ML20126M938

Abnormal Transient Operating Guidelines (Atog) Comparison of Crystal River Unit 3 to Oconee Nuclear Station Unit 3

ML20126M938
Person / Time
Site:	Crystal River
Issue date:	07/31/1985
From:	BABCOCK & WILCOX CO.
To:
Shared Package
ML20126M937	List: 3F0785-33, Responds to 841001 Request for Addl Info Re Procedures Generation Package for Emergency Operating Procedures. Abnormal Transient Operating Guidelines (Atog) Comparison of Crystal River Unit 3 to Oconee Nuclear... Encl ML20126M938
References
12-1156769, 12-1156769-00, NUDOCS 8508050132
Download: ML20126M938 (51)

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Abnormal Transient Operating Guidelines (ATOG)

Comparison of Crystal River Unit 3 to Oconee Nuclear Station Unit 3 i

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Comparison Of Crystal River Unit 3 To Oconee Nuclear Station Unit 3 12-1156769-00 Doc. ID-Serial No., Revision No.

For Florida Power Corporation y

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INTRODUCTION The Owners of Babcock and Wilcox-designed nuclear power reactors have developed guidelines to aid preparation of operating procedures for the mitigation of transients and accidents in response to Item I.C.1 of NUREG-0737, " Clarification of TMI Action Plan Requirements."

The approach selected by the B&W Owners Group resulted in plant-specific Abnormal Transient Operating Guidelines (ATOG) based on generic symptoms of upsets in heat transfer.

Since there is no generic version of ATOG, the Nuclear Regulatory Commission reviewed the ATOG developed for the Oconee Nuclear Station, Unit 3 (ONS-3) and thus the Safety Evaluation Report issued in September of 1983 is based on the ONS-3 version of ATOG (Ref. 1).

The purpose of this document is to facilitate NRC review of the plant-specific ATOG developed for the Florida Power Corporation (FPC) Crystal River Unit 3 (Ref. 2) by comparison of the Procedural Guidelines (Part I) of the Crystal River Unit 3 and ONS-3 ATOCs.

The Crystal River Unit 3 ATOG is consistent with the ONS-3 ATOG in overall philosophy, use of symptoms, and priority of major actions.

However, the plant specific nature of ATOG does result in differences, the reasons for which are identified in this document.

SCOPE This document contains sections correlating to each major heading of the Crystal River Unit 3 ATOG Part I, Procedural Guidelines.

Each section identifies differences between the Crystal River Unit 3 version and the ONS-3 version previously reviewed by the NRC and explains the reasons for these differences.

In general, each difference exists for one of the following reasons:

1.

Plant-specific differences in equipment, NSS design, setpoints or procedures.

2.

Improvements incorporated as a result of the NRC review of the ONS-3 ATOG or as a result of the " learning curve" related to ATOG development.

Changes due to the NRC review primarily consist of item identified in References 3 and 4.

Reference 5 was issued after completion of the final Crystal River Unit 3 ATOG.

3.

Preferential differences of a non-technical nature that reflect i

Crystal River Unit 3 preferred methods for operation or training.

In addition, this document provides composite flow charts that use the Crystal River Unit 3 logic diagrams from ATOG Part I as a base.

The logic diagrams have been modified to show differences with respect to the ONS-3 version, specifically:

1.

Steps that are unique to the Crystal River Unit 3.

2.

Steps that are unique to the ONS-3 ATOG.

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3.

Steps that are in a different sequence.

4.

Differences in setpoint or wording.

A composite flow chart is provided for every Crystal River Part I logic diagram except III.C, " Excessive Heat Transfer".

The overall logic of the Crystal River Figure III.C is similar to the Oconee version.

However, the additional steps required to address the Steam Line Break Isolation System (SLBIS) on Crystal River made it impractical to develop a composite flow chart.

Therefore, logic diagrams for Section III.C from both Oconee and Crystal River ATOCs are included.

Throughout this document, the terms " Crystal River" and "Oconee" will be used in lieu of " Crystal River Guidelines" and "Oconee Guidelines" respectively.

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SECTION I - IMMEDIATE ACTIONS 1.

Ites a and b under Reactor Trin:

Oconee instructs the operator to ma.nually trip the reactor and turbine.

Crystal River instructs the guideline user to verify trip of the reactor and turbine which implies, if they are not tripped then trip them. Consequently, both guidelines accomplish the same actions.

2.

Item e under Reactor Trio:

Crystal River instructs the gui.4eline u er to go to Section III.

This is an error.

It should state go to Sectior. II which is the same as Oconee.

3.

Item a under Forced Shutdown:

Crystal River is different from the Oconee traideline only to account for differences in the radiation monitoring equipment i. sed to indicate y

a steam generator tube rupture.

4.

Item b under Forced Shutdown:

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Different procedure numbers are referenedd.

They are plant specific procedures that accomplish the same basic function.

In addition.

the Crystal River specifically states to continue with Section II of ATOG while this is an implied condition on Ocoree.

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SECTION II - VITAL OTSTEM ST M S VERIFICATION

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1.

Crystal River ' verification Step 2.0 states the desired 'shtitdown margin while the equivalent step in the Oconee guidelines does not.

I The desired shutdown margin for both Crystal. River and Decnee is a Technical Specification parameter and is iterated it. Crysta'l River only for emphasis.

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2.

Crystal River Step 3.0 mistakenly listed the MSAvs(MSt[-411-412.-413,-

41 4.

These should be deleted from this step.' Thus, the step becomes similar to the Oconee Step 3.0.

3.

Crystal River verification Step 4.0 has a cla'rification criterion added to verify SG 1evels are ' decreasing.. Thia statement is to verify that feedwater is ru'uning' back enough 'to cause the SG 1evel to decrease. This is implied in the equivalent Oc'onee step (5.0).

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4. ( Crystal River Step.i. 0, " verify cross-tie'kive has opened," does got have an equiv ale nt step in the Oconee guidelines.

The' s tep is ' provided to address,s n,pecific design ' fdsture'in the Crystal s Azver MW system which does not exist in the Ocor.ee MW system design.

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Step ' 4.0,

" verify feecaster hgs r,u n ba ck, " and Step 6.0,

" verify i

letdevs flow throufr, Mock orifice only," are in reve/Je order from the pqgivalent steps ' in the Ocone'e guidelines (Steps 5.0 med 4.0 i

respecti.vely).

Sirce these are only verification steps, the outcome of one step does not affect the other. Consequently, they can be reversed.

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The remedial action 'for deonee Step 6.0 (loss of ICS/NNI power) refers to a site procedure.

Florida Power Corporation opted to I

include the remedial action procedure for 'a' loss of NNI/ICS in the ATCG guidelines.

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7.

Crystal River Step 8.0 and Oconee Stap 7.0 are equivalent.

They both address a loss of offsite power.

The differences between the steps reflect only plant design differences.

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Crystal River Step 9.0 ts equivalent to Oconee Step 8. 0..

The steps are structured differently to reflect differences in the' operation

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9. ' 'Crystal River has an additional *tep 10.0 to verify ' proper operation C

of ?.he Steam dine Break Isolation System (SLBIS).

Oconee does not have a similar sya' fen.

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10. (Crys tal !tiver verification Step 13'.0 and Oconee verification Step 11.0 are aquivalent.

However, they reflect a plant design difference.

Crystal River has a condenser vacuum pum'p while Oconee hs,s a condenser sie ejector.

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SECTION III.A - LACK OF ADEOUATE SUBC00 LING MARGIN 1.

Crystal River has an additional step (4.0) to address excessive heat transfer.

Both Crystal River and Oconee address this symptom near the end of Section III.A, but Crystal River addresses it also at this point to cover the event where loss of subcooling margin occurred due to excessive heat transfer.

In this case, the operator would transfer to Section III.C to terminate the overcooling transient. Then he would return to III.A if adequate subcooling margin still does not exist after stabilizing heat transfer.

2.

Crystal River Step 5.0 (" maintain proper SG 1evels") was placed after the additional Step 4.0 (refer to Item 1 above) since Step 4.0 corrects the causes that affect SG 1evel.

3.

Crystal River Step 7.0 checks for superheated conditions using only the incore the mocouples, while the equivalent Oconee step (6.0) references use of hot leg RTD's in conjunction with incore thermocouples.

This change was made in response to an NRC comment addressed in the March 14, 1983 supplement to the ONS-3 ATOG (Ref. 4, Item #13).

4.

Crystal River decision Step (8.0), for determining whether or not to transfer to CP-101, was placed before the step which checks for adequate primary to secondary heat transfer (Step 9.0) to stream-line the procedure. A large LOCA which requires going to CP-101 will also cause a loss of primary to secondary heat transfer because the RC temperature will go below the SG temperature.

Oconee provides the same actions as the Crystal River guidelines.

That is, for a large LOCA the heat transfer in both steam generators will be lost.

The answer to Oconee decision Step 7.0 will be "no" which will lead to Oconee decision Step 8.0.

The answer to decision Step 8.0 will also be "no" which will lead to Oconee Step 9.0 which is the decision step concerning whether or not to transfer to CP-101.

Oconee Step 9.0 is the same as Crystal River Step 8.0.

5.

Crystal River does not have the equivalent of Oconee Step 8.0.

Oconee decision Step 8.0 is not needed since both the "yes" and the "no" decision send the guideline user to Section III.B.

6.

Crystal River Step 12.0 includes a check for indication of a steam generator tube rupture (SGTR).

This has been added to complete the verification of plant stability and to address the possibility that a tube rupture may have caused or contributed to the loss of subcooling margin.

Crystal River decision Step 12.0 is a consolidation of Oconee Steps 13.0 and 14.0 plus the additional step for checking for a SGTR.

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7.

Crystal River Step 13.0 provides a step allowing further action at the dis cre tion of management rather than directing the guideline user to CP-105 as in Oconee Step 15.0.

At Crystal River Step 13.0, the primary to secondary heat is being controlled properly and the RCS is subcooled with no steam generator tube leaks.

Consequently, the plant can be safety maintained in this situation pending further instructions by station management.

Station management will dee ermine whether or not a cooldown is required.

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SECTION III.B - LACK OF HEAT TRANSFER 1.

Crystal River decision Step 1.0 directs the guideline user to Section III.A to address a lack of adequate subcooling margin.

Oconee does not direct the guideline user to Section III.A.

Instead, the Section III.B guidelines (Steps 2.0, 3.0, 4.0) include those steps of Section III.A which are applicable to the lack of heat transfer situation.

2.

Crystal River Step 9.0, concerning PORY operation, does not exist in Oconee, but was added to the Oconee scope by the July 2,

1983 supplement (Ref. 5, Attachment B).

3.

Crystal River Step 10.0 "when adequate heat transfer is restored...."

was placed before Step 11.0, " lower SG pressure to induce heat transfer,"

because Step 10.0 is a WHEN instruction.

In essence, the step is indicating that it should be followed whenever it becomes applicable while performing subsequent steps.

4.

Steps 12.0 and 13.0 of Crystal River are in reverse order from the equivalent steps (14.0 and 15.0) in Oconee.

There is no functional difference as both sequences accomplish the same actions.

5.

Crystal River decision Step 12.0 sends the guideline user to decision

-Step 16.0 to check if heat transfer exists if RC pumps cannot be bumped, while Oconee decision Step 15.0 sends the guideline user directly to CP-104 if the RC pumps cannot be bumped.

Crystal River sends the guideline user to Step 16.0 because the previous step (11.0) just lowered the SG pressure so the guideline user has to check for l

SG heat transfer before deciding on whether or not to go to CP-104.

Oconee has a previous step (13.0) which has already checked for SG heat transfer and determined that it does not exist.

Therefore, Oconee sends the guideline user directly to CP-104 if the RC pumps cannot be bumped.

6.

Crystal River Step 18.1 has the words " maintain appropriate SG 1evel".

These were added to emphasize that the required SG 1evels can vary because the RC subcooling margin may or may not exist and reactor coolant pumps could be operating.

Each of these situations will require a different SG 1evel.

7.

Crystal River and Oconee Section III.B guidelines have slightly different instructions after obtaining primary to secondary heat transfer and adequate subcooling margin (Crystal River Step 19.0 and Oconee Step 21.0).

Crystal River directs the guideline user to a procedural end step (status step 20.0) while Oconee instructs the guideline user to go to the cooldown procedures. These differences are unimportant because the plant has reached a safe stable condition.

Consequently, the plant can be safely maintained in this situation pending further instructions by station management.

Station management will determine whether or not a cooldown is required.

8.

After reaching the safe stable condition of Crystal River Step 19.0 or Oconee Step 21.0 (i.e., RC subcooled and adequate primary to secondary

heat transfer), starting the RCP(s) is desirable.

Both Crystal River and Oconee provide instructions to start RCP(s), but in a different manner.

Crystal River decision Step 19.0 states start two RCPs if adequate subcooling margin exists.

The Oconee equivalent of Crystal River Step 19.0 is Oconee Step 21.0.

Step 21.0 directs the guideline user to Cooldown Procedures which instruct the guideline user to start RCP(s).

9.

Crystal River Step 17.0 states, " RECOVER FROM HPI COOLING. IF INITIATED".

The phrase, "if initiated", does not exist in Oconee but was added to Oconee by the June 15, 1982 supplement (Ref. 3, Step 19.0 of III.B) in response to an NRC cosament.

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SECTION III.C - EXCESSIVE HEAT 'f*A*SFER 1.

General Section III.C of Crystal River contains a number of steps which are different from Oconee Section III.C.

These differences do not functionally alter the actions for excessive heat transfer but are necessary to address manual or automatic SLBIS actuation.

A composite flow chart is not provided for this section since the number of discrete differences would make it difficult to use.

A copy of each flow chart is provided for comparison.

The functional similarity is evident when both flow charts are compared as discussed in the following paragraphs.

2.

Step 1.0 of Crystal River states to check for Adequate Subcooling Margin.

Oconee also states to check for Adequate Subcooling Margin,

-but at the end of the excessive heat transfer procedure (Steps 8.0/12.0/19.0/23.0).

The AT0G concept requires that the operator always observe for a Loss of Adequate Subcooling Margin regardless of what procedure is presently being followed.

Consequently, the procedural step for observing subcooling margin does not need to be stated.

However, since the events which cause overcooling can also cause a loss of subcooling margin, the step to observe subcooling was. added to the excessive heat transfer procedure for emphasis.

However, the location of this step is not important.

3.

Step 2.0 of Crystal River states to increase makeup flow by starting the second makeup pump and taking suction from the BWST if the pressurizer level falls below 50" and RC pressure is increasing.

Oconee (Step 1.0) states to initiate HPI.

Both steps provide the same function which is to stop a decreasing RC inventory (associated with contraction of the RC).

However, Crystal River first attempts to stop the decrease by increasing makeup flow (by starting the second makeup pump) through the makeup control valve since this valve provides automatic pressurizer level control and directs flow to the normal makeup nozzle to limit thermal cycles on the other HPI nozzles.

4.

Crystal River has a Steam Line Break Isolation System (SLBIS) which is designed to automatically isolate a steam generator if the SG is overcooling due to a steam line leak.

Oconee does not have an automatic isolation system; consequently, the Crystal River and Oconee excessive heat transfer guidelines differ to account for this design difference.

The Crystal River SLBIS is accounted for in two situations.

The first situation assumes automatic actuation of SLBIS (Steps 3.0 and 4.0).

The second situation assumes the. operator isolates - the steam generator (s) by manually actuating SLBIS.

Crystal River directs manual SLBIS actuation in Steps 13.0 and 14.0 if automatic SLBIS action does not occur.

Crystal River Step 13.0 is similar to Step 2.0 of Oconee.

Step 13.0 is a decision step which directs action based on whether or not the overcooling SG is identified.

If the overcooling SC is apparent,

the operator isolates the overcooling SG (using SLBIS).

This step, along with Step 15.0 (close the EFPT steam isolation valve on isolated SG), accomplishes the same function as does Oconee Step 14.0.

Crystal River Step 15.0 is added because SLBIS does not close the EFPT steam isolation valve.

If the overcooling SG is not apparent, then Crystal River Step 14.0 instructs the operator to isolate both SG's (using SLBIS).

This step, along with Step 23.0 (close the EFPT steam isolation valve on both SG's), accomplishes the same function as does Oconee Step 3.0.

Crystal River Step 23.0 is added because SLBIS does not close the EFFT steam isolation valves.

5.

Crystal River Step 7.0 is a decision step directing action based on SG 1evel being greater than 90-95% on the operate range and increasing.

A similar step, which protects against rapid SG MW overfill is provided in Oconee, but as a substep of Step 3.0 (isolate both SGs) and Step 14.0 (isolate the overcooling SG).

6.

Crystal River, for one overcooling SG, instructs the operator to

" control heat transfer to the unisolated SG" in Step 16.0.

This step is similar to Oconee Step 17.0 " control heat transfer to SG without steam leak".

Crystal River also instructs the operator to establish EW flow to the isolated SG in Step 20.0 if the " pressure and level are stable on the isolated SG" as determined in decision Step 18.0.

This is similar to Oconee Step 21.0 which instructs the operator to " reestablish heat transfer to the isolated SG".

These same steps are followed af ter SLBIS actuation whether the SLBIS was automatically (Step 4.0) or manually initiated (Step 13.0).

7.

If both SG(s) are isolated, Crystal River Step 24.0 instructs the operator to " restore heat transfer to a steam generator with stable pressure and level" (i.e., to a SG with an isolable steam leak).

Then, Crystal River Step 26.0 restores heat transfer to the other SG if it has an isolable steam leak as determined in Step 26.0 by observing the SG pressure and level are stable.

Crystal River Step 14.0 and 26.0 combined, correspond to Oconee Step 10.0 while Crystal River Step 24.0 corresponds to Oconee Step 6.0.

These same steps are followed af ter SLBIS actuation whether the SLBIS was automatically (Step 3.0) or manually (Step 14.0) initiated.

8.

Crystal River Steps 17.0.and 25.0 check for a SGTR isusediately af ter establishing heat transfer to the good SG, following isolation of one or two SGs.

Then the guideline user is instructed to determine if heat transfer can be reestablished to the other SG.

This gives emphasis to start checking for a SGTR as soon as possible, i.e.,

l before reestablishing heat transfer with the other SG.

l I

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Crystal River Step 12.0 requires the operator to "stop all feedwater to both SG's".

Step 12.0 is entered if the steam line break is not large enough to actuate SLBIS and the leaking SG is not readily identifiable.

Isolating all feedvater will help identify the leaking SG by observing SG 1evels.

Oconee does not have an automatic steam line isolation system and therefore Oconee isolates both SG's in step 3.0 if the SG causing the overcooling cannot be identified.

10. Crys tal River Step 7.0 requires tripping MW pumps only if SG 1evel is greater than 95% and increasing while Oconee Steps 3.0 and 14.0 also trip MW pumps if pressurizer level is below 50" and decreasing.

The intent of tripping M W pumps is to terminate excessive MW flow.

Since other overcooling scenarios (e.g.,

small steam leak) could cause a decrease in pressuriser level, the pressurizer level determinant was deleted from Crystal River.

In addition, trip of the MW pumps is the first action on Crystal River (reverse from Oconee).

This change was made in response to an NRC comment (Ref. 3,Section III.C Steps 3.1 and 14.1).

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1 SECTION III.D - STEAM GENW8ATOR TUBE RUPTURE 1.

A guideline step equivalent to Crystal River Step 1.0 is not included 1

in Oconee.

This step addresses a lack of subcooling margin and l

improper heat transfer.

These symptoms should always be treated before a SCTR is treated.

This priority is a basic understanding in the ATOC philosophy.

Consequently, Crystal River Step 1.0 does l

not need to be provided but has been added for emphasis since a SGTR can cause a lack of adequate subcooling margin and/or improper j

heat transfer.

4 2.

Crystal River Step 2.0,

" start a local steam line survey and SG boron analysis", is equivalent to Oconee Substep 3.4.

This action 1

was placed at the beginning of the SGTR guidelines to emphasize i

starting the survey as early as possible.

3.

Crystal River Step 4.0 states to increase makeup flow and then initiate 1

HPI if makeup flow is not adequate, while Oconee Step 2.0 initiates 4

HPI.

Increased makeup flow should be sufficient for most tube leaks i

and therefore is attempted first.

4.

Crystal River step 4.2 (letdown isolation) is identical to Oconee step 3.1 but was placed under step 4.0 because it is functionally similar in controlling RC inventory.

5.

Crystal River unloads and trips the turbine below 12% reactor power (Step 5.3) while Oconee performs these actions at less than 20%

i power (Step 3.5).

The power limitation is based on turbine bypass capacity in order to prevent unnecessary lif ting of main steam safety valves.

Both the Oconee and Crystal River steps accomplish this function.

6.

Both Crystal River and Oconee require returning to Section I and II if the reactor trips during runback. However,the steps are sequenced differently.

Crystal River Substep 5.2 sends the guideline user to Step 6.0 if the reactor trips.

Then Substep 6.1 sends the guideline user to Sections I and II.

The Oconee guideline Substep 3.3 sends the guideline user directly to Sections I and II if the reactor trips during runback.

i 7.

Crystal River Step 6.0,

" reactor has tripped", is equivalent to Oconee Step 4.0 " control HPI as required."

Both steps contain the guidelines for the situation where the reactor has previously tripped.

The step titles are only stated differently.

8.

Crystal River Substep 6.4 directs the guideline user to Section III A addressing a loss of subcooling margin.

This is equivalent to Oconee Substeps 4.4 and 4.5 which provide the pertinent steps of Section III A, rather than directing the guideline user to Section l

III A.

9.

Oconee Step 5.0 checks for excessive heat transfer. This check is accomplished in Crystal River Substep 6.1.

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10.

Oconee Step 6.0 prepares for cooldown.

This step is not included

-in Crystal River because each of the three substeps have been incorporated in other steps.

Oconee Substep 6.1 is equivalent to Crystal River Substeps 4.2 and 6.2.

Oconee Substep 6.2 is equivalent to Crystal River Substep 10.2.

(Note:

This action is not included in the Crystal River cooldown steps for a loss of offsite power because the pressurizer heaters will become de-energizered.)

Oconee Substep 6.3 is included in Crystal River Step 2.0.

11. Crystal River has an additional step (9.0) to separate cooldown instructions for large SGTRs (Step 19.0 and following steps) and small SGTRs (Step 10.0 and following steps);

i.e., the SGTR is or is not within the makeup capacity of the makeup system.

Oconee has combined the instructions into Oconee Step 16.0 and subsequent steps, but notes those actions which differ (e.g., see Oconee Substep 16.3).

12.

Crystal River Step 14.0 is equivalent to Oconee Step 11.0.

Crystal River Substep 14.2 instructs the operator to keep the tube ruptured SG below 95% on the operate range.

The equivalent Oconee Substep 11.2 does not include this instruction because it is included in subsequent Substep 18.4.

13.

Crystal River Substep 14.5 states using the ADVs for steaming.

They must be used because the condenser is not available due to the loss of offsite power.

The equivalent Oconee Step 11.5 uses the TBS because the condenser remains available at Oconee following a loss of offsite power.

14.

Crystal River Substep 14.4 is a reminder that the fuel pin compression limits may be violated.

This is also true for Oconee but is not stated.

However, the information is included in Part II of the Oconee ATOG.

15.

Crystal River Substep 14.7 states "whenever the RCS becomes 30F colder than the adequate subcooling margin curve" while Oconee Substep 11.7 states "when a 50F subcooling margin is obtained."

Both terms accomplish the same objective of added subcooling.

The Crystal River version would provide more subcooling at lower pressures with a variable subcooling margin while the Oconee version would provide a constant 50F subcooling.

16.

Crystal River includes decision Step 20.0.

This decision step plus Steps 25.0 through 29.0 have been added to specifically address the situation of a SG with an unisolable steam leak.

Oconee has combined the instructions for an unisolable steam leak into Oconee Step 17.0 and subsequent steps.

For example, Oconee Substep 18.1 directs the guideline user to Step 19.0 if the tube ruptured SG and the inoperable (i.e., unisolable steam leak) SG are not the same. Substep 19.3 and 19.5 also relate to an inoperable SG.

17. Oconee Step 18.0 is equivalent to Crystal River Step 22.0.

However.

Oconee Substeps 18.5 through 18.8 are Oconee plant design specific and, therefore, are not included in Crystal River.

18.

Oconee Step 19.0 is equivalent to Crystal River Step 23.0 except for the Oconee Substeps 19.3 and 19.5 pertaining to an unisolable steam leak.

Oconee Substep 19.3 and 19.5 concerns are addressed in Crystal River Steps 25.0 through 29.0.

19. Crystal River Step 30.0 is equivalent to Oconee Step 20.0.

However, the Oconee step refers the guideline user to an Oconee plant specific procedure for continued plant cooldown.

20.

Crystal River Substep 18.3 is incorrect.

It should state THEN go to Step 19.0, otherwise go to Step 17.0."

Thus the step is equivalent to Oconee Step 13.3 by sending the guideline user to the step for cooldown and depressurization without RCPs.

21.

Crystal River Steps 29.4 and 29.5 are different from Oconee Step 19.6 because of an NRC cosament (Ref. 3 item #1);

i.e., if approaching 150F delta T,

then slow cooldown and if exceeding 150F delta T,

then stop cooldown.

22.

Crystal River Step 27.2 is different from Oconee Step 19.5 because of an NRC commment (Ref. 3 Item #1);

i.e.,

feed SC as necessary to maintain tube-to-shell delta T requirements.

23.

Crystal River step 17.2 is different from Oconee Step 11.2 because of an NRC comunent (Ref. 3 Item #2);

i.e., steam the TRSG as needed.

24.

Crystal River Step 14.6 and 19.3 state to " initiate" a rapid cooldown as opposed to " perform" as stated ir the corresponding Oconee steps (11.6, 14.4 and 16.3).

This change is intended to clarify follow-on operator actions (i.e., the operator continues while the rapid cooldown is in progress) and was made in response to an NRC comment (Ref. 3, Item #7a).

25.

Crystal River has an additional step (17.5) to clarify subsequent actions in response to an NRC comunent (Ret. 3. Item #7.b).

26.

Crystal River has added substeps under Step 30.0 to provide precautions to be considered in response to two NRC comments addressed in Reference 3 (Item #5 and Step 20.0 of III.D) and an NRC comment addressed in Reference 4 (Item f51).

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- 07

CP-101 - A LARGE LOCA HAS OCCURRED AND THE CORE FLOOD TANKS ARE EMPTTING 1.

Oconee Step 1.3, regarding CFT isolation, is not included in Crystal River since N2 introduction to the RCS is not a concern for large LOCAa.

For small break LOCAs where N2 introduction is not desired, the CFTs are isolated in procedures after transfer out of CP-101.

If the RCS is saturated, CP-103 will be used and the CF tank isolation valves will be closed in Crystal River Step 17.0.

If the RCS is subcooled, the CF tank isolation valves will be closed in site specific procedures.

2.

Crystal River has two extra steps (4.3 and 7.6) to add precautions for radiation monitoring and control.

3.

Crys tal' River does not contain a step equivalent to Oconee Step 1.0 regarding core flood line break.

The minimum LPI flow requirement of 1000 gym in each line, given in Step 5.0 of Crystal River, is based on providing adequate flow with a core flood line break.

4.

Oconee Step 5.0 " Throttle LPI and Building Spray Valves" is equivalent to Crystal River Substep 4.5.

Crystal River Step 8.0 " Establish dilution flow to RV" is equivalent to Oconee Substep 7.9.

Crystal River does not contain a step equivalent to Oconee Step 6.4 since the RCPs will not be running for a large LOCA.

5.

Crystal River does not include a step for securing RB spray as does Oconee (Step 7.7) because there is no requirement that the spray must be stopped.

6.

Crystal River Step 3.0 directs the guideline user to other cooldown procedures if CP-101 is entered when a large break LOCA does not exist.

Oconee assumes CP-101 is only for a large LOCA and avoids extra steps for transfers to other procedures.

CP-102 NORMAL COOLDOWN 1.

Crystal River decision Step 2.0 for using the pressurizer spray or the PORY is equivalent to Oconee Substep 4.3 2.

Crystal River Step 6.0, continue cooldown, is equivalent to Oconee Substep 4.4.

3.

Oconee Step 2.0 transfers the guideline user to CP-103 for RCS inventory control if a small break has occurred while Crystal River includes the pertinent actions in Step 5.0.

4.

Crystal River Substep 4.1 states a differential temperature limit of 100F, while Oconee Substep 4.1 states i 100F.

The limit is a tensile limit (tubes colder); therefore, 200F is correct.

, y i

t CP-103 - TRANSIENT TtnMIMATION FOLLOUING AN OCCUnRFMCE Tt,AT LEAVES TEE' RCS SATURATED WITE SG(S) nBt0VING nFAT 1.

substep 4.5, addressing " dry SG tube-to-shell limit", was added 5

to Crystal River as an optional precautionary acte.

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2.

Crystal River does not have an equivalent step to Cecnee Substep 4.5.

Substep 4.5, " makeup to BWST", was added to ocoate as an optional precautionary note.

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3.

Crystal River Step 6.0 provides a step for initiating'hPI cooling, i

l while Oconee directs the guideline user to CF-106 via Sten 5.0 for initiating RFI cooling.

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4.

Crystal River Steps 7.0 through 12.0 perform the same function as i

Oconee step 5.0 which is restoring SG heat transfer.

However, Oconee Step 5.0 directs the guideline user to CP-104.

Oconee CP-104 Steps 7.0 through 16.0 provide actions for, restoring SG heat transfer.

l l

5.

Crystal River step 13.0 states to start two RCFs while Oconee (Step l

6.0) states start one RCP. The goal, with SG heat transfer in progress,>

l is to operate two RCFs, preferably one in each loop.

Oconee has

)

s the RCP starte divided into more than one step. )conee starts one in Step 6.0 then starts the second one after, transfer.to either CF-102 Step 1.2 (with pressuriser bubble) via CP-105 or CF-105 Step i

l 8.3 (without a pressuriser bubble).

i

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l 6.

Crystal River Steps 17.0 and 21.0 includes the instruction to close l

the CFT isolation valves. Closing the CFT isolition valves is not mandatory during a saturated cooldown. However,7(t is desirable l

l to limit needless nitrogen addition to the RCS.

In addition, the adverse reactor building environment mey have deraded the core i

flood tank level instruments. Therefore, the time to close the CF tank isolation valves should not be basij on CF tank level.

The RCS pressure must get below approminately 100 peig before the CF tanks empty. At 100 pois the LFI system will be cooling the core, allowing the operator to stop RFI. Therefore, the conditions for stopping RFI were also applied to closing the CF tank isolation valves.

7.

Crystal River has an additional step (22.0) to address the option of switching to LFI/DNRS cooling. At this point in the procedure the RCS is in a saturated condition while cooling with the steam generators. This mode requires continuous injection flow sted control of saturated natural circulation. Therefore, conditions permitting, a transition to LFI/DNRS mode of cooling may be preferred.

8.

Oconee refers the guideline user to a plant specific shutdown procedure in Step 18.0 while Crystal River provides additional steps (24.3, 24.4 and 24.5) in the procedure on LPI cooling.

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1.

Crystal River Steps,4.0 through 6.0 of CP-103 perform the same function ',

s as Oconee Steps 7.0 through 16^.0 of CP-104.

The Oconee steps for restoring heat transfer are facluded in CP-104 while the equivalent steps for Crystal River are ircluded in CP-103 Steps 7.0 to 12.0.

J Therefore, the Crystal River CP-104 directs the guideline user to CP-103.

For enemple, Oconee CP-1M Step 15.0 states "Further Lower i

(

SG Pressure to Induce Baat ' Trausf er".

This same step is located in Crystal River CP-103 Step 10.0. " j 3

i Crystal River Step 7.0 is equ v, ant tl oconee substep 2.3.

3.

RCP operation and pressure-tdsp'erdeare limits see the same for both

( i;uidelines.

oconee and Crystal River but' ads - format ted differently in the 3

Oconee Step 1.0 checks pump status and Steps 2.0 and

'l * ; 5.0 address, pressore-temperature limits.

Crystal River addresses

1. both RCP 'tgerdriya and pressure-temperature limits in Step 3.0 since s

p RCP's 'ard ' star,:ed if subcooling mar gin is established and the pressure-testerature limits are above the subcooling margin.

s.

l' 4.

Crystal River Step 1.0 ' s tates to open or verify,open the PORY and PORY block valve.

The wording change to "open or verify open" g

for entry into CP-104 from Section III B'(feedwater available) accounts i\\

where BPI cooling has not yet been initiated air identified in an l

NRC comment (Ref. 3. Step 3.0 of CP-104).

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5.

Oconee has an entra ^ Step ; 6.0 for closing the CFT isolation valves l

I if the cooldown rate is controlled and the RC is subcooled.5 Since this iJ a standard operator action during cooldown, with a ):ubcooled

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RC, it waslnot included in Crystal River CP-104.

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CP-105 TRANSIENT TERMINATIONS WITH SG(S) REMOVING HEAT AND WITH A SUBC00 LED RC FOLLOWING AN OCCURRENCE THAT MAY REOUIRE PRESSUR72ER RECOVERY OR SOLID PLANT COOLDOWN 1.

The title of CP-105 in Crystal River has been revised to note that RCS subcooling is an entry condition.

2.

Oconee starts RCPs in Substep 8.3 while Crystal River starts RCPs in CP-102 to which the guideline user is directed in Substep 7.0 cr'E.5.

I 3.

Crystal River Steps 4.3 and 8.3 use "30F colder then adequate subcooling mart,in" while Oconee Steps 7.1 and 7.2 use "50F subcooling margin".

Both terms accomplish the same objective of added subcooling.

The j

Crystal River verrien would provide more subcooling at lower pressures with a variable' subcooling margin while the Oconee version would provide a constant 50F sub::ooling.

4.

Crystal River Step 8.0 is a condensed version of Oconee Steps 7.0 and 8.0.

They both provide the same instructions except for the variation in subcooling margin as discussed in Item 3.

5.

Crystal River Step 3.0 is equivalent to Oconec Substep 3.2.

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SPECIFIC RULE AND/OR GUIDELINE I - INITIATION OF MU/HPI Items 1.0 and 2.0 have been added to the Crystal River specific rules /

guidelines to clarify that it is applicable to loss of subcooling margin.

The Oconee version does not specify loss of subcooling margin nor does it state two HPI pumps at full capacity, but it is specified in the Part II of ATOG for both Oconee and Crystal River.

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SPECIFIC RULE AND/OR CUIDELINES 2 - HPI FLOW CONTROL 1.

The Crystal River specific rule / guideline uses a pressurizer level of 50 inches while the Oconee specific rule / guideline uses a pressurizer level of 100 inches. This is to account for plant differences in the elevation of the connection for the pressurizer level measuring instrumentation.

2.

The guideline for stopping HPI operation, which is also applicable to Oconee, has been added to the Crystal River specific rule / guidelines (Item 1.0).

The in'structions for determining the temperature when using Figure 3.

2 have been added to the Crystal River specific rules / guidelines (Items 2.1 a and b).

These are provided in the Oconee ATOG technical bases (Part II).

4.

The Crystal River HPI pump limits on flow rate are 90 gpm minimum and 545 gpa maximum.

The respective limits on the Oconee pumps are 100 gpm and 530 gpm.

SPECIFIC RULE AND/OR CUIDELINE 3 - EFW THROTTLING This Crystal River rule / guideline is structured differently to clarify between rules and guidelines and to include all three requirements for full EFW flow (Items 1.0, 2.0 and 3.0) and the additional guidelines for throttling (Items 1.0 and 2.0) as specified in the ATOG technical bases (Part II).

a SPECIFIC RULE AND/OR GUIDELINE 4 - SG LEVEL SETPOINTS The Crystal River version of this rule / guideline has been worded and structured differently for the following reasons:

1.

to clarify between the level setpoint rule for loss of subcooling margin and the level setpoint guidelines for all other conditions.

2.

to include the exception for loss of secondary pressure control.

SPECIFIC RULE AND/OR GUIDELINE 5 - RCP RESTART These specific rules / guidelines are also applicable to and used in the Oconee guidelines. They were consolidated and added to the Crystal River Specific Rules / Guidelines for guideline user assistance.

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o SECTION ICC 1.

Crystal River has an additional step (5.0) to open the PORV if the RC pressure reaches 2300 psig.

This step was an omission in the Oconee guidelines but was subsequently added as noted by an NRC comment (Ref. 4, Item #139).

2.

Crystal River Substep 8.1 has an added precaution not to decrease SG stesa pressure below the pressure necessary for the EFW pump turbine operation.

3.

Crystal River Substep 11.1 states to maintain RCS pressure 25-50 psi greater than SC pressure while Oconee Substep 10.1 uses 25-60 psi. The difference is insignificant as the intent is to prevent RCS repressurization.

4.

Crystal River Step 12.0 does not contain an equivalent substep to Oconee Substep 11.3.

This substep was deleted for the reasons given in an NRC comment (Ref. 4 Item #77).

5.

Crystal River has an additional Step 14.0 to open the high point vents. This step was added to address the possibility of transfer to Step 12.0 from Step 6.3 (i.e., bypassing Step 9.0) as noted by an NRC comment (Ref. 4, Item #272).

6.

The Oconee Step 16.0, "close the CFT isolation valves", has been combined with Steps 19.0, 24.2(d) and 24.6(e) in Crystal River to be more definitive as to when to close the CFT isolation valves while the RCS is saturated.

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7.

Oconee references an additional procedure in Step 25.0 to assist in addressing the unusual circumstances.

REFERENCES 1.

. Abnormal Transient Operating Guidelines for Oconee Nuclear Station Unit 3, 74-1123297-00, March 23, 1982.

2.

Abnormal Transient Operating Guidelines for Crystal River Unit 3,

74-1126473-00, October 8, 1982.

3.

Enclosure to Letter, D. D. Whitney to D. G. Eisenhut, June 15, 1982.

4.

Enclosure to Letter, D. A. Napior to B&W Owners Group, " Resolution of NRC Comments on Oconee ATOG," March 14, 1983.

5.

Enclosures to Letter, D. D. Whitney to D. G. Eisenhut, " Supplement to ONS-3 Final ATOG," July 2, 1983.

4

ATTACHMENT C 2.4.11 Specify the FOLLOW-UP steps taken by the operator to facilitate the diagnostic effort and restore the plant to stable conditions or place the plant in a safe, steady state condition.

o ACTION steps are functional statements that provide adequate guidance to experienced operator under low stress conditions.

c DETAIL steps present more detailed operational information for the corresponding action step.

Information is presented in memory blocks of 1 to 4 steps. Each step should be written assuming high stress conditions and use by less experienced personnel.

o The first follow-up action shall direct the operator to a VERIFICATION PROCEDURE.

NOTE Additional information interrupts the continuity of the presentation.

Delaying the user with more than essential facts should be avoided.

2.4.12 Provide the following ADDITIONAL INFORMATION to enhance the use of procedures.

Examples:

o CAUTION is precautionary and critical information necessary to prevent equipment damage or personnel injury, o NOTE is advisory information.

o FIGURE is a line drawing of the following types.

- Picture

- Diagram

- Graph o TABLE is a compact arrangement of related facts in orderly sequence usually in rows and columns.

o ENCLOSURE is any information not needed in a procedure section. This information may include data sheets, figures which do not require rapid reference, etc.

17 of 50

ug ATTACHMENT D Page 1 of 2 ICC Rev. O Date XX-XX-XX EP-290 FOLLOW-UPS (Cont'd)

ACTIONS DETAILS 2.7 WHEN RCS pressure and WHEN RCS pressure and temperature enter Region 2 temperature enter Region 2 of of Figure 1, Figure 1, THEN go to Section 1, THEN go to Section 1, Step 1.7 Step 1.7.

Figure 1 CORE EXIT FLUID TEMPERATURE FOR INADEQUATE CORE COOLING 2 goc 2400 SAT. LINE 2200 REGION CLAO >l400 IU

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REGON U

2 gisOO

$1400 kg200 ON 3

N3000 REGON g

600 00 -

TCLAO >l800 400 -

200 400 ECO S00 1000 1200 CCRE 60 COUPLE TEMP (*F)

EP-290 Page 10 of 15 ICC

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ATTACHMENT D

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Date XX-XX-XX EP-290 FOLLOW-UPf(Cont'di ACTIONS DETAILS 3.5 WHEN incore temperatures Observe:

In3Teate TsAT, TsAT meters THEN establish 1 RCP per TsAT monitors loop operation.

Figure 1.

1 Figure 1 CORE EXIT FLUID TEMPERATURE FOR i

INADEQUATE CORE COOLING 260C 3

SAT. LINE 2400

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2200 REGION 2000 CLAO >l400

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1800 -

REGION G

2 g isOO g1400 E

REGION

& 200 3

REGION g 000 4

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MO TCLAO >l800 AOO -

200 l

400 GOO 900 1000 1200 CCRE V-ERMOCOUPLE TEMP (*F)

EP-290 Page 14 of 15 ICC

O I ATTACHMENT E 3.6 Place Keeping Provide OPEN SPACE as in Appendix 2 for place keeping marks in each of the following:

o Steps o Lists o Tables Open space allows operators to make place keeping marks without obsuring procedural information.

26 of 50

Page 1 of 3 ATTACHMENT F CONSTRAINED LANGUAGE LIST Adjust Change the value of a setpoint or parameter to a new desired value.

Position valves or circuit breakers to provide the specified fluid or Align electrical flowpath.

Make specified parameters equal with respect to each other.

Balance Remove volume of liquid from a system or container, e.g., mode of Bleed the make-up and purification system that diverts letdown flow.

Add Boric Acid to provide additional negative reactivity.

Borate To start a piece of motor operated equipment, allow it to run for Bump approximately 15 seconds then stop it.

Divert around, e.g., to disable some automatic mode of a system or Bypass component.

Refers to possible response of equipment.

Can Fully shut a valve preventing flow.

Close Energize the load side of a circuit breaker.

Continue Resume an action.

Persist with a current action or step.

Cooldown Lower the temperature of a system or component.

Use valve (s) to control flow by moving valve full open or full Cycle closed.

De-energize Remove all sources of electrical power.

Render a specified component or function inoperable.

Defeat Depress Refers to pushbutton operation.

Reduce the pressure in a specified system or component.

Depressurize Determine Decide or establish conclusively the cause of some action.

Compute mathematically.

Drain Remove a liquid from a system or container through a flow path due to existing differential pressure.

Provide a component or switchgear with required electrical power.

Energize Writ Guide 3 1 of 3

ATTACHMENT F Page 2 of 3

, 4 Ensure Take necessary/ appropriate actions to guarantee component, reading, etc. is as specified.

Establish Create required conditions or state.

Flush Rinse a system or pipe using liquid.

Go Move to a specific place, e.g., for procedures, discontinue use of present procedure and perform actions of cited procedure.

Insert Place between other parts, e.g., lower control rods into the core.

Isolate Separate systems or components using an established boundary.

Latch Couple mechanical parts by means of a trip mechanism, e.g.,

contro1 rod to its drive.

Local Located at or near operated equipment or signal source, e.g., local temperature indication.

Lower Reduce the state of a system by decreasing a parameter or its numerical value.

Maintain Preserve a stated condition.

Manual Control Mode in which system parameters are changed by operator action.

May Refers to an operation which is possible, but perhaps not necessary.

Notify Provide with information.

Obtain Find and secure for use.

Observe Watch a stated parameter attentively.

Open Position a value to allow full flow.

Position a circuit breaker to prevent the flow of electricity to a load.

Per As specified in or named by procedure.

Perform Carry out specified actions or steps.

Purge Remove gas from a system or component while replacing the volume removed with an alternate type of a gas.

Rack-in Physically insert a circuit breaker to its full-in position.

Rack-out Physically withdraw a circuit breaker to its " racked-out" position.

Raise Increase the worth or value of a parameter.

Writ Guide 3 2 of 3

ATTACHMENT F Page 3 of 3 Reco'rd An account of activity, e.g., operator's log book, cassette tape.

Retain information for future reference, e.g., write on a form.

Reduce To cause the value of a stated parameter to become less.

Refer Direct to a source of help or information, e.g., for procedures, perform applicable actions of the cited procedure and return to the controlling procedure.

Regulate.

Control a parameter to obtain a desired value.

Remove Take away, e.g., move an object from one place to another.

Repeat Say or do again.

Reset Return an automatic logic system to its normal energized condition (preactuation state).

Restore Bring back to a previous condition, e.g., return a component or system to service.

Review Inspect, survey.

Select Choose what is desired from several dif ferent options.

Shall Implies mandatory requirement.

Should Implies non-mandatory, preferred, or desired method.

Stabilize Establish constant conditions.

Start Begin an activity.

Set into motion.

Stop Cause motion or activity to cease.

Throttle Place a value in an intermediate position to obtain desired flow rate or pressure.

Trip Activate a semi-automatic feature of a component.

Vent Remove gas from a system or container at a higher pressure by creating a flow path to a system or container of lower pressure.

Verify Prove to be true, exact or accurate by observation and comparison.

Withdraw Take back or from, e.g., raise control rods from the core.

Writ Guide 3 3 of 3

ATTACHMENT G Page 3 ACCEPTED ABBREVIATIONS AND ACRONYMS LIST Contr:1 Rod Driva Mechanism CRDM Condensate Storage Tank CST Concentrated Waste Storage Tank CWST Condensate Demineralizer System CX Crystal River Unit 3 CR-3 Direct Current or Decay Heat Closed Cycle Cooling System DC Decontaminate DECON Degree DEG Difference Between Two Temperatures DELTA T Demineralizer DEMIN Demerator Feed Tank DFT Decay Heat System DH Decay Heat Removal DHR Diameter DIA Discharge DISCH Diesel Jacket Cooling System DJ Diesel Generator A Annunciator Response DGAAR Diesel Gener,' tor B Annunciator Response DGBAR Diesel Lube Oil System DLO Departure From Nucleate Boiling DNB Domestic Water System DO Differential Pressure D/P Decades Per Minute DPM Drain DRN Demineralized Water System DW Drawing DWG Emergency Core Cooling Systems ECCS Emergency Diesel Generator EDG Emergency Diesel Generator Actuation EDGA Emergency Reactivity Control ERC Writ Guide 3 3 of 12

ATTACHMENT G p

g ACCEPTED ABBREVIATIONS AND ACRONYMS LIST Plant Review Committee PRC Pressure PRESS Pressurized Thermal Shock PTS Pounds Per Square Inch Differential PSID Purification PURIF Positive POS Pump PP or P when following system designation (ex:

SW P)

Pressurizer P2R Quality Assurance QA Quality Control QC Reactor Building RB Reactor Coolant System RC Reactor Coolant Drain Tank RCDT Reactor Coolant Bleed Tank RCBT Reactor Coolant Pump RCP Reactor Diagostic System RDS Recirculate RECIRC Required REQ'D Relative REL Revision REV Reheat Steam System RH Radiation Monitor Atmospheric RMA Radiation Monitor, Gamma RMG Radiation Monitor, Liquid RML Radiation Monitoring System RMS Revolutions Per Minute RPM Reactor Protection System RPS Reactor Protection System Actuation RPSA Resistance Temperature Detector RTD Rated Thermal Power RTP Writ Guide 3 9 of 12