Text

Rev 1 to Emergency Operating Procedures Generation Package
	ML20094B162
Person / Time
Site:	Brunswick
Issue date:	10/31/1984
From:	; CAROLINA POWER & LIGHT CO.
To:	;
Shared Package
ML20094B149	List: ML20094B146; ML20094B162;
References
	PROC-841031, NUDOCS 8411070046
	Download: ML20094B162 (191)
	v • d • e

f CAROLINA POWdR & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT EMERGENCY OPERATING PROCEDURES GENERATION PACKAGE REVISION 1 4

8411070046 841031 PDR ADOCK 05000324 F

PDR

p ABSTRACT H

The purpose'of this document is to identify the elements used by Carolina Power E. Light Company's Brunswick Steam' Electric Plant to prepare and implement improved symptom oriented emergency operating procedures.(EOPs) for use ty Control Room personnel to assist in mitigating the consequences of a broad range of accidents and multiple equipment failures. This document applies only to the E0Ps'so designated; it does not address emergency preparedness or emergency planning.

i.

PGP Iade 2 of 20

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r TABLE.0F CONTENTS Section-

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. ABSTRACT......

2 A.

INTRODUCTION.

5 5

1.

Purpose and Scope.

5

~2.

Background.-.

B.

BRUNSWICK STEAM ELECTRIC PLANT EMERGENCY OPERATING PROCEDURE UPGRADE PROGRAM.-.

.6 C.

BRUNSWICK STEAM ELECTRIC PLANT PLANT-SPECIFIC TECHNICAL GUIDELINE,

10 Di BRUNSWICK STEAM ELECTRIC PLANT WRITERS' GUIDE FOR

-EMERGENCY OPERATING PROCEDURES.....

I1 E..

BRUNSWICK STEAM ELECTRIC PLANT VALIDATION / VERIFICATION PROGRAM FOR EMERGENCY OPERATING PROCEDURES..

11 1.

Objectives of the Brunswick Validation /

Verification 2rocess...

12 2.-

Methods.of Brunswick E0P Validation /

-Verification.

13 F.

BRUNSWICK STEAM ELECTRIC PLANT SYMPTOMATIC EMERGENCY OPERATING PROCEDURES TRAINING..

14 G.

EMERGDiCY OPERATING PROCEDURE ADMINISTRATIVE CONTROL 17 APPENDICES APPENDIX I Plant-Specific Technical Guidelines for Emergency Operating Procedures APPENDIX II Writers' Guide for Emergency Operating Procedures r

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1, TABLE OF CONTENTS (Cont'd)~

Section Pm AFPENDIX III-Brunswick Steam Electric Plant. Validation /

Verification Program for Emergency Operating Procedures ATTACHMENT A Source of Parameters Used in the Plant-Specific-Technical Guideline

. ATTACHMENT B -- Use of the Plant-Specific Technical

- Guideline in Emergency Operating Procedures ATTACHMENT C Plant-Specific Technical Guideline Deviations From'the Generic Guideline a

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7 A.

INTRODUCTION 1.

Purpose and Scope This_docutent identifies the elements used by Carolina Power &

Light Company's Brunswick Steam Electric Plant to revise its emergency operating procedures. The Brunswick E0Ps have been restructured and reformatted to a symptom basis; i.e., converted to a-a' function oriented procedura as opposed to-the event oriented procedure. The revised E0P'will provide the operator with improved directions to mitigate the consequences of a broad range of accidents and multiple equipment failures. The guidance provided in this~ document applies only to Brunswick's E0Ps and not to other procedures; e.g., plant emergency procedures (PEPS).

i This document is based upon the NRC Guideline for Preparation of Emergency Operating Procedures; i.e., NUREG-0899, August 1982.

2.'

Background

Shortly af ter the accident at TMI, the NRC formed the Bulletins &

Orders Task Force (B&OTF) within the Office of Nuclear Reactor Regulation. 'The task force was. responsible for reviewing and directing the NRC activities associated with the Three Mile Island type accident for all operating plants to assure their continued safe operation.

On the basis of hRC's review, it was concluded that the General Electric' designed boiling water reactor plants were quite capable of coping with small break LOCAs and with feedwater transients with or

'without stuck open relief valves.

'The NRC did, however, identify improvements in the systems, procedures, and~ analysis, which will make the GE designed BWRs less susceptible to ' core damage durinc cecidents and transients, coupled with system failures or operato; errors. One of the recommendations from the B&OTF was to restructure and reformat the current E0Ps from an event basis to a symptom basis. The symptom based emergency operating procedures would be categorized according t'o general plant symptoms, such as loss of coolant inventory, as opposed to several separate existing associaced procedures;'i.e., LOCA insion containment, LOCA outside containment, and loss of normal feedwater.

The Loss of Coolant Inventory procedure would include the essential features of those existing precedures associated with LOCA inside containment, LOCA outside containment, and loss of normal feedwater, but would make use of the fact that the initial operator response for the latter procedures are similar.

PGP Page 5 of 20

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l Shortly after;the TMI accident, the Owners Groups were formed to study and resolve problems associated with the operation of their L

plants. The GE Owners Group concurred with the NRC and recommended that the emergency operating.pr'ocedures for nuclear plants be restructured and reformatted to a symptom basis, as opposed to the more event specific basis.

The Owners. Croup developed a generic guideline to be. used by the

. utilities'to producefsymptom based or function oriented emergency

. operating-procedures._ This guideline;-i.e., Emergency Procedure

' Guidelines, Revision 2,: NEDO-24934, June 1982, was reviewed and.

[

' approved by the Office _of Nuclear Reactor Regulation and issued to

.all licensees on February 8, 1983_(Generic Letter 83-05).

~

B '.

BRUNSWICK' STEAM ELECTRIC PLAFT EMERGENCY OPERATING PROCEDURE UPGRADE

, PROGRAM The Brunswick emergency instructions (EIs)-were found to have several-

. deficiencies.

One of these deficiencies was that there were too many Els. No clear guidance was.provided to help the' opera:or dettraine which-EI to use during multiple failures.

LEvent~ based procedures are-inadequate because they place a greater burden

+ pen the Reactor' Operator in that each event must be classified prior to

_veing able to pick up the right procedure.

The operator must then i

~

remember the immediate action to be performed.

If more than one procedure.is required concurrently, which is usually the case, the 1

l

. operator.must; establish the priority of actions.

l This type'of emergency operating procedure results in no systematic and consistent method established for _ handling emergency conditions.

' The -Brunswick E0P Upgrade Program consisted of the following general outline (see Figure 1):

1.

_ Converted some existing emergency instructions into annunciator procedures.

2.-

Converted some existing emergency instructions into abnormal operating procedures (AOPs).

3, Reworked ramaining emergency instructions and the generic guidelines l

into function! oriented immediate action flowcharts and subsequent action End Path Manual. procedures.-

The Brunswick emergency instructions were reviewed to determine their b

applicability to the E0P.- The general guide used was to place actions

[

1 required prior to a reactor scram into an AOP or annunciator procedure.

.The actions required subsequent to a scram were written into the t

. appropriate sections of the E0P. The disposition of all emergency

' instructions was documented to ensure all nec~essary procedural guidance p

was retained.

1 "PGP.

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EOP1 FIVE FLOWCHARTS AND END PATH MANUALS

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I PGP Page 7 of 20

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The generic guideline and the Brunswick PSTG were developed as guidelines from which a plant-specific E0P should-be developed. These guidelines lack the detail.necessary to be an effective procedure.

If the Brunswick

-PSTG (or the generic guideline) was used as a procedure, it would be possible for the operator to be in as many as eight procedures concurrently.- In order to make.the procedure usable for operators, the initial actions upon entering the 20P have been prioritized.

The entry condicion to the Brunswick E0P was defined as any reactor scram signal, manual or automatic.

In order to prioritize the initial operator ' actions, a list of-key parameters was developed.

The key parameters diagnose the plant conditions and quickly places the operator in the appropriate procedure. These key parameters are at'the top of each flowchart. Using this method, the operator need only recamber to pick up any of the five' flowcharts following a scram.

The key parameters on each flowchart will then direct the operator to the appropriate procedure.

As an example, if a scran occurs the operator will pick up any one of the five'ficwcharts and insert a manual scram. The next block on all flowcharts is the first key parameter; a decision block that asks if reactor power is less than 3%.

If reactor power is not less than 3%, the operetor will be directed to enter path I which contains reactivity E

control steps early in the procedure.

If reactor power is less than 3%,

reactivity control is a lower priority and the operator will continue to the next key parameter (see Figure 1).

Each flowchart contains the guidance necessary to control reactor vessel level, pressure, and power. The RPV control guideAine in the PSTG simply requires that upon entry to the guideline, RC/L (reactor water level control), RC/P (reactor pressure control), and RC/Q (reactor power control) be executed.oncurrently. Using the key. parameters relieves the

operator of the burden of executing three procediires concurrently.

It should be noted that this method does not skip or delete steps contained in the PSTG, ir simply diagnoses the plant conditions and prioritizes initial operator actions.

The containment control guideline and the contingency procedures were not prioritized. The necessary plant-specific details--numerical limits, graphs, etc., were added. These procedures are in the End Path Manual.

Once the. flowchart steps are completed, the operator will be directed from the flowchart to one of the sections of the End Path Manual. The End Path Manual is a specially designed binder that holds five scetions.

The manual folds out in a manner that allows concurrent use of all five

. sections of the manual without interference (see Figure 2).

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normal conditions, the operator will enter the end path procedure from o

-the flowchart. 11e cad path procedure will then direct the operator to other. sections of the End Path Manual'as required.

It is possible, under degraded conditions, to enter a contingency procedure directly from the flowchart.- The flowchart will establish that the entry conditions to the contingency procedure have been met and direct the operator to the appropriate procedure from'the flowchart.

In: order to ensure that all the steps from the PSTG are reflected in.the EOP, Appendix III.-Attachment B was developed. This attachment outlines where and how the steps of the PSTG were used in the E0P.

The following list of' Brunswick E0P improvements was accomplished as a result of the upgrade program:

1~:

Made immediate operator actions visible.

2.

Reduced reliance on operator memory.

.33 Guided operator to appropriate procedure.

4.

Removed confusion as to which procedure applied.

15.

" Improved. operator awareness of total plant conditions.

6.

Improved operator decision-making process.

7.

Improved operator training for emergency conditions.

8..

Provided! operator job performance -improvement.

C.

BRUNSWICK STEAM ELECTRIC PLANT PLANT-SPECIFIC TECHNIC /J. GUIDELINE The Eeneric guideline was used as a basis for the Brunswick Plant-Specific Technical Guideline.

The. format and arrangement of the Brunswick guideline closely parallels the generic guideline.

Since the Brunswick technical guideline is based upon the generic guideline, which has been validated by the Owners Group and approved by the NRC, there is no requirement to validate the Brunswick Plant-Specific Technical Guideline.

The' brackets in the generic guideline enclose plant unique setpoints, design ' limits, pump shutoff pressures, etc., and parentheses within brackets indicate the source for the bracketed variable. The generic guidelines-are generic to CE-BWR-1 threugh six designs in that they address all major systems which may be used to respond to an emergency.

Because no specific plant includes all of the systems in these guidelines, the guidelines are applied to individual plants by deleting statements which are not applicable or by substituting equivalent systems where appropriate.

PGP Page 10 of 20

In converting the generic guideline into the Brunswick PSTG, the processes listed above were used.

Where brackets were used, plant unique information was inserted.

In order to ensure the accuracy of this

.information, the source of each parameter used in the PSTG has been listed _in Appendix III, Attachment A.

In addition, as part of a general r

validation / verification process, and independent review and verification was performed of all numerical limits and graphs contained in the Brunswick PSTG and E0Ps. This included both calculated limits and graphs and limits determined directly from plant data.

Where-the generic guideline contains systems that Brunswick does not have,;the systems are deleted or equivalent systems inserted. This is not considered a deviation from the generic guideline since the intent of the guideline is met; i.e., using whatever systems are available at

-Brunswick to accomplish the required action.

All deviations from the generic guideline are documented in Appendix III, Attachment C.

Deviations include using numerical limits other than those specified, deletins or altering steps that apply to Brunswick, or changing any step in the generic guideline that would change the intent of the guideline. All deviations require justification which are included in Appendix III, Attachment C.

D.

_ BRUNSWICK STEAM ELECTRIC PLANT WRITERS' GUIDE FOR EMERGENCY OPERATING PROCEDURES The Brunswick E0P Writers' Guide is based upon the requirements of Guidelines for the Preparation of Emergency Operating Procedures, NUREG-0899. August 1982, Section 5.0, Plant-Specific Writers' Guide, and the industry's Emergency Procedures Writing Guideline,.INPO-82-017, July 1982.

The Brunswick-EOP Writers' Guide contains all the necessary information and guidance for translating the technical information into Brunswick's E0Ps (see Appendix II).

I E.

BRUNSWICK STEAM ELECTRIC PLANT VALIDATION / VERIFICATION TROGRAM FOR EMERGENCY OPERATING PROCEDURES L

L The Brunswick E0Ps have undergone an extensive process of i

validation / verification to establish the accuracy of information provided and to determine that these procedures can be accurately and efficiently carried out.

The validation / verification process has addressed both technical and human engineering-adequacy of the Brunswick EOPs.

All Brunswick licensed personnel, consisting of operators and engineers, have participated in extensive classroom (desk top reviews) and simulator exercises, using the upgraded E0Ps during special courses and annual requalification training.

Simulator exercises hrve been conducted at three simulators; i.e., Browns Ferry, Limerick, and Hatch.

i i

PGP Page 11 of 20 L.

A preimplementation training session for all licensed personnel was completed in late 1983. The training was conducted on the Brunswick simulator.

F The.EOPs were revised many times during the E0P development phases as a result of licensed personnel comments and recommendations.

This experience indicates, with a large degree of confidence, that the upgraded Brunswick EOPs are adequate to mitigate transients and

-accidents.

1.

Objectives of the Brunswick Validation / Verification Process Objective 1:

.The Brunswick E0Ps are technically correct; i.e.,

they accurately reflect the technical guidelines.

Discussion:

The GE Owners Group has validated and the NRC has approved the Generic Emergency Operating Procedure Guidelines (Revision 2).

The generic guideline was used to develop the BSEP Plant-Specific Technical Guideline and the Brunswick E0Ps.

Objective 2:

The Brunswick EOPs are written correctly; i.e., they accurately reflect the writers' guide.

Discussion:

The Brunswick EOP Writers' Guide was used in the preparation of the E0Ps (see Appendix 11). The purpose of the writers' guide is to provide administrative and technical guidance on the preparation of E0Ps to ensure they are complete, accurate, convenient, readable, and acceptable to the BSEP Control Room personnel.

Objective 3:

The Brunswick E0Ps are usable; i.e., they can be understood and followed without confusion, delay, or errors.

Discussion:

. Brunswick's licensed personnel experience in the use of the new E0Ps during classroom and simulator exercises has demonstrated that the procedures can be accurately and efficiently carried out and that the E0Ps are adequate to mitigate transients and accidents.

The General Physics Corporation conducted a Human Factors Review of the Brunswick flowcharts.

Comments and recommendations from the licensed personnel at Brunswick and General Physics Corporation (Human Factors Review) were used to 4

revise; i.e., improve the E0Ps.

PGP Page 12 of 20

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Obje'ctive 4:

.There is a correspondence between the E0Ps and the

. Brunswick Control-Room / plant hardware; i.e...

-control / equipment indications that'are referenced are available (inside and outside-the Control: Room), use

_.the same designation, use the same units of

-measurement and operate as specified in the

. procedures.-

- objective 5:

The language and level of information presentation in the Brunswick'EOPs is compatible'with the minimum t

number, qualifications, training, and experience of'

the plant operating staff.

Objective 6:

There is a high level of assurance that the

' Brunswick EOPs work; i.e.,-the procedures guide the operator in the mitigation of transients and accidents.

Discussion:

The licensed operator training sessions, Brunswick Control Room walk-throughs, preimplementation reviews

.by ONS, QA, operations, and Engineering, and an independent Human' Factors Review adequately-substantiates that Objectives 4, 5, and 6 have been

~

met.

'2.

' Methods:of Brunswick EOP Validation / Verification

~ The-methods of-Brunswick E0P validation / verification are listed as follows-(see Appendix III):

a.

Desk' top reviews b.

Simulator exercises c.

' Control Room walk-throughs

+

(1) Phase I (operational scenarios)

(2)

Phase II (check of each step of E0P)

(3)- Backspanel walk-through

" (4)

Outside Control Room walk-through j

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Preimplementation review of Brunswick E0Ps

~ Documentation of technical guidelines (see Appendix III, le. -

- Attachments A, B, and C) f.

Independent Human Factors Review (summary) 4 PGP Page 13 of 20 t

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F.

BRUNSWICK STEAM ELECTRIC PLANT SYMPTOMATIC EMERGENCY OPERATING PROCEDURES TRAINING.

All Brunswick licensed personnel; i.e., operators and engineers, have had

- extensive training in the use of tbe new E0Ps (see Figure 3 and Appendix IV). During the training sessions, comments ~and recommendations

.from_the trainees were recorded. A response to each comment was made by the 'EOP development group and was sent to the Shif t Operating Supervisor for each group of operators. This method of feedback encouraged operator input to the_new E0P development process. The EOPs were greatly improved by this valuable input.

A daily quiz was eiven to each trainee during this training.

The trainees participatica and quir grade were documented (see Figure 4).

Thel trainees were also evaluated during the simulator training (see Figure 5).

Simulator exercises were selected to meet the following objectives:

1.

Control manipulations required by the Harold Denton letter, dated March 28, 1980, Enclosure 4.

2.

Exercise all portions of the flowcharts.

3.

Exercise all procedures in the End Path Manual that the simulator is crpable of simulating.

4.

Exercise flowchart branching; i.e., path-to-path arrow changes, key parameter changes, path-specific parameter changes.

The simulator exercises used for validation and verification were also used for training.

Examples of these exercises are included in Appendix III.

The licensed personnel at Brunswick received the following E0P training:

1.

Initial Classroom Training a.

Location: Plant Training facility b.

Subjects:

(1) Course Description (2) Background (3) Existing BSEP Procedures (4) BSEP's Approach to Owners Group Guidelines (EPGs)

(5) Use of Brunswick's New E0Ps PGP.

Page 14 of 20

L c.

Duration of training per group:

Four days ad.

Number of. groups:

Five e.

Schedule:

Beginning February 3, 1982 (three days each week),

ending March'5, 1982 The' objective of initial operator training was to licensed personnel.

to the concepts of~ symptom-based procedures. The initial draft of the flowcharts were used during this training to introduce licensed

-personnel to techniques of flowchart use and get their response to

-using flowcharts for operator actions. The response to flowchart use was very favorable.

2.

Initial Simulator Training a.

-Location: Limerick simulator

.b.

Subj ect:

Simulator Training Using New Symptomatic Emergency Procedures c.

Duration of training per group:

Four days d.

-Number of groups: Twelve e.

Schedule:

Beginning March 13, 1982, ending May 18, 1982 This training involved actually using the flowcharts on the Limerick simulator.

The flowcharts used were the initial draft. The End Path Manual procedures were not developed for this training.

3.

. Emergency Procedure Guideline Training a.

Location:

Plsnt Training f acility b.

Subject:

GE Owners Group Guideline (EPGs) c.'

Duration of training per' group:

Four days d.

Number of-groups:

Eight

.e.

Schedule: Beginning December 1982, ending May 1983 This training session introduced licensed personnel.co the concepts of the generic guideline and how they were used in the Brunswick EOP. During this training, the containment control and contingency procedures were reviewed.

l

PGP, Page 15 of 20 l

4.

Simulator Training a.

Location: Hatch simulator b.

Subject:

Simulator Training Using New Symptomatic Emergency Procedures c.

Duration of training per group:

Four days d.

Number of groups: Fourteen

-e.

Schedule:

Beginning January 31, 1983, ending May 29, 1983 This training-involved using flowcharts, end path procedures, and containment control and contingency procedures. The remainder of the_ procedures in the End Path Manual were not developed.

5.

E0P Preimplementation Training.

a.

Location: Brunswick simulator / classroom b.-

Subj ects:

(1)

Flowcharts (2) End Path Manuals (3)

E0P Network (4) BSEP E0P Limits

-(5)

E0P Exercises (6) Operation Outside License Conditions or Technical Specifications (7)

E0? Administrative Controls c.-

Duration of training per group:

Four days d.

Schedule: Beginning November 7, 1983, ending December 30, 1983 This-training involved using' flowcharts and all End Path Manual J

. procedures in the classroom and on the simulator. While not all procedures could be exercised on the simulator, each procedure in the End Path-Manual was reviewed in the class to ensure all personnel were adequately trained on all aspects of the E0P.

-c

'PGP Page 16 of 20

6.

EOP Training for Auxiliary Operators The Brunswick Auxiliary Operators received the following E0P training:

a.

Location: Plant Training facility b.

Subj ect:

E0P Training for Auxiliary Operators c.

Duration of training:

Sixteen hours d.

Schedule: -Beginning November 7, 1983, ending December 30, 1983 This training ensured that Auxiliary Operators were adequately trained in the portions of the E0P they would be expected to perform; i.e., steps that are performed outside the Control Room.

G.

EMERGENCY OPERt. TING PROCEDURE ADMINISTRATIVE CONTROL The Brunswick Administrative Procedures Manual, Volume I, Section 5.5.2, generally outlines how the E0Ps are to be maintained.

LWhen thanges occur in the plant design, technical specifications,.

-technical guidelines, writers' guide, other plant procedures, or Control Room that will affect the E0Ps, they shall be revised'on a timely basis to reflect these changes.

In addition, when operating and training experience, simulator exercises, Control Room walk-throughs, or other.

information indicate that. incorrect or incomplete information exists in the E0Ps,- they shall be revised on a timely basis.

.-Any revision to the E0P must be consistent with the following documents:

1.

Brunswick E0P Writers' Guide 2.

Brunswick E0P Technical Guideline 3.

Brunswick E0P Calculation Procedures 4.

General ' Electric Topical Report, NEDO-24934, Emergency Procedure Guidelines' latest revision The E0P Committee (see Section D of Appendix III) will be an ongoing E0P review committee at Brunswick. Changes to the E0P will be approved by the E0P Committee as well as the normal administrative procedure for document control. The E0P Committee will determine if the change requires validation and verification and what type of validation and verification is required. A permanent procedure will be developed which will described the requirements and the process for the continuing validation and verification of the ECP.

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PGP.

Page 17 of 20

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FIGURE 5 SIMULATOR-TRAINING SYMPTOMATIC EMERGENCY OPERATING INSTRUCTIONS NAME LICENSE s

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'B = USED PROCEDURE CORRECTLY C = EXECUTED PATH CHANGES CORRECTLY 4

D = ENTRY TO AND USE OF END PATH PROCEDURE MANUALS E = COMMUNICATION F = ACTION TAKEN k' HEN KEY PARAMETERS CHANGE G = ACTION TAKEN k' HEN PATH-SPECIFIC PARAMETERS CHANGE E = SYSTEM MANIPULATION AND VERIFICATION REMARKS (MANDATORY IF ANYTHING OTHER THAN SATISFACTORY)

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PGP Page 20 of 20

I a

CAROLINA POWER & LIGHT COMPANY BRUNSWICK f TEAM ELECTRIC PLAhT APPENDIX I

. PLANT-SPECIFIC TECHNICAL GUIDELINE FOR EMERGENCY OPERATING PROCEDURES 4

Appendix I Page 1 of 48

s

. INTRODUCTION-

- Based on the :BWR system design, the following Symptomatic Emergency Procedure

' Guidelines have been developed:

L*

RPV Control Guideline L' -

-Containment Control Guideline

-The RPV Control Guideline restores and maintains RPV water level within a l satisfactory range, shuts down the reactor, controls RPV' pressure, and cools down the RPV to cold shutdown conditions. This guideline is entered after low RPV water-level,-high drywell pressure, or an-isolation has occurred or when a condition which requires reactor. scram exists and reactor power is above 3% or cannot be determined.

llum Containment Control Guideline controls pr,imary containment temperatures, pressure, and level whenever suppression pool temperature, drywell temperature,-drywell pressure, or suppression pool water level is above its normal operating limit or suppression pool water level is below its normal

operating limit.

At various points throughout these guidelines, precautions are noted by the symbo1~/~# /. The number within the box refers to a numbered " Caution"

~

contained in the Operator Precautions section. These " Cautions" are brief and concise red flags for the operator.

At.various. points within these guidelines, limits are specified beyond which certain actions are required. While conservative, these limits are derived j

from engineering analyses utilizing best-estimate (as opposed to licensing) models. Consequently, these limits are not as conservative as the limits specified in a plant's Technical Specifications. This is not to imply that

-operation beyond the Technical Specifications is recommended in an emergency.

-Rather, such operation may be required.under certain degraded conditions in order to safely mitigate the consequences'of those degraded conditions. The limits, specified in the guidelines establish the boundaries within which continued safe operation of the plant can be assured. Therefore, conformance with' the guidelines does not ensure strict conforman'ce with a plant's Technica1' Specifications or other licensing bases.,

The entry conditions for these Emergency Procedure Guidelines are symptomatic of both emergencies and events which may degrade into emergencies. The guide-Llines specify actions appropriate for both. Therefore, entry into procedures

' developed from these~ guidelines is not, conclusive that an emergency has

occurred.

Appendix 1I Page 2 of 48

g-

- TABLE '0F CONTENTS SECTION PAGE OPERATOR PRECAUTIONS.

4 1.

RPV C0!frROL GUIDELINE 12 Reactor Water Level Control'(RC/L) 13 Reactor Pressure Control (RC/P).

15 Reactor Power Control,(RC/Q) 19 CONTAINMENT CO.VTROL GUIDELINE 23 C0tfrINGENCY PROCEDURES.

34 Appendix I Page 3 of 48

- - = - - -..

OPERATOR PRECAUTIONS a :. ;. :. ;. :. :, ;. :.* :. ; :. :. :. :. :. :, :, a :.**:. :.

. :. :.. :. ***************** a :. a :. ;. :...... :. **

CAUTION #1 Monitor the' general state of the plant.

If an entry condition for either the RPV Control Guideline or the Containment Control Guideline occurs, enter that procedure. When it is determined that an emergency no longer exists, enter the normal Operating Procedure.

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CAWION #2 Monitor RPV water level and pressure and primary containment temperatures and pressure from multiple indications.

. :. ;. ;. a a :.****+*a :. :. :. ;. :. : *:..-

. ;. ;, ;.: . :. ;. :. ; : :. :. :. :. a :. :. a ;. :. ;. :. :. : :.*************:... ;. ;. a.,. :. a :. ;. :. ;. a ******* a ;. :, ;. :, : :, a :. :. :. ;. ;. :, :.

CAUTION #3 If a safety function initiates automatically, assume a true initiating event has occurred unless otherwise confirmed by at least two independent indications.

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a ;. :. z e***** :. :. :....... :. :. ;. :.* :. a ;. :. ;. a

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CAWION #4 Whenever RHR is in the LPCI mode, inject through the heat exchangers as soon as possible.

- - - s ;. :. :. : :. ; ;. ;. :. :. :. ;. : :. :. :. ;, :.. :. :, ;. ;. :. ;, ;. :.*1............

Appendix I Page.4 of 48

5:

\\l.

0.

. ;. :. ;. ;. :. :. ;. :. :. ;.. :. ;. ;. :. ;, :. : :. :. :. ; :, :, :. :. ****************++******:. -..

CAUTION #5

Suppression pool "-sperature is determined by

Unit 1 Only:

Unit 2 Only:

.The average of Computer Point 1 on CAC-TR-4426 OR Points'W108 and W117 Point 1 on CAC-TR-4426 OR

.OR Computer Point G050 OR The average of Points 14 Computer Point G051.

and 21 on CAC-TR-1258.

Drywell average temperature is determined by Computer Point C074 on PT-16.2.

x******** :. :, :. ;, ;. ;. :. :, ;, :. :. *********** :. :. ;. ;. ;. :. :. :. ; **************

. a :. ; ;. ;:. :. ;, ;. :.

CAtTl' ION #6 Whenever temperature near the instrument reference les vertical runs

~ ~

exceeds the temperature in the table and the instrument reads below the-indicated level in the table,-the actual RPV water level may be anywhere below the elevation of the lower instrument tap (see page 6).

Indicated Temperature Level Instrument

'Any 255 in Shutdown Range Level 150 to 550 in Any 54 in Wide Range Level O to 210 in 304*F-170 in

. Narrow Range Level 150 to 210 in CAUTION #7 Heated reference leg instrument B21-N026A and B indicated levels are not reliable during rapid RPV depressurization below 500 psig.

For these conditions, utilize cold reference leg instruments to monitor RPV water level.

Appendix I Page 5 of 48 a'

).

NOTE DRYCELL TEMPERATURE NEAR THE LEVEL INSTRUMENT REFERENCE LEGS 15 DETERMINED BY:

UNIT ONE ONLY UNIT TWO ONLY A THE AVERAGE OF POINTS 1,2, A.THE AVERAGE OF POINTS 9 AND 10 3 AND 4 ON CAC-TR-1258 ON CAC-TR-4426-1 AND POINTS 8 AND 9 ON C AC-TR-4 4 2 6-2.

r

.QS.

.QB.

THE AVER AGE OF COMPUTER THE A'<ERAGE OF COMPUTER PCINTS POINTS WlO9,WilO,Fl47 AND W109,WilO.Fl47 AND Fl48.

F l4 8, 70 60 t

SAFE b.

n W>

W

.J 40 l

O l

W e

UNSAFE RPV WATER LEVE POTENTIALLY SELOW TAF 20 l

10 100 200 300 400 500 DRYWELL T EM PER ATURE (*F)

CAUTION 6 ALL HEATED REFERENCE LEG INSTRUMENTS I

L Page 6 of 48 l

Appendix I l

e,

=

..;,;;,*************S.v****

-x.

"y CAUTION #8 f

Observe not positive suction head (NPSH) requirements for pumps taking suction from the suppression pool (see_page 8).

k******** :, ;. :, ;. ;, :. a :. ;, ;. :. :. :. ;. :. ;. ***:. :.., ;. ;, ;,. *******************

CAUTION #9 If signals of high suppression pool water level -24 inches (high level suction interlock) or low condensate storage tank water level 3.0 feet (low level suction interlock) occur, confirm automatic transfer of or manually transfer HPCI and RCIC suction from the condensate storage

' tank to the suppression pool.

J. J. ; ; ;. ;, ; J. J. J. J.

J. J.. ;.. J.. A :. A A A A ;, A A A A :. A e i. A A A J. A :. i. :. A a i. ;, ******************************

CAUTION #10 l'

Do not secure or place an ECCS in MANUAL mode unless, by at least two independent indications, (1) misoperation in AUTOMATIC mode is confirmed or (2) adequate core cooling is assured.

If an ECCS

.is placed in MANUAL mode, it will not initiate automatically. Make frequent checks of the initiating or controlling parameter. When

manual operation is no longer required, restore the system to AUTOMATIC / STANDBY mode if possible.

i L

. ; J.., -., ;. :. ; ; :, ;, :. :. ;. :. :, ;. J. ;. ;. :. :. a :. :. ;, :, :, :. : :. :. ;. ; :. ;, ;. :. :. ;, ********** ;, :, :. :, ;, :. ************ :. ;. :. ;. :. ;, :. :.

CAUTION #11 i

If a high drywell pressure ECCS initiation signal 2.0 psig (drywell pressure which initistas ECCS) occurs or exists while depressurizing, prevent injection from those core spray and RHR pumps not required to assure adequate core cooling prior to reaching their maximum injection pressures. When the high drywell pressure ECCS initiation signal clears, restore core' spray and RHR to AUTOMATIC / STANDBY mode.

, ;. ;. ;. ;.: . ;, ;. :. :. ;. :. ;, :. :. ;, ; ;, ;. : :. ;. ;. ;, :. :. ;. ;, ;. ;. ; :. :.. :. ; ;......,..., :. :. ;. : :...., :. ;, ;.- a *****+ ***** :. a :. :. J. :. :. :. :.

I-I' i

Appendix I Page 7 of 48 i

L

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Appendix I Page 8 of 48

w

- - - - ,..a;,;........aat.***************<...

CAUTION (112 Do not throttle HPCI speed below 3000 rpm or RCIC speed below 2000 rpm (minimum turbine speed limit per turbine vendor manual).

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3

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CAUTION /113 Cooldown rates above 100*F/hr (RPV cooldown rate LCO) may be required during periods of rapid RPV depressurization.

- - - - a :. :. :. :. :, ;. ;. a :. ;......,.... :. a a :.**********:......... :. & a a a a a :... :. *********** a a a a a......... :.**

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a...... : :. a CAUTION (114

.Do not depressurize the RPV below 120 psig (HPCI low pressure isolation setpoint) unless motor driven pumps sufficient to*

maintain RPV water level are running and available for injection.

- - - - ... :. ;. ;. :. ;, ;, ;, :. ;. :. :. a :. ;, :..... ;. ;, :. a a :. :. :. :. a :. :. :. :. :. :, :. *:.

. a s: . :.., :. ;, ;,... :. ;. ;. ******

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CAUTION //15 Open SRVs in the following sequence if possible:

A,E,J.B,F, D,G,C,H i'

- - - - :. :, :. :. :..... a :. : :. a :. :, ;. ;....,. :. ;, :,... :. a.;

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. ;. :. ;. :. ;. ;, ;. a ;, :. :. :....... :. :. ;. ; :.

...... :. :. a :. ;. :.. :. a ;....... :. a ;.

CALTTION (/16

. Bypassing RPV low water level ventilation system and MSIV isolation interlocks may be required to accomplish this step.

.: . ;. a a :. **** :. :. ;. :.... :. ******1.. ;.................. :. ******************** * *** a..............

Appendix I Page 9 of 48

m.

8 LL L

.k CAUTION (117 Cooldown rates above 100*F/hr (RPV cooldown-rate LCO) may be required

-to conserve RPV water inventory, protect primary containment integrity, or limit radioactive release to the environment.

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CAUTION (118.

i If continuous LPCI operation is required to assure adequate core cooling, do not divert all RHR pumps from LPCI mode.

. ;, :. ;. :. :. ;. ;. :. ;, a :. :. :. ;, ;. :. ;. a :. ;. ;. :.s ;, ;. ;,.. :. :. :,., :. ;, ;. ;, ;.*****:... :. ;,. ;. :, :, :. :. ;,******** a ;. ;. ;, ;.. :.*****

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,..... ;. ;. ;, :. a : **:..,.,.... :. * :.

t CAtTTION (119 Manually trip SLC pmps at 0% level in the SLC. tank.

- - .
    
    , a :. ;, :. :. :. ;, :. ;, ;, :. ;, :... :. :. : :. :. a ;. :. :. :, a :, :. :. :. :... ; : : :. ;, ;. :. :. :..... :. ; :. ;. ;. :. :. ;. a ;, :. :. :. :. :.

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CAtTTION #20 Defeating RSCS interlocks may be required to accomplish this step.

......;.;.;.........;.**********,...;.t.

. :. a ;. ;, :. ;. ;. ;..... :.************:...

CAUTION (121 Elevated suppression chamber pressure may trip the RCIC turbine on high~ exhaust pressure.

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.....a**

Appendix I Page 10 of 48

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r 1

. :. ;. ;. ;. ;. ; :. ;. ;. :. :. :. :, a :, ;, :. :, :. ***** ********************** :....,,.-

. :. ;........... a :. *******

i-CAUTION #22 Defeating' isolation interlocks may be required to accomplish this stop.

.: . ;. ;. :. ;. :. :. :. :. ;. :. ;. :. :, ;. ;, : ;. :. ;, :. :.********************* a :, :. :. :. :. :. :. :. :. ;. :. :. :. :. **:. a : :, ;. :. :. :. ;. :. :. ;, ***

-- zaz.

--: z:.zazzaa ;;;;z*azzaa *;;;;;azaa;.za;.;;

azaa;;;;;,a;.;;..aaaaaaa CAlTTION #23 Do'not initiate drywell cprays unless suppression pool water level is below -1 inch (elevation of bottom of Reactor Building to suppression chamber breakers).

1

- - :. :. ;. :, :. :. ;. :. ; :. :. *****:, :.. :, :. :. :. :. ; ; :. :. :. : a ;. ;. :, :. * :, ;, ;. :. :. ;. :,****************** :. :. :. ; :. :. :, :. :. ;. :.

CAUTION #24 A rapid increase in injection into the RPV may induce a large power excursion and result.in substantial core damage.

- - - - :. :. ;. :. :. ;, ;. ; a ;. :. :. :. ;. :. ;. :. :. ;. ;, ;. ;. :. ;. ;. ;. :. :. ;, ;. ;. :. ;. :, a ;, ;. ;, :. :. :. :. :. :. * ;, :. ;. :. :. a a ******;, ;. :. ; ;. :. :. **

CAUTION #25 Large reactor power oscillations may be observed while executing.

this step.

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Appendix I Page 11 of 48

7 IC~

ej.

i f

RPV CONTROL GUIDELINE (n

= Purpose-The purpose.of this guideline is to:

Restore'and maintain RPV water level within a satisfactory range, 9

Shut down the reactor, and Control RPV pressure and cool down the RPV to cold shutdown conditions (RPV water temperature below 212*F).

Entry Condition A condition which requires or has initiated a reactor scram.

Operator' Actions

.RC-1 If reactor scram has not been initiated, initiate reactor scras.

Irrespective of the entry condition,. execute Steps RC/L, RC/P and' RC/Q concurrently.

\\

Appendix I' Page 12 of 48 O

l I

i l

RC/L Monitor and control RPV water level.

RC/L Confirm initiation of any of the following:

Isolation ECCS-Emergency diesel generator Initiate any of these which should have initiated but did~not.

If while executing the following step:

Boron Injection is required, enter CONTINGENCY #7.

1*

RPV water level cannot be determined, RPV FLOODING IS REQUIRED; enter CONTINGENCY #6.

- RPV Flooding is required, enter CONTINGENCY #6.

RC/L-2 Restore and maintain RPV water level between

+162.5_ inches (Iow level scram setpoint)

9 and +208 inches (high level trip setpoint)

10 with one or more of the following systems:

11 1

RPV Pressure Range System,

for System Operation Condensate 200-0 psig Condehsate/ Booster 350-0 psig Feed Pumps 1250-0 psig CRD 1490-0 psig RCIC 1190-62 psig

12 HPCI 1280-120 psig RHR 200-0 psig Core Spray 300-0 psig JAppendix I Page 13 of 48

x If RPV water level cannot be restored and mainrained above

+162.5 inches (low level scram setpoint), maintain RPV. water level above 0 inches.(top of active fuel).

t If RPV water leval can be maintained above 0 inches (top of

~

active fuel) and the ADS timer has initiated, prevent automatic RPV depr.essurization by resetting the ADS timer.

If RPV water level cannot be maintained above 0 inches (top of active fuel), enter CONTINGENCY #1.

If Alternate Shutdown Cooling is required, enter CONTINGENCY #5.

RC/L-3f Proceed to cold shutdown in accordance with GP-05.

F F

4 1

Appendix I.

Page 14 of 48 L

'RC/P Monitor and control RPV pressure.

If while executing the following steps:

Emergency RPV Depressurization is anticipated, rapidly

13 depressurize the RPV with the main turbine bypass valves.

-Emergency RPV Depressurization or RPV Flooding is required and less than seven (number of SRVs dedicated to ADS) SRVs are open, enter CONTINGENCY #2.

RPV Flooding is required and at least seven (number of SRVs dedicated to ADS) SRVs are open, enter CONTINGENCY #6.

RC/P-1 If any SRV is cycling, manually open SRVs until RPV pressure drops to 950 psig (RPV pressure at which all turbine bypass valves are fully open).

Appendix I Page 15 of 48 L

If while executing the following st'eps:

-Suppression pool temperature cannot be maintained below the Heat Capacity Temperature Limit,

8 maintain RPV pressure below the Limit.

13

14 C.

I1 I

L

'M ii.

(

b 100 1

y

, t')NSAFE.

5 180

?

.'q

= 170 kt

'k -

% e0

'A L

150 I

SAFEW 140 130 120 5 110 a

1 100 0 100 200 300 400 500 000 700 800 900 10001100 RPV PRESSURE (PSio!

J Heat Capacity Temperature Limit Suppression pool water level cannot be maintained

13 below the Suppression Pool Load Limit, maintain

14 RPV pressure below the Limit.

r.'4 1

1.

1

~

unsApa -

E d

Nl c

-' 2 5

a0 SAFE

'Ji__

v 2

i I

I I

700 a00 s00 1.000 1.i00 REACTom PmES$URE t SIG)

Suppression Pool Load Limit Steam Cooling is required, enter procedure developed from Contingency #3.

Appendix I Page 16 of 48 O

If while executing the following steps:

Boron Injection is required, and The main condenser is available, and There has been no indication of gross fuel failure or steam line break, open MSIVs to reestablish the main condenser as a

16 heat sink.

RC/P-2 Control RPV pressure below 1105 psig (lowest

14 SRV lifting pressure) with the main turbine bypass valves.

RPV pressure control may be augmented by one or more of the following systems:

SRVs.

If the continuous SRV pneumatic

15 supply is or becomes unavailable, depressurize with sustained SRV opening.

HPCI

12 RCIC RWCU (recirculation mode) if no boron has been injected into the RPV.

Main steam line drains RWCU (blowdown mode) if no boron has been injected into the RPV.

Refer to sampling procedures prior to initiating blowdown.

3 l

Appendix I Page 17 of 48

b a

If while executing the following steps the reactor is not shut down, return to Step RC/P2.

RC/P-3 When RPV water level is stabilized and either:

All control rods are inserted to position 00 (maximum subcritical banked withdrawal position), or 570 pounds (Cold Shutdown Boron Weight) of boron have been injected into the RPV, or

.The reactor is shut dovn and no boron has been injected into the RPV, Depressurize the RPV and maintain cooldown

14, #17 rate below 100*F/hr-(RPV cooldown rate LCO).

RC/P-4 When the RHR~sEutdown cooling interlocks clear,

18 initiate the shutdown cooling mode or RHR.

If the RHR shutdown cooling mode cannot be established and further cooldown is required, continue to cool down using one or more of the systems used for depressurization.

If RPV cooldown is required but cannot be accomplished and all control rods are inserted to position 00 (maximum

- suberitical banked withdrawal position), ALTERNATE SHUTDOWN COOLING IS REQUIRED; enter CONTINGENCY #5.

RC/P-5 Proceed to cold shutdown in accordance with GP-05.

v

- Appendix I Page 18 of 48 m.

..m.

RC/Q Monitor and control reactor power.

If while executing the following steps:

All control rods are inserted to position 00 (maximum subetitical banked withdrawal position), terminate boron injection.

The reactor is shut down and no boron has been injected into the RPV, enter GP-05.

RC/Q-1 Confirm or place the reactor mode switch in SHUTDOWN.

RC/Q-2 If the main turbine-generator is on line and the MSIVs are open, confirm or initiate recirculation flow runback i

to minimum.

RC/Q-3 If reactor power is above 3% (APRM downscale trip) or cannot be determined, trip the recirculation pumps, t

Execute Steps RC/Q-4 and RC/Q-5 concurrently.

RC/Q-4 If the reactor cannot be shut down before

19 suppression pool temperature reaches 110*F (Boron Injection Initiation Temperature),

BORON INJECTION IS REQUIRED; inject boron into the RPV with SLC and pravent automatic initiation of ADS.

RC/Q-4.1 If boron cannot be injected with SLC, inject boron into the RPV by one or more of.the following methods:

CRD RWCU l

~

Feedweter l

HPCI RCIC Appendix I Page 19 of 48 i

u-A w-

RC/Q-4.2 If boron is not being injectec octe tne RPV by RWCU, confirm automatic isolation of or manually isolate RWCU.

RC/Q-4.3 Continue to inject boron until 570 pounds (Cold Shutdown Boron Weight) of boron have been injected into the RPV.

RC/Q-4.4 Enter End Path Procedure for cooldown following boron injection.

RC/Q-5 Insert control rods as follows:

RC/Q-5.1 If any scram valve is not open:

Remove H12-P609 C71-F14A C and FISA and F16A H12-P611 C71-F14B,D and F15B and F16B (fuses which doenergiza RPS scram solenoids).

Close F095 (scram air header supply valve) and open drain valves for C12-PSL-3363 and -3364.

When control rods are not moving inward Replace:

H12 P609 C71 F14A C and F15A and F16A H12-P611 C71-F14B,D and FISB and F16B (fuses which deenergize RPS scram solenoids).

Close drain valves for C12 SSL-3363 and -3364 (scram air header vent valves) and open F095 (scram air header supply valve).

RC/Q-5.2 Reset the reactor scram.

If the reactor scram cannot be reset:

1.

Start both CRD pumps.

If no CRD pump can be started, cent'mue in this procedure at Step RC/Q 5.6.1.

2.

Close F034 (110U accumulator charging water header valve).

Appendix !

Page 20 of 48 4

_~

I 4

3.

Rapidly insert control rods manually

20 until the reactor scram can be reset.

4.

Reset the reactor scram.

5.

Open F034 (HCU accumulator charging water header valve).

RC/Q-5.3.If the scram discharge volume vent and drain valves are open, initiate a manual reactor scraa.

1.

If control rods moved inward, return to i

Step RC/Q 5.2.

2.

Roset the reactor scras.

If the reactor scras cannot be reset, continue in this procedure at Step RC/Q 5.5.1.

3.

Open the scram discharge volume vent and drain valves.

RC/Q 5.4 Individually open the scram test switches for contrst rods not inserted to position 00 (maximum suberitical banked withdrawal position).

When a control rod is not moving inward, close its scram test switch.

RC/Q 5.5 Roset the reactor scram.

If the reactor scram cannot be reset 1.

Start both CRD pumps.

If no CRD pump can be started, continue in this procedure at Step RC/Q 5.6.1.

2.

Close F034 (HCU accumulator charging water header valve).

RC/Q 5.6 Rapidly insert control rods manually until all control rods are inserted to position 00

20 (maximum subcritical banked withdrawal position).

- AppendLx I Page 21 of 48

If.any control rod cannot be insertec to position 00 (maximum subcritical banked withdrawal position):

1.

Individually direct the effluent from F102 (CRD withdraw line vent valve) to a

- contained radwaste drain and open F102 (CRD with, draw line vent valve) for each control rod not inserted to position 00 (maximum j

suberitical banked withdrawal position).

2.

When a control rod is not moving inward, close its F102 (CRD withdraw line vent valve).

4 LAppendix I Page 22 of 48

CONTAINMENT CONTROL GUIDELIST.

Purpose The purpose of this guideline is to control primary containment temperatures, pressure and level.

Entry Conditions The entry conditions for this guideline are any of the following:

Suppression pool temperature above 95*F (most limiting suppression pool temperature LCO)

Drywell. temperature above 135'F-(drywell temperature LCO or maximum normal operating temperature, whichever is higher)

Drywell pressure above 2.0 psig (high drywell pressure scram setpoint)

Suppression pool water level above -27 inches (maximum suppression pool water level LCO)

Suppression pool water level below -31 inches (minimum suppression pool water level LCO).

Operator Actions Irrespective of the entry condition, execute Steps SP/T, DW/T, PC/P and SP/L concurrently.

Appendix I Page 23 of 48

SP/T Monitor and control suppression pool temperature.

SP/T-1 Close all SORVs.

As soon as it is recognized that the valve will not close, scram the reactor.

SP/T-2 When pool temperature exceeds 95*F (most

18 limiting suppression _ pool temperature LCO),

(

operate available suppression pool cooling.

SP/T-3 Before suppression pool temperature reaches 110*F (Boron Injection Initiation Temperature), scram the reactor.

SP/T-4 If suppression pool temperature cannot be maintained

8 below the Heat _ Capacity Temperature Limit, maintain

13 RPV pressure below the Limit.

14 If suppression pool temperature and RPV pressure cannot be restored and maintained below the Heat Capacity Temperature Limit, EMERGENCY RPV DEPRESSURIZATION IL REQUIRED; enter the RPV Control Guideline at Step RC-1 and execute it concurrently with this procedure.

_ 200 g

g_

1 m

w 1

1 1 1

y 1

.N L.190

~ \\

i UNSAFE a 180 1 N Q

ll N' ~ '"

$ 170 l

! N_

y 150 O

l SAFE a 140 z

Ei; 9 130 ii y 120 a

S 110

=

o m m m

o m 100

^1

'i 0 100 200 300 400 500 600 700 800 900 10001100 RPV PRESSURE (PSIG)

Heat Capacity Temperature Limit l

Appendix I Page 24 of 48

w-DW/T Monitor and control drywell temperature.

-DW/T-1 When drywell temperature exceeds 135'F (drywell

6 temperature LCO cr maximum normal operating temperature, whichever is higher), operate available drywell cooling.

DW/T-2.

If drywell temperature near the cold reference leg instrument vertical runs reaches the RPV Saturation Temperature, RPV FLOODING IS REQUIRED; enter the RPV Control Guideline at Step RC-1'and execute it concurrently with this procedure.

S

.Q em ez D_ $50 8;3ao 2

unsarE 3

e-5" lif

.~

$@450 wW 400 M_'2.;-

ww r

zg

$y f

,1 1

.i, 1

1 y,,

y

[

I

!saFEj 23 300 1

r g

.l4.gj:

i g

l lz:

i i i ii 1

1 1 1

dz 250 l_

,I '

l

'1 1

r g D 200 Oa 0 100 200 300 400 500 600 700 800 900 1,000 RPV PRESSURE (PSIG)

RPV Saturation Temperature I

l.

l L

['

Appendix I Page 25 of 48 I

e -

DW/T-3 Before drywell temperature reaches 300*F (maximum

18 drywell design temperature) but only if suppression chamber temperature and pressure are below the Drywell Spray Initiation Pressure Limit, shut down recirculation pumps and drywell cooling fans and initiate drywell sprays.

300 -n.;w maaa...;. ;Ma uusi.::e

=:::

,t n;:Jn:'n: !:::::::':!?;'C:ndd=E"*:=:ll M!!!! * * :.ii ::n:

so " UMh!";;;.*;;;;d":":::f;;'tM"::::ntn::::

b,. '. l "..U.. !!;.u.h M, u

.u..o.

,.... m

.,.,.,..i.-m n

e.

..,. c....

aso

.....s.

n

; M, u': .h.M.!, * ; :: : '! f. :. :. 7 : ".M:U.n:n.::::nn:"::.:.:

..,un C e4o nW 4U;U;M:nh U======= :::::::=== l

n. :.: M i'l u ;.;:T: a.,i.;n'*====n. 3:=.= *.:n.==."::

e-

.... =

<u E ato u,,; E. 3.HZ.3..nt,U::n.ts =. n.:.=..::::::::.:::::=:

2

..u.....o.,

y

....' ;..,2 :*. M.r :. :. *=.n. i.n.n.t.:.n.t.:.:.::n.:U..n.n.:::.::.:

= coo

. n

.u..

g

.....- - m ".

' ;i.. ", M.. : '..:n..t :::: n:*:=..==..:::.: ::. n.n.:.

aw seo u....-

r

.,.. u...-

e g '50

. M.. P.. : '.n:::::=.=.=.=.=..====.=."n:m2:."===.=:

,..a,c....,.r-

,.rrrra a

<Z 140 o

120 m

M y soo tae so so do 0

10 to 3o do So 60 To So to l

SUPPR E SSION CHAMBER PRESSURE (PSIG)

DRYWELL SPRAY INITIATION PRESSURE LIMIT DW/T-4 If drywell temperature cannot be maintained below 300*F EMERGENCY RPV DEPRESSURIZATION IS REQUIRED; enter the RPV Control Guideline at Step RC-1 and execute it concurrently w'ith this procedure.

Appendix.I Page 26 of 48 e,

m

-,m--

a

,a

-e-

,-.~e--n,,--v~---,---,-,e e--

,e

-n-,-e

,-m---

-,-... - ---,v--.-

PC/P Monitor and control primary containment pressure.

PC/P-1 Operate the SBGT and drywell purge as required, only when the temperature in the space being evacuated is below 212*F (Maximum Noncondensable Evacuation Temperature).

Use SBGT and drywell

21 purge operating procedures.

PC/P-2 Before suppression chamber pressure reaches

8, #18 16.5 psig (Suppression Chamber Spray Initiation i

Pressure) initiate suppression pool sprays.

PC/P-3 If suppression chamber pressure exceeds

18 16.5 psig (Suppression Chamber Spray Initiation Pressare) but only if suppression chamber temperature and pressure are below the Drywell Spray Initiation Pressure Limit, shut down recirculation pumps and drywell cooling fans and initiate drywell sprays.

SCO 200 250 C 240 L

N220 JN $ A F E

?

I200 t

l is0 E es0 I

ei.o i

510 l

5Em t

R eO SO O

to to 30 40 50 60 70 SO 90 SUPPRES SION CHAMBER PRESSURE (PSIG)

DRYWELL SPRAY l

INITIATION PRESSURE LIMIT Appendix I Page 27 of 48

-.m...

PC/P-4 If suooression chacber oressure car.nc: ce maintained below the Pressure Suppression Pressure, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED.

,_+_-

+4 SANEI

2

$' o I

u sara.

5

-e

+i

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.o 4.

so u

SUPPRES$10N CHAMSER PRES $URE (PSIG)

Pressure Suppression Pressure PC/P-5 If suppression chamber pressure cannot be maintained below 58 psig (the Primary Containment Design Pressure), RPV FLOODING IS REQUIRED.

1 Appendix I Page 28 of 48

PC/P-6 If suceression cha=ber cressure can=c: ce maintained below 58 psig-(the Primary Containment Pressure Limit), then irrespective of whether adequate core cooling is assured:

Initiate suppression pool sprays.

If suppression chamber temperature and pressure are below the Drywell Spray Initiation Pressure Limit, shut down recirculation pumps and drywell cooling fans and initiate drywell sprays.

500

.. : :....a i..... t., <,.......<- e. '., ; ; m_

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'*0

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:U:m ':"";.:::: Int:::::::::::: Int ::=

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E

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u :;,g., g,.

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t-u t e : :: n.:::::::==============.

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J

. :::;..nnum::::= ::.".:::::= ::U In:

5 es: :;l: MJ. n m:n::::== ::::=========

: : : p ~ =.=.====.==.=-.==,=.r=er=ra==,==.,=,=====,:::e::==.

m g

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=

z too u

6, 20

.=

l E too l

Io l

m ao e

l so l

40 0

10 to 30 40 50 so 70 So 90 SUPPR E SSION CHAMBER PRESSURE (PSIG)

DRYWELL SPRAY INITIATION PRESSURE LIMIT PC/P-7 If suppression chamber pressure exceeds 58 psig (the Primary Containment Pressure Limit), vent the primary containment in accordance with the procedure

22 l

containment venting to reduce and maintain pressure below the Primary Containment Pressure Limit.

1 l

i Appendix I Page 29 of 48

SP/L Monitor and control suppression cool water level.

SP/L-1 Maintain sup;iression pool water level between 27 inches (maximum suppression pool water level LCO) and 31 inches (minimum suppres-sion pool water level LCO), Refer to the

8, #9 sampling procedure prior to discharging water.

t SP/L-2 If suppression pool water level cannot be maintained above the Heat Capacity Level Limit, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED; enter the RPV Control Guideline at Step RC-1 and execute it concurrently with this procedure.

TABLS 1. (SP/L) DeSAT C APACITY LSD EL WEDIT rY IIveeNT

'Nes' eses 'N r

terF 9000 TO **00 seg een 70 *000 so g

'88

300 TO eDO song

'W' y00 TO 900 poif

'W' e00 TO 700 seg

'98* '

900 TO ene on g

'43*'

e.

.00, 0,00 300 70 00 seg e f ** *

.,0 3 s.r.

,,0,0.

ef Ls58 ?inase ttopong g.pj oeCa w'

-2

\\

p J.

sars.

s

--m-g4 "N

.e 5

~

l 6W<:

k

__e 0

10 20 30 40 50 AT c(erg H

Heat' Capacity Level Limit

+

4 Appendix I Page 30 of 48 s_

{

- = ' at n in ed SP/L-3 If suppression pool water level cannoe aa below 27 inches (maximum suppression pool water level LCO):

SP/L-3.1 If adequate core cooling is assured, terminate injection into the RPV from sources external to the primary containment.

SP/L-3.2 If suppression pool water level cannot be

13 maintained below the Suppression Pool Load

14 Limit, maintain RPV pressure below the Limit.

+s M

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F, I

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1 :

4

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i M

i i i i f i

-2 i

i

i1 i:

1 li

i

l ii i;'

i r

i i i

iiiii 700 800 900 1,000

100 REACTOR PRESSURE (PSIG)

Suppression Pool Load Limit If suppression pool water level and RPV pressure cannot be restored and maintained below the Suppression Pool Load Limit, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED; enter the RPV Control Guideline at Step RC-1 and execute it concurrently with this procedure.

Appendix I Page 31 of 48

SP/L-3.3 Before suppression pool water les A reaches -1 inch (elevation of bottom of Mark I Reactor Building to suppres-

18 sion chamber vacuum breakers) but only if suppression chamber temperature and pressure are below the Drywell Spray Initiation Pressure Limit, shut down recirculation pumps and drywell cooling fans and initiate drywell sprays.

Soo tto 26.

E 2.o L

Ntto UN S A FE E

atoo

_.[to b f6.

i

^

ei.o o

W

=

2 eoo t

E eo Go a

o

,o to so..

.o

.o 1.

.o

.o SUPPRESSION CHAMBER PRESSURE fPSIG)

DRYWELL SPRAY INITIATION PRESSURE LIMIT l

l l

l Appendix I Page 32 of 48 o

(_

n.

e SP/L-3.4: If suppression pool water level exceeds -1. inch (elevction of bottom of' Mark I Reactor. Building to suppres-

23 L __

sion chamber vacuum breakers), continue

-to operate drywell sprays.

S 1

Appendix I Page 33 of 48

1 l

CONTINGENCY ul LEVEL RESTORATION If while executing the following steps:

Boron Injection is required, enter C0!GINGENCY #7.

RPV water level cannot be determined, RPV FLOODING IS REQUIRED; ent.er CONTINGENCY #6.

-RPV Flooding is required,' enter CONTINGENCY #6.

Cl-1 Line up for injection and start pumps in two or more of the following injection subsystems:

Condensate RHR A RHR B-RHR C~

=.

RHR D

~

Core' Spray A' Core Spray B If-less than two of the injection subsystems can be lined up, commence lining up as many of the following alternate injection subsystems as possible:

Fire System ECCS Keepfill Systems t

c Condensate Transfer System SLC (test tank)

SLC (boron tank)

J RER Service Water Cross-tie l'

Appendix'I Page 34 of 48 ci

-e w

.r

-e r---

-+ -

-,,r.

u a

-_L

,w a

au-y Cl-2 Monitor RPV pressure and water level.

Continue in tnis procedure at

~

the step indicated in.the following table.

RPV PRESSURE REGION (350 psig)1 (120 psig)*

HIGH INTERMEDIATE LOW INCREASING Cl-3 C1-4 Cl-5 RPV.

LEVEL

~

DECREASING Cl-6 Cl-7 (RPV pressure at which core spray shutoff head is reached) 2 4.

(

(HPCI low pressure isolation setpoint) 8 If while executing the following steps:

The RPV water level trend reverses or RPV pressure changes region, return to Step Cl-2.

RPV water level drops below +45 inches (ADS initiation setpoint), prevent automatic initiation of ADS.

C1-3'RPV WATER LEVEL INCREASING, RPV PRESSURE HIGH Enter the RPV Control Guideline at Step RC/L.

Cl-4 RPV WATER LEVEL INCREASING, RPV PRESSURE INTERMEDIATE IF HPCI and RCIC are not available and RPV pressure is increasing, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED. When RPV pressure is decreasing, enter the<RPV Control Guideline at Step RC/L.

If HPCI and RCIC are not available and RPV pressure is not increasing, enter the RPV Control Guideline at Step RC/L.

If HPCI or RCIC-is available, when RPV water level reaches +162.5 inches (Iow level scram setpoint), enter the RPV Control Guideline at Step RC/L.

Page 35 of 48

Appendix I e--

m

+y-w w

.w-y

-c-w

,--,y,e y-=.e

-,,-ew+--sw-+,+-ge

--=9.,+e--y--yp--

,eww s-,,

<-g--ep4-==-

Cl-5 RPV WATER' LEVEL INCREASING, RPV PRESSURE LOW If RPV pressure is increasing, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED. When RPV' pressure is decreasing, enter the RPV Control Guideline at Step RC/L.

'Otherwise, enter the RPV Control Guideline at Step RC/L.

C1-6 RPV WATER LEVEL DECREASING, RPV PRESSURE HIGH OR IhTERMEDIATE If HPCI or RCIC is not operating, restart whichever is not operating.

If no CED pump is operating cnd no injection subsystem is lined up for injection with at least onc pump running, start pumps in alternate injection subsystems which are lined up for injection.

When RPV water 1cvel drops to 0 inches (top of active fuel):

LIf no system, injection subsystem or alternate injection subsystem is lined up with at least one pump running, STEAM COOLING IS REQUIRED. When any system, injection subsystem or alternate injection subsystem is lined up with at least one pump running, return to Step C1-3.

If any RPV injection exists, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED. When RPV water level is increasing or RPV pressure drops below 120 psig (HPCI low pressure isolation setpoint) return to Step Cl-3.

Cl-7 RPV WATER LEVEL DECREASING, RPV PRESSURE LOW If no core spray subsystem is operating, start pumps in alternate injection subsystems which are lined up for injection.

If RPV pressure is increasing, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED.

When RPV water level drops to 0 inches (top of active fuel),

enter CONTINGENCY #4.

e Appendix I Page 36 of 48

( n-CONTINGENCY r2-EMERGENCY RPV DEPRESSURIZATION C2-1 When either:

13, #14 Boron Injection is required and all injection into the RPV except from boron injection systems and CRD has been terminated'and prevented, or Boron Injection is not required, C2-1.1 Open all ADS valves.

If any ADS valve cannot be opened, open other

. SRVs until seven (number of SRVs dedicated in.

ADS) valves are open.

C2-1.2 If less than three (Minimum Number of SRVs Required for Emergency Depressurization) SRVs are open and RPV pressure is at least 50 psig

22 (Minimum SRV_ Reopening Pressure) above suppression chamber pressure, rapidly depressurize the RPV

-using one or more of the following systems (use

-On order which will minimize radioactive release to the environment):

Main Condenser RHR (steam condensing mode)

' Main Stean Line Drains HPCI Steam Line RCIC Steam Line

Head Vent If RP*l Flooding is required, enter CONTINGENCY #6.

C2-2 Enter the RPV Control Guideline at Step RC/P-4.

Appendix'I Page 37 of 48 4

m.-

,---,+--..e

-c....,-

..c--.-.

.---cc

,,,--,,..-,._,r,-

.ow-ep-w,

7 CONTINGENCY #3 STEAM COOLING C3-1 If while executing the following steps Emergency RPV Depressur-ization is required or any system, injection subsystem, or

, alternate injection subsystem is lined up for_ injection with at least one pump running, enter CONTINGENCY #2.

E When RPV water level drops to 100 inches (Minimum Zero-Injection-RPV Water Level)'or if RPV water level cannot be determined, open one SRV.

When RPV pressure drops below 700 psig (Minimum Single SRV Steam Cooling-Pressure), enter-CONTINGENCY #2.

L Appendix-I-Page 38 of 48 4

?

CONTINGENCY s4 CORE COOLING WITHOUT LEVEL RESTORATION-(SPRAY COOLING)

C4-1 Open'all ADS valves.

13 If any ADS' valve cannot be opened, open other SRVs until seven (number of

-SRVs de'dicated to ADS) valves are open.

C4-2 Operate core spray subsystems with suction from the suppression pool.

When at least one core spray subsystem is operating with auction from the suppression pool and RPV pressure is below 120 psig (RPV pressure for rated' core spray flow), terminate injection into the RPV from sources external to the primary containment.

C4-3 When RPV water level is restored to 0 inches (top of active _ fuel), enter the RPV Control Guideline at Step RC/L.

g Appendix I Page 39 of 48

CONTINGENCY v5 ALTERNATE SHUTDOWN COOLING C5-1 Initiate suppression pool cooling.

C5-2 Close the RPV head vents, MSIVs, main steam line drain valves, and HPCI and RCIC isolation valves.

C5-3 Place the control switch for one (Minimum Number of SRVs Required for Alternate Shutdown Cooling) SRV in the OPEN position.

C5-4 Slowly raise the RPV water level to establish a flow path through the open SRV back to the suppression pool.

C5-5 Start one core spray or RHR pump with suction from the suppression pool.

C5-6 Slowly increase core spray or RHR injection into the RPV to the maximum.

C5-6.1 If RPV pressure does not stabilize at least 107 psig (Minimum Alternate Shutdown Cooling RPV Pressure) above suppression chamber pressure, start another core spray or RHR pump.

C5-6.2 If RPV pressure does not stabilize below 164 psig (Maximum Alternate Shutdown Cooling RPV Pressure), open another SRV.

C5-6.3-If the cooldown rate exceeds 100*F/hr (maximum kPV cooldown rate LCO), reduce core spray or RHR injection into the RPV until the cooldown rate decreases below 100*F/hr (maximum RPV cooldown rate LCO) or RPV pressure decreases to within 50 p:;ig (Minimum SRV Reopening Pressure) of suppression chamber pressure, whichever_ occurs first.

.CS-7 Control suppression pool temperature to maintain RPV water temperature above 70*F (RPV head-tensioning limit).

C5-8 Proceed to cold shutdown in accordance with GP-05.

1 o

l

[

l I

Appendix I Page 40 of 48

-e

-,4 y,m--

,.wr

--c--e~,+-y-<-,.

h, e-

w wy---

e

,,-- g--, - - *

--ve-w--,

,-=--,e+,

-,-r m -- m - -

r-,-

we-e-

7 x

CONTINGENCY r!6 RPV FLOODING

- C6-1 If at least three (Minimum Number of SRVs Required for Emergency Depressurization) SRVs can be opened, close the MSIVs main steam line drain valves, HPCI, RCIC and RHR steam condensing isolation valves.

,C6-2 If any control rod. is not inserted to position 00 (maximum subcritical banked withdrawal position):

C6-2.1 Terminate and prevent all injection into the RPV except from boron injection systems and CRD.

If.while executing the following step, RPV water level can be determined and RPV Flooding is not required, enter

. CONTINGENCY #7 and the RPV Control Guideline at Step RC/P-4 and execute these procedures concurrently.

C6-2.2 When RPV pressure is below the Minimum Alternate RPV Flooding Pressure, commence and slowly increase injection into the RPV with the following. systems to maintain RPV pressure above the Minimum Alternate

24 RPV Flooding Pressure:

Minimum Alternate RPV Number of Open SRVs Flooding Pressure (psig) 7 100 6

120 5

145 4

190' 3

250 2

380 1

770 Condensate Pumps CRD RHR Appendix I Page 41 of 43 sw w

v.m y-r

=

eyr--.

w y,.

--=,----+v-gg+v--e rwe,.-e.

,-i-.

-ey,-

e--

e---i.

. =.

/

If RPV pressure cannot be maintainea aoeve une. Minimum Alternate RPV Flooding Pressure, commence and slowly increase injection into the RPV with the following systems to maintain RPV pressure above the Minimum - Alternate RPV Flooding Pressure:

Core Spray s

Fire System ECCS Keepfill Systems Condensate Transfer System RHR Service Water Cross-tie C6-2.3 When:

All control rods are inserted to position 00 (maximum subcritical banked withdrawal position), or The reactor is shut down and no boron has been injected into the RFV, continue in this procedure.

C6-3. If RPV water level cannot be. determined:

C6-3.1 Commence and increase injection into the RPV with the following systems until at least three (Minimum Number of SRVs Required for Emergency Depressurization) SRVs are open and RPV pressure is not decreasing and is at least1100 psig (Minimum RPV Flooding Pressure) above suppression chamber pressure.

Core Spray RHR Condensate Pumps CRD

. Fire System ECCS Keepfill Systems SLC (test tank)

SLC (boron tank)

RHR Service Water Cross-tie Page 42 of 48 Appendix I w

m'

---w-r

-ue

--n-

-- s mre - - '~* - -

v

~twwwe' vw's='w=-

mww-----,

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.C5-3;2-Maintain RPV pressure at least 100 psig t.51ntmu= RPV Flooding Pressure) above suppression chamber pressure by throttling

injection.

C6-4 If RPV water level can be determined, commence and increase injection

-into'the RPV with the following systems until RPV water level is

. increasing:

Core Spray RHR Condensate Pumps CRD Fire System ECCS Keepfill Systems Condensate Transfer System SLC (test tank)

SLC (boron tank)

RHR Service Water Cross-tie C6-5 If RPV water level cannot be determined:

C6-5.1 Fill all RPV level instrumentation reference columns.

C6-5.2 Continue injecting water into the RPV until temperature near the cold reference leg instrument vertical runs is below 212*F and RPV water. level instrumentation is available.

If while executing the following steps, RPV water level can be determined, continue in this procedure at Step C6-6.

C6-5.3 If it can be determined.that the RPV is filled or if RPV pressure is at least 100 psig (Minimum RPV Flooding Pressure) above suppression chamber pressure, terminate all injection into-the RPV and reduce RPV water level.

Appendix I Page 43 of 48

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~If RPV water level indication is not restored within the Maximum Core Uncovery Time Limit after commencing termination of injection into the RPV, return to Step C6-3.

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10 20 30 40 50 WAXIMUM CORE UNCovERY TIME - MINUTES Maximum Core Uncovery Time C6-6 When suppression chamber pressure can be maintained below 58 psig (the Primary Containment Pressure Limit), enter RPV Control Guideline at Steps RC/L and RC/P-4 and execute these steps concurrently.

Appendix I Page 44 of 48

CONTINCENCY t:7 LEVEL / POWER CONTROL If while executing the following steps:

RPV water level cannot be determined, RPV FLOODING IS REQUIRED;

' enter CONTINGENCY #6.

RPV flooding is required, enter CONTINGENCY #6.

C7-1-If:

Reactor power is above 3% (APRM downscale trip) or_cannot be determined, and Suppression pool temperature is above 110*F'(Boron Injection Initiation Temperature), and Either an SRV is open or opens or drywell pressure is above 2.0 psig (high drywell pressure scram setpoint).

lower RPV water level by terminating and preventing all

' njection into the RPV except from boron injection systems i

-and CRD until either:

25 Reacter power drops below 3% (APRM downscale trip), or

~ RPV water level reaches 0 inches (top of active fuel), or All SRVs remain closed and drywell pressure remains below 2.0 psig (high drywell pressure scram setpoint).

If while executing the following steps Emergency RPV Depressurization is required, continue in this procedure at Step C7-2.1.

Appendix I Page 45 of 48

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0 If while executing the following step:

Reactor power is above 3% (APRM downscale trip) or cannot be determined :and RPV water level is above 0 inches (top of active fuel), and

~

Suppression pool temperature is above 110*F (Boron Injection Initiation Temperature), and.

Either an SRV is open or opens or drywell pressure is above 2.0 psig (high drywell pressure scram setpoint),

-Return to Step C7-1.

'C7-2 Maintain RPV water level either:

9, #10, #11, #24 If RPV water. level was deliberately lowered in Step C7-1, at the level to which it was lowered, or If RPV water level was not deliberately lowered.in Step C7-1,

.between +162.5 inches (low level scram setpoint) and

+208 inches (high level trip setpoint),

with the following systems:

RPV Pressure Range System For System Operation Condensate 200-0 psig Condensate / Booster 350-0 psig Feed Pumps 1250-0 psig CRD 1490-0 psig

12 RCIC 1190-62 psig HPCI 1280-120 psig RHR 200-0 psig Appendix-I Page 46 of 48

t-t:

x

'If RPV _ water level cannot be'so maintained, maintain RPV ' water level above 0 inches (top of' active fuel).

If-RPV water level cannot be maintained above 0 inches (top of active fuel), EMERGENCY RPV DEPRESSURIZATION IS REQUIRED:

-C7-2.1 Terminate and prevent all injection into the RPV except from boron injection systems and CRD.

C7-2.2 When RPV pressure is below the Minimum Alternate

24 RPV Flooding Pressure, commence and. slowly increase injection into the RPV with the follow-ing systems to restore and maintain RPV water level above 0 inches (top of active fuel):

Mininum Alternate RPV Number of Open SRVs Flooding Pressure (psig) 7 100 6

120 5

145 4

190 3

250 2

380 1

770 Condensate /Feedwater System CRD RCIC HPCI RHR If RPV water level cannot be restored and maintained above 0 inches (top of active fuel), commence and slowly increase injection into the RPV with the following systems to restore and maintain R.PV water level above 0 inches (top of active fuel):

Core Spray-Fire System Appendix I Page 47 of 48 i

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l ECCS Faepfill Systems Condensate Transfer System RKR Service Water Cross-tie If while executing the following step reactor power commences and continues to increase, return to Step C7-1.

C7-3 When 287 pounds (Hot Shutdown Boron Weight) of boron have been injected or all control rods are inserted to position 00 (maximum suberitical

~ banked withdrawal position), restore and maintain RPV water level between

+162.5 inches (low level scram setpoint) and +208 inches (high level trip setpoint).

If RPV water level cannot be restored and maintained above +162.5 inches (low level scram setpoint), maintain RPV water level above 0 inches (top of active fuel).

'If RPV water level cannot be maintained above 0 inches (top ef active fuel), El:ERGENCY RPV DEPRESSURIZATION IS REQUIRED; return to Step C7-2.1).

If. Alternate Shutdown Cooling is required, enter CONTINGENCY #5.

C7-4 Proceed to cold shutdown in accordance with the End Path procedure.

Appendix I

.Page 48 of 48 k__

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t-u, CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLANT e

APPENDIX II WRITERS' CUIDE Y

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x FOR EMERGENCY OPERATING PROCEDURES 8

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. Appendix II-Page 1 of 46 t

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TABLE OF CONTENTS y

' Section' Page

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1.0 INTRODUCTION

11 ti..

.1;1; PURP0SE;...................'........................-11 e

J 1.2' SC0PE..........;.......'............................

11 2.0- ORGANIZATION OF EMERGENCY OPERATING PROCEDURES..........

11 3.03 ORGANIZATION OF BSEP FLOWCHARTS.........................

11

$3.1; DESIGNATION AND' NUMBERING..........................

11 3.2 REVISION AND' AUTHORIZATION.........................

13

'3.3 UNIT IDENTIFICATION FOR FLOWCHARTS.........'....... 13 3.4 'PAGE IDENTIFICATION................................

13 3.5. F0RMAT.............................................

13 3.6 DECISION SYMB0L....................................

13 3.7' ACTION:SYMB0L......................................

15 3.8' INFORMATION SYMB0L'................................

15 3.9 ARROW SYMB0LS......................................-15 3.10 CONNECTING LINES...................................

15

'3.11: ENTRY CONDITION FOR FLOWCHARTS.....................

15

.3'.12 KEY PARAMETERS.....................................

16 4

3.13 PATH SPECIFIC. PARAMETER........................... 16

'3.14 AUTOMATIC ACTIONS................................. 16 3.15 IMMEDIATE OPERATOR ACTIONS.........................--16 p

3.16 OPERATOR CAUTIONS.................................

16

-3.17 PLACE KEEPING AIDS.................................

17 3.18 WRITING STYLE FOR FLOWCHARTS.......................

17 p

3 Appendix II.

Page 2 of 46 a

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e TABIE OF CONTENTS (Cont'd)

~

Section-Page.

3.19 VOCABULARY....................................... 18 x+

'3.20 SEQUENCING......s.................................

18

-3.21 VERIFICATION STEPS...............'.................

21-7

)

3.22 LOCATION /INFORMATION.............................

21 3.23 NUMERICAL VALUES.................................

21 1

'3.24 ABBREVIATIONS, LETTER SYMBOLS, AND ACRONYMS......

22 i

3.25-TYPING FLOWCHART STEPS...........................

22 w.

3.26 PREPARING'AND MOUNTING FLOWCHARTS................

22 3.27 REPRODUCTION OF FLOWCHARTS.......................

22 p, 3.28 REVISIONS TO FLOWCHARTS..........................

23

(

3;29 LOCATION OF FLOWCHARTS...........................

23

.1 4.0 ORGANIZATION OF BSEP'END PATH MANUALS................

23 7

4.1 DESIGNATION.AND NUMBERING........................

25 14.2 COVER SHEET......................................

25 7

4.3 _ REVISION SHEET.......~............................

25 a

- 4.4-PROCEDURE DESIGNATION AND NUMBERING..............

25 c4.5 REVISION NUMBERING AND DESIGNATION...............

25 4.6 PAGE IDENTIFICATION AND NUMBERING................

28 4.7 F0AMAT...........................................

28 3

4.7;l

'Page Format.............................

28 4.7.2 Procedure Organization..................

28

~

9 4.7.3 Section and Step Numbering.............

30 g

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$.4.8 WRITING INSTRUCTIONAL STEPS.......................

0 3

Ya N

4.8.1' Instructional Step Length and content... 30 I.

3^

Appendix II Page 3 of 46-

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TABLE OF CONTENTS (Cont'd)

- Section-Pg 4.8.2-Use of Logic Terms.....................

32 4.8.3

-Cautions...............................

35 4.8.4 Notes..................................

35 4.8.5

-Calculations...........................

36

-4.8.6

.Use of Underlining.....................

36 t

.4.8.7 Referencing and Branching to Other

Procedures or Steps....................

36

^

4.8.8

' Component Identification...............

37 4.8.9 Level of Detail........................

37 4.8.10 Printed Operator Aids..................

38 4.8.11-Revision to Procedures.................

39 1

4.8.12 Unit Identification for End Path

-Manual Procedures......................

39 4.8.13

. Recurrent Steps........................

39 t.,

4.8.14 Equally Acceptable Steps...............

40 4

5.0 MECHANICS OF STYLE....................................

40 5.1 SPELLING.........................................

40

.5.2 HYPH EN AT ION......................................

4 0 5.3 PUNCTUATION......................................

41 5.3.1 Brackets................................

41 5.3.2 Co1on...................................

41 5.3.3 Comma...................................

41 5.3.4 Parentheses.............................

41 5.3.5

' Period................................. 41 Appendix II Page 4 of 46 u

-TABLE OF CONTENTS (Cont'd)

Section-M 5.4 VOCABULARY.......................................

42 5.5 NUMERICAL VALUES........<........................

42 1

g 5.6 ABBREVIATIONS, LETTER SYMBOLS, AND ACRONYMS......

42 6.0 TYPING F0RMAT.........................................

42 6.1 GENERAL TYPING F0EMAT............................

42 3

6.2-PAGE ARRANGEMENT.................................

43 6.3 HEADING AND TEXT ARRANGEMENT.....................

43 6.4 BREAKING OF W0RD S................................

4 3 6.5 ROTATION OF PAGES................................

4 3 6.6 PRINTED OPERATOR AIDS............................

44 6.6.1 Figures.................,....w,....... 44 6.6.2'

' Tab 1es.................................

44

.6.7 CAUTIONS AND N0TES...............................

4 5 6.8 US E OF FOLDOUT PAGES.............................

4 6 6.9 USE OF OVERSIZED PAGES IN END PATH MANUALS.......

46 6.10 USE OF REDUCED PAGES.............................

46 7.0 REPRODUCTION..........................................

46

j[

Appendix II Page 5 of 46

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A ABBREVIATIONS ADS

-Automatic Depressurization System ANS'.American Nuclear Society

.MRSI.- American National Standards Institute LAOP -' Abnormal Operating Procedure APRM - Average Power. Range Monitor ASDC -LAlternate Shutdown Cooling

~

ATWS - Anticipated Transient Without Scram BOP Balance of Plant CAC - Containment Atmospheric Control CAD - Containment Atmospheric Dilution CCP --Containment Control Procedure

- COND Condensate CONV - Conventional

.CRD - Control Rod Drive

CS-'- Core Spray.

- CST - Condensate Storage Tank

_DW/T - Drywell Temperature TEBOP - Emergency Bearing Oil Pump ECCS - Emergency Core Cooling System EI - Emergency. Instruction E0P - Emergency Operating' Procedure EPP

-End Path Procedure E&RC - Environmental &-Radiation Control ESOP - Emergency Seal Oil. Pump.

p-Appendix II Page 6 of 46

ABBREVIATIONS (Cont'd)

EXCH - Exchanger FW - Feedwater

-CM - General' Manager-GP General Plant Operating Procedure HCLL --Heat Capacity Level Limit

'HCTL - Heat Capacity Temperature Limit HCU1-Hydraulic Control Unit HDR - Header HI - High-HPCI - High Pressure Coolant. Injection HK - Heat Exchanger IA - Instrument Air IAN'- Instrument Air Noninterruptible IRM - Intermediate Range Monitor KV - Kilovolt LCO - Limiting Condition for Operation LEP - Local Emergency Procedure LOCA - Loss of Coolant Accident LPCI. - Low Pressure Coolant Injection LPCS - Low Pressure' Core Spray MCC - Motor Control Center MG - Motor Generator MSIV - Main Steam Isolation Valves MSL - Main Steam Line

-NDTT - Nil-Ductility Transition Temperature NPSH - Net Positive Suction Head Appendix II Page 7 of 46

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.- [

-NUC - Nuclear PC/Pf ' Primary. Containment Pressure

. PEP

. Plant Emergency Plan RAD -[ Radiation

~

-RBCCW - Reactor. Building Closed Cooling Water RCIC

Reactor Core Isolation Cooling.

RC/L - Reactor' Control Level RC/P - Reactdr Control Pressure-

~

'RC/Q'- Reactor Control Power--

RECIRC - Recirculation RHR'- Residual. Heat Removal RPS~--Reactor Protection System

~RPV'- Reactor Pressure Vessel RSCS -- Rod Sequence Control System RTGB - Reactor Turbine Gauge Board

/RWCU - Reactor Water Cleanup

~

j RWM - Rod Worth Minimizer RX - Reactor

-SA - Service Air.

' SAT - Startup Auxiliary Transformer SBGT - Standby Gas Treatment

' SJAE - Steam Jet Air' Ejector SLC.- Standby Liquid Control-SRM - Source Range Monitor

.SORY - Stuck Open' Relief Valve SOS

' Shift Operating Supervisor

Appendix-II Page 8 of 46

~SP/L.- Suppression Pool Level:

SP/T

Suppression Pool Temperature

!.SRP -' System Recovery Procedure SRV.- Safety Relief Valve L

SULCV - Startup Level Control-Valve TB'CW - Turbine Building Closed Cooling Water C

~ TIP - Traversing In-Core Probe t:

Appendi:t II Page 9 of 46

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I I

FIGURES AND TABLES Figure:

h 1-Flowchart Identification 12 2-Standard Logic Symbols 14 3

End Path Arrangement 24 4

Cover Sheet 26 5

-List of Effective Pages 27

6.

Example Procedure-29 Table.

Pages

~1-Action Verbs 19-20

Appendix II Page 10 of 46

w a

'1.0' INTRODUCTION 1.1. PURPOSE

~

-The purpose of'this document is to provide administrative and

-technical guidance on'the' preparation of Emergency Operating

Procedures (EOPs) to ensure that they are complete, accurate, convenient, readable, and acceptable to the BSEP Control Room s

= personnel.

1.2 SCOPE

.This Writers' Guide applies to the writing of BSEP EOPs; i.e.,

flowcharts and the associated written instructions which are in the

' - c7 End Path Manuals.

-2.b'ORGANIZATIONOFEMERGENCYOPERATINGPROCEDURES The E0Ps shall consist of symptomatic or function-oriented procedures which'are in flowchart format and End Path Manuals which are in written format.

c3.0 ORGANIZATION OF BSEP FLOWCHARTS

.The-BSEP Flowcharts shall consist of function-oriented paths.

The EOP Users' Guide outlines the Brunswick E0Ps and describes how these procedures are to be used by the Control Room personnel to handle Lemergency and' potential emergency situations.

3.1. DESIGNATION AND NUMBERING The flowcharts are the procedures that govern the plant operation during emergency conditions and specify immediate operator actions

-to be taken to bound'the problem and to. return the plant to a stable condition.

Each flowchart shall be uniquely identified (see Figure 1). This.

identification permits easy administration of the process of procedure preparation, review, revision, distribution, and operator use.

The identification shall be located at the upper left of each

. flowchart.

" j :.,

Appendix II Page 11 of 46 s

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Appendix II Page 12 of 46

3..

5 n

a

.x The' flowcharts shE11 not have.other identifying titles. The philosophy is for the operator to immediately enter any flowchart when the E0P entry condition occurs. Once the operator enters

~

~the flowchart, it will lead to the proper procedural steps.

3.2 REVISION AND AUTEORIZATION Each fiowchart shall include information which identifies the current revision designation and authorized signatures. This

'information shall be located at the upper right of each flowchart (see' Figure 1).

3.3 UNIT IDENTIFICATION FOR FLOWCHARTS The flowcharts are identical for both units and no unit identifier is.needed.

If a step applies to one unit only, the following format shall.be used:

19. Unit 2 only - START one RHR pump If a step applies to both units and there is a need to differentiate

~

~between units due to nomenclature, valve number, etc., the following format shall be used:

21; Unit 1 only - OPEN HPCI outboard injection valve E41-F007

22. -Unit 2 only - OPEN HPCI outboard injection valve E41-F006

~

3.4 PAGE IDENTIFICATION There shall be no page identification on the flowcharts. The

-Immediate Action Steps for each flowchart shall be included on one page.

3.5 FORMAT The flowcharts shall utilize standard logic symbols (see Figure 2).

These symbols shall be arranged in a decision tree type flowchart consisting of Information/ Caution, Decision, and Action Steps that provide the operator with guidance-intended to bound the problem and get the plant into a safe condition quickly, systematically, and consistently (see Figure 1).

3.6 DECISION SYMBOL This symbol shall contain a question which the operator is to answer YES or NO.

The question shall pertain to a plant parameter, setpoint, switch position, or system condition.

Appendix II Page 13 of 46

1.

FIGURE 2 Standard Logic Symbols s

Appendix II Page 14 of 46

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If the particular step is designated as a key or path-specific parameter, it should have an action symbol superimposed over the standard decision symbol.

These important steps are further highlighted by making the decision symbol lines heavier than normal (see Figure 2).

The operator may be required to return to these steps.

3.7 ACTION SYMBOL This symbol shall contain a specific action, command, or verification which the operator should perform.

3.8 INFORMATION SYMBOL This symbol shall contain information which may be useful to assist the operator in diagnosing plant conditions. The symbol is also used to provide operator cautions. -If the symbol is used for information, "INFORMATION" shall be the first word in the block 3.9 ARROW SYMBOLS There shall be two basic types of arrow symbols used on the flowcharts (see Figure 2).

The path-to-path arrows guide the operator from one flowchart to another. The path-to-end-path arrow guides the operator from the Immediate Action Steps (flowcharts) to the appropriate Subsequent Action Steps (End Path Procedures).

3.10 CONNECTING LINES There shall be two basic line widths used to guide the operator through the flowchart.

The operator should follow these lines, always entering the symbols at the top and exiting the symbols at the sides or bottom.

The wide line, Yellow Brick Road, represents the expected plant response for each flowchart.

The narrow lines are equally important. They represent possible response of the plant for many situations on each flowchart.

No lines shall cross or intersect on the flowcharts, except where two or more enter the same symbol.

3.11 ENTRY CONDITION FOR FLOWCHARTS The entry conditions shall be, "Any Reactor Scram."

The entry condition for each flowchart is identical (see Figure 1).

Appendix II Page 15 of 46

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^3.12 KEY PARAMETERS iEach' flowchart shall-have identical initial formats; i.e.,

the entry I

conditions'followed by the key parameters (see Figure 1).'

+

- The laty parameters are very important. - They establish the priority

'of' actions and guide the ' operator to the appropriate procedure.

.-3.13 PATH-SPECIFIC. PARAMETERS

'The path-specific parameters are located on the Yellow Brick Road.of

.the flowcharts. These steps are emphasized by the use of heavy.

~ decision symbols and superinposed action symbols..

~

3.14 AUTOMATIC ACTIONS The following automatic actions shall be verified on the flowcharts:-

. Group Isolations ECCS: Actuation Diesel Generator Auto Start These actions should-be placed on the flowcharts at points where it is'known that.the-condition for the automatic action has been met.

-As an example, if Path 4 is entered, it is known that reactor water

~

7

~

' level has decreased below +112".

This requires isolation of valve-Groups 1, 2,-3, 6, and 8; auto start of HPCI and RCIC; recire. pump start; etc.. These actions should be verified or manually initiated on-Path 4.

3.15 IMMEDIATE OPERATOR ACTIONS The steps on the flowcharts are the Inunediate' Operator Action Steps.

~

+

These operator actions are taken to stop'further degradation of existing conditions and to mitigate their consequences or to bound

.e

-the problem.

The.immediate operator actions shall be visible to the operator; 1

.therefore, no need or requirement exists to memorize these~ actions.

3.16 OPERATOR CAUTIONS

. Operator cautions shall be included on the. flowcharts where appropriate. The cautions are enclosed in information symbols.

If the symbol is used as a caution, the word " CAUTION" shall be the

+

first word in the symbol.

Cautions shall be placed prior to the step to which they apply.

L Appendix II Page 16 of 46 J._,

m 3.17 PLACE KEEPING AIDS s.

The' flowcharts shall be mounted on a lightweight surface such as styrofoam and covered with a thin transparent layer of plastic, which can be marked on with a felt-tip pen or grease pencil. The operator shall check off the steps of the flowchart as they are performed.

Felt-tip pen ink and grease pencil are easily erased.

3.18 WRITING STYLE FOR-FLOWCHARTS The flowchart steps shall be written in a style that presents the information in a simple, familiar, specific, and unambiguous manner.

The flowchart steps should be brief and exact. The following guidelines should be used for flowchart development:

+

a.

Decision and Action Steps shall deal'with only one idea.

b.

Complex evolutions should be prescribed in a series of steps, if possible.

c.

Operator actions should be specifically stated, d.

Identification of components should be in everyday terms; i.e.,

operator language.

e.

Expected results of routine tasks need not be stated.

f.

Words and meanings shall be consistent throughout the flowcharts.

g.

Use only accepted abbreviations that are familiar to the operator; i.e., the ones listed in this Writers' Guide.

h.

Avoid the use of time-dependent operator actions.

1.

Use units of measure that are familiar to the operator.

The operator should be able to relate the u'its to those referenced n

on the plant instrumentation without conversion, translation, or mental manipulation.

j.

Generally, notes and tables should not be used on flowcharts.

However, it is permissible to use them if this simplifies the procedure.

k.

Word order should be selected to require a minimum of punctuation on the flowcharts.

Appendix II Page 17 of 46

3.19 VOCABULARY Words used in the steps of the flowcharts should convey precise understanding to the trained operator. The following rules are to be used:

a.

Use simple words.

Simple words are usually short words of few syllables.

Simple words are generally common words, b.

Use common usage if it makes the procedure easier to understand.

c.

Use words that are concrete, rather than vague, specific rather than general, familiar rather than formal, precise rather than

blanket, d.

Verbs with specific meaning should be used.

Some examples of suitable verbs are listed in Table 1.

e.

Equipment status shall be denoted as operable, available, er running, depending upon the specific condition of the equipment.

Operable and available mean that the system, component, or device is capable of performing its intended function (s) in the intended manner.

Running denotes that the system, component, or device is performing its intended function (s).

3.20 SEQUENCING Tasks and Action Steps shall be sequenced according to technical necessity, which should be che overriding consideration.

Additionally, the physical layout and organization of the Control Room is an important consideration in sequencing tasks for optimal staff movement and monitoring when performing a sequence of tasks and actions.

Appendix II Page 18 of 46

Table 1.

Examples of Action Verbs 4

Verb Application

ADJUST To regulate.or bring to a more satisfactory state; for example, " ADJUST CAD Tank pressure to 100 psig" ALIGN To' place a system in proper or desired configuration for an intended purpose; for example, " ALIGN CAD Vaporizer to Reactor Building" ALLOW-To permit a stated condition to be achieved prior to proceeding; for example, " ALLOW discharge pressure to stabilize" CHECK' To perform a comparison with a procedural

+

requirement; for example, " CHECK Reactor Building Area Radiation and Vent Radiation Monitors" CLOSE.

To change the physical position of a mechanical device so that it prevents physical access or flow or permits passage of electrical current; for example, "CLOSE Valve FW-V177" COMPLETE To accomplish specific procedural requirements; for example, " COMPLETE data report QA-1, " COMPLETE Steps 7 through 9 of Section III"

ESTABLISH To make arrangements for a stated condition; for example, " ESTABLISH communication with the Control Room" INSPECT To measure, observe, or evaluate a feature or characteristic for comparison with specific limits; method of inspection should be included; for example, " visually INSPECT for leaks" ISOLATE To close one or more valves in a system fo* the

' purpose of separating or setting apart a complete system or a portion of the system from the rest;

.for example, " ISOLATE Interruptible Instrument Air Header using RTGB Controls"

-MAINTAIN To keep :Ln an existing state; for example, MAINTAIN the reactor vessel water level between +162 and +208 inches, with.one or more of the following systems.

-Appendix 11 Page 19 of 46

Table 1.

Examples of Action Verbs (Continued)

V_e_rb -

Application OPEN To change the physical position of a mechanical device, such as valve or door, to the unobstructed position that permits access or, prevents passage of electrical current; for example, "0 PEN Valve FW-V177" PLACE To~put in a particular position; for example, " PLACE mode switch to ' SHUTDOWN'"

. RECORD To document specified condition or characteristic; for example,

" RECORD discharge pressure"

- REDUCE

.To cause a parameter to decrease in value; for example, " REDUCE reactor pressure with Bypass Valve Manual Jack" SET.

To physically adjust'to a specified value an adjustable feature; for example, " SET HPCI Speed Controller to maintain RPV water level near normal" START To originate motion of an electric or mechanical device directly or by remote control; for example, " START RHR and Core Spray Pumps" STOP Opposite of start; for example, "STOP the Condensate Pumps" SYNCHRONIZE To make synchronous in operation;.for example,

" SYNCHRONIZE the Diesel Generator to the (E) Bus" THROTTLE To operate a valve in an intermediate position to obtain a certain flow rate; for example, " THROTTLE Valve Ell-F017A to..."

TRIP To manually activate a semi-automatic feature; for example,

" TRIP incoming Feeder Breakers to 4KV Emergency (E) Busses" VENT To permit a gas or liquid confined under pressure to escape at a vent; for example, " VENT CRD Scram Air Headers" VERIFY To observe the expected condition or characteristic; for example, " VERIFY on Ojt START both CRD Pumps" Appendix II Page 20 of 46 N

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= ~

4 m

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sc l

r 3.21 VERIFICATION' STEPS-u 1 Verification Steps are used to determine whether the objective of a

~

~"

task or a sequence'of actions has been achieved. This is easily.

accomplished on the flowchart; e.g., " Manually start HPCI" followed by;"HPCI. Start Successful?" In this example the operator would check off;the Command Step, enter the Verification Step, check it off, then. continue'following the appropriate-route.

This arrangement-ensures that equipment response and operator

~

actions have occurred and are correct for given situations.

If an-Action Step cannot be accomplished, the operators are trained to so indicate; i.e... circle the step and continue on through the procedure.

h-

- 3.22' LOCATION INFORMATION

.11e flowchart steps shall provide' necessary information on the location'of equipment. controls, or displays that are infrequently used, are in out-of-the-way places, or are otherwise difficult to

. find.

Additional location information should be provided in the End Path Manuals,-Operator Training,-and at remote locations.

s

- 3.23 NUMERICAL. VALUES-

-The,use of numerical values shall be consistent with the following rules:.

a.

Arabic numerals shall be used.

j b.

For numbers less than unity, the decimal point shall be preceded by a zero; for example. 0.1.

c.

The number of significant digits shall be equal to the-number of significant digits available from the display and reading precision of the operator.

d.

Acceptance values should be specified in such a way that addition and' subtraction by the user is avoided, if possible.

This can generally be done by stating acceptance values as limits. Examples are as'follows:' +170 inches ~ minimum, +200 inches maximum, +170 inches to +200 inches. A statement of midpoint and the upper and lower limits may be used when appropriate; for example, 10 mil 11 amperes (9.5 to 10.5).

Avoid using +.

e.

Engineering units should always be specified for numerical r

values of process variables.. They should be the same as those used on the Control Room displays; for example, psig'instead of psi.

gAppendix II Page 21 of 46 kaa,., O.-.. ii

y 3

3.24 ABBREVIATIONS, LETTER SYMBOLS, AND ACRONYMS The use of unfamiliar abbreviations should be avoided because they may be confusing to those who are to use the procedures.

Abbreviations may be used, where necessary, to save time and space and when their meaning is unquestionably clear to the operator.

Consistency should be maintained throughout the flowcharts (see Abbreviation. List in this document).

Capitalization of abbreviations should be uniform. The period should be omitted in abbreviations, except in cases where the omission would result in confusion.

Abbreviations, symbols, and acronyms should not be overused. Their use should be for the benefit of the reader. They can be beneficial by saving reading time and ensuring clarity when space is limited.

3.25 TYPING FLOWCHART STEPS Gothic elite, pitch 12, typewriter element shall be used.

The flowchart steps should be typed on Standpat Applique System pressure sensitive sheets. The words of each step should be arranged; i.e., centered to best utilize the available space. Avoid typed information toGchitig-"Efre symbol borders.,

3.26 PREPARING AND MOUNTING FLOWCHARTS The flowcharts' layout (i.e., symbols and connecting lines) are prepared on sheets of 3 mil matte polyester drafting film.(mylar) using standard drafting instruments; i.e., a special template and filmograph drawing leads such as Berol No. 6375 El.

The typed steps are then transferred to the drawing film.

The completed flowcharts shall be reduced by 50% and mounted on lightweight boards such as styrofoam.

\\

Each board shall then be laminated with a thin, transparent plastic material.

Each flowchart board may be framed with lightweight aluminum for additional strength.

3.27 REPRODUCTION OF FLOWCHARTS Reproduction of the flowcharts may be done on a standard blueprint copier. All copies of flowcharts must be legible and readable under s

expected conditions of use.

Reduced flowcharts on film (mylar) should be used for the original.

t w

Appendix II Page 22 of 46 L

g.

Ll 3.28 REVISIONS TO FLOWCHARTS

~

JThe current revision of'each' flowchart shall'be maintained on film (mylar), both full size and half size, and be kept in the plant vault along with paper reproductions of prior revisions.

When changes occur in the plant design, Technical Specifications,.

Technical Guidelines, Writers' Guide, other plant procedures or Control Room that will affect the flowcharts, the flowcharts should be revised on a timely basis to reflect these changes.

In addition, when operating and training. experience, simulator exercises, control rcom walk-throughs'or other information indicates that incorrect or

'7,?

incomplete-information exists in..the flowcharts, the flowcharts should be revised on a timely basis. These changes should be reviewed.to ensure coneistency with the Technical Guidelines ar.d the Writers' Guide.

Operators should be encouraged to suggest improvements to the flowcharts.

.3.29 LOCATION OF FLOWCHARTS The flowcharts and End' Path Manuals shall be located conveniently to the operator. A table that is-dedicated for E0P use only shall be located in the Control Room for each unit. This table shall be large enough to accommodate the End Path Manual when it is fully extended. Each table shall have one complete set of E0P-01.

Additional. copies of procedures shall be maintained in Operations working files.

Each table shall have a chart rack. This rack will hold all flowcharts. The rack will be staggered in a manner that makes the

. path number of each flowchart visible.

4.0 -ORGANIZATION OF BSEP END PATH MANUALS The Brunswick End Path Manuals consist of the following written procedures:

e a.

End Path Procedures (EPP) b.

Containment Control Procedures (CCP)

System' Recovery Procedures (SRP) c.

d.

Local Emergency Procedures (LEP)

):.

e.

Contingency Procedures (CP)t The above procedures shall be in identical format. The five sections of

~

the End Path Manual shall be located as indicated by Figure 3.

Appendix II Page 23 of 46 3

FIGURE 3 t

I l

Appendix II Page 24 of 46

4.1 DESIGNATION AND NUMBERING

_The End Path Manuals contain the instructions that govern the plant operation during emergency conditions and specify the subsequent operator actions to be taken to return the plant to a stable condition.

Each procedure shall be uniquely identified. This identification permits easy administration of the. process of procedure preparation, review, revision, distribution, and operator use (see Section 4.0).

4.2. COVER SHEET-Every End-Path Manual. Procedure shall have a cover sheet (see

' Figure 4).

The purposes of this cover. sheet are:

(1) to identify the procedure and (2) to indicate the approval status. A descriptive title is to be used that identifies the procedure.

4.3 REVISION SHEET' Every procedure shall.have a revision sheet (see Figure 5).

The revision sheet will be the second page of each procedure.

4.4 PROCEDURE DESIGNATION AND NUMBERING The identifying number and designation for all procedures in the En'd Path Manuals shall include the information contained in the following example:

Example:

BSEP/VOL VI/EOP-01/EPP-2A Specific Identification End Path Procedure 2A Procedure Designation Plant Operating Manual Volume Plant Designation 4.5 REVISION NUMBERING'AND DESIGNATION The latest. revision shall be indicated on the cover sheet for each procedure (see Figure 4).

Appendix II Page 25 of 46

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FIGURE 4 Cover Sheet

o.

A Pendix II Page 26 of 46 P

u-

f-j' FIGURE 5

.<(

List of Effective Pages I

l p

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f

Appendix II Page 27 of 46

4 The second sheet of each procedare shall be the revision sheet (see Figure 5). This sheet contains a list of effective pages and revision numbers.

At the lower right hand corner of each page of the procedure, wit..

the exception of the cover page, the abbreviation "REV" will be used, followed by digits denoting the current revision for each page.

To identify revisions to the text of the procedure a change bar, located in the right margin alongside the text change, will be used to indicate a change in the text (see Figure 6).

4.6 PAGE IDENTIFICATION AND NUMBERING Each page of the procedure shall be identified by:

(1) the procedure designator and number (located on lower Icft of sheet),

(2) the page number specified as "Page,_,of __," (this information shall be centered at the bottom of each page, as shown in Figure 6),

and a revision number on the lower right of each sheet; i.e., REV. 01.

4.7 FORMAT The format for cach procedure in the End Path Manual shall be consistent.

4.7.1 Page Format A sentence format shall be used for all procedures in the End Path Manual. A sample page format is presented in Figure 6.

4.7.2

. Procedure Organization The following section headings shall be used for all procedures in the End Path Manuals a.-

TITLE - The title shall be stated for operator association with the entry conditions.

The example title (Figure 6) represents a title for an End Path Procedure.

Other examples of procedures in the End Path Manual:

Example As Drywell Temperature Control Example B:

System Recovery Procedure for TBCCW Appendix II Page 28 of 46 L

t n

FIGURE 6 Example Procedure s

t t

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l P

Appendix II

i b.

, PLANT CONDITION OR INTRY CONDITION - The entry conditions for the End Path Procedures are the plant

^

conditions which exist at the exit point from the flowchart.

Figure 6 is an example of an End Path F

Procedure for which the plant condition (entry condition) is exit pcint A on Flowchart 2.

Another example of an entry condition is as follows:

Example: Drywell temperature above 135'F The entry conditions should include alarms, indications, operating conditions, automatic system actions, or other unique symptoms that the operator is to use. These conditions guide the operator whether or not to execute the procedure.

c.

OPERATOR ACTIONS - The operator actions will be short, concise, identifiable instructions that give appropriate directiot to the user.

4.7.3 Section and Step Numbering Instructional steps will be numbered and indented as follows:

4 C.

OPERATOR ACTIONS 1.

VERIFY.

a.

CHECK.

(1)

POSITION.

Operator, place keeping aids are indicated by a horizontal line as shown above.

t 4.8 WRITING INSTRUCTIONAL STEPS Writing instructional steps shall be consistent in the End Path '

Manuals.

~

9 4.8.1 Instructional Step Length and Content I

Instructional steps will be concise and precise.

Conciseness denotes brevity;-preciseness means exactly

-defined. -Thus, instructions should be short and exact.

General rules to be used in meeting these objectives are as follows:

a.

Instructional steps should deal with only one idea.

' Appendix II Page 30 of 46 1

2..

l i/

't b,

. Short, simple sentences should be'used in preference to long, compound, or complex sentences.

f][L c.

Complex evolutions should be prescribed in a series

[Fyi g ;

of steps, with each step made as' simple as f.

i/) j{,

practicable.

I' u) d.

Objectives-of operator actions should be specifically

[3

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. 4 stated. This includes identification of exactly what is to be done and to what.

3 ' ;'

a

. e.

For instructional steps that involve an action verb y

- relating to three or more objects, the objects will be listed with space provided for operator checkoff.

3 I-f.

Limits should be expressed quantitatively whenever possible (refer to Subsection 3.23).

g.

Mandatory sequence of steps is assumed unless otherwise stated..

. h.

- Identification of components and parts should be complete.. Equipment and system names should be highlighted by initial capitalization.

Instruction content should be written to communicate i

to the user.

j.

Expected results of routine tasks need not be' stated.

p k.

When actions are. required based upon receipt of an annunciated alarm, list the setpoint of the alarm for ease of verification.

1.

When requiring resetting or restoration of an alarm i

s or' trip, list the expected results immediately, following the resetting or restoration, if it would be beneficial to the operator.

i

.T m.

When considered beneficial to the user for proper l it understanding and' performance, describe the system response time associated with performance of the instruction.

n..

When system response dictates a time frame within which the instruction must be accomplished, prescribe such time frame.

If possible, however, avoid using time to initiate operator actions. Operator actions should be related to plant parameters.

' Appendix II:

Page 31 of 46 e v e

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When additional _ confirmation of system response is considered necessary, prescribe the backup readings to be made.

4.8.2 Use of Logic Terms / Statements The logic terms AND, OR, NOT, IF NOT, WHEN, THEN, and IF are often necessary to describe precisely a set of conditions or sequence of actions.. When logic statements are used, logic terms will be highlighted so that all the

. conditions are. clear to the operator.

Emphasis will be achieved by using capitalization and underlining. All.

letters of the logic terms shall be capitalized, and the words will be. underlined.

Use logic terms as follows:

a.

Use of AND:

When attention should be called to combinations of conditions, the word AND shall be placed between the description of each condition.

Example:

16.

IJ[ RWCU_ has isolated AND a break in the RWCU System is not suspected, THEN RESET the Group 3 isolation AND RESTART RWCU.

(OP-14)

The word AND shall not be used to join more than three conditions.

If more than three conditions need to be jcined, a list format shal1~ be used. The list format may be used to' join less than four conditions when it makes the procedure more readable.

Example:

22.

WHEN:

a.

Reactor vessel level can be maintained above +170 inches AND b.

Reactor' pressure can be maintained below 1045 psig AND c.

Primary containment parameters are within the limits specified in the Containment Control Procedure, Appendix II Page 32 of 46

rz:,

THEN EXIT this procedure AND ENTER the appropriate section of the General Plant Operating Procedure for

- hot. standby or cold shutdown as directed by the SOS.

When used as a single or compound conjunction, the

- word "and" need not be emphasized.

Example:

12.

TRIP HPCI turbine and place in " STANDBY",

b.

Use of OR:

The word Oj! shall be used when calling attention to alternate combinations of conditions. The use of the word fg! shall be in the inclusive sense.

Example:

14.

IF:

a.

All control rods are fully mounted fyt b.

The reactor is shutdown and no boron has been injected

))Ijgi continue in the procedure Step 20.

The use of OR in the exclusive sense will be avoided whenever poss'ible. To specify the exclusive "0R",

the following may be used:

"either A Oft B but not both."

c.

Use of ))[, IF NOT, WHEN, and THEN When Action Steps are contingent upon,certain conditions or combinations of conditions, the step shall begin with the words ]g[ or WHEN followed by a description of the condition or conditions (the.

antecedent), a comma, the word THEN, followed by the action to be taken (the consequent). WHEN is used for an expected condition. ))[ is used for an unexpected but possible condition.

Example:

15.

))[' the MSIVs are open, THEN rapidly DEPRESSURIZE the reactor with the bypass valve opening jack.

18.

WHEN reactor pressure is below 200 psig, THEN PLACE control switches for three SRVs to "0 PEN,"

Appendix 11 Page 33 of 46 mr--

Use of IF NOT should be limited to those cases in which the operator must respoud to the second of two possible conditions. Jg[ should be used to specify the first condition.

1 Example:

))[ reactor vessel level is increasing, THDI TRIP one RHR pump. IF NOT, THEN START one RHR pump.

THEN shall not be used at the end of an Action Step

-to instruct the operator to perform the next step because it runs actions together.

Example:

12.

Verify all control rods are fully inserted, THEN commence a reactor dispressurization per GP-05.

Actions which are imbedded this way (1) may be overlooked and not-be-performed, (2) make it difficult to verify the performance of each action when a checkoff or sign-off is used, and (3) can be confused with a logic statement.

d.

Combinations of Logic Terms The use of AND and OR,, along with E and THEN, within the same step.should be avoided. When AND and OR are used together, the logic statements can be-confusing and ambiguous. For example:

IF condition A AND condition B OR condition C occurs, THEN go to Step 5.3.6 This statement has two possible meanings:

(1) IF both condition A AND condition B occur, THEN IUitoStep5.3.6 (2) ))[ both condition A AND condition B occur, THEN go to Step 5.3.6 pR_

Jg[ both condition A AND condition C occur, THEN go to Gtep 5.3.6.

If the use of AND and 011 within the same step cannot be avoided, the more explicit form (as illustrated in examples.1 and 2 above) should be used.

Appendix II Page 34 of 46

y 4

4.8.'3 Cautions End Path Manual cautions shall be included in the written

-procedure in a format that makes them stand out from the steps of a procedure.

The cautions shall be placed immediately before the procedural steps to which they apply.

The caution in its entirety shall be completed on the same page as the instructional step to which it applies.

The cautions should have a row of asterisks before and after them.

Cautions shall extend across the entire page and shall be highlighted as shown in Figure 6.

This placement of cautions helps ensure that the procedure user observes the caution before performing the step.

It should be used to

' denote a potential hazard to' equipment or personnel

. associated with or consequent to the subsequent instructional step. A caution statement should not include an action.

Example Caution:

CAUTION Large reactor power oscillations may be observed while executing this step.

- - - - w*************************

4.8.4 Notes If additional information other than cautions is necessary to support an action instruction, a note should be used.

A note should present information only, not instructions.

The note should be centered and indented approximately eight spaces from the margin. The note in its entirety shall be completed on the same page as the instructional step to which it applies.

Example Note:

NOTE The reactor head flange and head temperatures should be maintained greater than 70*F when head bolts are tensioned.

Page 35 of 46

. Appendix II w.-4

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p 4.8.5 Calculations Mathematical calculations should be minimized in.the LEOPs. If'a value has to be determined in ordec to perform a procedural step, a chart or graph should be used whenever possible.

'4.8.6 Use of Underlining Underlining will be used for emphasis of logic terms,

. cautions, notes,. miscellaneous emphasis, and conditional statements.

4.8.7 Referencing and Branching to Other Procedures or Steps a.

Referencing-Referencing implies-that an additional procedure or additional steps will be used as a supplement to the procedure presently in use. Referencing other steps within the procedure being used, either future-steps or completed steps,~should be minimized. When only.a few steps are involved in'the referencing, the steps should be stated in the procedure wherever they are needed.

If_ referencing cannot be avoided, the following format should be used:

To reference a step _within the same procedure:

1.

.))[ all control rods are fully inserted,-

THEN CONTINUE la this~ procedure at Step 15.

To refererne steps _ contained in another procedure:

5.

Il[ suppression pool temperature AND reactor

_ pressure CANNOT be restored AND maintained in the " SAFE" region of the Heat Capacity Temperature Limit graph, (see Figure 1, SP/T), THEN reactor depressurization is 3

required. DEPRESSURIZE the reactor per Step 6 in the "End Path Procedure."

b.

Branching Example of concurrent procedure use: ))[while executing this procedure, any of the following

_ primary containment parameters are exceeded, THEN ENTER the associated procedure in the Containment Control Section of this End Path Manual and EXECUTE it concurrently with this procedure.

' Appendix II Page 36 of 46

me

~

a-4 1

ti' g

Example of, branching from one procedure to another:

J'

~

IJ[ reactor vessel _ level CANNOT beLmaintained above 0 inches, THEN EXIT this'End Path Procedure and ENTER 4

the " Level-Restoration: Procedure" in the Contingency

~

Section=of this End Path Manual.

- Use quotation marks to emphasize the title.of the

~

referenced or branched procedure; for example, THEN EXIT this' procedure land ENTER the " Steam; Cooling s

Procedure" in the Contingency Section of this End

^

Path' Manual.

m 4.8.8 Component Identification With respect to identification of components, the following rules are to be followed:

a.-

Equipment, controls, and displays will be identified

- y

' in operator language (common usage) terms. These terms;may not always match engraved names on panels but will be complete.

A b.

When the engraved names and numbers of panel; placards and alarm windows are specifically the item of concern in the procedure, the engraving should be quoted verbatim and emphasized by using all capitals.

c.

The names _of plant system titles are emphasized by initial capitalization.

d.-

If;the component is seldom used or it is felt that Lthe! component would be difficult to find, location information should be given in parentheses ~following the identification.

4.8.9 Level of Detail Too stich detail in E0Ps should be avoided ~in the interest of being-able to effectively execute the instructions in a timely manner. The level of detail raquired is the detail-that a newly trained and licensed operator would desire

~

during an emergency. condition.

l

~

To assist in identifying the appropriate level of detail, the follewing examples of verb use may be used:

a.

For power-driven rotating equipment, use START,

- STOP.

b.-

For valves, use OPEN, CLOSE, THROTTLE open,

[

THROTTLE close, THROTTLE.

w p.

Appendix IIf Page 37 of 46-e

For power distribution breakers, use SYNCHRONIZE, c.

CLOSE, and TRIP.

d.

For control switches with a position placement that establishes a condition, the verb " PLACE" should be used, along with the engraved name of the desired position; i.e., PLACE the Mode Switch to " SHUTDOWN._"

Standard practices for observing abnormal results e.

need not be prescribed within procedural steps.

For example, observation of noise, vibration, erratic flow, or discharge pressure need not be specified by steps that start pumps.

4.8.10 Printed Operator Aids Printed operator aids should be used in order to avoid calculations in the E0P, assist operator decision making, or consolidate information.

When information is presented using graphs, charts, tables, and figures, these aids must be self-explanatory, legible, and readable under the expected conditions of use and within the reading precision of the operator.

a.

Units of Measure Un16s of measure on figures, tables, and attachments should be given for-numerical. values that represent observed, measurement data, or calculated results. A virgule (slant line) should be used instead of "per."

f Examples:

ft/sec, lbs/hr

' b.

Titles and Headings f.

Capitalization should be used for references to

- tables and figures within text material and column headings with a table.

Examples: Refer to Figure 201 for.

. as shown in Table 201, Equipment Power Supplies, the.

c.

Figure, Table, and Attachment Numbering Sequential arabic / numbers should be assigned to figures, tables, and attachments in separate series. The sequence should correspond with the order of their reference in the text. The symbol

"#" and abbreviation "No." are unnecessary and should not be used. The number alone suffices.

Appendix II Page 38 of 46 p.-,.-

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J

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~

(following formats may be used for these steps:

IJ[ while. executing this procedure,-reactor L3..

vessel level CANNOT be determined OJL reactor

-=

l vessel flooding'is required, THEN EXIT this End Path. Procedure AND ENTER the " Flooding Procedure" in the Contingency section of this End Path Manual.

6.

MAINTAIN' reactor pressure below 950 psig with

-SRVs.

Use opening sequence'A, E, J, B, F, D, G,.

C, H.

4'.8.14

' Equally Acceptable Steps Equally acceptable. steps are those for which a number of alternate steps:may1be equally acceptable. The most acceptable method should be the first step.

If this step cannot be accomplished, an alternate method should be provided.'

.5.0 MECHANICS OF STYLE.

5.1. SPELLING

' Spelling should be consistent with modern usage. When a choice of spelling is offered by a dictionary, the first spelling.

should be used.

5.2 ' HYPHENATION.

Hyphens are used between elements of a compound word when

~

usage calls for it.

The following rules should be followed-

' ~

for hyptienation:

a.

When doubt exists, the compound word should be restructured to

-avoid hyphenation.

I b.

Hyphens should be used in the following circumstances:

In compound numerals from-twenty-one to ninety-nine; for example:

one hundred thirty-four In fractions; examples: one-half, two-thirds.

In compounds with "self"; examples:

self-contained, self-lubricated.

"When the last letter of the first word is the same vowel as the first. letter of the second word--as an alternative, two words may be used; example:

fire-escape or fire' escape.

p Appendix II Page 40 of 46 F-h

R When misleading or awkward consonants would result by joining the words; example: bell-like.

LTo avoid confusion with another word; examples:

re-cover to prevent confusion with recover, pre-position to avoid confusion with preposition.

When a letter is linked with a noun; examples:

X-ray, 0-ring, U-bolt, I-beam.

To separate chemical elements and their atomic weight; examples: Uranium-235, U-235.

.5. 3 PUNCTUATION Punctuation should be used only as necessary to aid reading and

. prevent misunderstanding. Word order-should be selected to require a minimum of punctuation. When extensive punctuation is necessary for clarity, the sentence should be rewritten and possibly mad.- into several sentences. Punctuation should be in accordance with the following rules:

5. 3.1 -

Brackets Do not use brackets.

5.3.2 Colon Use a colon to indicate that a list of items is to follow; for example, RESTORE cooling flow as follows:

5.3.3 Comma Use of many commas is a sign the instruction is too complex and needs to be rewritten. Therefore, evaluate the number of commas to ensure the instruction is not.too complex.

Use a ecmma after conditional phrases for clarity and ease of reading.

Example: WHEN level decreases to 60 inches, THEN START pump.

5. 3. 4 -

Parentheses Parentheses shall be used to indicate alternative items in a procedure, instruction, or equipment numbers.

5.3.5 Period Use a period at the end of complete sentences and for indicating the decimal place in numbers.

Appendix Il Page 41 of 46 L

p.

t

' 5. 4' VOCABULARY Words used in procedures should convey precise understanding.

to the trained person. 1The_following rules apply:

-a.

Use simple words.. Simple words are usually short words of few

= -

syllables.. Simple words are generally common-words.

-b.

Use common usage if.it makes the procedure easier to Lunderstand.

c._

Use_words'that are concrete rather'than vague, specific rather-than general,~ familiar:rather than formal, precise rather than blanket.-

d.

Define key words that may be understood in more than one sense.

e.-

. Verbs with specific meaning should be used.

Examples are listed in Table 1.

f.

Equipment status should be denoted as follows:

Available.or operable - These worde mean that a system, subsystem, train, component, or device is capable of-performing its specified function (s) in the intended manner.

Implicit in this definition is the assumption that all necessary attendant' instrumentation, controls, normal and emergency electrical power sources, cooling or

~

seal: water, lubrication, or other auxiliary equipment required for the system, subsystem, train component, or

' device _to perform its function (s) are also capable of-performing related support: function (s)'.

5.5 NUMERICAL VALUES The use!of-numerical values should remain consistent with those-rules mentioned in Subsection 3.23.

5.6 - ABBREVIATIONS, LETTER SYMBOLS, AND ACRONYMS gc

_The use-of abbreviations, letter symbols, and acronyms should remain consistent with those rules mentioned in Subsection 3.24.

6.0 " TYPING FORMAT

.6.1 GENERAL TYPING FORMAT' For the End Path Manual Procedures, the following general requirements shall be followed:

a.

Paper size should be 8 1/2 x 11 inches.

~ Appendix II Page 42 of 46 l.

.b.

White bond paper should.be used, c.

Procedures may be typed on an electric typewriter or vord-processor.

d.

. Elite,-12 pitch typewriter element may be used.

6.2' PAGZ ARRANGEMENT a.

Page margins are 1 inch from the left edge of paper and 1 inch from the right edge of paper.

b.

Page identification information will be centered and 1 inch' from the bottom of the page.

c.

The text will begin 1 1/4' inches from the top of the paper and end at least1three line spaces above the page information.

Tables and figures shall-be readable with the page so arranged.

Rotation of printed matter should be minimized for Emergency Instructions.

6.3 HEADING AND TEXT ARRANGEMENT Block style, as illustrated in Figure 6, is to be used. Section headings shall be in full capitals, with an underscore, a.

Section numbers shall begin 1 inch from the left edge of page.

b.

Two line spaces shall be allowed between headings and respective text.

c.

Two line' spaces shall be ellowed between paragraphs.

d.

Text.will be typed using one-line spacing.

6.4 BREAKING OF WORDS

^

Breaking of words shall be avoided to facilitate operator reading, f

6.5 ROTATION OF PAGES If pages need to be rotated, these rules shall be followed:

a.

The top of the page with rotated print is the normal left-hand

. edge.

b.

The page margins do not rotate.

c.

Page identification and numbering will not be rotated.

Appendix II Page 43 of 46

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6.6 PRINTED OPERATOR AIDS 6.6.1 Figures Figures include graphs, drawings, diagrams, and illustrations.

The following rules are established:

a.

_The figure number and its title are placed three line spaces below the figure field.

b.

The figure number and title should be of elite type, 12 pitch, c.

The figure field must not violate specified page margins.

d.

The figure field should be of sufficient size to offer good readability.

e.

The essential message should be clear; simple presentations are preferred.

f.

Grid lines of graphs should be at least 1/8 inch apart; numbered grid lines should be bolder than unnumbered grid lines.

g.

Labeling of items within the figure should be accompanied by arrows pointing to the item.

h.

The items within the figure should be oriented naturally insofar as possible. For example, height on a graph should be along the vertical axis.

1.

In general,. items within the figure should be labeled.

Typed labels should use elite type, 12 pitch.

Handwritten labels should be printed, using all

~

+

capitals, with letters and numbers at least 1/8 inch high.

j.

All lines in figures should be reproducible.

6.6.2 Tables Tables should be typed using the following rules:

a.

Type style and size should be the same as that for the rest of the procedure when possible.

b.

The table number and title should be located above the table field and three line epaces below preceding text.

Appendix II Page 44 of 46

4 A' heading.should be entered.for each column and c'.-

centered within the column; the first letter-of words in the column headings should be capitalized.

d.'

Horizontal lines should be placed above and below the column headings; vertical lines,:while desirable, are

.~.ot necessary or required..

e.'

Tabular headings should be' aligned as follows:

~

Horizontally by related entries.

' Vertically by decimal point for numerical entries.

Vertically by first letter for word entries; however, run-over lines should be indented three spaces.-

~

~f.

Double spacing between horizontal entries suffices to segregate such entries, although horizontal lines may Lalso be used if-desired. JIf used, double horizontal.

lines =should be used above and below the column headings.

g.

. There-should not be a vacant cell in the table.

If no entry-is necessary, "NA" should be entered to indicate not applicable.-

6.7 CAUTIONS AND NOTES All notes and cautions should be distinguishable from the rest of the: text by using the following' format (see Subsect!.on 4.8.3)..

a..

-The applicable headings " NOTE" and " CAUTION" should be capitalized, centered.

-b.;

.The text of the note or caution should be block format, single-spaced.

c.-

Cautions shall be further highlighted by asterisks two line spaces above the heading and two spaces below the last line of the text.

d.

Cautions should be extended across the entire page.

Je.t ' Notes should be centered and indented'eight spaces from the margin (see Subsection 4.8.4).

App;ndix;II' Page 45 of 46 J

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4 CAROLINA POWER & LIGHT COMPAhT

BRUNSWICK STEAM ELECTRIC PLAhT APPENDIX III VALIDATION / VERIFICATION PROGRAM-FOR EMERGENCY OPERATING PROCEDURES f

-\\

Appendix III Page 1 of 35

r, TABLE '0F CONTENTS

- Section Title Page

=A Desk Top Review 3

B Simulator Exercises 6

-C Control Room Walk-Through 11

=

D

.Preimplementation Review of 18 Brunswick E0Ps E

Human Factors Review 35 ATTACHMENT A Source of-Parameters ATTACHMENT B Use of Technical Guidelines in E0Ps

-- ATTACHMENT C Deviations from Guidelines Appendix III Page 2 of 35 4

k

A.

Desk Too Review The Desk Top Review of the Brunswick E0Ps consisted of the classroom training sessions conducted at the plant training facility.

The following classroom training sessions were conducted:

1.

Initial classroom training from February 1982 to March 1982. This training introduced operators to the flowcharts and techniques of flowchart use.

2.

Generic guideline training from December 1982 to May 1983. This training introduced operators to the concepts of the generic guidelines and how they are used in the Brunswick E0P.

3.

Preimplementation training from November 1983 to December 1983.

This training involved all procedures associated with the E0P. Each procedure was reviewed in the classroom, step by step, to ensure they are usable and the language and level of detail in the E0P was compatible with the experience of the operating staff.

During each of these training sessions, trainees were encouraged to ask questions and make comments concerning the new E0Ps. These comments were of both technical and human engineering nature.

All important comments and recommendations were recorded by the instructor and used to revise the E0Ps when desirable or appropriate.

Some examples of licensed personnel comments and the E0P development group's response are included as follows:

1.

Is it necessary to manually scram the reactor as the first action on the flowcharts?

Rasponse:

Yes. This is a conservative ection as a backup to the automatic scram.

2.

Some old EIs require the operator to execute a manual scram. Where is this guidance to be located in the new procedures?

Response

This guidance will be contained in annunciator procedures or abnormal operating procedures.

Appendix III Page 3 of 35

3.

The mode switch step appears too soon on the flowcharts. This could result in a Group 1 isolation on Unit 2.due to high steam line flow.

Response

This. step will be relocated on the next revision to the flowcharts.

-- 4.

'Should a reference be made on the flowcharts to operating or other procedures?

Response

If the actions on the flowcharts do not reference operating procedures and the operator feels it necessary, these procedures may Le used.

5.

The reactor should not be suddenly depressurized (manual ADS) unless it.is absolutely necessary.

Response

The flowcharts will be revised to prevent unnecessary manual ADS.

6.

Why is the service water supply to the vital header not checked on the flowcharts?

Response

The flowcharts will be revised to include steps concerning the vital header.

7.

The flowcharts should contain earlier guidance for reactor water level control.

Response

Revisions will be made on the flowcharts to provide guidance for earlier level control.

8.

When placing the RER System in suppression pool cooling, it is unclear which loop to use and exactly when the lineup should be.

. Response:

Loop selection will be left to the operator's discretion.

Specifying a certain loop would unnecessarily restrict the~

operator's ability to recognize plant conditions.

~9.

Is it necessary to monitor the diesel load when starting small motors such as the drywell cooling fan?

Appendix III Page 4 of 35 m

Response

-Yes.

The diesels could be h'eavily loaded at the time the fan motors are started.

10.

After a loss of off-site power and automatic diesel generator start, the.RPS MG sets should_be started locally to allow resetting of RPS o

and group isolations.

Response

'This step has been added on the flowcharts.

11.

Should there be guidance provided to the operator which would

-prevent the second opening of an SRV shortly after it has been opened?

i This would minimize the hazard of the SRV opening when the tail pipe contains an above normal amount of water.

Response

The SRV opening sequence is specified on the ficwcharts and will be posted in the Control Room. This, in conjunction with the SRV memory lights, should be sufficient guidance.

12.

Color code or change the path-to-path arrow symbols to geometric symbols; e.g.,

circle, square, triangle, etc.

Response

The path-to-path arrows will be color coded on the flowcharts that are used in the Control Room.

13.

The path specific parameters should be highlighted.

Response

These parameters have been highlighted by using heavy lines for th.e decision symbol.

' 14.

At_the exit points from the flowcharts the word " Procedure" is confusing; it is suggested that the words "End Path Manual" be used.

Example:

GO TO END PATH MANUAL 5 SECTION MM

Response

This has been revised on the new flowcharts.

Appendix III Page 5 of 35

C

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'15.

The;' connecting lines?at the lower right portion of Flowchart 3 are r'

too close.

Response

- This situation has been corrected on the' latest revis' ion of

-! T4; Flowchart 3.

1 B.

Simulate-Exercises During the early stages of the Brunswick E0P development process, the-Browns Ferry simulator was used several times for conducting simulated

, emergency exercises, using both the old event-oriented emergency instructions and the new' symptomatic or function-oriented E0Ps.

cThe following multiple failure exercises (problems) ara examples of.the scenarios used for simulator validation of the new E0Ps:

. Problem 1 Initial Conditions:

100% Powe.-

f Equipment-Failures:

Loss of Off-Site Power Failure of Two Diesels Loss of HPCI Break in the Drywell i

Problem 2-Initial Conditions:

100% Power Equipment Failures:

Loss of RBCCW Loss of Drywell Coolers Problem 3 Initial Conditions:

100% Power LEquipment Failures:

Loss of Off-Site Power Failure of Two Diesels Loss of HPCI Problem 4

' Initial Conditions:

100%

Equipment Failures:

Large Condenser Tube Leak Loss of RCIC Loss of HPCI

' Appendix III Page 6 of 35 c

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,y The conclusions.following these initial simulator exercises indicated that the Brunswick approach; (i'e., flowcharts for immediate action steps) to s'mptom-based E0Ps was a viable solution to the E0P problem and y

.that the operators'quickly adapted to the new format.

The Limerick simulator was used in 1982 for training all licensed

. personnel in the use of the new EOPs. A list of simulator exercises was

~

developed which provided adequate exposure to all portions of the Brunswick flowcharts.

'The 1983 s'imulator. training was conducted at the Hatch simulator. The

.new E0Ps.were again used for this training.

'The simulator exercises used were chosen from the following list:

Exercise No.

Description 1

Loss of Instrument Air - Manual Scram 2:

Loss of CRD Pumps - Manual Scram 3

IRM Failure - Automatic Reactor Scram 4

Loss of Feedwater - Startup Mode Loss of Feedwater - Run Mode 5-6' EHC Failure - Bypass Valves Fail Closed 7-EHC Failure - Bypass Valves Fail Open Loss of HPCI Loss of RCIC 8

EHC Failure - Bypass-Valves Fail Closed-Loss of Off-Site Power 9

LOCA Small 10 Loss of Feedwater LOCA 11 Loss of Off-Site Power Loss of HPCI Loss of RCIC 12-Stuck Open SRV - Manual Scram 13

' Turbine Trip Bypass Valvss Fail Closed Appendix III Page 7 of 35 m

A Exercise No.

Descriotion 14 Turbine Trip Stuck Open Bypass Valve-LOCA - Small 15 Turbine Trip - High Power 16 Fuel Cladding Failure 17 Loss of Coolant - Small 18 EHC System Malfunction - Pressure Regulator Oscillation 19 Loss of Feedwater 20 Steam Leak Outside Containment 21 LOCA 22 Loss of Vacuum 23 Loss of Feedwater Loss of HPCI Loss of RCIC 24' Condenser Tube Leak Loss of HPCI Loss of RCIC LOCA 25 Turbine Trip Stuck Open Relief Valve (SORV) 26 Turbine Trip Turbine Bypass Valves (BPV) -

Failed Closed Loss of HPCI 27 Turbine Trip Feedwater-Regulator Failure 28 Steam Line Break Loss of HPCI Loss of RCIC 29 Loss of Feedwater LOCA 30 High Conductivity - Manual Scram

' Appendix III Page 8 of 35

Exercise No.

.Descriotion 31 MSIV Closure LOCA 32 EHC Failure - Pressure Regulator Failure - Low EHC Pressure Regulator Fails - High 33 Turbine Trip LOCA 34 Recirculation Pump Trip During each of these simulator training sessions, trainees were encouraged to ask questions and make comments concerning the new EOPs.

These comments were of both technical and human engineering nature.

These simulator training sessions have indicated.that there is a high

-level of assurance that the procedures will guide the operator in mitigating transients and accidents.

' An example of a simulator exercise is included (see Figure 1).

+

Appendix III Page 9 of 35 t

L

FIGURE 1 SIMULATOR EXERCISE EXERCISE:.[,'*11" ' - 3 pan Valne Fail Open Jz FILE NO.

7-w.7 7

loss of RCIC OBJECTIVES: vpon completion of thi exercise the student will be able to:

Enier the EOF's (flowcharts) upon reactor scram and return the plant to a safe shutdown condition by correct execution of the EOF steps.

REFERENCFS - RELATED LER's:

. Rafarencass ' RSEF Sytytomatic EOF Training Course Balated 122's: None INITIAL CONDITIONS:

Fower 81 Turbine on turning gear.

Mode switch in startup.

INSTRUCTOR GUIDE:

Direct the trainees to continue the startup.

Activate RFV failure.

. Activate the other malfunctions after reactor scram.

SHIFT TURNOVER INFORMATION:

None MALFUNCTIONS OVERRIDES REMOTE OPS.

Turbine Bypass Valves Fail open IFCI Trip RCIC Trip SUPPLEMENTAL INFORMATION:,

l Fail HFCI and RCIC af ter the reactor scram has occurred.

l EXPECTED RESPONSE: AS PER SERIAL PILATED CHECK 0FF Enter Fath 2.

l SUCCESSFUL COMPLETION OF THIS EXERCISE FULFILLS THE FOLLOWING NRC AND INPO REQUIREFENTS:

Barold Denton letter (NRC), March 28, 1980 - Enclosure 4, Items 16, 23 & 25.

Appendix III Page 10 of 35 l

~

C.

Control Room Walk-Through The NRC guideline for preparation of emergency operating procedures (i.e., NUREG-0899) recommends that the licensee conduct Control Room walk-throughs as one method of the validation / verification of the plant-specific emergency operating procedures.

The purpose of the Control Room walk-through is to establish the accuracy of information and instruction contained in the Brunswick E0Ps, to determine that the procedure can be accurately and efficiently carried out, and to demonstrate that the procedures are adequate to mitigate transients and accidents.

Both technical and human engineering adequacies have been addressed during this walk-through.

The objectives of the walk-through were as follows:

1.

Ensure the Brunswick E0Ps.are usable;. i.e., they can be understood and followed without confusion, delays, errors, etc.

2.

Ensure there is correspondence between the procedures and the Control Room / hardware; i.e., control / equipment / indications that are

. referenced are available (inside and outside of the Control Room),

use the.same designations, use of the same units of measure, and operate as specified in the procedures.

3.

Ensure the. language and level of information presented in the E0Ps is compatible with the minimum number, qualifications, training, and experience of the operating staff.

The walk-through consisted of the following portions:

1.

Control Room Walk-Through Phase I (Operational Scenarios)

This phase of the V&V process involved SR0s and R0s walking through the E0P on the Brunswick site-specific simulator. Figure 2 was used as a check sheet for this walk-through.

2.

Control Room Walk-Through Phase II (Check of Each Step of the E0P)

The purpose of this walk-through was to ensure that there is a correspondence between the procedures and the Control Room hardware.

Each step of the E0P was checked to ensure the instrumentation and controls referenced by the E0P were available, use the same designations, use the same units of measure, and operate as specified in the E0P.

Figure 3 was used as a check sheet for this walk-through.

3.

Back Tanel Walk-Through Since not all instrumentation referenced by the EOP is contained in the Control Room (or simulator), a back panel walk-through was conducted to ensure this instrumentation was available and adequate.

Figure 4 was used as a check sheet for this walk-through.

Appendix III Page 11 of 35

'4.

Outside Control. Room Walk-Through-Various evolutions in the E0P must be performed outside the Control Room. To ensure these procedures are usable and correct,_a walk-through cf each of these procedures was performed. Figure 4 was used as a check sheet for these walk-throughs.

The following is a list of the exercises used for the Control Room walk-through Phase I.

1.

Manual. Scram at Low Power (Startup Mode) Due to Loss of Instrument Air

2..

Turbine Trip at 100% Power

~

3.

Loss of Feedwater at Low Power (Startup Mode) 4.

Loss of Feedwater at 100% Power 5.

Fuel Cladding Failure at 100% Power 6.

Steam Leak Inside Containment (Small Leak Assumed) 17.

Loss of Coolant Accident Inside Drywell 8.

Main Steam Line Rupture 9.

EHC System Failure at 100% Power (Turbine Control and Bypass Valves Fail Open) 10.

EHC System Failure at Low Power (Turbine Bypass Valves Fail Closed While Turbine is on Turning Gear) 11.

Loss of Condenser Vacuum 12.

Anticipated Transient Without Scram at 100% Power 13.

Manual Scram Due to High conductivity 14.

Loss of Feedwater Loss of HPCI Loss of RCIC 15.

Turbine Trip Stuck Open SRV

'16.

Turbine Trip

. Turbine Bypass Valves Fail Closed Loss of HPCI Appendix III Page 12 of 35 1

-, _ _. ~ _. _-

'17. ' Loss of Off-Site Power

~

-Loss of HPCI

( Loss of.RCIC An example of the Control Room walk-through exercise is included (see Figure.2).

Discrepanciesthatwerenotedduringthesewalk-throughswererecordedon EOP discrepancy sheets (Figure 5).-

B Appendix III Page 13 of 35 I a m

_____.m_,___

r 1

FIGURE 2.

. CONTROL ROOM E0P WALK-THROUGH EXERCISE (g) 1.

Assumed initial condition (i.e., power level, general state of the plant, etc.) 100% power-2.

. Assumed as1 functions:

LOSS OF COOLANT ACCIDENT - RECIRCULATION PUMP SUCTION PIPING RUPTURE 3.

Procedures.used (i.e., flowcharts and end path manual procedures):

4.

Exercise checkoffs:

YES NO a.

Easily Read b.

Read Rapidly Without Interruption c.

Precisely-Understood d.

Understood Without Aid of Additional Material Reader Accepts Information Presented e.

f.

Technically Correct g.

Nomenclature Correct.

h.

Units.of Measure Consistent i.

' Physical Conflicts Between Staff Avoided j.

Duplication'of Tasks Avoided k.

. Supervisor Able to Keep Up With Staff Actions 5.

Remarks:

6.

Exercise Performed By:

SRO RO R0 3

Appendix III Page 14 of 35 L-

'U FIGURE 2 CONTROL ROOM E0P WALK-THROUGH EXERCISE (g) 1.

Assumed initial condition (i.e., power level, general state of the plant, etc.) 100% power 2.

Assumed malfunctions:

IOSS OF COOLANT ACCIDENT - RECIRCULATION PUMP SUCTION PIPING RUPTURE 3.

Procedures used (i.e., flowcharts and end path manual procedures):

4.

Exercise checkoffs:

YES NO a.

Easily Read b.

Read Rapidly Without' Interruption c.

Precisely Understood d.

Understood Without Aid of Additional Material Reader Accepts Information Presented e.

?,'

f.

Technically Correct g,>

l

~

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Nomenclature Correct S y _

h.

Units of Measure Consistent i.

Physical Conflicts Between Staff Avoided-j.

Duplication of Tasks Avoided k.

Supervisor Able to Kaep Up With Staff Actions i

5.

Remarks:

I 4

6.

Exercise Performed By:

SRO RO t

RO I

Appendix III, Page 14 of 35

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FIGURE 3 CAROLINA POWER & LIGHT COMPANY BRUNSWICK STEAM ELECTRIC PLAhT C0hTROL ROOM WALK-THROUGH VALIDATION FORM E0P - 1 PROCEDURE TITLE WALK-THROUGH CHECK 0FFS YES

-a.

.Can step be performed with existing instrumentation and controls?

b.

Is. nomenclature consistent?

c.

Units of measure consistent?

REMARKS

. WALK-THROUGH PERFORMED BY SRO DATE RO' DATE Appendix-III-Page 15 of 35

FIGURE 4 CAROLINA POWER &' LIGHT COMPANY

' BRUNSWICK STEAM ELECTRIC PLANT E0P WALK-THROUGH VALIDATION FORM

-For instrumentation and controls, panels, cabinets, and terminal boards outside the Control Room E0P - 1 PROCEDURE TITLE REV.

FLOWCHART COORDINATE PAGE STEP PLANT WALK-THROUGH CHECK 0FFS YES NO a.

Can the step be performed with existing

~ instrumentation and controls?

~~

'b.

AYe7strumentation, controls, panels, cabinets, and terminal boards clearly identified.

c.

Is nomenclature consistent?

d.-

Can jumpers and inhibits be easily installed?

REMARKS WALK-THROUGH PERFORMED BY SRO DATE Appendix III Page 16 of 35

{T FIGURE 5 BRUNSWICK STEAM ELECTRIC PLANT EOP DISCREPANCY. SHEET PATH NO.

PROCEDURE REVISION FLOWCHART COORDINATE PAGE STEP DISCREPANCY FOUND DURING:

Desk Top Review 0 control Roo= W/T Other Simulator Training C Control Room Use

~ DISCREPANCY ORIGINATOR DATE RESOLUTION-APPROVED YES _

NO _

(Check one)

MANAGER - OPERATIONS DATE PROCEDURE REVISED BY DATE FORM

' Appendix III Page 17 of 35

A D.

Preimplementation Review of Brunswick EOPs Immediately prior to the implementation of the Brunswick E0Ps, an extensive review was conducted by four groups; i.e., Operations, Technical Support (Engineering), Quality Assurance, and On-Site Nuclear

~

Safety.

A committee was formed to coordinate the preimplementation' review.

1.

EOP Review Committee Purpose The purpose of this committee is to maintain a documented program for an ongoing evaluation and update of the Brunswick emergency operating procedures.

Membership The committee is comprised of the following:

a.

Chairman b.

Assistant to the Chairman-c.

Operations Representative d.

-Quality Control Representative e.

Engineering Representative f.

On-Site Nuclear Safety Representative Each member should have a designated alternate.

All changes in membership of the cocaittee should be approved'by the Manager -

Operations.

Training The committee members and the designated alternates should attend a training session designed to familiarize them with the background development of BSEP E0Ps and the review / revision process.

Committee Responsibilities The committee should establish and maintain a documented program for an ongoing evaluation and update of the E0Ps as follows:

Document Control of Procedure:

The BSEP E0Ps are controlled within the existing plant Document Control system 'and will be consistent with the plant's Administrative Manual.

Appendix III Page 18 of 35 l'

i Reproduction of Procedures:

All copies of the BSEP E0Ps shall be clearly legible. When it is necessary to replace an entire procedure or make partial revisions, as a result'of use, wear, etc., the replacement copy shall be equal to the quality of the original.

Ongoing Evaluation:

- Brunswick has established a program for the ongoing evaluation of emergency operating procedures. The program consists of the following considerations:

Evaluation of the technical adequacy of the E0Ps in light of operational experience, use, training experience, any simulator exercises, and/or Control Room walk-throughs.

Evaluation of the organization, format, style, and content as a result of using the procedures during operations, training, simulator exercises, and walk-throughs.

Evaluation of staffing and staff qualifications relevant to using the E0Ps.

Updating E0Ps:

When changes occur in the plant design, technical specifications, technical guidelines, Writers Guide, other plant procedures, or Control Room that will affect the EOPs, these procedures should be revised on a timely basis to reflect these changes.

In addition, when operating and training experience, simulator exercises, Control Room walk-throughs, or other information indicates that incorrect or incomplete information exists in the emergency operating procedures, they should be revised as necessary.

All changes should be reviewed to ensure consistency with the Brunswick Technical Guidelines and the Writers Guide. Operator feedback will be needed to assure that the E0Ps are adequately maintained and amended as required.

Plant Administrative Procedures for E0Ps:

The committee members should be cognizant of the plant administrative procedures for E0Ps:

Volume I, Book 1 of the plant Administrative Procedures Manual contains the following statement:

"When any revision is made to the Brunswick E0Ps, it shall be consistent with the E0P Writers Guide and the Plant EOP Technical Guidelines." The Brunswick Plant Specific E0P Technical Guidelines must be consistent with General Electric's Topical Report NEDO-24934~, Emergency Procedure Guidelines, except as noted in the l

Emergency Procedures Generation Package.

Appendix III Page 19 of 35

l I

e t-1 Member Responsibilities The following representatives have responsibilities as indicated:

Chairman The chairman or his alternate shall coordinate committee activities, assign tasks, and E0P revisions prior to submitting for final plant approval.

Assistant to Chairman As primary aide to the chairman, the Assistant should attend EPG related meetings, maintain cognizance of generic guidelines, and stay abreast of INPO developments. He should also be knowledgeable about NRC activities related to emergency operating procedures.

Operations Representative This person _will assist the committee relative to usability,

. operational correctness, operating experience feedback, and training feedback.

Quality Assurance Representative The QA individual shall be concerned with written correctness per E0P Writers Guide.

Technical Support Representative Through this representative, BSEP Technical Support can assure accuracy of BSEP plant-specific calculations and plant modifications that may affect the EOPS.

On-Site Nuclear Safety Representative ONS shall communicate all current safety - technical specifications and license conditions as related to the Brunswick E0Ps, via this representative.

Each representative is responsible to ensure the entire E0P is reviewed prior to implementation.

Individual check sheets are used for each group (see Figures 6-19).

All discrepancies are noted on the EOP discrepancy sheet and resolved prior to implementation.

Appendix III Page 20 of 35

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.. FIGURE 6.

0PERATIONS E0P VERIFICATION CHECK SHEET YES NO 21 I.

USABILITY A.

Level of Detail

^

1.~

Is there sufficient information to perform the specified actions at each step?-

2.

'Are the alternatives adequately described-

' at each decision point?

~3.

-Are the labeling, abbreviations, and'loca-tion information as provided in the E0P sufficient to enable the operator to find the needed equipment?

4.

Is the E0P missing information needed to manage the emergency condition?

r

~

5.

- Are the contingency actions sufficient to. address the symptoms?

6.

Are the titles and numbers sufficiently descriptive to enable the operator to-i

. find referenced and branched procedures?

lB.

Understandability o

1.

Is the E0P easy to read?

2.

Are the figures and. tables easy to read with accuracy?

3.

Can the values on figures and charts be easily determined?

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FORM t

Appendix III Page 21 of 35 4

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.c FIGURE 7-YES NO 4.

Are-cautions and note statements readily understandable?

5.

Are the E0P steps readily understandable?

II.

OPERATIONAL CORRECTNESS A.

Plant Compatibility 1.

Can the actions specified in the procedure be performed in the designated sequence?

-2.

Are there alternate success paths that are not included in the E0Ps?

3.

Can the information from the plant instru-mentation be obtained, as specified by the E0P?

'4.

Are the plant symptoms specified by the EOP adequate to enable the operator to select the applicable E0P?

5.

Are the E0P entry conditions appropriate for the plant symptoms displayed to the operator?

6.

Is information or equipment not specified in the E0P required to accomplish the task?

7.

Do the plant responses agree with the EOP basis?

8.

Are the instrument readings and tolerances stated in the E0P consistent with the instrument' values displayed on the instruments?

FORM Appendix III Page 22 of 35

}

FIGURE 8 YES NO 9.

Is the E0P physically compatible with the work situation (too bulky to hold, binding would not allow them to lay flat in work space, no place to lay the E0Ps down to use)?

10.

Are the instrument readings and tolerances specified by the E0P for remotely located instruments accurate?

B..

Operator Compatibility 1.

If the time-intervals are specified, can the procedure action steps be performed on the plant within or at the designated time intervals?

2.

Can the procedure action steps be performed by the operating shift?

3.

If specific actions are assigned to individual shift personnel, does the E0P adequately aid in the coordination of actions among shift personnel where necessary?

4.

Can th'e operating shift follow the designated action step sequences.

L 5.

Can the particular steps or sets of steps be readily located when required?

'6.

Can procedure exit point be returned to without omitting steps when required?

7.

Can procedure branches be entered at the correct point?

8.

Are EOP exit points specified adequately?

FORM Appendix III Page 23 of 35

FIGURE 9 III. TECHNICAL ACCURACY YES NO 1.

Entry Conditions or Symptoms Information a.

Are the entry conditions of the EOP listed correctly?

b.

If additional entry conditions have been added, do they comply with the following:

(1) Appropriate entry conditions for which E0P should be used?

(2) Not excessive.

2.

Instructional Step, Caution, and Note Information a.

Are E0P differences:

(1) Documented (2) Explained b.

Is the EOP technical foundation (strategy) changad by the following changes in E0P

-steps, cautions, or notes:

(1) Elimination (2) Addition (3) Sequence (4) Alteration c.

Are correct, plant-specific adaptations incorporated per E0P:

(1) Systems (2)

Instrumentation (3) Limits (4) Controls (5)

Indications FORM Appendix III Page 24 of 35

.~,

TIGURE 10

.YES 3.-

Plant Hardware Information a.

Is the following plant hardware specified

^J in the EOP available for operator use:

(1) Equipment-(2) Controls (3) Indicators (4)

Instrumentation m

FORM Appendix III Page 25 of 35

FIGURE 11 ENGINEERING E0P VERIFICATION CHECK SHEET Quantitative Information:

A.

IDo the quantitative values, including tolerance bands, used in the E0P comply with the calculation procedure for EOP guidelines?

.lB.

-Where calculation procedure for E0P guideline values are not used in the

-EOP, are the EOP values computed accurately?

C.

When calculations are required by the E0P, are equations presented with-

. sufficient information for operator use?

D.

When jumpers or inhibits are used in.the EOPs, are the instructions

accurate, e.g., cabinet designation and terminal points?

I COMMENTS t

Y FORM

- Appendix III Page 26 of 35 6

u.

FIGURE 12 QUALITY ASSURANCE EOP VERIFICATION CHECK SHEET YES NO I.

-PROCEDURE-GENERAL A.

Written Correctness 1.

Lenibility Are the text, tables, graphs, figures, and charts legible to the evaluator?

2.

E0P Format Consistency Do the following sections exist in each E0P:

(1) Title (2) Entry Conditions or Plant Condition (3) Operator Actions 3.

Identification Information a.

Is the procedure title descriptive of the purpose of the procedura.

-b.

Does the cover sheet correctly provide the following:

(1) Procedure Title (2) Procedure Number (3) Unit Number (4) Revision Number (5) Number of Pages FORM Appendix III Page 27 of 35

,w

>Ti s

i FIGURE 13 YES NO Does each page correctly provide the c..

.following:

(1) Procedure Designator (2) Revision Number (3) Page of Numbers d.

Does the procedure have all its pages?

~

.II... STEP, CAUTION, NOTE-SPECIFIC A.

Written Correctness 1.

Information Presentation a.

Are instruction steps numbered correctly?

t b.

Are operator-optional sequence steps identified?

c.

Are instruction steps constructed to comply with the following:

1)

Steps deal with only one idea 2)

Sentences are short and simple 3)

Operator

.tions are specifically stated (4) Objects of operator actions are specifically stated i

(5) Objects of operator actions are adequately stated (6)

If there are three or more objects, they are listed (and space is provided for operator check-off) 7 (7) Punctuation and capitalization are proper FORM e

Appendix III Page 28 of 35 m.- u m.

m

.m

. m.

L n

s FIGURE 14 YES NO (8) Abbreviations are correct and understandable to the operator, d.

Do instruction steps make proper use of logic struc-ture?

-e.

When an action instruction is based on receipt of an annun-ciator alare, is the setpoint of the alarm identified?

f.

Are precautions and cautions used appropriately?

g.

Are precautions and cautions placed properly?

h.

Are precautions and cautions constructed to comply with the following:

1.) They do not contain operator actions 2.)

They do not use exten-sive punctuation for clarity 3.)

They make proper use of emphasis 1.

Are notes properly used?

j.

Are notes properly placed?

k.

Are notes worded so that they do not contain operator actions?

1.

Are numerical vclues properly written?

m.

Are values specified in such a way that mathematical opera-tions are required of the user?

FORM Appendix III Page 29 of 35

s A

FIGURE 15' YES NO n.

'Is a chart or graph provided in the procedure for necessary operator calculations?

o.

Are units of measure in the E0P the same as those Lused on equipment?

t a.

FORM Appendix.III Page 30 of 35

r~

FIGURE 16 YES NO 2.

Procedure Referencing and Branching a.

Do the referenced and branched procedures identified in the E0Ps exist for operator use?

b.

Is the use of referencing minimized?

c.

'Are referencing and branching instructions correctly worded?

(1)

"go to" (branching)

(2) " refer to" (referencing) d.

Do the instructions avoid routing users past important information such as cautions preceding steps?

e.

Are the exit conditions compatible with the entry conditions of the referenced or branched procedure?

FORM Appendix III Page 31 of 35 d.

m

r:

s F

k.

~

FIGURE 17~

ON-SITE NUCLEAR SAFETY E0P. VERIFICATION CHECK SHEET g

'YES NO N/A

'I.

Evaluation:

4 A.

Does the procedure conform to the current technical specifications?

'3.-

Does'the procedure reflect the as-built condition of the unit?

C._

'Does the procedure (or related data or work-sheet) provide for the independent verifica-tion and sign-off of computations (Volume I, Section 11.8)?

D.

If any follow-up action, test, or procedure must be performed upon the completion for this procedure, does the procedure or a related document.(e.g., work order) instruct the user regarding what follow-up action is required and whom to notify?

E.

Does the procedure prohibit isolation or prohibit defeat of redundant safety systems when required to be operable?

F.

-Does the procedure provide sign-off steps for.

returning safety systems to service (Volume I, Section 11.8, and 01-01)?

G.

Does the procedure require notification of the Shift Operating Supervisor / Shift Foreman prior to defeating or testing of safety systems?

H.

Have provisions for independent verification

.of affected valveLand switch positions, prior to returning the system to service, been provided (Volume I, Section 11.8)?

FORM Appendix III Page 32 cf 35

n-FIGURE 18 YES NO N/A-

-s I.

Acceptance criteria of procedure matches tech-nical specifications requirements?

J.

Does the procedure meet the ANSI-18.7, Section 5.3 (1976) requirements?

II. Safety Evaluation Adequacy A.-

The procedure / change does not prevent conform-ance to or require a change to technical speci-fications?

B.

The procedure / change does not create an unreviewed safety question?

C.-

The safety analysis provides a written basis for the determination that the procedure does not constitute an unreviewed safety question?

FORM Appendix III Page 33 of 35

1 FIGURE 19 BRUNSWICK E0P VERIFICATION I.

PATH NUMBER PROCEDURE REV.

FLOWCHART COORDINATE OR PAGE AND STEP NUMBER VERIFICATION BY OPS _

QA

.ENG _

ONS'

.II.

E0P SOURCE DOCUMENT USED

[.

A.

GE NEDO-24934 (Rev. 2) Emergency Procedures Guideline

[

B.

Brunswick Specific E0P Technical Guideline C.

Brunswick E0P Writers Guide D.

Brunswick Plant-Specific Calculations for E0P

[

E.

Brunswick Technical Specifications

[

F.

Brunswick FSAR

[

G.

Other H.

Other EVALUATOR DISCREPANCIES (Signature)

(Identify)

DATE FORM

. Appendix III Page 34 of 35 m

m.

E.

GENERAL PHYSICS HUMAN FACTORS EVALUATION OF BRUNSWICK EMERGENCY INSTRUCTION FLOWCHARTS General Physics Corporation has condacted a human factors evaluation of the Brunswick E0P flowcharts. The technical approach used was to conduct a literature review to develop a set of human factor guidelines for evaluating the format and implementation of E0P flowcharts.

The guidelines were divided into eight areas:

identification information, content, symbol coding, nomenclature / punctuation, functional flow and branching, readability, ease of use, and accommodation of revisions / multi-unit concerns.

The guidelines generated from the literature review were then compared to the latest revisions of the E0P flowcharts.

Control Room operators who had simulator experience and training in flowchart use were also interviewed.

As a result of the human f actors study, several changes have been made to the format and style of the flowcharts. These changes, such as highlighting key areas, have enhanced the usability of the flowcharts.

All areas of concern identified by the human factors study have been-satisfactorily resolved.

Appendix III Page 35 of 35

2' I

1 6

CAROLINA POWER & LIGHT COMPAhT BRUNSWICK STEAM ELECTRIC PLAST ATTACHMENT A APPENDIX III SOURCE OF PARAMETERS USED IN THE PLANT-SPECIFIC TECHNICAL GUIDELINE 4

Attachment A, Appendix III Page 1 of 15

m

/

SOURCE OF PARAMETERS USED IN THE PIJNT-SPECIFIC TECHNICAL GUIDELINE (PSTG)

~ A.'

CAUTIONS 1.

Caution No. 6 Parameter /Value:

Temperature and indicated levels Source:

Calculation Procedure'for Guidelines (Appendix C), Section 4.1.1 2.

Caution No. 8 Parameter /Value:

Net positive suction head curves Source:

Core Spray, Calculation Procedure for Guidelines (Appendix C), Section 4.2 HPCI, Calculation Procedure for Guidelines (Appendix C), Section 4~.2 RCIC, Calculation Procedure for Guidelines (Appendix C), Section 4.2 RHR, Calculation Procedure for Guidelines (Appendix C), Section 4.2 3.

Caution No. 9 Parameter /Value:

Suppression pool high level suction interlocks Source:

Brunswick Technical Specification Table 3.3.3-2, page 3/4 3-35 Parameter /Value:

CST low level suction interlock Source:

Brunswick System Description 32.1, page 15 4.

Caution No. 11 Parameter /Value:

Drywell pressure which initiates ECCS Source:

Brunswick Technical Specification Table 3.3.3-2, 2.a, page 3/4 3-34 Attachment A, Appendix III Page 2 of 15 v

5.

Caution No. 12 Parameter /Value:

HPCI and RCIC minimum speed Source:

Brunswick Operating Procedures HPCI, OP-19, Section 2.6, page 1 RCIC, OP-16, Section 2.6, page 1

-6.

Caution No. 13 Parameter /Value:

Reactor cooldown rate Source:

Brunswick Technical Specification 3.4.6.1, page 3/4 4-13 7.

Caution No. 14 Parameter /Value:

HPCI low pressure isolation setpoint Source:

Brunswick Technical Specification Table 3.3.2-2, 4.a.2, page 3/4 3-19 8.

Caution No. 15 Parameter /Value:

SRV opening sequence Source:

Brunswick Drawing 9527-D-2793 Brunswick Drawing 9527-F-1131 9.

Caution No. 17 Parameter /Value:

Reactor cooldown rate Source:

Brunswick Technical Specification Limiting Condition for Operation 3.4.6.1, page 3/4 4-13 10.

Caution No. 23 Parameter /Value:

Elevation of bottom of Reactor Building to suppression chamber vacuum breakers Source:

Brunswick Drawing 9527-F-2813 Attachment A, Appendix III Page 3 of 15

B.

RPV CONTROL GUIDELINE,

' ' ~ Purpose' Parameter /Value:

Cold shutdown condition Source:

Brunswick Technical Specification

_ Table 1.2,_page 1-8 1.

_-Reactor Control / Level RC/L-2 Parameter /Value:

Reactor scram - low water level

. Source:

Brunswick Technical Specification Table 2.2.1-1, page 2-4 Parameter /Value:-

Turbine ~ trip - high reactor water level Source:

Brunswick System Description 19 Table 2.4, page 22

-Parameter /Value:

Condensate /Feedwater System Source:

Brunswick System Description 32 Section 3.2.7, page-64 Parameter /Value:

CRD System Source:

Brunswick System Description 08 Section 3, page 21 Parameter /Value:

RCIC System 4

Source.

Brunswick System Description 16 Low: Table 2.4, page 35 High: Section 3.1, page 44 Parameter /Value:

HPCI System Source:

Brunswick System Description 19 Low:

Table 2.4, page 22 High:- Section 3.2, page 37 and Section 3.3, page 38 Parameter /Value:

Core Spray System Source:

Brunswick System Description 18

. J'N '

Section 3'.2l1, page 15 Attachment A, Appendix III Page 4 of 15 D

l~

te l

Parameter /Value:

RHR System 7

Source:

Brunswick System Description 17 4 '

Section 3.2.1, page 42 2.

Reactor Control / Pressure I

RC/P-1 Parameter /Value:

RPV pressure at which all turbine.

bypass valves are fully open Source:

Brunswick General Plant Operating Procedure 01, Section B.4.5.19 RC/P-2 Parameter /Value:

Lowest SRV lifting pressure Source:

Brunswick System Description 20 Section 3.1, page 23 RC/P-3 Parameter / Values Cold shutdown weight of boron Source:

Calculation Procedure for Guidelines ts' (Appendix C), Section 4.1.4 g

Parameter / Values RPV cooldown rate LCO Source:

Brunswick Technical Specification 3/4.4.6, page 3/4 4-13 3.

Reactor Control / Power RC/Q-3 Parameter /Value:

APRM downscale trip Source:

Brunswick System Description 09 l

Section 2.4, page 2 5 RC/Q-4 n

Parameter / Values Boron injection initiation temperature Source:

Calculation Precedure for Guidelines (Appendix C), Section 4.1.5 1

Attachment A, Appendix III Page 5 of 15

.m.

m

RC/Q-4.3 Parameter /Value:

Cold shutdown weight of boron Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.4 RC/Q-5.1 Parameter /Value:

Fuses which deenergize RPS scram solenoids Source:

Unit 1 - Brunswick Drawing FP-50015 Unit 2 - Brunswick Drawing FP-55046 Parameter /Value:

Scram air header supply valve Source:

Unit 1 - Brunswick Drawing 9527-D-2517 Unit 2 - Brunswick Drawing 9527-D-25017

- RC/Q-5.2 Parameter /Value:

HCU accumulator charging water header valve Source:

Unit 1 - Brunswick Drawing 9527-D-2516 Unit 2 - Brunswick Drawing 9527-D-25016 RC/Q-5.6

. Parameter /Value:

CRD withdrawal line vent Source:

Unit 1 Brunswick Drawing 9527-D-2517 Unit 2 - Trunswick Drawing 9527-D-25017

.C.

' CONTAINMENT CONTROL GUIDELINE 1.

. Entry Conditions Parameter /Value:

Most limiting suppression pool temperatu;e LCO s

Source:

Brunswick Technical Specification 3.6.2.1, page 3/4 6-9 Parameter /Value:

Drywell temperature LCO Source:

Brunswick Technical Specification 3.6.1.1, page 3/4 6-8 Attachment'A, Appendix III Page 6 of 15

'sN-sr.

F g-

=

w =

7 r 4m Y r

't7tu-p 9?7-M

?

74'

'-t

-T-T

-*wt f*W

--"T

-7T'

=

Pr-eWWt-

s

~,

Parameter /Value:

High drywell pressure scram setpoint Source:

Brunswick Technical Specification Table 2.2.1-1, page 2-5 Maximum suppression pool water -

Parameter /Value:

level LCO

_ Source:

Brunswick Technical Specification 3.6.2.1, page 3/4 6-9 Parameter /Value:

Minimum suppression pool water level LCO Source:

Brunswick Technical Specification 2

3.6.2.1, page 3/4 6-9

' 2.

Suppression Pool Temperature SP/T-2 Parameter /Value:

Most limiting suppression pool temperature LCO Source:

Brunswick Technical Specification 3.6.2.1, page 3/4 6-9 SP/T-3

'(;

Parameter /Value:

Boron injection initiation temperature I,,

Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.5 SP/T Parameter /Value:

Heat capacity temperature limit curve Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.2 3.

Drywell Temperature DW/T-1 Parameter /Value:

Drywell temperature LCO u

Source:

Brunswick Technical Specification 3.6.1.1, page 3/4 6-8 e

5,

' Attachment A, Appendix III Page 7 of 15

,,v a

mw

,-..--n---

,w,-,,

--w--

,----,.,w,,-n.

.,0,,.,,-,,,,,

DW/T-2 Parameter /Value:

Drywell temperature near cold reference leg vertical runs Source:

Elevation and azimuth of condensing chamber and vertical runs, Brunswick Drawing 9527-LL-70080, sheets 6, 6A, and 15 Elevation and azimuth of drywell temperature detectors, Brunswick Drawing 9525-F-35036 DW/T-3 Parameter /Value:

Maximum drywell design temperature Source:

Final Safety Analysis Report, page 6.2.1-4 Parameter /Value:

Drywell spray initiation pressure limit Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.8 4.

Primary Containment Pressure PC/P-2 Parameter /Value:

Suppression chamber spray initiation pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.9 PC/P-3 Parameter /Value:

Suppression chamber spray initiation pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.9 Parameter /Value:

Drywell spray initiation pressure limit Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.8 PC/P-4 Parameter /Value:

Pressure suppression pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.0 Attachment A, Appendix III Page 8 of 15

~e,--e

PC/P-5 Parameter /Value:

Primary containment design pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.11 The operating margin gained through the use of a curve for this parameter does not warrant the additional complications imposed by a two-dimensional limit. Therefore, the curve has not been used, and RPV flooding is required at the most limiting suppression chamber pressure.

PC/P-6 Parameter /Value:

Primary containment pressure limit Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.12 The operating margin gained through the use of a curve for this parameter does not warrant the additional complications

~ imposed by a two-dimensional limit. Therefore, the curve has not been used, and spraying of the primary containment is required at the most limiting suppression chamber pressure.

Parameter /Value:

Drywell spray initiation pressure limit Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.8 PC/P-7 Partmeter/Value:

. Primary Containment pressure limit

. Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.12 The operating margin gained through the use of a curve for i

this parameter does not warrant the additional complications imposed by a two-dimensional limit. Therefore, the curve has not been used..and venting of the primary containment is required at the most limiting suppression chamber pressure.

5.

Suppression Pool Level SP/L-1 Parameter /Value:

Maximum suppression pool water level LCO Source:

Brunswick Technical Specification 3.6.2.1, page 3/4 6-9 Attachment A, Appendix III Page 9 of 15

~_, _. - __ __ _ __

l 1

Parameter /Value:

Minimum suppression pool water level LCO Source:

Brunswick Technical Specification 3.6.2.1, page 3/4 6-9

.SP/L-2 Parameter /Value:

Heat capacity level limit

-Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.13 SP/L-3 Parameter /Value:

Maximum suppression pool water level LCO Source:

Brunswick Technical Specification 3.6.2.1, page 3/4 6-9 SP/L-3.2 Parameter /Value:

Suppression pool load limit Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.3 SP/L-3.3 Parameter /Value:

Elevation of bottom of Mark I internal suppression chamber to drywell vacuum breakers Source:

Brunswick Drawing 9527-F-2813 Parameter /Value:

Drywell spray initiation pressure limit Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.8 SP/L-3.4 Parameter /Value:

Elevation of bottom of Mark I internal suppression chamber to drywell vacuum breakers Source:

-Brunswick Drawing 9527-F-2813 Attachment A, Appendix III Page 10 of 15

~

m.

---W'>

+

y g y7,,,.--

---y73

.c

---e

-rmy%=

q w

4 p

D.

CONTINGENCIES 1.

Level Restoration Cl-2 Parameter /Value:

RPV pressure at which core spray shutoff head is reached Source:

Brunswick System Description 18 Section 3.2.1, page 15 Parameter /Value:

HPCI low pressure isolation setpoint Source:

Brunswick System Description 19 Table 2.4, page 22 Parameter /Value:

ADS initiation setpoint Source:

Brunswick System Description 01 Table 2.4.1, page 40 Cl-4 Parameter /Value:

Low level scram setpoint

. Source:

Brunswick Technical Specification Table 2.2.1-1, page 2-4 Cl-6 Parameter /Value:

HPCI low pressure isolation setpoint Source:

_ Brunswick Technical Specification Table 3.3.3-2, 2a, page 3/4 3-34 2.

Emergency RPV Depressurization C2-1.2 Parameter /Value:

Minimum number of SRVs required for emergency depressurization

^ Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.15 Parameter /Value:

SRV reopening pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.16 Attachment A, Appendix III Page 11 of 15 2-

-vi w-v--,

,7_,

3.

Steam Cooling C3-1 Parameter /Value:

Minimum zero-injection RPV water level Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.17-The lower range of BSEP RPV level instrumentation is -100 inches.

Parameter /Value:

Minimun single SRV steam cooling pressure Source:

Through a bounding calculation applicable to all plants, the RPV pressure producing steam flow through one SRV sufficient to limit peak cladding temperature to 2200*F has been determined to be 700 psig. This number is supplied by GE.

4.

Core Cooling Without Level Restoration (Spray Cooling)

C4-2 Parameter /Value:

RPV pressure for rated core spray flow Source:

Core Spray Pump Technical Manual (FP-5700) 5.

Alternate Shutdown Cool h C5-3 Parameter /Value:

-Minimum number of SRVs required for shutdown. cooling Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.18 C5-6.1 Parameter /Value:

Miaimum alternate shutdown cooling RPV pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.18

. Attachment A, Appendix III Page 12 of 15 r

v-~-

r v-v-yv->

e

C5-6.2 Parameter /Value:

Maximum alternate shutdown cooling RPV pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.18 C5-6.3

' Parameter /Value:

Maximum RPV cooldown rate LCO Source:

Brunswick Technical Specification 3.4.6.1, page 3/4 4-13 Parameter /Value:

Minimum SRV reopening pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.16 C5-7 Parameter /Value:

Head tensioning limit Source:

Brunswick General Plant Operating Procedure 01, Section E.4.28 6.-

RPV Flooding C6-1 Parameter /Value:

Minimum number of SRVs required for emergency depressurization Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.18 C6-2.2 Parameter /Value:

Minimum alternate RPV flooding pressure Source:

' Calculation Procedure'for Guidelines (Appendix C), Section 4.1.19 l

[-

C6-3.1 I

Parameter /Value:

Minimum number of SRVs required for emergency depressurization i

L Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.15 l

Attachment A, Appendix III Page 13 of 15

(,

Parameter /Value:

Minimum RPV flooding pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.20

-C6-3.2:

Parameter /Value:

Minimum RPV flooding pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.20 C6-5.3 1

Parameter /Value:

Minimum RPV flooding pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.20 C6-5.4 Parameter /Value:

Maximum core uncovery time limit Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.21 C6-6 Parameter /Value:

Primary containment pressure limit Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.12 The operating margin gained through the use of a curve for this parameter does not warrant the additional complication imposed by a two-dimensional limit.

Therefore, the curve has _not been used, and RPV flooding is required at the most ILaiting suppression chamber pressure.

7.

Level / Power Control C7-1 Parameter /Value:

APRM downscale trip Source:

Brunswick System Description 09 Section 2.4, page-2-5 Parameter /Value:

Boron injection initiation temperature Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.5 Attachment A, Appendix III Page 14 of 15

.. High drywell pressure scram setpoint Parameter /Value:

Source:

Brunswick Technical Specification Table 2.2.1-1, page 2-4

'C7-2 Parameter /Value:

RPV pressure range for system operation Source:

See Reactor Control / Level, Section B.1 page 4 of 15 C7-2.2 Parameter /V'alue:

Minimum alternate RPV flooding pressure Source:

Calculation Procedure for Guidelines (Appendix C), Section 4.1.19 C7-3 Parameter /Value:

Hot shutdown boron weight Source:

Calculation Procedure for Guidelines.

(Appendix C),- Section 4.1.22 Parameter /Value:

Low level scram setpoint Source:

Brunswick Technical Specification Table 2.2.1-1.4 Parameter /Value:

High level trip setpoint -

I Source:

Brunswick System Description 19 Table 2.4, page 22 t

Attachment A, Appendix III Page 15 of 15 i

.~.

d N

t a

ATTACIDfENT B

-APPENDIX III Use of the Plant-Specific Technical

't Guideline'in Emergency Operating Procedures t

s 0.

~

h l

Attachment' B, Appendix III Page 1 of 17 I

ATTACllMENT B Appendix III Use of the PSTG in the Emergency. Operating Procedures A.

INTRODUCTION The PSTG was used throughout the Brunswick E0Ps. However, the guideline was used as a guide only, not a procedure.

The flowcharts have been designed to eliminate operator confusion associated with when to enter-the E0P and exactly what actions should be taken during the initial few minutes following the onset of the potential emergency condition.

When the ficwchart steps are completed, the operator will be directed to one of the procedures in the End Path Manual.

The purpose of this document is to assist the procedure writer / reviewer in determining how to convert the PSTG into the E0P.

It defines where the PSTG. appears in the E0P.

It will also serve as part of the verification / validation process by ensuring that all steps from the PSTG are reflected in the E0P.

B.

E!GRY CONDITIONS The entry condition to the Brunswick EOPs is any condition which requires or' initiates a reactor scram. The operator then needs only to remember to pick up any one of the five flowcharts following a scram.

C.

OPERATOR ACTIONS 1.

RC-1 If reactor scram has not been initiated, initiate reactor scram.

The first action on each Brunswick flowchart directs the operator to manually scram the reactor.

2.

Irrespective of the entry condition, execute Steps RC/L, RC/P, and RC/Q, concurrently.

The steps from FC/L, RC/P, and RC/Q are contained on Paths 1, 2, 3, 4, and.5.

The key parameters on each flowchart prioritize the order of execution of these sections.

Attachment B, Appendix III Page 2 of 17 L:

D.

RC/L - REACTOR VESSEL LEVEL CONTROL 1.

RC/L Monitor and control RPV water level.

1 The Brunswick operators are trained to constantly monitor and control.RPV level.

2.

RC/L-1 Confirm initiation of any of the following:

Isolation ECCS Emergency Diesel Generator Initiate any of these which should have initiated but did not.

The flowchart directs the operator -to-veri 4y-automatic actions. as required; e.g., on Path 4.

The first action step past the key parameters directs the operator to verify' automatic start or to manually start HPCI, RCIC, and SBGT. Three steps later the operator is directed to verify closure of Groups 1, 2, 3, 6, and 8 isolation valves.

If auxiliary power is not available (on any flowchart), the operator is directed to verify on or to manually start the diesel generators. The operator is also directed to start the diesel generators, RHR, and core spray pumps if the RPV water level decreases to +45 inches. This guidance is on the Yellow Brick Road (i.e., the wide dark line), shortly after the key parameters. k'here the flowchart has identified a parameter that an automatic action is associated with, the flowchart should verify that automatic action.

i 3.

If while executing the following step:

I Boron inject: 7n is required, enter CONTINGENCY #7.

RPV water level cannot be determined, RPV FLOODING IS REQUIRED; enter CONTINGENCY #6.

RPV flooding is required, enter CONTINGENCY #6.

If the reactor does not scram (i.e., all control rods do not insert to position 00) or the power is above 3% following the initiation of a scram signal, the operator is directed to Path 1.

If boron Attachment B, Appendix III Page 3 of 17 y y

,-,,mm--m-,,

-, w -,.-,-.,,.

,,,--,.,----.s-

.,,,wg.,-y

,w-

-,-m--

a,, -,,-,

m

- l A

2 -

injection is then required while on Path 1, the operator is directed to execute the boron injection steps of Contingency #7.

If the RPV water level cannot be determined while on the flowchart, the. operators-are trained to answer all water level questions as if theilevel is low and/or dacreasing. This will lead through the-i required steps to line up all high pressure and low pressure ECCS prior to exiting the flowchart. The end path procedure provides-the following guidance:

IF while. executing this. procedure, reactor vessel level' CANNOT be determined OR reactor vessel flooding is required, THEN EXIT this End-Path Procedure and ENTER the " Flooding Procedure" in the Contingency section of this End Path Manual."

RPV flooding is' required for two severe containment problems;. i.e.,

when the primary containment temperature increases to the RPV saturation point and when the primary containment pressure reaches the design pressure.

~

The Brunswick containment control procedures, primary containment temperature and primary containment pressure control direct the

- operator to the flooding procedure for each problem.

4.

RC/L-2

. Restore and maintain RPV water level between +162.5 inches (Iow level

. scram setpoint) and +208 inches

9 (high level trip setpoint) with

10 one or more of the following systems:

11 Condensate /Feedwater' System 1250 - O psig RPV pressure range for system operation)

CRD System 1490 - 0 (RPV_ pressure range for system operation)

RCIC System 1190 - 62 psig.(RPV pressure range for system operation)

12 HPCI System 1280 - 120' psig (RPV

- pressure range for system operation)

Core Spray System 300 - O psig (RPV pressure range for system operation)

RHR System 200 - 0 psig (RPV pressure range for system operation).

Rather than merely' listing-systems-to maintain vessel level, the Brunswick flowcharts prioritize the use of systems by defining plant conditions-through~ fault tree logic; e.g., on Path 4 the vessel level has decreased below +112 inches which automatically closes or Attachment B, Appendix III Page 4 of 17 w,er-'wy*w w wr gar-www m--9 WuNt-*'g-v7sr re*rw-"evM-Nw W vt w TM-4*-'99T-T*'trww w -w m - wcr 9 --wqy gg vM-uty.gg weiig e--,-+w wywp*w yq7

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directs the operator to close the MSIVs. __The procedure then directs the. operator to use HPCI, RCIC, and'CRD to maintain level since the-Feedwater System ;is now unavailable.

If the operator-is unable to maintain RPV ' level with high pressure. systems, the reactor is -

depressurized and low pressure systems are used to restore level.

On Paths 2 and 3, if the~MSIVs are open or pressure is below 350 psig,;the Condehsate/Feedwater System is used to maintain RPV level'.

-If the operator is unable to' maintain level with Condensate /

i Feedwater,'HPCI and/or RCIC are used.- If-level still cannot be maintained, the operator will be directed to Path 4 in-preparation

-for LPCI or Core Spray.use.

' Paths 1 and 5 follow the same pattern; the most desirable system that is available is used to maintain level. Each flowchart specifies level to be maintained between +170 and +200 inches.

~

Instructions to restore and maintain level between +170 and +200 inches and a' list of systems and pressure ranges are included as one of the first steps in each end path procedure.

5.

If RPV water level cannot be restored and maintained above

+162 inches (low level scram setpoint), maintain RPV water level above'0 inches (top of active fuel).

Each flowchart directs operators to continue increasing injection flow to the reactor until level is either increasing, stable, or above_the'high level trip setpoint. Each end path procedure

.provides guidance to maintain level between +170 and +200 inches.

If this level.cannot be maintained, the alternate band (above 0 inches) is specified.

6.

If RPV water level can be maintained above 0 inches (top of active fuel) and the ADS timer has initiated, prevent automatic RPV depressurization by resetting the ADS timer.

Flowcharts 2, 3, and 4 do not contain this step since a high drywell

_ pressure signal is necessary to initiate the ADS timer. Flowcharts 1 and 5 contain this step.

If level control problems are encountered while in the End Path Manuals, operators will be directed to the Level Restoration Contingency, which contains the guidance to prevent automatic

-initiation of ADS if RPV level can be maintained above 0 inches.

Attachment B, Appendix III Page 5 of 17

-7.

If RPV water level cannot be maintained above 0 inches (top of active fuel), enter CONTINGENCY #1.

-If, while using the flowcharts, the RPV water level cannot be maintained in the normal range, the operator is directed to the

= level restoration actions (Contingency #1).

All end path procedures direct operators to Contingency #1 if level cannot be maintained above 0 inches.

8.

If alternate shutdown cooling is required, enter CONTINGENCY #5.

End path procedures direct operators to GP-05 for the purpose of taking the reactor to cold shutdown.

If normal shutdown cooling cannot be established, Abnormal Operating Procedure 15 would be entered. AOP-15 prioritizes which method of alternate shutdown cooling is appropriate.

9.

RC/L-3 Proceed to cold shutdown in accordance with GP-05.

When the emergency conditions no longer exist (i.e., the RPV level, pressure, and power are under control (normal) and no containment problems exist), the operator exits the E0P and enters the General Operating Procedure to take the plant to the desired mode; e.g., hot standby cr cold shutdown.

10.

Cautions associated with Step RC/L.

a.

Caution #9 is to be covered in training and indicated on the RTGB.

.b.

Caution #10 is placed in each End Path Manual prior to the first Operator Action Step.

c.

Caution #11 is to be covered in training and included in the Users' Guide.

d.

Caution #12 is to be placed on the RTGB near the HPCI cnd RCIC Speed Controllers.

Attachment B, Appendix III Page 6 of 17

... - ~ --

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E.

REACTOR CONTROL / PRESSURE 1.

RC/P Monitor and control RPV pressure.

The Brunswick Operators are trained to constantly monitor and control RPV pressure while executing the steps of the E0P.

l 2.

If while executing the following steps:

Emergency RPV depressurization is anticipated, rapidly depressurize the RPV with Main

13 i

Turbine Bypass Valves.

Emergency RPV depressurization or RPV flooding is required and less than seven (number of SRVs dedicated to ADS)

SRVs'are open,. enter CONTINGENCY #2.

RPV flooding is required and at least seven (number of SRVs dedicated to ADS) SRVs are open, enter CONTINGENCY #6.

4 Emergency RPV depressurization is not expected to be required within the first few minutes following a reactor scram; i.e, while the operators are using the flowcharts. The only times the operator is directed to rapidly.depressurize the RPV on the flowcharts is in extremely degraded, low water level situations; e.g.,

the water level is below the top of active fuel or the RPV pressure must be maintained below 350 psig to accommodate low pressure system injection.

It is unlikely that the main condenser would be available in this case. 'If depressurization is required while in the end path procedure, the operator is directed to first attempt to use the main turbine bypass valves and then the SRVs.

In both flowcharts and end path procedures, if depressurization is required and cannot be accomplished with SRVs or to the main condenser, the operators are directed to Contingency #2 (Emergency Depressurization Procedure).

If flooding.is required, the operator will be directed to Contingency #6 (Flooding Procedure) from the end path procedure.

The Depressurization Steps are contained in Contingency #6. This simplifies the procedure by not going from an end path procedure, to a depressurization procedure, and then to a flooding procedure.

Attachment B, Appendix III Page 7 of 17

3.

RC/P-1 If any.SRV is cycling, manually open SRVs until RPV pressure drops to 950 psig (RPV pressure at which all Turbine Bypass Valves are fully open).

The flowchart directs the operator to prevent SRV cycling; e.g.,

immediately following the key parameters, the HPCI, RCIC, and SRVs are used to control RPV pressure below 950 psig. This guidance is repeated several times throughout the flowchart at the appropriate locations. The end path procedures also contain adequate RPV pressure control guidance.

4.

If while executing the following steps:

Suppression pool temperature cannot be maintained below the heat capacity

8 temperature limit, maintain RPV

13 pressure below the limit.

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me Heat Capacity Temperature Limit The heat capacity temperature limit is included in the Brunswick Containment Control Procedure (Suppression Pool Temperature Control-SP/T) as follows:

Step 3 of SP/T-IF suppression pool temperature CANNOT be maintained below the heat capacity temperature limit (See Figure 1, SP/T), REDUCE reactor pressure with the Bypass Valve Opening Jack or SRVs to maintain reactor pressure below the limit.

l l

Attachment B, Appendix III Page 8 of 17 t

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13 limit, maintain RPV pressure below the

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Suppression Pool Load Limit

-The suppression pool load limit guidance is included in the Suppression Pool Level Control - High Level (SP/L) Procedure in the End Path Manual as follows:

Step 4 of SP/L-High - E suppression pool water CANNOT be maintained below the suppression pool limit (see Figure 1, SP/L-High),

REDUCE reactor pressure with the Bypass Valve Opening Jack or SRVs to maintain reactor pressure below the limit.

Steam cooling is required, enter procedure developed from CONTINGENCY #3.

If steam cooling is required, the operator is directed to leave the Level Restoration Procedure as follows: E no high pressure, low pressure, or alternate coolant injection system is available, THEN EXIT this procedure and ENTER the " Steam Cooling Procedure" in the Contingency section of this End Path Manual.

' Attachment B, Appendix III Page 9 of 17 f

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5.

If while executing the.following steps:

Poron injection is required, and cThd Main Condenser is-available, and There has been no indication of gross fuel failure or steam line break,

~

open MSIVs to reestablish the Main Condenser

16 as a heat sink.

When entering the. Brunswick E0Ps, if an ATVS condition exists, the operator is quickly directed to Path 1 by.the first (highest priority) key parameter. Path 1~ directs-.the operator to reopen the MSIVs and to reestablish the main condenser as a heat sink whether or not. boron injection is required.

At all locations in the E0Ps, when this. guidance'is provided, the operator.is directed to check

.the availability of the condenser and to check for indications of fuel failure or steam line break.

6.

RC/P-2 Control RPV pressure below 1105 psig (lowest SRV lifting pressure; with the-

14 Main Turbine Bypass Valves.

RPV pressure control may be augmented by one or more

.of the following systems:

SRVs.- If the continuous SRV pneumatic supply is-or become

15 unavailable, depressurize with sustained SRV opening.

HPCI.

12

RCIC RWCU (recirculation mode) if no boron has been injected into the RPV.

l

Main Steam Line Drains RWCU (blowdown mode) if no boron has been injected into the RPV. Refer to sampling procedures prior to initiating blowdown.

- Attachment B, Appendix III Page 10 of 17

A11' flowcharts coitain. Pressure Control Steps following the key.

~

parameters. The instruction is to maintain pressure below 950 psig

.with SRVs,:if necessary. -Following a scram, the main turbine bypass valves should automatically ~contro11 reactor pressure if the MSIVs I

are open. _ If.the bypass valves fail to control reactor pressure or i-

.the MSIVs close,.it is appropriate to use SRVs to control pressure at this early point;in a transient.

All flowcharts also contain.

instructions to use HPCI and RCIC-for pressure control if required.

n

. Flowcharts 1, 3, 4 and 5 also attempt to restore the main condenser i

as'a-heat sink if plant conditions: allow.

The End Path Procedures prioritize the systems used for pressure control..The first priority is the main condenser, followed by SRVs, HPCI,-RCIC, steam condensing mode, MSL drains, and RWCU. The choice at this point is left to.the discretion of the operator.

i ~

7.

If while executing the follow'ing steps the reactor is not shut down, return to Step RC/P-2.

2

' Reactor Pressure Control Steps are repeated throughout the flowcharts 6

and end path procedures to ensure adequate pressure control ~is-maintained.'

r T

5 8.

PS/P-3 When RPV water level is stabilized and either:

All control rods are inserted beyond.

position 00 (maximum subcritical banked withdrawal position), or 570 pounds (cold shutdown boron weight) of boron have been injected into the RPV, or The reactor is shut down and no boron has been injected into the RPV, 4

Depressurize the RPV and maintain cooldown rate below

14, #17 100*F/hr (RPV cooldown rate.LCO).

1 If all control rods inserted past position 00 following a scram, the operator would enter Flowchart 2, 3, 4, or 5.

When the reactor and containment parameters have stabilized, the end path procedure will direct operators to GP-01 for hot standby or cold shutdown, as.

required.

i Attachment B, Appendix III Page 11 of 17

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RC/P-3 (Cont'd)

If boron has been injected, End Path Manual 1 requires 570 pounds of boron to be injected or all control rods to be inserted to position _00 before' a cooldown is commenced.

In either' case, cooldown rate is limited to less than 100*F/hr by-the procedure.

9.

RC/P-4 When the RHR shutdown cooling interlocks clear, initiate the

18 shutdown cooling mode or RHR.

If the RHR shutdown cooling mode cannot be established and further cooldown is required, continue to cool down, using one or more of the systems used for depressurization.

If RPV cooldown is required but cannot-be accomplished and all control rods are inserted to position 00 (maximum suberitical' banked withdrawal position), ALTERNATE '

SHUTDOWN COOLING IS REQUIRED;. enter CONTINGENCY #5.

Shutdown cooling is established per EPP-IN or-in End Path Manual 1

- if boron has'been injected.. In either case, if normal shutdown cooling cannot be established, operators are directed to Abnormal Operating Procedure.l.

(Alternate Shutdown. Cooling Methods) for the 5

proper guidance to establish an alternate means of shutdown cooling.

10.

RC/P-5 Proceed to cold shutdown in accordance with GP-05.

End Paths 2, 3, 4, and 5 direct the operator to proceed to' cold shutdown per GP-05.

If boron has been injected, operators will remain in End' Path 1,' which contains the necessary guidance to prevent-inadvertent criticality and limit the spread of boron to other plant systems.

11.

Cautions associated with Step RC/P.

a.

Caution #8 is to be placed on the RTGB as NPSH graphs for HPCI,

-RCIC, RHR, and Core Spray.

l

' Attachment B, Appendix III Page 12 of 17

<r

m-b.

l Caution #12 is to'be placed on the RTGB near the HPCI and RCIC

' Speed Controllers.

Caution #13 is included in the Users' Guide.

If the reactor is c.

rapidly depressurized, the operator is aware that cooldown rates will be exceeded.

d.

Caution #14 is included in the EOPs anytime the reactor is depressurized.

e.

Caution #15 is mounted on the RTGB and-is included in the flowcharts and End Path Manuals anytime the operator is directed to use the SRVs.

f.

Caution #16 is written into the Level / Power Control Flowchart and the associated end path procedures.

g.

Caution #17 is included in the Users' Guide.

If cooldown rates in excess of 100*F/hr are required, the procedure will direct the operator to do so, h.

Caution #18 is included in the flowcharts and End Path Manuals anytime RHR is to be used in any mode other than LPCI.

F.

-REACTOR CONTROL / POWER - RC/Q 1.

RC/Q Monitor and control reactor power.

The Brunswick Operators are trained to monitor reactor power. The

'first key parameter on the Brunswick flowchart directs the operator to determine whether or not the control rods are inserted to position 00 and that reactor power is less than 3%.

2.

If while executing the following steps:

All control rods are inserted to position 00 (maximum subcritical banked withdrawal position), terminate boron

' injection.

The reactor is shut down and no boron has been injected into the RPV, enter GP-05.

If the reactor fails to shut down upon the initiation of a scram signal, the operator is directed, by the first key parameter, to go to Path 1.

If boron is not injected and if the control rods can be Attachment B, Appendix III Page 13 of 17

fully inserted, the operator will be directed to return,to one of the other flowcharts; i.e., Path 2, 3, 4 or 5.

However, if boron injection is initiated, the operator remains on Path 1 or End Path Manual 1.

3.

RC/Q1 Confirm or place the Reactor Mode Switch in SHUTDOWN.

All flowcharts require placing the mode switch to shutdown.

Path I places the mode switch in shutdown only if the MSIVs are closed.

This prevents an MSIV closure and subsequent loss of the main condenser as a heat sink.

4.

RC/Q-2 If the Main Turbine Generator is on line and the MSIVs are open, confirm or initiate recirculation flow runback to minimum.

On Path 1, the reactor recirculation pumps are placed at minimum speed as one of the initial actions.

5.

RC/Q-3 If reactor power is above 3% (APRM downscale trip) or cannot be determined, trip the recirculation pumps.

On Path 1, the reactor recirculation pumps are tripped following runback to minimum speed if power is above 3%.

6.

Execute Steps RC/Q-4 and RC/Q-5 concurrently.

- The Level / Power Control flowchart contains the necessary guidance for boron injection and also requires the execution of Local Emergency Procedure 02 (Alternate Control Rod Insertion) concurrently with the flowchart.

7.

RC/Q-4 If the reactor cannot be-shut down before suppression pool temperature reaches

19 110*F (boron injection initiation temperature), BORON INJECTION IS REQUIRED; inject boron into the RPV with SLC and prevent automatic initiation of ADS.

Attachment B, Appendix-III Page 14 of 17

This guidance is contained on Path 1 and in LEP-02 (alternate control. rod insertion).

8.

RC/Q-4.1 If boron cannot be injected with SLC, inject boron into the RPV by one or more of the following methods:

CRD RWCU Feedwater HPCI RCIC If neither SLC pump will operate, the Level / Power Control flowchart directs the operator to LEP-03 (Alternate Boron Injection) which contains the steps necessary to inject boron from systems other than SLC.

9.

RC/Q-4.2 If boron is not being injected into the RPV by RWCU, confirm automatic isolation of or manually isolate RWCU.

If boron injection is required and an SLC pump is successfully started, RWCU will be isolated.

If an SLC pump cannot be started, RWCU will be isolated in LEP-03, if it is not being used to inject boron.

b 10.

RC/Q-4.3 Continue to inject boron until 570 pounds (cold shutdown boron weight) of boron have been injected into the'RPV.

If boron injection is required, operators will be directed to Contingency #7 (Level / Power Control Flowchart).

11.

RC/Q-5 Insert control rods as follows:

Local Emergency Procedure 02 (Alternate Control Rod Insertion) contains Steps RC/Q-5.1 through RC/Q-5.6.

This LEP will be entered anytime all control rods are not inserted past position 00 following a scram.

Attachment B, Appendix III Page 15 of 17

12.- Cautions associated with Step RC/Q.

a.

Caution #19 is in Flowchart 1, End Path Procedures.

b.'

Caution #20 is in LEP-02 (Alternate Control Rod Insertion).

G.

CONTAINMENT CONTROL The Brunswick conta'inment control procedures are located in the Containment Control section of each End Path Manual. These procedures are not expected to be needed immediately following the onset-of a potential emergency condition. However, for those conditions requiring entry-into the containment control procedures prior to the time the reactor is scrammed, the initial E0P guidance has been included in other procedures.

For example, should the suppression pool temperature exceed 95'F.during normal operation, an abnormal operating procedure (A0P-14) provides guidance for the operator to initiate suppression pool cooling and to scram the reactor prior to the pool temperature reaching 110*F.

Upon manual' scram, the EOP would be entered, Immediate Action (flowchart)

Steps. executed, and the end path procedure entered, at which time the operator is directed to enter the containment control procedures (if an entry condition exists) and to execute the containment control procedure concurrently with the end path procedure.

The entry conditions and operator actions for the ccatainment control

. procedures for.the Brunswick E0P are identical to the PSTG. Plant-specific information is added as required.

H.

LEVEL RESTORATION (CONTINGENCY # H Contingency 1 is contained in the Level Restoration procedure in the Contingency section of each End Path Manual.

The entry conditions and operator actions are identical to the PSTG with plant-specific information added as required.

I.

EMERGENCY DEPRESSURIZATION (CONTINGENCY #2)

Contingency 2 is contained in the Emergency Depressurization procedure in the Contingency section of each End Path Manual. The entry conditions and operator actions are identical to the PSTG with plant-specific

,information added as required.

J.

STEAM COOLING (CONTINGENCY #3)

Contingency 3 is contained in the Steam Cooling Procedure in the Contingency section of each End Path Manual.

This procedure has been written in flowchart format.

Attachment B, Appendix III Page 16 of 17 l

K.

SPRAY COOLING (CONTINGENCY #4)

Contingency 4 is contained in the Spray Cooling Procedure in the Contingency section of each End Path Manual. This procedure has been written in flowchart format.

L.

ALTERNATE SHUTD0h'N COOLING (CONTINGENCY #5)

Contingency 5 is conrained in Abnormal Operating Procedure 15.

M.

FLOODING PROCEDURE (CONTINGENCY #6)

Contingency 6 is contained in the Flooding Procedure in the Contingency section of each End Path Manual with plant-specific information added as required.

N.

LEVEL /P0h'ER CONTROL (CONTINGENCY #7)

Contingency 7 is contained in the Level / Power Control flowchart. The procedure was written in a flowchart format due to its complexity; i.e.,

requires many decision and branching points that must be observed during the execution of the procedure. The entry conditions and operator actions are identical to the PSTG with plant-specific information added as required.

Attachment B, Appendix III Page 17 of 17 I

~

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-. +, -

ATTACHMEhT C APPENDIX III Brunswick PSTG Deviations from the Generic Guideline The' emergency procedure guidelines are generic to GE-BWR 1 through 6 designs Tin that they address all major sys ns which may be ased to respond to an emergency.

Because no specific plant includes all of the systems in the

~

generic guidelines, the guidelines are applied to individual plants by deleting statements which are not applicable or by substituting equivalent systems where appropriate. For example, plants with no low pressure injection system will delete statements referring to LPCI, and plants with low pressure core flooding will substitute LPCF for LPCI.

This appendix provides a technical basis for the points at which the Brunswick PSTG deviates from generic guidelines.

a L

Attachment C, Appendix III

.Page 1 of 13

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TABLE OF CONTENTS i

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Section Page

'I.

' Operator Precautions.

3 II. RPV' Control Guideline.

3 III. Containment' Control-Guideline.

4

,IV.. Contingency, Procedure.

10 t.

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l-Attachment C, Appendix III.

Page 2 of 13 i

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Operator Precautions Coution'23 Generic Guideline

-Do not initiate drywell sprays unless suppression pool water level is below [17 feet 2 inches (elevation of bottom of Mark'I internal suppression chamber to drywell vacuum breakers less vacuum breaker opening _ pressure in feet of water)).

Brunswick PSTG Do not initiate drywell' sprays'unless suppression pool water. level is below -1 inch (elevation of bottom of Reactor Building to suppression pool vacuum breakers).

Justification The purpose of this caution is to prevent negative containment pressure in excess of design limits. At Brunswick, the Reactor Building-to suppression pool vacuum breakers are at a lower elevation than the suppression pool to drywell vacuum breakers. The lower of these elevations'is therefore used in the Brunswick PSTG, II.

RPV Control Guideline Entry. Conditions Generic Guideline

-a.

RPV high pressure 1045 psig

~

b.

RPV level below +162.5 inches c.

Drywell pressure above 2.0 psig d.

An isolation which requires or initiates a reactor scram A condition which requires a reactor scram ar.d reactor power is e.

above 3% or cannot be determined.

4.

Brunswick PSTG-A condition which requires ~ or has initiated a reactor scram Justification i

The entry c'ondition for Brunswick E0Ps is conservatively defined as any reactor scrad signal, manual or automatic.

If a true emergency condition-does not exist, the E0P will be exited when plant parameters are stable.

If a true emergency does exist, the operator (E

will be in the proper procedure and taking appropriate steps very AttachmentIC, Appendix III Page 3 of 13 I

~

y-early in the accident. The entry' condition is else very clear;

- there:is little room for. doubt as to which procedure applies.

' III. Containment Control Guideline Step DW/T-3 Generic Guideline DW/T - Before drywell. temperature reaches [340'F

18 (maximum temperature at which ADS qualified or drywell design -temperature, whichever.is lower)] but only if [ suppression chamber temperature and drywell pressure are below the

(-

~

drywell spray initiation pressure limit], [ shut

~

down recirculation pumps and drywell cooling

' fans and)'ini,tiate drywell sprays [ restricting flow rate to less than 720 gpm (maximum drywell spray flow rate limit)).

s Brunswick PSTG DW/T-3 Before drywell temperature reaches 300*F

18 (maximum drywell design temperature) but only if suppression-chamber temperatureJand pressure are below the drywell spray initiation pressure

- limit, shut down recirculation pumps and drywell cooling fans and initiate drywell sprays.

Justification The drywell spray flow rate' limit lin the generic guideline is the-product of two phenomenons associated with spraying the drywell.

The first is the convective cooling effect when drywell sprays are initiated following a high energy line. break in the drywell. The final pressure will be a_ function of the total air mass in the containment; a lower initial air mass will result in a lower final

. pressure. ' The suppression chamber to drywell vacuum breakers are-

= sized to accommodate the pressure drop.resulting from spraying the

. drywell following;a LOCA with all'noncondensables purged to the suppression chamber.

However, if the initial air mass was very low, theLfinal= containment pressure may decrease'below atmospheric at a rate beyond the capacity of the Reactor Building' to suppression

~

. chamber vacuum breakers. j Drywell spray must therefore not be initiated unless the total air mass in the containment is sufficient to ensure the negative' pressure limit will not be exceeded when i drywell temperature decreases to the spray temperature.

4

- The second phenomenon, evaporative cooling, occurs if the drywell.

sprays are actuated in a hot, low humidity environment. The

- pressure drop. associated with this mode of. cooling is potentially so rapid that negative containment pressures in excess of design may

~ Attachment C, Appendix III-Page 4 of 13 p.

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occur within a few tenths of a second folieving sprer initiation.

This transient is beyond the capabilities of the suppression pool to drywell vacuum breakers.

These two limits are so restrictive as to all but preclude initiation of drywell sprays under all conditions.

One solution is

- to limit the flow rate of drywell sprays, thereby reducing convective and evaporative cooling rates. This method is not feasible at Brunswick due to system design.

A second solution is to calculate the maximum pressure drop that-could occur due to the evaporative cooling effect.

If this pressure drop is less than the maximum negative pressure capability of the suppression pool to the drywell boundary, the evaporative cooling effect is not a concern and the drywell may be sprayed at rated flow if the' limits of the convective cooling effect are met.

These calculations were performed at Brunswick. The maximum pressure drop from the evaporative cooling effect has been determined to be less than the maximum negative pressure capability of the suppression pool to drywell boundary. The Brunswick PSTG therefore sprays the drywell at rated flow if the mass of noncondensables in the containment is sufficient to prevent. negative pressures in excess of design.

PC/P-2 Generic Guideline PC/P-2 Before suppression chamber pressure reaches

8, #18

[17.4 psig (Suppression Chamber Spray Initiation Pressure)], but only if

[ suppression chamber pressure is above 1.7 psig (Mark III Containment Spray Initiation Pressure Limit)] [ suppression pool water level is below 24 feet 6 inches (elevation of suppression pool spray nozzles)], initiate suppression pool sprays.

Brunswick PSTG PC/P-2 Before suppression chamber pressure reaches

8, #18 16.5 psig (Suppression Chamber Spray Initiation Pressure) initiate suppression pool sprays.

Justification The suppression pool spray nozzles at Brunswick are at elevation

-+12 feet 10 inches. The upper end of the suppression pool level instrument's rangt is +6 feet.

If suppression pool level increases above +6 feet, the operator would not be able to determine the actual suppression pool level.

Since the only concern with initiating suppression pool sprays with the nozzles submerged is Attachment C, Appendix III Page 5 of 13

~

that is would have no effect upon containment pressure, it is more conservative to simply require spraying in an attempt to control containment pressure, PC/P-3 y

Generic Guideline PC/P-3 If suppression chamber pressure exceeds

18

[17.4 psig (Suppression Chamber Spray Initiation Pressure)) but only if (suppression chamber temperature and drywell pressure are below the drywell spray initiation pressure limit], [ shut down recirculation pumps and drywell cooling fans and] initiate drywell sprays (restricting flow rate to less than 720 gpm (maximum drywell spray flow rate limit)].

Brunswick PSTG PC/P-3 If suppression chamber pressure exceeds

18 16.5 psig (suppression chamber spray initiation pressure) but only if suppression chamber temperature and pressure are below the drywell epray initiation pressure limit,

-shut down recirculation pumps and drywell cooling fans and initiate drywell sprays.

Justification See justification for DW/T-3, page 4 of 13.

PC/P-5 The wording of the steps in the generic guideline and the Brunswick PSTG are identical. The deviation in the step is due to the PSTG using a numerical limit rather than a graph.

Justification The suppression chamber' design pressure is an absolute value based upon an assumed maximum suppression pool level. A higher water level, however, will increase the hydrostatic head exerted upon submerged locations at a rate of 0.433 psi per foot of level increase.

Since this increased pressure cannot be detected by instruments located above the water surface, the design pressure must be derated accordingly.

Once the suppression pool water level reaches the elevation of the suppression chamber pressure instrument tap, further increases in hydrostatic head will be sensed directly by the instrument and continued deration is unnecessary. This is the basis for the graph contained in the generic guidelines.

' Attachment C, Appendix III Page 6 of 13 em-

-y m

, - +,,

w

.. = -

N" "Y

At Brunswick, use of.this graph would resn't aaaitional margin

'a

==

'of 3.41 psi.

This small increase in margin does not warrant the

-additional complication of using a two-dimensional limit during the highly stressful situation of primary containment pressure approaching design limits.

Brunswick has therefore opted to derate the primary. containment design praasure by 4 psi and use this absolute limit. This provides the operator with a clear point at

=which positive action should be taken.

PC/P-6 Generic Guideline

~

PC/P-6 If suppression chamber pressure cannot be maintained below the primary containment pressure limit, then irrespective of whether adequate core cooling is assured:

If suppression pool water level is below [24 feet 6

. inches (elevation of suppression pool spray nozzles)], initiate suppression pool sprays.

If [ suppression chamber temperature and drywell pressure are below the drywell spray initiation pressure-limit], [ shut down recirculation pumps and drywell' cooling fans and] initiate drywell sprays

[ restricting flow rate to less than 720 gpm (maximum drywell spray flow rate limit)].

~ Brunswick PSTG PC/P-6 If suppression chamber pressure cannot be maintained below 58 psig (the primary containment pressure limit), then irrespective of whether adequate core cooling is assured:

Initiate suppression pool sprays.

If suppression chamber temperature and pressure are below the drywell spray initiation pressure limit, shut down recirculation pumps and drywell cooling fans and initiate drywell sprays.

Justification First bullet, see justification for PC/P-2, page 5 of 13.

Second bullet, see justification for DV/T-3, page 4 of 13.

PC/P-6 Primary Containment Pressure Limit (PCPL)

-Attachment C, Appendix III Page 7 of 13

Generic Guideline

.The generic guideline differentiates between the design pressure of containment.and the PCPL with PCPL being a higher limi..

l Brunswick PSTG The Brunswick PSTG treats the design pressure and PCPL as one limit.

' Justification The PCPL is defined as the suppression chamber pressure beyond which

. primary containment integrity _can no longer be assured.

Primary containment integrity must be maintained,_even at the expense of adequate core cooling, to provide protection against the potential uncontrolled release of radioactivity to the environment. This rationale is appropriate because no assurance can be provide'd that adequate core cooling will be maintained in the event of containment

-failure since the containment failure mechanism or location cannot be predicted and will probably result in subsequent loss of adequate core cooling due to loss of the source of water for ECCS, loss of ECCS pumps or piping integrity, or loss of RPV support and integrity.

Brunswick is currently using design pressure as the PCPL. This is'the only limit that is technically justifiable at

.this-time' Brunswick is currently evaluating containment vent valves, SRV solenoids, containment penetrations, etc., for pressures and temperatures in excess of design.

Brunswick is also involved with developing a generic basis for this limit with the BWROG Emergency Procedures Committee. We will continue with the effort to upgrade the PCPL.. When sufficient technical justification is _ avail-able to support a higher limit, Brunswick will update the PSTG.

In the interim, Brunswick will use design pressure as the PCPL.

Allowing pressure in excess of design.could-lead to failure of

-containment vent valves or. loss of SRV operability which could lead to ultimate containment failure or an' uncontrolled release of

-radioactivity.

SP/L-3.3 Generic Guideline SP/L-3.3 Before suppression pool water level reaches

18

-(17 feet 2 inches (elevation of bottom of Mark I intereal suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water)] but only if (suppression chamber temperature and drywell pressure are below the drywell spray initiation pressure limit], [ shut down recirculation pumps and drywell cooling fans and]' initiate drywell sprays (restricting flow rate to less than 720 gpm (maximum drywell spray flow rate limit)].

I L

Attachment; C, Appendix III Page 8 of 13 l

i'

..,c Brunswick PSTG SP/L-3.3 Before' suppression pool water level reaches

18 7 inches (elevation of bottom of Mark I suppression chamber. vacuum breakers) but only if suppression chamber temperature and pressure are below the drywell spray initiation pressure limit, shut down recirculation pumps and drywell cooling fans and initiate drywell sprays.

Justification Vacuum breaker elevation, see justification for caution 23, page 1 of'13.

.Drywell spray flow rate, see justification'for DW/T-3, page 4 of 13.

SP/L-3.4 Generic Guideline SP/L-3.4 If suppression pool water level exceeds

23 (17 feet 2 inches (elevation of bottom of Mark I internal suppression chamber to drywell vacuum breakers less vacuum breaker opening pressure in feet of water)] continue to operate ~

L drywell sprays (belei 720 gpm (maximum drywell spray flow rate limit)].

. Brunswick PSTG L-SP/L-3.4 If suppression pool water level exceeds

23

-1 inch (elevation of bottom of Mark I Reactor Building to suppression chamber vacuum breakers),

continue to operate drywell sprays.

Justification See justification for caution 23, page 1 of 13.

SP/L-3.5

~ Generic Guideline SP/L-3.5 When primary containment water level reaches [104 feet (maximum primary containment water level limit)],

terminate injection into the RPV from sonrces external to the primary containment irrespective of whether adequate core cooling is assured.

Attachment C, Appendix III Page 9 of 13

1 Li 4 Brunswick PSTG This step is deleted from the Brunswick PSTG.

Justification' Instrumentation is not provided at Brunswick to measure the water level to the top of the-drywell.

The calculation procedure for the

.technica1' guideline has shown that the hydrostatic pressure resulting from complete flooding of th'e drywell will not exceed design pressure..In addition, the suppression pool level control procedure will raquire terminating injection from sources external to primary containment if suppression pool level is above +6 feet and-adequate core cooling is assured.

IV.

Contingency Proceduras Contingency 1 Step C1-7'of generic guideline, Step Cl-6 of Brunswick PSTG, NOTE:

The difference in step numbers in this contingency is due to the generic guideline requiring initiation of IC in Step Cl-1.

Brunswick does not have an IC and this step has been deleted.

Generic Guideline Cl-7 RPV WATER LEVEL DECREASING, RPV PRESSURE HIGH OR INTERMF.DIATE If HPCI or RCIC is not operating, restart whichever is not operating.

If no CRD pump is operating but at least two injection subsystems are lined up for injection with pumps running, EMERGENCY RPV DEPRESSURIZATION IS REQUIRED.

When RPV water level is increasing or RPV pressure drops below [100 psig (HPCI or RCIC low pressure isolation setpoint, whichever is higher)],

return to Step Cl-3.

If no CRD pump is operating and no injection subsystem is lined up for injection with at least one pump running, start pumps in alternate injection subsystems which are lined up for injection.

When RPV water level drops to (-164 inches (top of active 7

fuel)]:

If no system, injection subsystem or alternate injection subsystem is lined up with at least one pump running, STEAM COOLING IS REQUIRED. VHen any system, injection subsystem or alternate injection subsystem is lined up with at least.one pump running, return to Step Cl-3.

Attachment C, Appendix III Page 10 of 13

Otherwise, EMERGENCY RPV DEPRESSURIZATIOS IS REQUIRED.

When RPV water level is increasing or RPV pressure drops below [100 psig (HPCI or RCIC low pressure isolation setpoint, whichever is higher)], return to Step Cl-3.

Brunswick PSTG Cl-6 RPV WATER LEVEL DECREASING, RPV PRESSURE HIGH OR INTERMEDIATE If HPCI and RCIC are not operating, restart whichever is not operating.

If no CRD pump is operating and no injection subsystem is lined up for injection with at least one pump

. running, start pumps in alternate injection subsystems which are lined up-for injection.

When RPV water level drops to 0 inches (top of active fuel):

If no system, injection subsystem, or alternate injection subsystem is lined up with at least one pump running, STEAM COOLING IS REQUIRED.

When any system, injection subsystem, or alternate injection subsystem is lined up with at least one pump running, return to Step C1-3.

If any RPV injection exists, EMERGENCY RPV DEPRESSURIZATION IS REQUIPED. When RPV water level is increasing or RPV pressure drops below 120 psig (HPCI' low pressure isolation setpoint), return to STEP Cl-3.

Justification The Brunswick PSTG delays RPV depressurization until RPV level decreases to the top of the active fuel for the following reasons:

1.

Adequate core cooling is maintained so long as RPV water level remains above the top of active fuel.

2.

The time during which RPV. water level decreases to the top of the active fuel can best be used to line up alternate methods of kPV injection to reverse the decreasing RPV water level trend.

This it also the method used in revision 3 of the generic guideline which has been approved by the NRC.

Contingency 2 Step C2-1.2 of generic guideline Step C2-1.1 of Brunswick PSTG NOTE:

The difference in the step numbers in this contingency is due to the generic guideline requiring initiation of IC in Step C2-1.1.

Brunswick does not have an IC and this step has been deleted.

Attachment C, Appendix III Page 11 of 13

Generic Guideline C2-1.2 If suppression pool water level is above (4 feet 9 inches (elevation of top of SRV discharge device)]:

Open all ADS valves.

If any ADS valve cannot be opened, open other SRVs until (seven (number of SRVs dedicated to ADS)]

valves are open.

Brunswick PSTG C2-1.1 Open all ADS valves.

If any ADS valve cannot be opened, open other SRVs.until seven (number of SRVs dedicated in ADS) valves are open.

JJustification The suppression pool at Brunswick is encased in concrete.

Each room below the suppression pool-elevation is independent; i.e.,' flooding in one room will not cause all rooms to be flooded.

If an unisolable leak were to occur in four of the five rooms simultaneously, they could equalize with the suppression pool and the T quencher would remain covered.

If the fifth room was also flooded by a leak from the suppression pool, i.e.,

the entire area below the suppression pool elevation was flooded, the.T quencher would only be partially covered.

The elevation at the top of the T-quencher is 9 feet.

The Brunswick

EOPs, i.e., suppression pool low level procedure, directs the operator to depressurize the reactor at 6 feet 6 inches.

In order fcr the suppression pool level to be below the top of the T-quencher, a simultaneous leak would have to occur in both RHR rooms, both core spray rooms, and the HPCI room. This is not considered credible; therefore, this step has been deleted from the Brunswick EOPs.

Contingency 7 - Level / Power Control - Box Preceding Step C7.1 Generic Guideline If while executing the following steps RPV flooding is required or RPV water level cannot be determined, control injection into the RPV to maintain reactor power above [8% (reactor flow stagnation power)]

but as low as practicable.

However, if reactor power cannot be determined or maintained above (8% (reactor flow stagnation power)], RPV FLOODING IS REQUIRED; enter.[ procedure developed from CONTINGENCY No. 6].

Attachment C, Appendix III Page 12 of 13

m j

l Brunswick PSTG If while executing the following steps:

RPV water level cannot be-determined, RPV flooding is required; enter contingency No. 6.

RPV flooding is required, enter contingency No. 6.

Justification The requirement to attempt to maintain reactor power above 8% if RPV flooding were required while injecting boron was based upon the assumption that if RPV water level were reduced sufficiently, natural circulation flow would stagnate and reactor power would stabilize at a constant of 8% known as the " reactor flow stagnation power." Later analysis has shown that the reactor power may actually vary from 6% to 30% under this condition, depending upon the initial conditions and analysis assumptions chosen.

For this reason, the Brunswick PSTG does not ettempt to maintain power at 8%

if flooding is required while injecting boron.

Rather, the Brunswick PSTG requires that the flooding procedure be entered if flooding is required while injecting boron.

The steps in the flooding _ procedure will remain unchanged. However, the basis for the minimum alternate RPV flooding pressure must be redefined. The original basis was that if the differential pressure between the RPV and the suppression pool is maintained equal to or greater than the specified value, the resulting steam flow through Since this 8%

the open SRVs will be equivalent to 8% reactor power.

number is no longer valid, the minimum alterrate RPV flooding pressure has been defined to be the minimum RPV pressure at which steam flow through the open SRVs is sufficient to remove all decay heat from a completely uncovered core by steam heat transfer alone ten minutes after a shutdown from 100% power with no clad temperatures in excess of 1500*F. This pressure is based on the assumption, supported by extensive test data, that fuel perforations

. will not _ occur if peak clad temperature is maintained below 1500*F.

Thus maintaining RPV pressure above the minimum alternate RPV flooding pressure assures that no fuel damage will occur even if the reactor is not shut down during the flooding evolution.

This deviation is considered to be conservative, even though not NRC approved, since the 8% power assumption has been proven to be incorrect. The approach used in the Brunswick PSTG is also the same approach that.is in revision 4 of the generic guideline.

Page 13 of 13 Attachment C, Appendix III

.

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