep ,15. 9.1 RNO: The instruments listed for. " trending data" would not provide a trend unless the operator took note of listed S/G pressure instrument readouts on at least two different occasions or " points in time", ag. Step 18.3: The statement that either the " normal" or " alternate" charging line (but not both) should be placed in service, was confusing. This statement was more appropriate for a " note" preceding step 18.3. ah. Step 19: This step lacked RNO actions for manual operation of listed valves in the event the valves could not be closed from the MCB. a _.
. i, 4 4 \\ 33 ai. Step 20.1: This step inappropriately contained 2 separate confirmation actions - check to ensure RHR not in $1 mode of operation by,1) noting "RCS pressure less than 260 psig" or 2) noting "RHR aligned for ntrmal cooldown", aj. Step 20.2: Same comment as on step 8.3 above, ak. Step 21.1: This step was not complete, since loop flow, as well as breaker position, is a proper indicator of a running RCP. al. Step 21.1.7 RNO: Same comment as on step 15.0 ebove. am. Step 21.1.7 RNO (RCP Bearing oil lift rump items): Same comment as on step 15.9 above. an. Step 21.1.8 RNO (NC flow): Same comment as on step 3.3 RNO above, ao. Step 21.1.8 RNO: The ins; r.:ments listed for " trending data" would not provide a trend unless the operator took note of listed S/G pressure instrument readouts on at least two different occasions or " points in time", ap. Step 21.2: This step was not complete since loop flow, as well as breaker position is a proper indicator of a running RCP. aq. Step 22.1: Same comment as on step 8.3 above, ar. Step 22.1 RNO: Same comment as on step 2.2 RNC Above. as. Step 22.1 RNO: The statements of "not using bcth 00RVs" and "to use aux spray if PORVs are unavailable" was not $ncluded in a note preceding step 22.1. at. Step 23.1: In determining required boren addit $on, this stop stated 2 rather than 1 "most preferred" method of determination, au. Step 25.1 RNO: Step contained an "IF/THEN/ OTHERWISE" logic statement not defined in the FNP writer's guide. av. Step 26.1: Same comment as on step 1.1 above. aw. Step 26.1 RNO: Same comment as on sten 1.1 RNO above. ax. Step 26.5: This step lacked an RNO action for an alternative method of D/G shutdown in the event the D/G could not be shutdown with the diesel stop pushbutton.
_ _ _ _ _ _ _ _ - _ -.
4, ! N 6' E '
- v.
34 ( u 2; i {{ ~
% ay. Step 29.3 RHO: This step provided information. It did not ! ~# . provide alternative actions nor direction $ to .nove to another j
.q, area of the procedure. - , ' cz. Step 29.4 RNO: Same comment as on step 29.3 RN0'above. , ba. Step 29.5 RNO: Same comment as on step 29.3 RNO above, , bb. Stap 29.7.1 RNO: Same comment as on step 15.9.1'RNO above. , be. Step 31.1 RNO: Same comment as on step 8.3 above. . 1 bd. Step 31.3 RNO: The statement that "AFW flow was to be stopped [ if any of the "above" termination criteria was met -rather than ! criteria "on the previous page" or "in RNO step 31.2, page
50/55" - was inappropriately stated. RNO step 31.3 was located , at the top of page 51/55. . 8.- ECP-3.2 SGTR with loss of reactor coolant saturated recovery i desired l a. Stop 5.4.4 RNO: As a last resort .to cooldown using an intact or faulted S/G, this step directed.cooldown using the ruptured S/G. ' It did not specify whether the condenser dumps or the atmospheric reliefs were preferred nor were any cautions or t notes added considering inplant and offsite dose projections and ~: precautions. b. Step RNO 17.1.8: This step verified naturai circulation but did
not include a required delta T. Other procedures, e.g. A0P-28.1 i step 5.15 note, specify a required delta T. ' c. Step RNO 21.1: The comma af ter ". . . and 21.4" was incorrect. .: The remainder of the paragraph was not a new sentence. '
d. PSTG DEV, step RNO 27.3: The ERG step 28 feed termination criteria were qualified "then stop feed flow to the ruptured S/G unless needed for RCS cooldown". The FNP step did not contain
that qualification nor was the deviation justified. f ' .9. ECP-3.3 SGTR without pressurizer pressure control ' a. Steps 1, 6.1, 6.2, 8.2, 24, 27, and 32: These steps referred to 1 steam generator level indicators LI-474, LI-484 and LI-494. Even though these indicators had scale divisions similar to adjacent level gauges they were not marked with units of measure. h' . a- _ -
- - - - . - - _ . - - - - _ _ .__ , - . j int 1 s ' 3 35 b. Step 2.2.1 RNO: _ This step used an action word which was not ' defined in the writer's guide, - c. Figure.1: _The page had to be rotated to be used. Also, thv divisions for pressure did not clearly indicate if the values were in psi, psig or psid. L VI. FRP comments: 1. FRP-C.1 response to inadequate core cooling a. Steps 7.1 and 7.2: These steps referred to steam generator level indicators LI-474, LI-484' and LI-494. Even though these indicators had scale divisions similar to adjacent level gauges they were not marked with units of measure. -b. Step 14.3 RNO requires opening reactor head vent valves HS- ' - 2213A, 2213B, 2214A, and 2214B. The switches on the MCB for i these valves are located such that the identification tag for ' the valves is hard to identify. c. Step 16: This step does not address 'that this step is for the "SI" accumulators, as shown in the ERG, FR-C.1, Section 20. 'd. Steps 16,1 and 2.2: These steps' refer to RHR flow indicators FI-605A and FI-605B. These indicators have scale divisions but. they are not marked with units of measure. 4 e.- Figure 1, the page must be rotated for use, Also, the divisions for pressure do not clearly indicate if values are in' psi, psig or psid. 2. FRP-C.2. Response to degraded core cooling a. Step 1 first caution: This caution did rot identify the hazard related with tripping the RCPs. -b. PSTG DEV Step 1: The ERG step 1 required operators to " Verify - SI valve alignment." The E0P_ did nct include that requirement,. and this E0P step deviation f rom the ERG was not justified in the JD. Also, the ERG required operators to verify $1 flow in- all trains.- while the E0P required operators to check any high' head safety injection flow greater than zero. The E0P did not require checking all trains, and 'this E0P step deviation from p the ERG was not justified in the JD.
fg , . e . - L
36 I A
L .'I o c. Step 1.6 RNO: This step contained six action substeps that t' lacked verbs or step numbers. In addition, one.substep implied that the operator was to check SI ficw indicator FI-943, but no , [ expected value was given. l I d. Step 1.7 RNO: This step contained an action subitep that lacked FI-940". The i a verb or step number. The substep was: - " , l implied desired action was to check the flow indicator, but no ' expected value was given. , 1 e. Step 1.7.1: This step contained four action substeps that i lacked verbs or step numbers. I f. atei - 1.7.2 RNO and 1.7.3 RNO: The tables in these steps are note anged in a standard logical order, in that the columns go , froft ieft to right instead of from top to bottom. [ . I L g. V ep 3.4: This step required operators to check the position of tour reactor vessel head vent valves. The identification
numbers for these valve indications on the control board were i located under the hanciswitches, and were very difficult to see, h. . Step 4.1: The fourth substep lacked a checkoff place. r i 1. PSTG DEV, Step 6.2 RNO: This step stated "If intact S/G pressures greater than 103 psig, then open accumulator discharge' , valves..." The stated concern in the JD was that RCS pressure -i not be 50 low that accumulators would discharge nitrogen- into !' the RCS. The ERG opened the accumulator discharge valver. with. no lower ' limit on SG or RCS pressure, and acknowledged the.tLnitrogen. might be injected into the RCS. This E0P step deviation from the ERG was not adequately justified in the J0. , j. Step 7.1 RNO: This step required reading 395 gpm on an , inappropriate meter scale that was graduated in 20 gpm ' increments. , 'k. Step 8: This step required operators to reduce pretsure in all i intact steam generators to 103 psig. The steam generator pressure indications on the control board had no Reg. Guide 1.97 + markings. 1. Step 8.2: This step contained action substeps that lacked verbs and step numbers, Also, one substep stated "stm dump intik train A in on and to byp intik when required". The when required value was not stated and one typo was included. l.4 . -.
g a
'
er
37 > . - c L , ?
3. FRP-C.3 Response to saturated core cooling ! rI_ a. $tep 1 note: _ Changing this note to a caution statement would - !? have been reasonable since disruptice of on-going cooling
' mechanisms - while performing actions called for in ECP-3.2 - p with damage to plant equipment was a distinct possibility. , t h b. Step 4.2: The instruments listed - TI-463, TI-471 and PI-472 - ' , -for " trending of data" would not provide'such information unless ! r. nperators were to take note of the listed instrument readouts on
at lean two different . occasions .or " points . in time" .' . , L Comparisons of safety- related instruments TI-463 & 471 to k 'nonsafety-related computer points were made. l > c. Step 4.2 RNO: The statements of closing the PORV block valves-
, , "if required" was not necessary. Other lists in the procedure
simply stated " closed".
- _
4. FRP-H.1 response to loss of secondary heat sink
- .
,
a. Step 20.): 'This step referred to steam generator level
indicators L1-474, LI-484, L1-494. Even though these indicators ' has scale divisions similar to adjacent level gauges they were
.not marked with unii. of measure. ! , w t 5. FRP-H.2 Response to steam generator._ overpressure
, . a. Step 2: 'This step lacked an RNO action for alternative methods of closing the valves in the event the valves could not be > . closed from the MCB. ! ' > ' - b. Step 4.4:'The statement of releasing steam to the TDAFW pump "if' /d possible" was not necessary. Also, this step lacked an RNO for ' an alternative method of opening the valves in the event they 9' , . could not be opened from the MCB. ' o , ' c. Step 5.): The instruments listed in the previous step for . . " trending of data" would not provide such information unless the-- operator were to take note of the listed S/G pressure instrument 1 readouts on at least 2 different occasions or " points in time". ! ' d. Step 6,1 RNO: This step lacked an.RNO for alternative methods" of manually closing the AFW valves in the event the AFW flow control or isolation valves could not be closed from the MCB. 3 e. Step 7 RNO: This step inappropriately contained two separate J actions " attempts to release steam from affected S/G" and "go
to procedure and step in effect". i .. e l3 ' ! , -
. _ _ _ _ _ _ - _ _ _ v i 38 f. Attachment 1 (items noting specific S/Gs): The use of the word "affected", in many cases, was redundant and, often, unnecessary. 6. FRP-H.3 Response to steam generator high level a. Step 3.1 RNO: This step lacked an RNO for alternative methods of manually closing the MDAFW valves in the event the MDAFW flow control or isolation valves could not be closed from the MCB. b. Step 3.1.2 RNO: The words " locally unlock" did not appear in the approveo f acility action verb list, Table 1 of the FNP writer's guide". c. Step 4.2: S/G 1evel instruments listed in the previous step (number 4) for " trending of data" would not provide such information unless the operator were to take note of the listed S/G 1evel instrument readouts on at least 2 different occasions or " points in time". d. Step 5.3 RNO: The words " locally unlock" did not appear in the approved facility action verb list, Table 1 of the FNP writer's guide", e. Step 6 RNO: Use of "lF"/"THEN" logic, at the start of the RNO was not necessary and was redundant. The follow-up statement, ..to assist in valve closure" explained the function of the " TEST position and was not necessary. Both items were confusing and misleading. The remaining statement, .. place its " essociated test switch in the TEST position" would have sufficed as an RNO item, The follow-up checklist statements of "if required" was not necessary and was confusing, f. Step 7: The listed radiation monitors did not use the facility assigned names associated with each monitor. The term " normal" was not definitive as an indication of monitor status. Operators displayed inconsistency in their determinations of what monitor levels were considered " normal" or " abnormal". 7. FRP-H.4 response to loss of normal steam release capabilities a. Caution Step 1: This caution statement used a conditional step structure. This did not follow the recommendations provided in the writer's guide.
-
'. , , n . I
L- > , i. ' ' . b. Step 1: This step used the word "TRY" whien was not identified in the writer's guide, ' t= c. Step.1.1.3: This step used a symbol for feet which was not listed in the writer's guide. I d. Step 3.5 and 4.6, Attachment 1: These steps used the words "go' to step 1.2 of main procedures." Step 1.2 of FRP-H.4 contained
'
the exact wording as steps 3.4 and 4.5 of-Atta-hment 1; this , [ could cause confusion for the operator. g o [: e. Attachment 1, S tep 4.4.1: This step used the word " Monitor." This word was not identified as an action word in the writer's ' guide, l f. Attachment-1, Step 4.4.2: This step stated "if air supply is too
high THEN reduce." This step did not identify what "too high": ! was. 8. FRP-H.S Response to steam generator low level l i a. ' Step 4: Since the meter was graduated in.20 gpm per division, > it was not possible to read 25 gpm. b. Step 4 caution: Ine caution required that AFW flow to any S/G J with level 68 percent not' exceed 100 gpm. Completion of the . vertical column lineup in step 4.2 initiated maximum flow to i ~ that generator, There was no subsequent step to throttle '
(- 'AFW flow, !
' c. Step 5 caution: This caution was an action statehent. d. Step 5.1 RNO: Additional location information was required for- valve NIN21V927. It took about 15 minutes to tocate during I walkthroughs. e. Step 6: No instructions were provided as to level'to maintain.. .f ~E-
9. FRP-I.1 Response to high pressurizer level i a. PSTG DEV, Step 3.5: BIT isciation occurred in ERG step -1. a ' Deferring BIT isolation to step 3.5 was a deviation from the ERG- step sequence. No step deviation justification was available. -l 10. FRp-I.2 Response to low pressurizer level 4 a. No comment - < 'I ' . '.
. _ _ _ _ _ , 4 ,, . I 40 11. FRP-I.3 Response to voids in reactor vessel
a. Step 2.2: MLB3 1-1 and MLB3 6-1 lacked descriptors, b. Step 2.2.2 RNO: The statements of not stopping both 1A and IB recire fans"and not stopping both 1A and IB exhaust fans was not included in a note preceding step 2.2.2 RNO. c. Step 2.3: The statements of not . opening both normal and alternate charging- line valves was not included .in a ' note proceding the step, d. Step 2.3 RNO: This step inappropriately contained two separate actions " closing charging flow control valves"'and " opening charging line_ isolation valves". Also, follow-up- list statements of not opening both norma) & alternate charging line valves was not included in a note preceding step 2.3 RNO. e. Step 3: The use of the words "if required" or "as required".was redundant and unnecessary. f.- Step 6.3 RNO: This step provided, information. It did not' provide alternative actions nor directions to move:to another area of the procedure, g. Step'6.4 RNO: See step 6.3 RNO above. h. Step 6.5 RNO: See step 6.3 RNO above. -1. Step 6.8 (RCP bearing oil lift pump items):. The statements of white oil pressure indicating lights and lift pump operation after RCP operation were not included in a note preceding step 6.8. j. Step 7.1.1: The statements of opening one but not both post- LOCA containment sample points (1 or 2 and 3 or 4) was not included in a note preceding step 7.1.1. k.- . Step 7.2 RNO:- This statement was not presented in logic-format. 1, Step 8.1.3 RNO: The statement in this step of "not using both PORVs" was confusing. This statement was more appropriate for a note preceding the step, - m. Step 8.2.1: TSLB3 7-1, 7-2, & 7-3 lacked descriptors. 1 -
1 l - _
[
g .. . . , i g > h 41
-
n. Step 8.2.3 RNO: This step inappropriately contained 2 separate , . t- actions - " verify PZR pressure less than 1950 -psig" and . " reattempt to block PZR pressure SI". . E a L o. Step 10.2.1: Same comment as on step 3 above. , L .
p. Step 11: This step lacked an RND for an alternative. method of . ensuring the purge & mini purge dampers are c*.osed and that the- r
fans are stopped, in the event the system cannot be operated from the Control Room. . . i .E q. Step 12.1:: This step lacked an RNO for an alternative method-of + ensuring that containment air recirculation fans & cooler valves- ! could be ' controlled, in the event the system could not be ! operated from the Control Room. , I c 12. FRP-P.1 Response to imminent pressurized thermal shock condition
a.. Step 1: The only " degrees F" indication on TR 410 was located - in small, difficult to read letters at the top of.the recorder. ! ! b. Step 1,4 RNO: This step was contrary to writer's guide ' requirements for continuously applicable conditional logic steps. In addition, the accompanying table included headings in the left hand column that extended into the adjacent column, f' c. Step 1.6 RNO: The table accompanying this step included a 1 conditional action step that violated writer's- guide , requirements for structure, in addition to incorrect placement.
d. Step 2.1 caution: This caution was a continuously applicable ! conditional action step that was contrary to writer's guide requirements for structure and terminology, e. Step 2.2: This step was written inconsistently with the form of t the step found in EEP-0, step 21.1. In addition, the expected [ responses #or items 6 and 7 of the accompanying component. list were complex and difficult to interpret. ' f. . Step 2.3 RNO: This step was a conditional action step' that deviated from writer's guide requirements, g. Step 4: This stip stated " Check if SI can be terminated. . ," l The use of "if" following "theck" was eliminated from other T steps in the FNP E0Ps, for example, step 24 of EEP-1. Justification for that elimination was stated as follows: " Deleted use of the term 'if' since its usage has been. restricted mainly as a logic term." 4 +
- .
l L. i h ' .s
_ .. .i ' '42 h. Step 4.1.4 RNO: The scale at the top of FR-154A was handwritten and did not match the paper used in the recorder. The operator questioned' stated that he would- refer to the ' paper, not the scale, for the needed reading. , i. Step 4.1.6 RNO: This step was contrary to writer's guide requirements for transition steps and failed to provide a page number for each access to Figure 2. j. Step 6.1: Item I in the accompanying component. list included two actions, contrary to writer's guide requirements, k. Step 7.5: Inclusion of the term "as necessary" failed to alter the action in this step and added unneeded length and complexity to_the step. ' l. Step 8.1 RNO: Same comment as on step 6.1. m. Step 8.2.6 RNO: Same comment as on step 4.1.6 RNO. n. Step 9.1 RNO: Same comment as on step 6.1. o. Step 9.2 table 1 and 2: Headings from the left hand column df these tables extended into the adjacent . column, adding clutter and reducing legibility, p.- Step 11 1 RNO: This step was contrary to writer's_ guide . requirements for conditional logic statements,- as did item' 2 of the accompanying component list. -j q. Step 11.2: This . step was contrary to the writer's guide requirements for continuously applicable conditional steps and: the use of the term "then " r. Step 11.4 caution: The caution was a continuously applicable action step incorrectly placed out of the action step sequence, structured contrary to writer's guide. requirements, and lacking a method for reminding the user of its applicability, s. Step 11.4: This step _ was contrary to writer's guide requirements for continuously applicable conditional steps,- for inclusion of more than one action in a step, and also lacked'a method for reminding the user of its applicability, t. Step 13.1 note: This note incorrectly used a conditional logic step structure. u. Step 13.1 RNO: The order of components for this step lacked any operational or technical basis and was out of order for efficient operator action, p
l' , ' '
y - -- -- , . . ' ) r
- c
43 c v. Step 14 caution: This caution was a conditional action step incorrectly placed out of the action step sequence, w. Step 17.1 RNO: This step was contrary to writer's guide- requirements for conditional action steps, as were both items. in the accompanying component list, x. Step 18 RNO: Some comment as step 17.1 RNO above. y. Step 19: -Same comment as step 4. z. Step 19.1: This step lacked an action verb, aa. Step 19.1 RNO: Same comment as step 18. ab. Attachment 1, step 1.4.1: This' step contained three different methods of referring to hot shutdown panel, ac. Attachment 1, step 1.6 caution: This caution was an action step incorrectly placed out of the step sequence, ad. Figure 2: This figure was difficult to read, due to small type size'and poor reproduction. -13. FRP-P.2 Response to anticipated pressurized' thermal shock conditions a. Attachment I step 1.1 RNO: Z-13, Z-125,'Z-123, 2-126, Z-124, and Z-122 were not identified as keys, b. Attachment 1 step 1.7.RN0: Z-139, Z-170, and Z-141 were'not'
identified as keys, c. Step 3: This step identified the cold leg temperature cooldown rate as the Technical Specification rate (100 degrees F in any 60 minute period). This was inconsistent with figure -1 which defined the cooldown ramp rate'as 100 degrees F/HR, d. Step 4.1: Same comment as step 3'above. e. Attachment 1 step 1.6 caution: This caution indi ates th'atLfor- the condition with all steam generators faulted at least 25 gpm AFW flow should be maintained to each steam generator to prevent. tne tubes from drying out. This is inconsistent with step 1.5- , ut RNO which limits AFW to 25 gpm for any faulted steam generator used for cooldown. 14. FRP-S.1 Response to nuclear power generation /ATWT a. Step 2.3 table: This table incorrectly included a conditional logic step within the first column. , 2 - - . !
Q- - _ 7. . . .
p.-
! V' > h 44 '
i I { 1 b. Step 4: Thi s step stated " Determine if emergency. boration 1
required." The use of "if" following " determine"'was eliminated
from other steps in the FNP E0Ps, for example, step 24 of EEP-1. _ Justification for that elimination- was stated as .follows: L " Deleted use of the term 'if' - since its usage .has been restricted mainly as a logic term." ! r c. Step 4.1 RNO: This step was contrary to writer's - guide . i " requirements for conditional logic step structure. l
- .
l[ d. Step 4.2 note: This note included action steps incorrectly.
W placed outside of the sequence of action-steps. t I- ~ guide- '4 i e. Step 4.2 RNO: This step was :ontrary to writer's [ requirements for the term "then." 7 f. Step 4.5: Same comment as step 4.1 RNO above. ! g. Step 4.5 RNO: This step failed to provide a page number for , easy access to Attachment 1. j . h. Step 5.1 RNO: This step deviated from writer's guide-
' F requirements for continuously applicable conditional logic steps and standard conditional logic steps. In addition, the operator required a rack out tool to complete the step. The tool would
have to . be acquired from the shift foreman. No tool is , available at the site of the action. - 1. Step 6.1.3 RNO table: Headings f rom the "SG" column of the j table extended into the adjacent column, adding clutter and , reducing legibility. . J. Step 6.2.2 table: Same comment as step 6.1.3 RNO table above. - -y k. Step 8.2: Same comment as step 4.5 RNO above. 1. Step 9 caution: This caution was an action step incorrectly placed out of the action step sequence, m. Step 9: Same comment as step 4 above, n. Step 9 RNO: This step deviated from writer's guide requirements on use of transition terms. ,
o. Step 10 RNO: This step deviated from writer's guide , requirements for conditional logic steps. In addition, the Core Physics Curve 5 referenced was difficult to read due to small 1 print and poor reproduction. p. Attachment 1: This attachment failed to apply writer's guide i requirements for conditional action steps to identify the conditions for use of the three tables. > +
3' c, . c' . i j- 45
, I !
q. Attachment 2, step 1.4.1: This step included three different i methods of reference to the hot shutdown panel. i 'i r.- Attachment 2, step 1.6 caution: Same comment as step 9 caution i above. i
15. FRP-S.2- Response to loss of core shutdown a. Step 3.3: It appeared that the FNP-1-SOP-2.1 step 4.5 process of reducing letdown pressure prior to opening the second orifice - should apply here. l 16. FRP-Z.1 Response to high containment pressure a. Step 3 caution: Thiscautionstepcontainedinstructionswhich-
-- j were inconsistent with the writer s guide, I b. Step 3.4L RNO: This . step required that the operator verify: no flow. The instruments for. reading flow were indicating a small
, flow at the zero flow condition.
.; c. Step 3.6 RNO: This step referred to adjacent level instruments l with different point size fonts. E -d. Step 1.7'RNO: This step referenced keys that were identified I inconsistently with the format.of other FRP procedures, l e. Attachment 4 step 1.1: This step referred to 8 key operated- ! valves without identifying the specific keys required to perform .i tha action. ' , 17. FRP-Z.2 Response to containment flooding - l a. Step 2: The ERG basis document identified primary makeup water, , demin water, service water, CCW and " plant specific list". This ' -step only included service water and CCW. j b. Farley had varied from the ERG step sequence. A step deviation:
was maae. However, as a result of the reordered step sequence, plant engineering staff was not informed of the sample results; i they were however consulted concerning sump content disposition. 7 18. FRP-Z.3 Response to high containment radiation level j a. Step 1: The form of.this step contained in EEP-1 also contained - a step to verify the MINI PURGE SUPP FAN /EXH FAN stopped. ! i ,
e -i m - , - - -
> . . - b V' 46 7 I -VII. CSFST comments 1. CSF-0. Critical safety function procedure a. The procedure did not specify a reporting method for ' CSFST manual monitoring nor were the WOG recommended forms' used. , During the simulator evaluation, the person acting as the.STA orally - reported an . orange path before he had completed a complete CSFST monitoring cycle.. The SS misunderstood that report and inferred.the orange path was the dominant path, b. Based 'upon simulator abservations, the Farley process for reporting CSFST status results consisted of exception rather ' than periodic reporting (e.g. the STA stated he would only report changes and then only changes which involved red or- orange paths). 2. CSF-0.1 Critical safety function status tree - suberiticality- a. .During simulator walkthroughs, the NRC noted the SPDS- suberiticality tree went yellow intermittently due to -SUR bounce. . The licensee stated that -Westinghouse had been contacted about the problem and had revised the sof tware - to smooth the algorithm. Since that change, the problem had .not .. been noted in the plant. It was not clear that the same revision was applied to the simulator. F 3. CSF-0.2 Critical safety function status tree - core cooling a. No comments i- ' 4. CSF-0.3 Critical ' safety function status. tree - heat sink a. PSTG DEV: The horizontal line connecting the- NR level entry . ._ block "yes" output to the S/G pressure block was not- contained on the ERG tree. A revice of the ERG basis indicated.that the Farley CSF' was correct and the ERG tree was in error.- Farley noted and corrected the error but' did not- adequately document the deviation. 5. CSF-0.4 Critical safety function status tree - integrity a. No comrnents 6, CSF-0.5, Critical safety function status tree - Containment a. No comments 7. CSF-0.6 Critical safety function status trees - inventory a. Determination of "all upper head & upper plenum levels equal 100 percent": FNP Unit 2 did not have an operable "RVLIS", thus preventing the use of this status tree. _
, , . - _. .
- 4
< , ' . .I 47- x; , , b. ERG CSF-0.6 did not implement- the. ERG ES-0.3 and ES-0.4. background document statements prohibiting CSF-0.6 transfer to - FR-I.3 while in ES-0.3 or ES-0.4. The ERG considered the matter
a training item, however during walkthroughs, the operators were
not aware of the limit. VIII. AOP comments:- . 1. 'AOP-1.0 excessive RCS leakage 1 a.. Step 3.2: This step did not indicate that at 5% VCT level the . charging pump automatically shifts to RWST. . : b. . Step 5.7.1:~ This step did not list the following CTMT radiation ' ' monitors to be checked: R-2 CTMT Area R-7 Incor; NI Area R-11 CTMT Atmosphere < R-12 CTMT Atmosphere R-27A CTMT (High Range) R-27B CTMT (High' Range) c. Step 5.7.2: This step did not require the operator to notify - plant chemistry to verify that the RCS sample system was aligned for normal operation. d. Step 5.7.3: This step did not indicate the CTMT sump level instrument- to be 'used nor did it indicate that this1 instrument - was to be located on the "B0P" panel, e. Step 5.7.4: This step did not identify the radiation monitors to be used, i.e. R-17A and R-17B. f. Step 5.7.5: This step did not identify the level instrument to be used 1.e. LI-470. , g. Step 5.7.6: This step did not identify the methods to be 'used; to check for increased radiation released from the steam generators. , The two methods available were-from steam line radiation monitors ' R-70A, B, and C, or by taking grab samples. ~ -h. Step 5.7.7: This step did not indicate that the surveys were to be.taken by HP and that radiation monitors R-3, R-4, R-6 and R-8- needed to be checked to locate areas in the auxiliary building that might have leakage. 1. Step 5.7.8: This step did not identify how the tanks werc , to be checked for excessive level increase. ' - - _
,. . 48 , j. Step 5.7.9: .This step did not identify how the RCDT. was to be checked for excessive inleakage. k. Step 5.7.10: This step did not include a list of the filters to be checked for leakage and the location of these filters. 1. Step 5.7.12: This step did not identify how the tank levels were
to be monitored for excessive level increases. 2. A0P-2.0 Steam generator tube leakage ' a. Step 5.9: .~ In this A0P, steam generator tube leakage rates up to . about 200 gallons per minute could be occurring. This step i - required implementation of EIP-9, Radiation exposure estimation and classification of emergencies. EIP-9 in turn referenced . EIP-17 Notification of unusual event, and EIP-12, Alert, for- classification of events. None of these procedures clearly ' required declaration of a NOVE, contrary -to NRC guidance in NUREG 0654, Four of five SR0s interviewed stated that their . interpretation of the EIDs was that a NOVE was not required.. The procedures also did not require manning the TSC or any other ' augmentation of onsite personnel, b. Step 5.13: This step required that, if the leak rate; was greater than 300 gpd.(0.2 gpm), then operators were to place the plant in hot standby within three hours and-continue to cold shutdown. It did not give adequate guidance to the operators in the event of a leak rate as large as 200 gpm, in
-the areas of: rate of power reduction, isolation of the' steam ! generator, rate of cooldown, reduction of RCS pressure to stop- ' the leak, or other' guidance similar to that contained tin the - + emergency operating procedure for steam generator tube rupture.. It also did not caution operators about overfilling - a steam generator or reference the plant procedure for- blocking up a > main steam pipe to prevent excessive pipe stress. 3. AOP-3.0 Turbine trip 6 P-9 setpoint > a. Step 4.3: This step included an incorrectly punctuated plural! to "RCP." In addition, the step indicated "4160V AC busses" in: - contrast to the control board label which indicated "4.16KV."- b. Step 5.11.2: This step referenced FNP-1-UDP-1.2 for unit startup. This procedure included directions to close SGFPIA RECIRC VLV NIN21V909A. This was located such that the operator - must stand on a pipe to complete the action. . c. Step 5.12 caution: This caution was contrary to writer's guide requirements for conditional logic statements. L i ' , l , I /
y y; m . . L 49 ' , p i' . d. Step 5.12.1: This step was contrary to the writer's guide ' requirements for directive action- step structure. e. Step 5.12.3 note: This note included a continuously applicable - conditional step incorrectly placed outside of the step y ' sequence. In addition, no reminder was provided to the user of the continuous applicability of the step. f. . Step 5.12.62: This step . deviated from the writer's guide requirements for transition terms.
4. A0P-4.0 Loss of reactor coolant flow f a. Step 5.1: This step did not provide the system identification- numoers for the main feedwater regulating valves' and bypass
valves. b. Step 6.5.1: This step did not provide the identification numbers- for the spray valve controllers, c. Step 6.5.3: This step did not provide the identification numbers for the spray valves, d, Step 6.5.5: This step did not identify the number of PORVs required to be used and the identification number of the PORVs. e. Step 6.5.6: This step did not reference procedure SOP 1.2 as the- procedure to follow to control pressure.
f. Step 6.7.1: This step did not indicate that a boron sample needed to be taken by the chemistry group. 5. A0P-5.0 Loss of electrical train A and/or B , a. Step 4.2: No provision existed for transition back into this procedure in order to perform the remaining immediate action: steps. b. Steps 5.4 and 5.4.5: Overused logic statements, i.e., "IF/THEN/WHEN/THEN/IF DESIRE 0" logic path was- found in - the action steps, These caused unnecessary confusion, c. Step 5.5.2: Indication for determining precisely "0.27 Mw" was not available, d. Step 5.5.4: Closure of breaker ED08 was an interlocked closure upon actual breaker closure of EA09. ! e. Steps 5.6 and 5.6.7: Overused logic statements, i.e., l "IF/THEN/IF/OR/NOT/THEN" logic path was found in these action l steps. These caused unnecessary confusion. I a -
R, -, ' o i 50 i ' , f. Steps 5.8, 5.9 and 5.10: Three different methodologies of , presenting the term "not required" appeared in these. three _ sequential steps. g. Step 5.12: The term " normal operation" wa's not defined, . h. Steps 5.18.2, and 5.18.3: The action verb " parallel" did'not
appear on f acility. action verb lists. Both of these steps contained two separate actions " parallel the busses" and ' " return D/Gs to standby operations". t 6. AOP-6.0 Loss of instrument air a. Step 5.2.1::This' step and. step 5.2.2. were interchanged. Control room operators would first use the TDAFW pump to maintain level f since the AFW MOV's are located on the " BOP" panel, b. Step 5.2.2: See item a above. The new step 5.2.2: This step will preferably indicate that the AFW MOV's are located on the " BOP" panel and list the valves, c. Step 5.4: This step stated that instrument air may be supplied-
- from a temporary source. However, the procedure did not provide
any guidance as to what or how this temporary source was to be provided. Steps to activate this system were not provided. d. Steps 5.4.2.3 and 5.4.2.4: The location of valves N2P19V561.and N1P19V560 was not identified. Alladder was, required to operate these valves, e. Steps 5.5.2, 5.5.3 and 5.5.4: These steps did not indicate the. locations of valves Q1E21V135, 01E21V134A&B ' and ' Q1E21V581. These valves were located in the penetration ' room, 100 ' foot elevation. f. Step 5.6.1: This step did not read "stop - TDAFW - pump if operating". g. Step 5.6.2: This step did not indicate the location of these valves (main steam valve room). , b.- Step 5.7: This step did not state that use of manual handwheels to operate-the MN STM ATMOS PRESS REL VLV 1A (B, C) was to.only be used 'if the valves could not be operated' from the control room by using the alternate air supply from the emergency air . o compressors. l 1. Step 5.8.1: The valves to be operated were not identified. k:' .
, ' , , .. I i- L 51 g 7. AOP-7.0 loss of turbine building service water 1 L" 'a . Step 5.3.1: This step contained no list of components whose - temperature was to be checked to verify that their temperature had returned to normal. < 8. A0P-8.0 Partial loss of condenser vacuum a. Step 4.1: This step . incorrectly structured a continuously applicable conditional. logic step. b. Step 5.3: This, step deviated from writer's guide requirements for transition terms. E c. Step 5.10: This step incorrectly structured a continuously ' applicable _ conditional logic step. . . 9. A0P-9.0 Loss of the on service train of component cooling water ! a. No comment. f 10. AOP-10.0 loss of train A or B se vice water a. Step 4.2: This step did not identify valves to be closed to isolate !W to the turbine building. b. Step 5.5: This step did . net identify the- valves to be used to isolate CCW supply to the SFP and RHR heat exchange evaporator o packages and hydrogen recombiners. c. Step 5.6.1: This step did not it.Jicate that the SW pump miniflow< valves were to be closed, d, Step 5.6.2: This step did not describe how to look for leaks.- e. Step 5.6.3: This step did not identify the location of the valves. l -- f. Step _ 5.7:- This step did not identify the valves 'and valve numbers to be used to isolate this equipment, g. Step 5.9: This step did not indicate the location of the valves. l 11. AOP-11.0' Loss of river water l a. Step 5.4: The meter was marked with one foot per scale increment. It was not capable of reading 184' 4". <
.-. ___ " , l 52 N ,
-12. AOP-12.0 Residual h' eat removal system malfunction' a. Purpose: Divisional sectioning of activities did not include .' all major activities. Numbering of sections did not follow sequential pattern. Pump cavitation was listed separately .f rom RHR pump malfunctions. Sections 5.5 or 5.6, as noted in step i 5.4.8, and section 5.7 as noted in step 5.4.9, was not listed. b. Step 5.1.1. This step failed to discriminate between ' " indications of RHR pump malfunctions" and " evidence of RHR pump - i cavitation". , c. Step 5.2.2 note: TFis note contained caution information of adjusting RHR flow slowly to minimize further pump cavitation which would cause further equipment or system degradation, d. Step 5.2.2: This step structure and arrangement and - valve titling created confusion as to what was to be accomplished by this step. e. Step 5.2.3 note: This note contained caution items e.g., personnel in channel head areas, primary manways being removed and SI check valves being disassembled. f. Step 5.3: This " step" was a section on venting of the RHR system. " Step" 5.3 was not titled as a "section". g. Step 5.4 & substeps 5.4.1'- 5.4.9: These steps provided guidance upon loss of both trains of RHR cooling." Step" 5.4 was; not titled as a "section". h. Step 5.4.1 (first bullet): This information was confusing as to , which steps were to be performed concurrently and which were to be performed sequentially, i. Step 5.4.8: This step contained two separate actions - " alignment of a charging pump to provide flow (per section 5.5)" and " set-up for gravity draining of the RWST to the RCS via RHR (per section 5.6)". j. Step 5.5 note: This note followed rather than preceded step 5.5.
k. Step 5.5: This " step" was a section on aligning - the charging pumps for injection from the RWST to the RCS. " Step" 5.5 was not titled as a "section". 1. Step 5.5.1.2: This step stated that alignment of the pump was tq>ed upon the " location and size of any leak", however, the pumps, within the context of this procedure, were to be used for back-up cooling. m. Step 5.5.2.2: Same comment as step 5.5.1.2 above.
. u . f
. 53 o n. Step 5.5.3.2: Same comment as step 5.5.1.2 above, o. ' Step 5.6: :This " step" was a section on aligning the RWST to the RCS via the RHR system. " Step" 5.6 was not titled as a "section". p. Step 5.7: This " step" was a section on establishing a secondary heat sink to reduce RCS pressure. " Step" 5.7 was not titled as- at"section", q. -Step 5.7.1 note: This note contained caution information, e.g., using'this section:of the procedure only if primary nozzle dams e are removed and manways installed. r. Step 7.1.2: This step did not provide specific direction in " correcting the condition which caused the valve closure", ' s. Appendix 1 Step 1.1 note: This note contained caution information,e.g. ,- ensuring that " time is not wasted. . . .but contamination should be minimized as much as possible". t. Step 1.2: Same comment as step 5.2.2 above, u. Step 1.4: Same comment as step 5.2.2 above. - 13. AOP-13.0 Loss of main feedwater .a. No comment. 14. A0P-14.0 Penetration room high pressure a. Symptom 2.2: B-92, the B train alarm,'was not included. b. Step 3.1: This step' listed-valves that close automatically on a high energy line break. The -list was dif ferent from the' one in the ARP, and was incorrect. c. Step 3.2: This step listed valves that close automatically on s high penetration room pressure. The-list was different from the one in the ARP, and we.s incorrect. This step also did not include. alarm B-92. d. Step 5.4: Prior to this step, the procedure required operators to verify automatic isolations and to reduce penetration room pressure by operating a filtered exhaust, This step required operators to reopen letdown isolation valves. Reopening these 1 valves prior to determining the source of the leak could restart a primary coolant leak outside containment, which would be undesirable. The licensee identified this deficiency and corrected it in Revision 5 to this procedure, dated March 2, 1990, i - . , =m-
Lo: , o 54 e, + . 15. A0P-15.0 Chlorine tank leakage a.
- Step 5.1: This step deviated from writer's guide requirements
for transition terms b .. -Step 5.2: This included a. typographical error in the word . . . " determine." s c.. Step 5.7: .This step deviated from writer's guide requirements- for' transition terms. .16. A0P-16.0 CVCS malfunction a. Step . 5.4.2.8: This step provided information,- not specific actions. This information was not included in a note' preceding step 5.5. b. Step 5.5.2.4: This step did not provide specific actions for removal of the excess letdown system. 17. A0P-17.0 Malfunction of RCS pressure control system a. No comment. 18. AOP-18 Nuclear instrumentation malfunction a. Step' 2.4.4: This step did not direct the operator to monitor the Gamma Metrics nuclear instrumentation, b. Step 2.4.5: This step f ailed to reference' TS ' 3.9.2, which- required operators to-determine shutdown margin. . L c. Step'3.4.3: This step required the operator to turn the speaker " selector switch to the opposite channel. The switch had three. positions: A1, Normal, and A2. .The step did not identify the' desired switch ~ position. The step also did not state that the -- desired switch position ~ would power only the containment. speaker. d. Step 4.4.5: This step was unclearly wri tten . It stated: " ...the automatic re-energizing of the source range high voltage. must be energized by placing both source range...". The apparent intention was to state that the automatic re-energizing b of the source range was-' disabled, and that the operator must manually energize the source range, to tr' p .the e. Step 5.4.2: This step directed the operator i e associated bistables for the f ailed channel, on Table 1. Table 1 listed no bistables; but did list channels, test switches, card locations, status lights, and annunciators. ,
p- a , r: . , s , k , 55 ! j ! The test switches in the cabinets had two unlabeled positions: , up and down. Directions in this step and labels in the . cabinet were not sufficiently clear to prevent unnecessary trips of the i plant.
19. AOP-19.0 Malfunction of rod control system q f i M a. Step 2.3.2: The step should direct a "go to" transfer to FNP- > p- 1-EEP-0, not a referral to EEP-0. The reactor.had been tripped in response to a continuous rod withdrawal-after failing to stop- 1 o[ the withdrawal using the bank selector switch, j i ! L b. Steps 3.4.1, 4.4.1 and 6.4.1: The wording for steps which 1 i placed the turbine DEH control in hold was not standardized. tatement was redundant - and was not contained in a note. c. Step 5.5: This step contained two separate actions - '! shutdown - to hot standby condition" and "obtain NRC permission prior to return to power operation". 21. A0P-21.0 Severe weather - a. Symptoms 2.1 and 2.2: These procedure entry symptoms included tornado warning and 24 hour forecast of winds in excess of' 89 . mph. The control room -_had no formally established source of- such weather information, and did not routinely receive weather
- l
forecasts. l. - ? - , I
y- ' - i . C ,. , [ 56 b. Step 5.11: This step stated: " Consider placing both units in mode 3 two hours prior to sustained ' winds in excess of 89 mph reaching the plant site." It did not require operators to shut down the units, and did not give guidance on what f actors to consider. The offsite power transmission ~ 11nes were not l! designed to withstand winds in excess of 89 mph., therefore L ~ off site power would likely be lost if expcsed to. such high' winds. g[ 22. A0P-22.0 Flooding of the river water structure a. No comment. 23.~ A0P-23.0 Plant computer malfunction (SPDS) a. Step 5.1: This step did not contain sufficient information to ' indicate that procedure STP-37.0 had to.be implemented within one hour cf the plant computer becoming inoperable. 24. A0P-24.0 Loss of RCS flow with solid plant condition- a. Step 5.3.4: This step did not identify the various gauges and instruments necessary to identify system pressure,' temperature, . flow, etc, This inadequacy prevented completion of.this step. 25. AOP-25.0 Condenser tube leakage a. Step 5.1: This step stated " Determine if an actual condenser tube leak exists. . ." The use of "if" following " determine" was- eliminated from other steps lin the FNP E0Ps, for~ example, step 24 of EEP-1. Justification for - that elimination -was stated as' follows: " Deleted use of the term 'if' since its usage'has been restricted mainly as a logic term." b. Step 5.1.1: This incorrectly structured an action step by using- the gerund form of a verb. p c. Step 5.1.2: Same comment as step 5.L 1 above. L ' d. Step 5.2: This step was incorrectly split between two pages. e. Step 5.2.1: This step incorrectly contained two distinct actions, f. Step 5.2.4. note: This note incorrectly used the form .of. continuously applicable conditional logic steps, g. Step 5.2.5.1: Same comment as step 5.1.1 above, b. Step 5.2.5.2: Same comment as step 5.1.1 above. , i_
-%.. . ,. 5'
- .-.
1
, 7 , 57 l l < i.
- Step 5.2.6: This step deviated from writer's guide requirements
l 'for transition terms.
, J. Step 5.2.8: This step deviated from writer's guide requirements
for a continuously applicable conditional step in the sentence beginning " Maintain'." In addition, it deviated from writer's ! guide- requirements for transition. . terms, . and include. two- distinct action steps. , k. Step 5.3.4: Same comment as step 5.2.6 above. , 1. Step 5.3.5.1: Same comment'as step 5.2.6 above. m. Step 5.3.5.2: Thi s step deviated from . riter's guide w - requirements for conditional logic steps. In addition, it incorrectly' used passive voice. -! n. Step 5.4.1: This step included two actions and incorrectly
included one action step within parentheses. , , o. Step 5.4.3: This step included two distinct actions. i i p. Step 5.4.4: Same comment as step 5.2.6 above, i q. Step 5.4.6: This ' step contained incorrect punctuation of: an - acronym and included two distinct actions. . r. Step 5.4.9: Same comment-as step 5 2.6 above. < . s. Step 5,4.10.1: This step deviated from writer's . guide ' requirements for continuously. applicable logic statements, j . t. Step 5.13: Same comment as step'5.12 above, l 26. A0P-26.0 Main turbine DEH system malfunction a. No. comment.
27. AOP-27.0 Emergency boration a. . Step 5.4: This step lacked a page number to aid access to the- + referenced table. b. Step 5.5: Thi r, step included a reference to technical Specifications but failed to indicate the number. ' c. Step 5.5.2: This step was an incorrectly structured conditional r action step. d.- Step 5.6: -This step deviated from writer's guide requirements for transition terms. , I '> d e-
T
, _ _ .-. __ . _ _ _ _ .. .
. 58- , e. Tab 1'e 1: This ~ table included references to . technical specification ~and boron tables but f ailed to. indicate the,
relevant number for either. 28. AOP-28.0 Control room ' inaccessibility a. Step-5.4.3: This step included actions located at both HSP-A and HSP-C. - An- unmarked-- tripping hazard was noted between the'- location of these.two panels. b. Step 5.5:. This step deviated from writer's guide requirements for conditional logic steps. c. . Step 5.12.1 note: This note incorrectly included a conditional .' logic step out of the sequence of steps, d. Step 5.13: The substeps to this step lacked action. verbs, e. Step 5.17.9: This step included a typographical error in the word "Feedwater." f. Step: 5.18 note: This note was actually an action step incorrectly placed out of.the-sequence'of action steps, g. Attachments: No page numbers were indicated for the attachments to this procedure. h. Step 5.6: This step deviated from. writer's guide requirements for transition terms. 29. A0P-28.1 Fire.or: inadvertent fire protection system actuation- .in the cable spreading room a. Step .5.5: Attachment 13 did not establish clear lines of communication between the Hot Shutdown Panel area and the remote locations of manual actions. b. Step ' 5. 7.1 :.. Labeling in this step was inconsistent with the . panel, c. Step 5.7.2: Switch design was inconsistent with similar- switches for similar equipment on other parts of the panel, ' d. Step 5,8.1 note: This note contained required operator actions.- e. Step 5.9: The scales on adjacent opposite train instruments had different point size' fonts. ' f. Step 5.9.6: This step required steam generator pressure control of 1005 psig on an instrument with an inappropriate scale.
, y - - - - - - 4 ., . . -
, . I h 1 59 i g. ' Step 5.11.2: This step required. the simultaneous closure of three main steam isolation valves which was. not physically possible. ' h. Step 5 13: Loss of site power was not denoted as Loss . of , offsite power or LOSP. . i. Step 5.14.6.2: This' procedure step did not identify the location of the controls for: the reactor vessel head vent ^ valves. Additionally, it introduced contaminated material into l the atmosphere in the vicinity of CVC-MOV-8808A, B and; C which ! ' must be locally operated in step 6.10. j. Step 5.14.7: This step required pressurizer pressure control between- 2220 and 2300 psig on an instrument with an inappropriate scale. - k. Step 5.15 note: This note indicated that incore thermocouples ' should be monitored as another means of determining T-hot. There was no clear method for accomplishing this. _Addi ti or. ally ,
required operator actions were contained in this note, j 1. Step 5.17.1: This step required that proper hot standby conditions be verified by observing RCS -wide. range temperature ! (T-hot) without defining proper hot standby conditiens.
i m.- Step 5.17.2: This step required- that proper . hot standby conditions be verified by observing RCS wide range temperature (T-cold) without defining proper hot standby conditions.
n. Step 5.17.3: This step required that Nuclear power decreasing I conditions be determined. The instrumentation available was not 4 capable of easily indicating a decreasing power range. The [ appropriate requirement would be the determination of sub power- 1 range level. 1 o. Step 5.17.7 note: This note - required that, to obtain a CST level greater than 11 feet, a tygon hose be attached to the drain valve Q1P11V508. The drain valve-was behind a five foot high concrete wall without permanent access. The tygon hose connections were not available, - and instructions for . attaching the hose or measuring the CST tank level was not available. -The ! opergtors interviewed were not aware of the tygon hose storage .l location. Additionally, required operator actions were contained in this note, p. Step 5.17.7 caution: Required operator actions were contained in this caution statement. .. .
7.. p-. , .- hy 60 q. Step 5.17.7: This step required that the condensate storage tank level be measured and that the level be determined to be a minimum level of 5.3 feet. The condensate storage tank level , gauge did not have evenly spaced divisions between the foot ' marks. It was not clear where the indication for 5.3 feet was
located, r. Step 5.17.9: This step required that the pond level be determined locally. The scale used on the measuring device hed a unique scale that had five divisions per foot with the third '
division mark between the foot marks elongated.
~ s. Step 5.24.1: This step required the determination of the required boron concentration for hot standby; however, the core burnup (MWD / TON) was not available. Appropriate instructions for boron concentration calculations were not included at this step. t. Steps 5.24.1 and 6.1.1: These steps refer to the curves required to calculate boron concentration; however, these curves were referred to by different titles. u. Steps 5,24.2, 5.24.8, and 6.1.8: These steps all refer to a required sample of the RCS for Boron; however, the steps were worded differently. v. Steps 5.24.5 and 6.1.5: Same comment as step 5.24.2 above, w. Steps 5.24.7 and 6.1.7: Same comment as step 5.24.2 above. , x. Step 6.3.1: This step does not provide instructions for the preparation for containment entry. y. Step 6.3.3 caution 1: This caution wes not formatted in the same manner as the other caution statements in this procedure, z. Step 6.3.3 caution 2: This caution contains actions that are [ not contained in procedural steps. There was no direction on where or how to determine the number of running CRDM fans, aa. Step 6.3.3 caution 3: This caution was not positioned directly prior to the step to which it was applicable, A
- "'
-; . , -4 61 e ab. Step 6.3.4: This step did not contain instructions on hsw to accomplish it's action from outside the main control room. ac. Step 6.4: Same comment as step 6.3.4 above, ad. Step 6.7: Same comment as step 6.3.4 above, ae, steps 6.11.1 and 6.11.2: These steps contained the terminology "towards approximately", this terminology is in conflict with guidance provided in NUREG 0899, 30. A0P-28.2 Fire in the control room a. Step 5.7.1: Labeling in this step was inconsistent with the panel, b. Step 5.7.2: Switch design was inconsistent with similar switches for similar equipment on other parts of the panel, c. Step 5.8.1 note: This note contained recuired operator actions, d. Step 5.9: The scales on adjacent opposite train instruments had different point size fonts. e. Step 5.9.6: This step required steam generator pressure contros of 1005 psig on an instrument with an inappropriate scale. f. Step 5.11.2: Thi s step required the simultaneous closure of three main steam isolation valves which was not physically- possible, g. Step 5.13: Loss of site power was not denoted as Loss of offsite power or LOSP. h. Step 5.14.6.2: This procedure step did not identi fy the location of the controls for the reactor vessel head c .' n t valves. Additionally, it introduced contaminated materu into the atmosphere in the vicinity of CVC-MOV-8808A, which must be locally operated in step 6.10. 1. Step 5.14.7: This step required pressurizer pressure control between 2220~ and 2300 psig on an instrument with an inappropriate scale. J. Step 5.15 note: This note indicated that incore thermocouples should be monitored as another means of determining T-hot. There was no clear method for accomplishing this. Additionally, required operator actions were contained in this note. l = _ _ -
p a , p :< ,
- , ;
, , , l' '
, 62'
, , T i j [' . . . - . st'andby. 1 - k. . Step 5.17.1: This . step required that proper hot . conditions. be verified by observing' RCS wide range temperature . ' (T-hot)--without defining proper hot standby conditions. 1 1. Step 5.17.2: This step required that propert hots standby
conditions be verified by observing RCS wide range temperature _: (T-cold) without defining proper hot standby conditions. l .> m. Step 5.17.3: This step required that Nuclear power decreasing. '! conditions be' determined. The instrumentation available was not t capable of easily indicating . a decreasing power, range. -The. appropriate requirement would be the' determination of sub -power
range level.
n. Step 5.17.7 . note: This note- required that, to obtain a CST level greater than 11 feet a tygon hose be attached to'the drain'
valve Q1P11V508. The drain valve was behind a five : foot high ' -concrete. wall wittout permanent access. - The ~ ltygon. hose connections were not available, and-. instructions for attaching j the hose or measuring the CST tank : level was' not available. The - cperators interviewed were not aware of the tygon- hose storage location. The equipment was stored in_ the - large equipment j cabinet, which was located in the fire' area that was abandoned - when this procedure was 'in effect. Additionally, required' . operator actions were contained in this note. . o. Step 5.17.7 caution: Required-operator actions were contained - in this caution. statement. p. Step '5.17.7 : This step required that the condensate storage ~ t tank level be measured and that the ~1evel be determined to be ~a 4 minimum level of 5.3 feet. The condensate' storage tank level . gauge did not have evenly spaced divisions between- the foot - marks. It was not clear where the indication for 5.3 feet was - located, q. Step 5.17.9: This step required that the pond level be- ! determined locally. The scale used on the measuring device had i ' a unique scale that had five divisions per foot with the third division-mark between the foot marks elongated. r. Step 5.24.1: Thi s step required the determination of the i , required boron concentration for hot standby; however, the: core burnup (MWD / TON) was not available. Appropriate instructions for boron concentration calculations were not included at this_ step. s. Steps 5.24.1 and 6.1.1: These steps refer to the curves required to calculate boron concentration; however, these curves were referred to by different titles. . $w
_ _ - - _ - ' { i. -,e
. lsh 1 -* 63 , c 1 . . -
t.- ' Steps 5.24.2, 5.24.8, :and 6.1.8:' These~ steps all- refer: to a - required sample of the RCS for Boron; hcwever. the' steps were i 1
- .
worded differently, i u. Steps 5.24.5 and 6.1.5: These steps fconveyed : identical' (
- instructions; however, the steps were worded differently.
v. Steps 5.24.7 and 6.1.7:1 Same comment as step 5.24.5 above, w. Step 6.3.1: This . step does not provide instructions . for the- preparation for containment entry, d a a" x. Step 6.3.3E caution 1: This . caution was not formatted in the.
same: manner as-the other cautions in this procedure.- y. . Step 6.3.3: caution 2: This caution contains actions that are ' " - not contained in procedural steps. There was no direction on- where or how to determine the number.of running CRDM fans.- 3 a' z. Step 6.3.3 caution 3: This caution was.not positioned directly prior to the step to which it was applicable. aa. Step 6.3.4: This step did not contain instructions on how to-
accomplish it's action from outside the main 'contro11 room. r 31. A0P-29.0 Plant fire . '
v
- i
a. Appendix 1, Step 1.1.1: This step required operation ofEservice water valves Q1P16V539 andLQ1P16V538, service water headers.A and. B recirc to the pond. ' The valves were located in- unit- 1 valve boxesu 2A and: 2B, approximately- 10 feet above thelfloor. There were.no ladders nearby for' access to:the: valve; operators. M The only, available way to; reach the valve -operators involved
' walking on a wet, slippery pipe approximately 10 feet.above the ~ floor with no catwalk and no handrail or other handholds.' ' , b. Appendix 2, Steps 1.3 and 1.4: The locations of valves- 4 -QSP16V505 and QSP16V506 were not stated. Some. operators - had
- "
difficulty' locating them. c. Appendix 4, Step 1.3: The location . of 1-CVC-LCV-115D was not : I stated. One-operator had difficulty locating it. ! , d. Appendix 4,. Step 2.3 and Appendix 6, Step 4.2: These-steps I required isolating and venting air to the main steam atmospheric - , L "' relief valves, in the main steam valve room. These air valves s were not well marked and were difficult to locate. i . - b v n i
pm - - 1. ,. ~ , ! n' f 64- i ' ' 6, Step 4.3: These steps e. Appendix .4, Step 2.4. and Appendix -
- .
required' operating the: main steam atmospheric relief _ valves; by ' using the local handwheels, in the main steam valve room. Some operators stated that there was not adequate physical access to . two-00 these valve handwheels for an operator to safelly operate ? them in this abnormal procedure: 1-MS-PCV-3371A and ' 1-MS-PCV-33710, ?< . f., _ _ Appendix- 6, Step 2.0: This step - contained -a - list-_ of ' instrumentation that could ' potentially -initiate a spurious protective action signal. The list included condensate storage L tank level, which was not included in the similar list .that appeared in Appendix 5, Step 6.0. tin' addition,- the list did not - n include RWST level, g. Appendi~x 6, Step 3.3.2: This step required operation of valve N1P19HV3611. In the. plant, this valve was numbered.Q1P19HV3611. h. -Appendix 10, Step 1.3.1: This step . required verifying that- switches SV2213B and: SV2214B were in NORMAL. The switches had- only two-positions: CLOSE and OPEN. . j . 1 .i . ~ Appendix - 10, Attachment 1, Step 1.2.1: Valve 1-RHR-MOV-8888A~ .l - .
- had no nametag.
4 j. Appendix 10, Attachment 1,. Step 1.6: This Ptep had I&C operate O RHR system -valves; the heat exchanger discharge and the heat- exchanger: bypass. Operation of these valves could affect RCSL temperature and . these. required appropriate- prior ' operational- training. In addition, the step. did not identify- the- equipment - l that I&C needed to take.to the RHR heat exchanger room.- I&C j personnel had no prior knowledge that' these~ I&C action steps ~ ]{ were in an A0P. > 32. A0P-29,1 Plant stabilization in hot standby and cooldown j without "A" train AC or DC power j i a. Step 5.0: This step did not properly title the secti_on d " subsequent operator actions". ' i b. Step 5.3: This step verified pumps running and proper CVCSi j valve alignment but it did not verify adequate seal injection -! , , ~ " flow" to the RCPs. H c. Step 5.5: This step verified pumps running and proper SW valve li alignment but it did not verify SW " flow" to auxiliary and t diesel building loads. . d. Step 5.9.3: Neither this step nor the specified attachment ! contained locations of the air supply isolation valves. ! ,
p, j o 'h le>
l _. ' ' y , i i 2 4 F 65' ' 'l-- ji -i ' e.- . Step 5.10.6: Same comment _as_ step 5.9.3 above. c: , f. . Step 5.10.8: This' step failed to describe actual -valve operation.from the emergency air:: compressor area. !
g. Step 5.13.2: Logic _ statements were used improperly, ! > , 1 k, n.. Step 5.13.5: -Same comment as step:5.13.2 above. , 1 g 1. Step 5.'13.6: Same comment as step 5.13.6'above.'
- i
m , J. Step 5.14.2.3: This , step was an ' intentional breach 'of L he RCS : ' t boundary and 'would. have created- contamination problems for the. g operators upon ' containment entry (step. 5.23) and when they- need ' to' isolate the accumulators (step 6.13). 4 k. Step 5.15.2.2: This step contained 2 separate actions ' -
" alignment of nitrogen to the PORVs" and " cycling: of the : PORVs >; tol reduce RCS pressure". l 1. Step 5.17.3: .This step did not contain_an action verb. y m .- : Step 5.17.4: Same comment as step 5.17 3 above. . a n. . Step 6.1.2: Thi.s step did not specify one' specific-reference. 1 o.-- Step 6~6.3: TSLB3 7-1, 7-2 and 7-3-lacked descriptors. . J p. Step 6.9.2: This step contained logic " maintain"/ "otherwise", q- . Step 6.10.1: Instruments 11sted for _" trending data" would .not' ,; ' provide.a trend unless'the operator took note.of the listed S/G ' ' 4 ~ pressure instrument readouts ontat 1 cast two different occasions q or " points in time". ! i r. Step 6.11.2: '!Stop" was not a logic _ term. This step contained two - separate actions " continue with: step 6- 12" and ' stop - . - cooldown with RCS 51200 psig and 350-degrees F". ]'t s. Step 6.12.1: This step contained two logic _ statements and two 4 - separate action areas, t. Step 6.15: This step contained two separate actions - "stabi11zation of RCS' pressure" and " establishing _ RHR". j .. 33. A0P-29.2 plant stabilization in hot standby and cooldown without "B" train AC or DC power a. Step 5.0: This step did not properly title the section l " subsequent operator actions". 4 ' m
_ - _ . . . . . . . . . . . _ .
- o;
J. : 66 b.- Step 5.3: This step verified pumps running and proper CVCS valve alignment but it did not verify adequate seal injection " flow" to the RCPs. c. Step 5.5: This step verified pumps running and proper SW valve alignment but it did not verify SW " flow" to auxiliary and diesel building loads. d. Step 5.9.3: Neither this step nor the specified attachment contained locations of the air supply isolation valves, e. Step 5.10.6: Same comment as step 5.9.3 above. f. Step 5.10.8: This step failed to describe actual- valve operation from the emergency air compressor area, g. Step 5.13.2: Logic statements were used improperly, h. Step 5.13.5: Same comment as step 5.13.2 above. i. Step 5.13.6: Same comment as step 5.13.2 above. j. Step 5.14.2.3: Tt.is step was.an intentional breach of the RCS boundary and would have created contamination problems for ;the ~ operators upon containment entry (step 5.23) and when they need. to' isolate the accumulators (step 6,13). k. Step 5.15.2.2: This step contained 2 separate actions - " alignment of nitrogen to the PORVs" and " cycling of the' PORVs- to reduce RCS pressure". 1. . Step 5.17.3: This step did not contain an action verb. m. Step 5.17.4: Same comment as step 5.17.3 above. n. Step 6.1.2: This step did not specify one specific reference, o. Step 6.6.3: TSLB3 7-1, 7-2 and 7-3 lacked descriptors. p. Step 6.3.2: This step contained logic " maintain"/ "otherwise", q. Step 6.10.1: Instruments listed for " trending data" would not provide a trend unless the operator took note of the listed S/G pressure instrument readouts on at least two different occasions or " points in time". r. Step 6.11.2: "Stop" was not a logic term. This step contained two separate actions " continue with step 6.12" and "stop cooldown with RCS 51200 psig and 350 degrees F". s. Step 6.12.1: This step contained two logic statements and two separate action areas.
--........-l-...'.'i....' ' ' - '" ' ' ' " " ' " - " ' - - " " ' " " " ' - - ' ' ' ' ..
- .-
67 t. Step 6.15: This step contained two separate actions - " stabilization cf RCS pressure" and " establishing RHR". 34. A0P-30.0 Refueling accident a. Step 4.1: This step used the word " decrease" which was not allowable by the writer's guide, b. Step _ 5.1: This step used " consider" in reference to possible actuation ~of the plant emergency alarm. c. Step 5.6: Use of the words, "as necessary" was confusing and unnecessary, d. Step 5.7.1 caution: This step made no reference to possible use of AOP-12.0, "RHR System Malfunction". e. Step 5.7.4: The actions contained in this step conflict with - previous actions contained in step 5.4. f. Step 5.7.5: Same comment as step 5,7.4 above, g. Step 5.-10: This step contained two separate actions " sampling of refueling cavity and SFP water" and " operation of the SFP - cooling and purification system". 35. A0P-31.0 Loss of service water pond a. Title: The title was inappropriate to the content. Actions contained in the procedure noted actions which mitigated a loss of pond make-up water not loss of the SW pond, b. Steps 3.3.3 and 3.3.4: This step referred .to -valves contained inside welded valve box areas. Access to_ these valves for _ possible manual operation during an emergency would be. hampered. c. Step 5.1: This step called for verification actions which could prove to be difficult. d. Step 5.3.4: This step included an unnecessary reference to FSAR section 9.2.1.3. e. Step 5.4: This step included unnecessary references to FSAR sections 2.4.14.1 and 9.2.5.3.B. f. Step 5.5.8: This step included an unnecessary reference to an ApCo letter, g. Step 5.5.9: This step included an unnecessary reference to an Southern Company Services letter. 1 . . . _ _ .
, - e ., 'f 68- h. Step 5.7: This step contained two separate actions - " verification of SW flow not exceeding river water flow to the pond" and " reduction of SW cooling system requirements". 1. Step 5.8: This step did not clarify the term " extended amount of time". Also, this step did not identify what " temporary pumps" or " tankers" were available as a back-up to the river water source. 36. AOP-32.0 High reactor coolant activity a. Step 5.4: Thi s step did not specify specific areas to' be surveyed in the containment & auxiliary buildings, b. Step 5.6: This step did not specify the sampling paths. c. Step 5.7: The logic word "not", in this step, was not capitalized. 37. A0P-33.0 High activity - radiation monitoring system a. Step 3.0: This step deviated from writer's guide requirements for conditional logic steps, b. Step 5.5: This step deviated from writer's guide requirements for transition terms, c. Step 5.8: Same comment as step 5.5 above. d. Step 5.12: This step included two conditions that were incorrectly numbered as action substeps. 38. AOP-34.0 Malfunction of RCS wide range pressure indication a. Step 5.1 caution: This caution contained only ." note" information and the caution apptared to be used for emphasis, b. Step 5.1: This step contained two separate actions "use of appropriate figure" and "use of F1-943 or FI-940 for determination of flowrate". 39. AOP-35.0 Loss of main control board annunciators a, Subsequent Operator Action: This procedure did not use nor refer to FNP annunciator response procedures. b. Step 5.2 caution: This caution was not clear as to why it was being used, c. Step 5.2: This step was unclear as to what would be a normal & what would be an abnormal condition (status). -- - _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ - - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ ___- _ ____-_ - ________ - ____________ ___ _ _ -___ -
I"~' mo ; . p. l t L - APPENDIX C WRITER'S GUIDE COMMENTS -This appendix contains writer's guide comments and observations. Unless specifically stated, these comments were not regulatory requirements. However, the licensee acknowledged that the factual content of each of these comments was correct as stated. The licensee further committed to evaluate each comment, to take appropriate action and to document that action. These items will be reviewed during a future NRC inspection. r ( I ~. Inadequacies in the E0P writer's guide- t E The Farley' E0P writer's guide did not thoroughly address each aspect I of the procedures nor did it define restrictively those aspects of ( the E0Ps that were addressed. In addition, some of the guidance contained in the writer's guide increases operator difficulty in understanding the E0Ps.
A. Non-restrictive writer's guide The Farley E0P writer's guide qualifies many aspects of the E0P structure tscribed within. For example, "As a general rule, caution L statements should not contain - any directed operator - actions. . ," k' check off lines "...may be provided for individual items listed under 4 a ' step or substep heading. . ."' "In general, (abbreviations and- acronyms used) will be limited to a well defined and understood set." This lack of- requirements results in variations in structure when procedure writers come to different conclusions- about adherence to the writer's guide. The Farley E0Ps include numerous inconsistencies due to ' lack of adherence to the writer's guide. Farley operators expressed concern about variation in the way. steps are written and could not clearly explain reasons for some of the variation in structure found in the E0Ps. B. Incomplete E0P writer's guide Aspects of the E0Ps that are not addressed in the Farley E0P writer's guide must t,e written according to the preference and judgment of the writer. As a result, inconsistencies are introduced into the- E0Ps- and the number increases over time. The Farley E0Ps reflect numerous inconsistencies at present. The following aspects of E0Ps are examples of items not addressed or not fully addressed in the text of the Farley E0P writer's guide: recurrent steps time dependent steps or continuously applicable steps diagnostic steps
' s o; 2 structure of action substeps structure of component lists placement of checkoff spaces method for splitting steps between pages only if the steps are . longer than one page method for indicating that steps are continued on next page when they are split between pages method for using AND and OR in the same sentence when it is unavoidable end an-example of this rationale for numbering or not numbering substeps use of auxiliary verbs expected rerponse format definitions of words commonly used and approved, for example: manually, locally and remotely inclusive list of acceptable action verbs inclusive list of acceptable acronyms and abbreviations specifying only one meaning for any acronym and representing any -expression by only one ccronym list of terminology to be avoided, including abbreviations for simple expressions, abbreviations - that are similar to each other,-and abbreviations that are complete words method for eliminating the need for page rotation discussion of the location.of the E0Ps in the control room and the techniques that will be used to differentiate E0Ps from other plant procedures a method for easily locating different parts of the' procedures, such as a table of contents or tnumb tabs between attachments C. Incorrect E0P writer's guide While many variations in procedure structure are possible, procedure design that fails to draw clear distinctions between different types of steps or different terms will make the steps more difficult for operators to understand due to the need to interpret the meaning of a format or a word in the step at hand. For example: , a un
14 , 3 , , 1. The Farley E0P writer's guide allows the use of conditional- logic sequences and passively worded operator actions in cautions and-notes. This practice has several potential risks. First, it increases the number of cautions and notes thereby . increasing the likelihood that the cautions and notes will be overlooked. Second, operators are trained to expect action steps to be numbered and located in sequence in the left hand column and RNO column of the procedure. Interviews revealed operator difficulties with the inclusion of actions in_ cautions and notes in the Farley E0Ps. r 2. The Farley .EOP writer's guide allows the' use of parentheses. However, it fails to limit. or restrict' the use. As a result, the Farley E0Ps include numerous examples of parentheses used to include information in a form other than that designated elsewhere- in the writer's guide. - For example, conditional statements can be found in parentheses within component- lists, increasing the complexity of the steps as well as making them more difficult to understand. 3. The writer's guide directs- writer's to use sentence fragments. Complete sentences are much more precise and easily understood -than fragments. The writer's guide also states that common American English Structure will be used. 'his necessitates the - use of complete sentences. II. Inadequacies in the AOP writer's guide With the exception of requiring single column as opposed to two column structure, the Farley writer's guide used for AOPs is extremely similar to the E0P writer's guide and contains the same weaknesses. In order to assure that- Farley A0Ps are written and maintained in a consistent manner, FNP-0-SOP-0.2 requires the same changes described above for the E0P writer's guide. . !
y - - [) ty: %:
^ , . e , 1 APPENDIX'D- NOMENCLATURE ' , h % s' _ appendix ' contains basic' ' plant nomenclature weaknesses. For_ example , . , instances where writer's - guide application to the E0P would cause'the~ ricader to: expect annexact nomenclature match with component nomenclature, yet there- ' . as no match. :lt also includes : instances where a complete match was neither w -required. nor found and the mismatch or lack of label'was sufficient to cause: concern. In addition, inadequate labeling methods -such as Jse of dymotapefor- - hand written labels was noted. The-licensee agreed in'each-case to evaluate. ~ - ? the'~ problem and makei the - appropriate changes. These items -will be' reviewed -during a future NRC inspection. Procedure Step /pg'. E0P nomenclature Component nomenclature- EEP-0 B.'II.18 Au+, Stop 011 TURB AUT0'STOP 14/14 MS-HV-33698 handwritten-label RNO 21.2/28. SPR VLV PK-444C dymotape-~ CLOSED label'- .. 1 SPR VLV PK-4440 dymotape CLOSED label 'l 32/34 R-03 RADIO CHEM LAB ' label for R-03 missing 38.2/38 DE03 -label missing , d .EEP-1 13.3 DE03 '
- .I -15.2 R-03
Attach. CVC-MOV-8132A .CVC-MOV-8132A- A - p 1 CVC-MOV-8886 CVC-MOV-8886A-A- a ! I CVC-MOV-8808A CVC-MOV-8808A-A - u q ' CVC-MOV-8808C CVC-MOV-8808C-A CVC-MOV-8130A CVC-MOV-8130A-A j CVC-MOV-8131A CVC-MOV-8131A-A I CVC-MOV-8133A CVC-M0V-8133A-A f CVC-MOV-8132B CVC-MOV-81328-B . . l
. . - m [Ih, ; ...,. ' . 4
_ ' ,p ~ h.in' _ 5 ' , , , - , >b' i jl. m, .. 4 4 4 f i I 3 .- ~; _ ~ > . I
- R' R-NOV-8889B-B -
~ ~ (, --RHR-MOV-8889- H - s CVC-MOV-8884 CVC-MOV-8884B-B-- Y>' CVC'-MOV-8838B - CVC-MOV-8808B-B h. - CVC-MOV-8130B iCVC-MOV-81308-B g CVC-MOV-81318- CVC-MOV-8131B-B w ~
- CVC-MOV-8133B-
CVC-MOV-8133B-B: g .. ~EEP-3: 3 . 6 . 61 'LCS HP GLAND LCS-HP. GLAND SVPPLY' <1 lRN0/7 SUPPLY BY-PASS MOV: SHUT 10FF MOV b' 8.3.2 INST AIR SUPPLY CNMT INST AIR 4 -RN0/14 .T0.CTMT' ~ SUPPLY VALVE- 'k " 8.3.3 -PRF RECIRC FAN PENE RM RECIRC FAN: ' -RN0/14- > .,: 12.3/22 CONDENSER COND AVAIL- - F:: AVAILABLE d w . LESP-0;-1 1.1.1- PK-464 controller dymotape CLOSED labeli n< .RN0/2 adjusted closed. I OPEN not labeled PC-3371A: also labeled as.3371AA . controller adjusted closed- .
CLOSED not-labeled- q OPEN not labeled- O d PC-3371B -dymotape. CLOSED label- O controller adjusted close'd' .0 PEN label size < s C*, inconsistent with' PC-3371A (C) labels
- i
PC-3371C- dymotape CLOSED 1abel~ '; controller adjusted closed y
- i
' ' no OPEN label i $ .i ~h4 i i r > 1 , ,. 1 f l . 1 s ' Og _
aw - -
- s
.' - - , . r ' ' s " + 4
- ,
!^$Qj kJ9lI.g . g, Ng ' ' - l 4
, . , . _ 4[ ~ '> ' 3. !
.: .:{ , - 1.1.2. - MSRs RESET RESET: worn off G
- RN0/3- , _
- t
3.1- 'A TRN. - Reactor. trip l breakers: ! - - not' labeled by train- , . - si B TRN. Reactor trip breakers not labsled by train? H , g ' i
- 6'1.1 'DF08 11 legible due'toldusti . ' RN0/11 _ -. . . , , , DH07 illegible due toidust a - 4 + ' i.11egible,due to dusti ,j DF13 . 7.1. 4 CHG FLOW- - handwritten OPENilabel-
- i
-RN0/18. FK-122 d < ~ handwritteniCLOSE label "I - ' , e 211.2 sN-31 - N-31B'- -[ - < i 'N-32- N-32B
- - . 14
.;
,v- " 12.4 . RESET- worn off- -r 7 ESP-0,3 ~ RNO 1.1.1 LTDN ORIF ISO VLV . LTON 'ORI F 150' VLV . .- . 45(60) ... , ,g. u -r
- ESP-1.1
4.2 DE03 _
3 26.2 ~R-11- CTMT ATMOSPHERE: 9 ESP-1.3 Att. 1 -. closed .on/off'; on = clossd- N i l .c LECP-0'0- '5. 4.1 RNO - .B1F sequencer ECCS stop reset'... ' , . , , reset ...
_( ?- l' 14, table NA There.was no~.Llabel ?; 1H plate.for bkr. 9
.. ; ECP-1.1 19 2/22 FK-122 - handwritten OPEN label. .t . J handwritten CLOSE label: j , .24.1/26 FR-154B scales obscured with peni i markings t .F FR-154A scales ooscured with pen' j , markings ) . . ECP-3.3: 22 DE03
.
. ~I I - , 4 m te " + 1 t
-a .
- ..
]' 4 FRP-S.1 2.1 RN0/2 GV LOWER GV CLOSE FRP-P.1 3/7 HHSI flow SI FLOW TO COLD LEG HDR HHSI flow SI FLOW TO HOT OR COLD LEG RECIRC 13.1/24 PK-145 handwritten "open" on bottom of controller; handwritten "close" on- top of scale FRP-I.4 2.2 RNO- CONT AIR ... SERV CONT AIR AOP-11,0 5.3 Q1P16V539 Q1P16V539-A A0P-28.1 5.7.7 CHG/HHSI Pump IC CHG/HHSI PUMP IC HS3600CB-B Q1E21HS3600CB-R CHG/HHSI Pump 1B CHG/HHSI PUMP IB HS3600BD-B Q1E21HS3600BD-B CCW Pump 1A CCW PUMP 1A HS3307AC-B Q1P17HS3307AC-B CCW Pump 1B CCW PUMP IB HS3307DC-B Q1P]7HS3307DC-B 1 5.8.1 MDAFW FLOW CONT TO MDAFW, FLOW CONT. S/G 1A SG 1A AFW-HV-3227A AFW-HV-3227A MDAFW FLOW CONT TO MDAFW. FLOW CONT. S/G 1B SG 1B AFW-HV-3227B AFH-HV-3227B MDAFW FLOW CONT TO M')4FW FLOW CONT. S/G 1C SG IC AFW-HV-3227C AFW-HV-3227C 5.8.2 AFW-FCV03227A, B, BTRNSOLEN01DS FOR BTRN. C (B TRN Solenoids) MDAFW FCV's MDAFW PUMP IB DG10 MDAFW PUMP IB (HS-3305BC-B) Q1N23HS-3305BC-8 5.8.3 TDAFW FLOW CONT TO TDAFW FLOW CONT. TO S/G SG 1A AFW-HV-3228A 1A AFW-HV-3228A (HS-3228AC) (HS 3228AC) TDAFW FLOW CONT TO TDAFW FLOW CONT. TO S/G SG 1A AFW-HV-3228B 1A AFW-HV-3228B (HS-3228BC) (HS 3228BC) TDAFW FLOW CONT TO TDAFW FLOW CONT. TO S/G SG 1A AFW-HV-3228A 1A AFW-HV-3228A (HS-3228CC) (HS 3228CC)
b; ca. . 5 TDAFW PMP STM TDAWF PMP. STM. SUPPLY SUPPLY FROM SG 1B FROM S/G 1B STM, ADM. STM ADM VLV MS-HV- VLV. MS-HV-3235A/3226 3235A/3226 (HS-3304AC) (HS-3304AC) , TDAFW PMP STM TDAWF PMP. STM SUPPLY. SUPPLY FROM SG IC FROM S/G IC STM. ADM. STM ADM VLV MS-HV- VLV. MS-HV-3235B 3235B (HS-3304BC) (HS-3304BC) 5.9.2 FCV-3227A MDAFW. FLOW CONT. TO S/G 1A AFW-HV-3227A . FCV-3227B MDAFW, FLOW CONT. TO S/G i 1B AFW-HV-3227B FCV-3227C MDAFW, FLOW CONT. TO S/G IC AFW-HV-3227CL 5.9.3 TDAFW PMP STM TDAWF PMP. STM SUPPLY SUPPLY FR0e. SG 1B FROM S/G 1B'STM. ADM. STM ADM VLV MS-HV- VLV. MS-HV-3235A/3226 3235A (HS-3304AC) TDAFW PMP STM TDAWF PMP. STM,' SUPPLY. SUPPLY FROM SG IC FROM S/G IC STM. ADM. STM ADM VLV MS-HV- VLV. MS-HV-3235B 3235B (HS-3304BC) -5.9.4 HIC-3228AB TOAFW FLOW CONT TO S/G 1A~ AFW-HS-3228AB HIC-3228AB HIC-3228BB TDAFW' FLOW CONT TO S/G 1B AFW-HS-3228BB HIC-3228BB HIC-3228CB TDAFW FLOW CONT TO S/G IC AFW-HS-3227CB HIC-3228CB 5.9.5 LI-0477A A WR STM. GEN. 1A WIDE RANGE- LEVEL LVL. LI-0477A LI-0487A B WR STM. GEN IB WIDE RANGE LEVEL LVL LI-0487B LI-0497A C WR STM. GEN. 1C WIDE' RANGE LEVEL LVL. LI-0497C 5.14.3 PRZR HTR BACKUP PRZR HTR BACKUP GROUP IB GROUP 1B EC-11 N1B31HS3599BB-B ,
WMu~ .. .. ' ~ ' ' ~ - y; M X @s, % ' x! ' V j ,i t ' . sc u_ 3 .: -- r, , , 6 j r; 4 - - lj n Q1B13 HS 2213BC-B- 01B13HS2213BC-B j ' Q1813'HS 2214BC-B Q1B13HS2214BC-B: ' HS-3601 '. BB-B ' .Q1E21HS-3601BB-B t - >
4 , ' ' . zi Q1813 HS 01150C-B L01B13HS0115DC-D- !
- ,
$. Q1P17 HS 3047BC-B .01P17HS3047BC-BJ i 3.; (.z .5.14.6.1 'FCV-122 CVC-FCV-0122 ] , " . .. . .i 5.17.4 LI-0477A .STM. GEN. lA-WIDE RANGE. LVL. LI-0477A l n LI-0487A ST . G WIDE RANGE ,. ' LI-0497A "STM.? GEN.11C-WIDE RANGE: g^ ' LVL'. LI-0497C' n
- >
- !
- 5.17i7l- CONDENSATE STORAGE. CONDENSATE-STORAGE LEVEL g ' LEVEL Q1P11LIO515-A- , 6.2.1 'FCV-122 CVC-FCV-0122
, r.T 6.3.5 LI-0477A-A WR STM GEN. IA WIDE 1 RANGE
LEVEL- LVL'. -' LI-0477A - '; s ' -LI-0487A B.WR: STM.' GEN. 1B WIDE RANGE- - LEVEL
- LVL. 'LI-0487B'
u . , t LI-0497A'C-WR' STM. GEN.'1C: WIDE. RANGE- . -LEVEL LVL.-LI-0497C: ' q + ' -6.3.6 -CONDENSATE STORAGE' CONDENSATE-STORAGE LEVEL y LEVEL Q1P11LIO515-A 4 6.6.3 FCV-122
- CVC-FCV-0122--
' - lA0P-28.2 .5.7.7 CHG/HHSI Pumpf1C. CHG/HHSI PUMP-10- . u- HS3600CB B. LQ1E21HS3600CB-B ~ ' . .
-CHG/HHSI-Pump IB CHG/HHSI PUMP IB ' ' ' 'HS3600BD-B Q1E21HS3600BD-B
' CCW Pump 1A CCW, PUMP'1A - 'HS3307AC-B Q1P17HS3307AC-B CCW Pump 1B CCW PUMP'1B -r HS330700-B Q1P17HS3307DC-B . . . m. d ,
. . &
vi c ~ 4 ,
,~ (, ,
- vm
e , 7 -5.8.1 MDAFW FLOW CONT TO MDAFW, FLOW CONT. S/G 1A ' e' SG 1A AFW-HV-3227A. AFW-HV-3227A MDAFW FLOW CONT TO M0AFW. FLOW CONT. S/G 1B -' SG 18 AFW-HV-3227B AFW-HV-3227B MDAFW FLOW CONT TO MDAFW. FLOW CONT. S/G 10 SG IC AFW-HV-3227C AFW-HV-3227C '~ 5.8.2 AFW-FCV03227A, B, B TRN SOLEN 0 IDS FOR B TRN r C (B TRN Solenoids) MDAFW FCV's MDAFW PUMP IB DG10 MDAFW PUMP 18 (HS-3305BC-B) Q1N23HS-3305BC-B 5.8.3- TDAFW FLOW CONT TO TDAFW FLOW CONT. TO S/G SG 1A AFW-HV-3228A 1A AFW-HV-3228A + (HS-3228AC) -(HS 3228AC) , TDAFW FLOW CONT TO TDAFW FLOW CONT. TO S/G' , SG 1A AFW-HV-3228B 1A AFW-HV-3228B , (HS-3228BC) (HS 3228BC)
TDAFW FLOW CONT TO TDAFW FLOW CONT. TO S/G SG 1A AFW-HV-322A 1A AFW-HV-3228A (HS-3228CC)- (HS 3228CC) I TDAFW PMP STM TDAWF PMP.'STM. SUPPLY SUPPLY FROM SG 1B FROM S/G 1B STM, ADM. STM ADM VLV MS-HV- VLV. MS-HV-3235A/3226 3235A/3226 (HS-3304AC) (HS-3304AC) TDAFW PMP STM TDAWF PMP, STM. SUPPLY SUPPLY FROM SG IC FROM S/G IC STM. ADM.
STM ADM VLV MS-HV- VLV. MS-HV-3235B 3235B(HS-3304BC) (HS-3304BC) 5.9.2 FCV-3227A MDAFW. FLOW CONT. TO S/G 1A AFW-HV-3227A' FCV-32278 MDAFW. FLOW CONT. TO S/G I IB AFW-HV-3227B 5 FCV-3227C MDAFW. FLOW CONT, TO S/G 1C AFW-HV-3227C 5.9.3 TDAFW PMP STM TDAWF PMP. STM.~ SUPPLY SUPPLY FROM SG 1B FROM S/G 18 STM. ADM. STM ADM VLV MS-HV- VLV. MS-HV-3235A/3226 3235A (HS-3304AC)
,_ , 7 ., . QQ;$ p Me ' h "' 8 ' . K, 1 _TDAFW PMP STM - TDAWF PMP-. STM.' SUPPLY
- [ ' SUPPLY FROM SG IC FROM S/G,1C.STM. ADM. STM ADM VLV MS-HV- VLV!. MS-HV-3235B 1 -3235B --(HS-3304BC). r 5.9.4: HIC-3228AB TDAFW FLOW CONT TO S/G 1Ac AFW-HS-3228AB HIC-3228AB HIC-3228BB TDAFW FLOW CONT-TO S/G 1B; 'AFW-HS-3228BB HIC-3228BB- ' HIC-3228CB TDAFW FLOW CONT.'TO S/G IC AFW-HS-3227CB HIC-3228CB 5.9.5! LI-0477A A WR STM, GEN.~ 1A WIDE RANGE' LEVEL LVL. LI-0477A1 , LI-0487A B WR- STM.. GEN. 1B WIDE RANGE- LEVEL LVLL LI-0487B LI-0497A C WR STM.-GEN. IC WIDE RANGE LEVEL. LVL. LI-0497C . 5.14.3 PRZR HTR BACKUP PRZR HTR BACKUP'- i GROUP IB EC-11 GROUP IB p N1831HS3599BB-B Q1B13 HS 2213BC-B- Q1813HS2213BC-B. ', , + Q1813 HS -2214BC-B ' Q1813HS2L14BC-3- -HS-3601lBB-B, Q1E21HS-3601BB-B4 Q1813 HS 0115DC-B~ .Q1813HS0115DC-B- Q1P17 HS_3047BC-B Q1P17HS3047BC-B, ' 5.14'.6.1 FCV-122' CVC-FCV-0122 L ^ , 5.17.4 LI-0477A STM. GEN; 1A--
WIDE RANGE , LVL. LI-0477A' l . i 4 h LI-0487A STM. GEN.'1B WIDE RANGE-- , ~ LVL. LI-04878 LI-0497A STM. GEN. 1C WIDE RANGE o L, LVL. LI-0497C- , t 4 5.17.7 CONDENSATE STORAGE CONDENSATE STORAGE-LEVEL _j LEVEL Q1P11LIO515-A a . .I L
yvm . ,- - .- - -- , p ( Qi} , p . ":y, . - 3 , f?' ' f - y;> ) 9. jj @y ' g. , f },. . , '
, .c " ' - 6. 2.1.. .FCV-122i .CVC-FCV-0122i = :n ' - ' ~6.3.5- LI-047.7A . A .WRJ- 'STM'; GEN.11A' WIDE'RANGEk -l - p- LEVEL LVL LI-0477A l] . ' LI-0487A~B-WR , ,!STM.- GEN;~1B WIDE RANGE: < ,
- c
LEVEL LVL'. . LI-04878- . ' , . ..- 1 LI-0497A..C WR STM. GEN IC: WIDE; RANGE ~ An LEVEL ^LVL; LI-0497C- ,, 6.3.6 CONDENSATE STORAGE ' CONDENSATE'STORAGEELEVEL; LEVEL Q1P11LIO515-A-
. 6 '. 5 '. 3 FCV-122 CVC-FCV-0122- A0P-29- 1.1/ SW TO WET PIT SERV WAT.. EMERG'. .. , ::l .A2,1 EAST.HDR ISO RECIRC TO-POND-- ' 7 SW TO P9ND
- SERV:WAT EMERG
-EAST HDR ISO .RECIRC TO-POND- ' SW-T0 POND SERV;WAT EMERG- , -WEST HDR ISO- .RECIRC TO POND. - . SW TO WET PIT SW. EMERG :RECIRC-- l WEST HDR ISO- tT0. POND ' 7.1/ .CCW RETURN FROM~ CCWiFROM'RCPj , A6 ', 5 - .RCP THERMAL- THERM BARRL . BARRIER- > i- a" ' 1. 3.1/. B-TRAIN' HEAD LREACTOR: VESSEL'
- LA10,1 VENT
- HEADJVENT VALVE =
.w
MISCELLANEOUS CCW:TO SECONDARY:
HEADER. HXS
- e
2 - j ,, . t , , a ' 1 -1 y ' . < , a s
.lc j , e , % , 1 APPENDIX E . ABBREVIATIONS A0P: ' Abnormal Operating Procedure ' ' Alabama Power Company APCo- ' , ~AP- Administrative Procedure ARP- Annunciator Response Procedure , 'ATWT Anticip'ated Transient Without Trip - BOP . Balance of P14nt CE Combustion Engineering CSF . Critical Safety Function V CSFST Cr.itical Safety Function Status Tree - CTMT Containment DEH Digital-Electro 'ydraulic H E0P ' Emergency Operating ~ Procedure ERG Emergency Response Guidelines 'ERP Emergency Response Procedure < FNP Farley Nuclear Plant , FSAR Final Safety Analysis Report HP Health Physics HSP Hot Shutdown Panel I&C Instrumentation and Control IFI. Inspector Followup Item 'JD ' Justification Document LOCA- Loss.of Coolant Accident MCB Main Control Board m NI Nuclear Instrumentation NOVE Notification of Unusual Event PGP. Procedures Generation Package -PORC Plant Operations Review Committee a .PRIP' Penetration-~ Room Isolation Panel j PS-N Plant Supervisor-Nuclear PSTG Plant Specific Technical Guidelines PSTG DEV PSTG Deviation
- RCDT
Reactor Coolant Drain' Tank 'RNO Response Not Obtained RVLIS Reactor Vessel Level Instrumentation System SAER Safety. Audit and Engineering Review -SCM Subcooling Margin SER. Safety Evaluation Report SFP Spent Fuel Pool S/G - Steam Generator i SGTL' Steam Generator Tube Leak -j SGTR Steam Generator Tube Rupture i SI Safety Injection i S0P System Operating Procedure i SPD Safety Parameter Display
3PDS- Safety Parameter Display System - ' TPNS Total Plant Numbering System
TSC' Technical Support Center l- -V&W Verification and Validation 3 WOG Westinghouse Owner's Group ' o - . - . U }}