ML20043B486
| ML20043B486 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/23/1990 |
| From: | Hairston W ALABAMA POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9005300093 | |
| Download: ML20043B486 (5) | |
Text
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U c-Alabuma Power Company L
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- 40 Inverness Center Paraay Post Othee Box 1295 B6rmingham. Alabama 35201 Telephone POS 66Fb501 W. Q. Hairston,111 senior vice Prescent May 23, 1990 Nuclear Opershons Alabama Power tre scworn vectroc sprom I
Docket Nos. 50-348 50-364
}L U. S. Nuclear Regulatory Commission i
ATTN Document Control Desk i
Vashington, D. C. 20555 i
Centlement t
Joseph M. Parley Nuclear Plant NRC Emergency Procedure Inspection Identified Veaknesses In Inspection Report No. 50-348/90-02 and 50-364/90-02 f
By letter dated April 24, 1990 the NRC identified weaknesses in:
1)
The Emergency Operating Procedure (EOP) verification and validation program as evidenced by an inadequate steam generator tubo leak' procedure and control room design inadequacies.
I 2)
Two plant fire protection procedures as evidenced by hot shutdown (HSD) panel labeling concerns, inadequate guidance for shutdovn margin (SDM) calculatiun in the procedures, a requirement to make a containment entry subsequent to opening of reactor head vents, inadequate instruction for manually ccnnecting tygon. hose to the condensate storage tank (CST) for level determination, and storage of equipment needed for CST level determination in the fire area.
3)
An inadequate writer's guide for E0P's and inadequate implementation of the writer's guide.
Alabama Power Company concurs with the inspection report which states that the Farley Nuclear Plant emergency procedures are adequate to support safe emergency operation. The inspection report has been reviewed and those deficiencies needing immediate corrective action have been identified and corrective action completed. Those remaining deficiencies have been evaluated and corrective action scheduled as appropriate.
i The identified weaknesses vill be corrected as follows:
1)
The steam generator tube leak procedure is an Abnormal Operating Procedure (AOP) not included in the E0P verification and validation program. However, the procedure vill be revised by June 1, 1990 i
to provide additional guidance to the operators. The control room design deficiencies vill be evaluated and incorporated as necessary into the Control Room Design Review (CRDR) vork which 1
vill be completed on both units during their next refueling outages. It should be noted that the inspection report identifies i
9005300093 900523 PDR ADOCK 05000348 0-t
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U.S. Nuclear Regulatory Commission E0P Inspection Identified Veaknesses Page 2 a significant number of human factor issues (such as meter precision requirements for AOPs) which are beyond the scope of CRDR as agreed to by the NRC in a letter from the NRC to Alabama Power Company dated May 8, 1985 which discussed an in-progress audit of the FNP CRDR program. These issues vill be reviewed and evaluated but Alabama Power Company does not consider their resolution to be tied to the present CF.DR completion schedule.
The nomenclature differences between the fire protection A0P's and 2) the HSD panel vill be resolved by December 31, 1990. The information needed to determine boron required for achieving an adequate SDM has been placed at the HSD panel. AOP's which require containment entry subsequent to opening of the reactor head vents vill be revised by June 1, 1990. The AOP's which install a temporary tygon hose for CST level vill be revised to include additional guidance on the installation process and more guidance on measuring CST level.
The equipment necessary to measure CST level locally has been moved out of the control room.
All E0P's and A0P's vill be reviewed such tisat any equipment referenced by procedure vill be verified to be available in the proper location and capable of use with existing guidance. These reviews and any changes vill be completed by August 1, 1990.
3)
Concerns associated with the E0P vriter's guide and its implementation vill be evaluated and appropriate revisions vill be implemented by August 1, 1990. The E0P vriter and his supervision have been counseled concerning proper implementation of the vriter's guide.
Additional discrepancies not associated with a specific area of weakness have been grouped into 28 categories. The attachment provides a list of each general category and provides an estimated completion date for actions to be taken.
If you have any questions, please advise.
Respectfully submitted, td sh h
V. G. Ilairston, III VGil,III/mgd 18.1.34 Attachment cc: Mr. S. D. Ebneter Mr. S. T. Ilofiman Mr. G. F. Maxwell I
ATTACHMENT i
NRC E0P INSPECTION FINDING CATEGORIES VITH PLANNED ACTION 1.
Some justification of dif ferences are inadequate or not provided. All E0P differences vill be reviewed and the justification document upgraded as appropriate by November 1, 1990.
2.
Deviations froa writer's guide requirements. The writer's guides vill be revised by August 1, 1990.
All E0P's and AOP's vill be reviewed against their revised writer's guides. The E0P's vill be completed by each unit's next refueling outage completion. The A0P's vill be completed by May 1, 1991.
3.
Pailure to specify ROP mode applicability. Operators vill be instructed on E0P mode applicability by June 1, 1990.
E0P's vill be revised as appropriate when V0G procedures on Mode 4 and 5 are received.
4.
No caution to transfer to REP-0 on Safety Injection. This item vill be reviewed and procedures changed if needed by December 31, 1990.
5.
No R0P user's guide, rules of use not defined. An E0P user's guide vill be written by July 1, 1990.
Operators vill be trained on the user's guide by November 1, 1990.
6.
Place keeping aids rarely used. This issue vill be reviewed.
Guidance on place keeping vill be included in the user's guide by July 1, 1990.
-7.
Writer's guide inadequate concerning:
caution, notes, logic terms, transition terne. The writer's guide for E0P's vill be revised to give additional guidance on these areas.
In addition, the writer's guide for A0P's vill be upgraded. These activities vill be completed by August 1, 1990.
8.
Substeps written without verbs and/or step numbers.
Guidance on substeps vill be included in the revised writer's guides for E0P's and AOP's which vill be completed by August 1, 1990.
9.
Poor quality of operator aids - handwritten / poor copies. Operator aids vill be reviewed. Changes vill be made to ensure E0P's and A0P's are easily used by the operator.
E0P's will be revised by each unit's next refueling outage completion and A0P's vill be revised by December 31, 1990.
10.
Labeling outside control room not consistent with E0P's.
Procedures and/or labels vill be changed or replaced to ensure procedures are consistent with labels by completion of the next refueling outage for each respective unit.
- 11. Main Control Board labeling incorrect. Main Control Board labeling is being reviewed and vill be upgraded as part of the CRDR process.
Both units vill be completed during their next refueling outages.
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Attachment Page 2 i
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Main Control Board meters do not provide required accuracy. As part of CRDR, scales for meters and gauges are being evaluated and changes vill be made as appropriate. This will be completed during the next refueling outage on each unit.
j 13.
Annunciators are designated numerically both horizontally and l
vertically. Designation vill be changed to alphanumeric.
Procedure changes vill be completed during the next refueling outage on each j
unit.
14.
AOP-2, S/G tube leak guidance inadequate. These procedures vill be revised to provide additional guidance by June 1, 1990.
15.
Notification Of Unusual Event not required by Emergency Plan for i
J Technical Specifications required shutdown, contrary to NUREG-0654.
Alabama Power company has discussed this issue with the NRC previously and has received concurrence with the Emergency Plan as written. No changes will be made.
16.
AOP-2 not verified or validated. This procedure is an AOP not includeJ in the E0P verification and validation program. The writer's guide for procedures other than E0P's vill be revised to provide additional guidance to ensure these procedures are technict;11y correct and usable.
17.
AOP guidance for SDN calculation following plant fire inadequate. A copy of curve 61, SDH requirements, has been placed at HED panels.
18.
Containment entry after opening head vents required by A0P-28.1 4.
28.2.
A0P's 28.1 and 28.2 vill be revised as needed for containment entry concerns by June 1, 1990.
19.
CST level equipment and instructions for its use are inadequate.
A0P's 28,1 and 2832 vill be reviewed for accessory equipment needed and revisions vi?.1 be made by May 31, 1990. All A0P's vill be reviewed and revised concerning accessory equipment needs by August 1, 1990.
20.
SRR item - verification and validation should ensure operators are able to properly accomplish procedure. Alabama Power Company believes the current validation and verification program does ensure the usability of the procedures as demonstrated by the. audit team's determination that the procedures vere adequate to support safe operation.
However, the writer's guide revision for E0P's vill include a requirement that validation consider of.erator usability of the procedure. This vill be done by August 1, 1990.
21.
Transference of conditional statements is not being done when changing procedures. Guidance on conditional statements vill be included in the user's guide. All operators vill be trained on transference of conditional statements by November 1, 1990.
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Attachment Page 3 t
- 22. Training program should be revised to state classroom training on i
major revision to R0P's or new B0P's vill be used only as substitute if training on the simulator or the control room vill delay issuing I
the procedure.
Further the training program should state that simulator training should occur as soon as possible. The training program for E0P's vill be revised to state that classroom training vill only be used as a substitute when the introduction of a nev l
procedure or a major revision vould be otherwise delayed due to simulator or control room unavailability. This vill be completed by July 1, 1990. Training on the simulator vill be accomplished as soon j
as possible.
- 23. Training for non-Operations groups (RP, CHRM, 160) is not adequate.
All emergency procedure requirements for non-Operations groups have been identified. Group supervisors will be provided a list of their responsibilities by June 1, 1990.
Supervision vill ensure their personnel are familiar with their groups responsibilities by July 15, 1990. These responsibilities vill be incorporated into the appropriate training programs for these groups by December 31, 1990.
- 24. No formal near.s exists for R0P feedback from operators. A formel program to establish emergency procedure feedback vill be established by June 30, 1990.
25.
Local operations of R0P nctions may be hindered byr poor lighting, ladders /platforas not readily accessible, steam leaks in the Main Steam Valve Room. The above concerns vill be evelbated by July 1, 1990. Actions to resolve these concerns if needed vill be initiated by August 1, 1990.
26.
Foldout page is reprinted on each facing page of every R0P page. This is believed to be n strength of FNP E0P's.
No change vill be made..
27.
Page numbering system does not provide user an indication of how far e
the end of the procedure is. The page numbering system for emergency procedures vill be revised.
This will be completed during the next refueling outage on each unit.
- 28. Review of NRC specific procedure comments and similar deficiencies.
The individual specific comments vill be evaluated and disposition docuntated. For comments that are included as changes, the following completion dates have been established.
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July 1, 1990 User's Guide August 1, 1990 Vriter's Guide Next refueling outage for each respective unit.
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E0P's May 1, 1991 AOP's I
VGH,III/REHamgd 18.1.34
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