ML20154F934
| ML20154F934 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/17/1988 |
| From: | Lange D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154F931 | List: |
| References | |
| 50-293-88-11, NUDOCS 8805240135 | |
| Download: ML20154F934 (17) | |
See also: IR 05000293/1988011
Text
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No. 50-293/88-11
Docket No. 50-293
License No. DPR-35
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Licensee: Boston Edison Corpany
ECO Boylston Street
Toiifo~n, Massachusetts 02199
Facility Name:
Pilgrim Nuclear Power Station
Inspection At:
Plyrouth, Massachusetts,
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Inspection Conducted: March 14-18, 1988
Inspectors:
W. Kennedy, NRR Team Leader
D. Florek, Sr. Operations Engineer, DRS, RI
C. Sisco, Operations Engineer, DRS, RI
G. Thomas, Nuclear Engineer, NRR
R. Gruel, Operator Licensing Examiner, PNL
L. Meyers, Research Psycholegist, BCL
Approved by:
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D.' Lange, Chi
SKR 5ection
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hspection Sumary:
Inspection on March 14-18, 1988 (Report No. 50-293/88-11)
Aress Inspected: Special announced team inspection by 2 regional inspectors,
H eadquarters personnel and 2 centractors of the emergency operating
pro <:edures (EOPs) and quality assurance measures. This included a cerparison
of the Plant Specific Guidelines and BWR Owners Group Energency Procedure
Guidelines (EPGs) with the E0Ps; cor.parison of Pilgrim Writer's Guide with the
E0Ps; walkthrough of selected E0Ps and Satellite Procedures; E0P evaluation
using simulator scenarios; qualifications of E0P responsible individuals,
review of ECP training progran; review of E0P verification and validation, and
review of E0P Quality Measures.
8805240135 880517
ADOCK 05000293
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Results:
No violations or deviations were identified in the inspection.
The
inspection concluded that the E0Ps were implerrented in acccrdance with the
Revision 4 of the BWR Owners Group EPGs and the plant's Procedures Generation
Program; however, 4 unresolved items were identified.
One unresolved item
involved a sequence of actions in an E0P different from that specified in the
EPG (See Section 4).
A second unresolved item concerned the inspectors'
inability te evaluate the adequacy of the procedures supporting the E0Ps,
called satellite procedures, due to the incerrplete status of the facility
walktitrough (See Section 8).
The third unresolved item concerned procedures
and training associated with containment venting (See Section 4 and 8).
The
fourth item concerned the lack of continued involvement of QA in the E0P
procedures program (See Section 11).
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DETAILS
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1.
Persons Contacted
BEco and BEco Contractors
- J. Alexander, Operations Section Manager
- H. Balfour, License Training Section Manager
- F. Barresi, Nuclear Training Development
R. Barrett, Operations Department Manager
- R. Bird, Senior Vice President, Nuclear
- C. Brennion, Senior S&SA Engineer
- R. Brune, Human Factors, HPT
- M. Davis, Consultant, Engineer, Ciel Consultants Inc.
J. Fulton, Assistant Vice President Engineering
- J. Gerety, Senior S&SA Engineer
- R. Grazio, Field Engineering and Regulatory Affairs Manager
- R. Hamilton, Compliance Division, Manager
- K. Highfill, Station Director
B. Horsman, Reactor Operator
- J. Howard, Vice President, Nuclear Engineering and QA
- G. Humes, Reactor Operator
C. Leonard, Nuclear Operations Supervisor
- P. Mastrangelo, Chief Operations Engineer
J. Mattici, QA Audit Division Manager
- W. Olsen, Nuclear Watch Engineer
T. Phipps, Reactor Operator
S. Powers, Reactor Operator
S. Rogers, Executive Consultant OEI
M. Santiago, Senior Training Specialist
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- F. Sche 11inger, Quality Engineering Division Manager
- J. Schilder, Senior Consulting Engineer, OEI
R. Swanson, NED Manager
K. Taylor, Nuclear Watch Engineer
- T. Trepanier, Senior Operations Engineer
- E. Ziemianski, Nuclear Training Manager
U.S. Nuclear Regulatory Commission
- T. Kim, Resident inspector
- D. Mcdonald, Project Manager, NRR
- C. Warren, Senior Resident Inspector
- denotes those present at the exit meeting held on March 18, 1988.
The
inspectors also contacted licensed operators, engineers, technicians, and
other personnel in the course of the inspection.
2.
Inspection Objective / Approach
This inspection was performed to determine whethe*, the Pilgrim Emergency
Operating Procedures (EOPs) had been prepared in accordance with the current
Procedure Generation Package (PGP) and whether the E0Ps and associated
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satellite procedures had been adequately implemented in the plant.
The
specific areas inspected include the following:
Review of the technical qualifications of E0P developers
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Comparison of the EPG, PSTG technical basis with the E0Ps
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Comparison of the writer's guide with the E0Ps
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Review of the E0P verification and validation
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Walkthrough of selected procedures in the plant
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Review of training on the E0Ps
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Exercising Procedures in the simulator
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Review of the E0P quality assurance measures
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3.
Qualifications of Individuals Responsible for E0P Development
A review was conducted to determine if the E0Ps were developed and
reviewed by a multidisepline team of technically qualified individuals.
The licensee development team consisted of BEco personnel from the
Engineering an Training organization, augmented with consultants from
Operations Engineering, Inc. (0EI), Human Performance Technology (HPT),
and Ciel Consultants, Inc. OIE, as consultants to the BWR Owners Group on
the development of the EPGs, provided engineering expertise in the
development of the plant specific technical guidelines (PSTGs) and the
validation effort.
HPT provided Human Factors consulting and CIE assisted
in the verification process.
A review of the technical background of the
team as well as interviews with the team members determined that the
members were well qualified and a multidisciplined team.
The inspector reviewed the Onsite Review Committee meeting minutes #87-136
and determined that the E0Ps were reviewed in accordance with Technical
Specifications.
4.
Comparison of Plant Specific Technical Guidelines, BWR Owners Group
Emergency Guidelines and E0Ps
This review included a comparison of the plant-specific technical guidelines
(P-STGs) with Revision 4 of BWR Owners Group Energency Procedure Guidelines
(EPGs) and a comparison of the E0Ps with the P-STGs.
Plant specific values
in the E0Ps were also assessed.
4.1 EPG/P-STG Review
No safety-significant deviations were found between Revision 4 of the
EPGs and the P-STGs.
However, since Revision 4 has not been formally
reviewed
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by the NRC, the future Safety Evaluation Report on Revision 4 may
indicate the need for licensee action on the P-STGs and the E0Ps.
4.2 P-STG/EOP Review
All E0Ps and those portions of satellite procedures which contained
steps based on the P-STGs were compared to the P-STG.
The following
differences were noted.
The licensee's review process had also
identified some of these findings as indicated.
RPV Control
Severai action steps within the RPV Level and F
sure sections of
this procedure had not been linked by appropriate marking to the
appropriate note.
The licensee stated that this concern had been
previously identified and was under review.
A decision step (presented in a box) within the RPY Level section of
this
procedure
regarding reactor power
level
did not provide
direction for the condition of power level not being able to be
determined.
Such direction is provided in an "override" statement
which pertains to the next step.
The licensee stated that this
concern had been previously identified and was under review.
Inconsistencies were noted in procedure branching.
The licensee
stated that those inconsistencies had been identified and were under
review.
Primary Containment Control
Primary containment venting was allowed by procedure after torus
pressure exceeds 11 psig but before reaching the Primary Containment
Pressure Linit (PCPL; 48 psig) irrespective of resultant reactivity
release rate.
Procedure 5.4.6 stated that venting, irrespective of
resultant reactivity release rate, was appropriate only when the
primary containment pressure is above the PCPL (or when drywell or
torus hydrogen concentration was above 6%).
The licensee stated that
they will revise the procedures to remove the inconsistency and
instruct operators to vent before_ reaching the PCPL.
PSTG steps PC/H-2.1 (suppression chamber spray), 2.2 (torus or
drywell vent), 2.3 (purge), and 2.4 (drpell spray) were reordered in
the E0P in the order of:
2. 2, 2. 3, 2.1, 2. 4.
The licensee had
not
previously
identified
this
potential
safety-significant
deviation.
Either analysis of the acceptability of E0P sequence or
procedure revision to match the PSTGs is required.
This is an
unresolved item (50-293/88-11-01).
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4.3 Satellite Procedures Review
5.3.23: Alternate Rod Insertion
An instruction regarding reset of alternate rod insertion was missing
from this procedure. The licensee stated that this omission had been
previously noted and is under review.
5.4.6:
Post Accident Containment Control (Venting)
The procedure directed using both a small vent path (1 or 2 inch
valves) and a large path (through 8 inch valves) for containrent
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venting.
In some scenarios it may not be necessary to open both sets
of valves if after opening only the 2 inch or the 1 inch valves the
the containment pressure is controlled appropriately.
The licensee
agreed to revise the procedure or justify not revising it.
A caution contained the words "If at all possible, ... shall ...".
This statement did not provide clear direction to the SRO.
The
licensee agreed to revise the procedure or justify not revising it.
Step 2 of Attachment A of this procedure stated that the E0P is
applicable when primary containnent pressure reaches 2.5 psig, as
opposed to above 2.5 psig.
The licensee agreed to revise this
statement.
The caution statement about rupture of the ductwork with venting did
not include notification of health Physics.
The licensee agreed to
rovise the procedure or justify not revising it.
Step 2 of Attachment A of this procedure was missing a statement
regarding opening the appropriate valves as necessary to perform the
step.
The licensee agreed to consider revising this staterent.
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Step 3 of Attachment A of this precedure did not provide cicar
direction to the operator on the value of primary containment
pressure to terminate torus venting.
The licensee agreed to revise
the procedure or justify not revising it.
The
items concerning containment venting will be collectively
included as part of unresolved items 50-293/88-11-03.
See Section 8
for additional containment venting items.
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5.
Comparison of E0P Writer's Guide With E0P
All E0Ps were reviewed to determine if they fc11 owed the guidance provided
in the licensee's Writer's Guide.
The licensee verbally committed to
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evaluate the following comrents, and to rodify the E0Ps or the Writer's
Guide at, appropriate.
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5.1 Cautions, Notes and supplemental Information
Blocks of supplemental information are used in E0Ps 01, 02, 06,
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and 09. The Pilgrim Writer's Guide does not provide guidance as
to what
information
is to be placed within supplemental
information blocks.
5.2 Logic Terms and Conditional Statements
a.
In E0P-03, Drywell Temperature, second action block, the BEFORE
statement does not follow the format stated in the writer's
guide. This also occurs in E0P-04.
b.
The term EXCEPT is used several times in E0P-04 and 03.
The use
of this term places exceptions after an action step.
In these
statements, the operator is told do something which he or she
may go ahead and do before reading the rest of the statement
which includes the exceptions.
5.3 Action Steps
a.
Throughout the procedures there are action steps which state
something "IS REQUIRED."
However, this construct, its format
and use are not addressed in the writer's guide.
b.
Some of the steps in the sample flowcharts are long and
complicated.
For example, in E0P-04, "Reset the secondary
containment isolation and restart reactor building H &
V,
defeating
high drywell
pressure and
1cw RPV water
level
isolation interlocks if necessary."
This step contains many
actions.
Furthermore, this step does not explain under what
conditions it would be necessary to defeat the high drywell
pressure and 1cw RPV water level isolation interlocks.
Another
example of a step that is too long is from E0P-01, "Irrespective
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of whether adequate core cooling is assured, terminate injection
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into the RPV from sources external to the primary containment
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UNTIL primary containment water level and torus pressure can be
maintained below the MPCWLL."
c.
In E0P-02, near the end of Reactor Power, there is a BEFORE
statenent whose action reads, "BORON INJECTION IS REQUIRED."
This action statenent does not follow the format for BEFORE
statenents,
d.
In E0P-02, in the next instruction block, the two numbered
actions are prefaced with the word "either". The word "either"
implies that the operator can perform either step 1 or step 2.
However, this may not be the case.
This construction is not
addressed in the writer's guide.
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5.4 Referencing and Branching
a.
Throughout the procedures the phrase "appropriate section of
Procedure..."
is
used
to
refer
the
operator to
another
procedure. More specific directions appear necessary,
b.
The writer's guide specifies a number of methods to refer the
operator to other procedures.
However, there are reference
statements which do not follow any of the methods in the
Writer's Guide.
For example, in E0P-01 the phrase "enter and
concurrently execute Procedure 2.6.1..." is used. In E0P-02 the
phrase "Insert control rods using one or more of the methods
detailed in Procedure 5.3.2.3..." is used.
5.5 Flow of Information
In E0P-02, path A is difficult to follow and some method is needed
to help indicate the direction of flow.
5.6 Miscellaneous
a.
In E0P-03
Torus Water Level, in the first action step, the
acronym PASS is used; this acronym is not defined in the Pilgrim
Writer's Guide.
b.
In E0P-03, Drywell Temperature, the first six-Sided symbol does
not contain a ccma after the IF or AND statements.
Also, in
the last two BEFORE symbols a coma is not placed after the
before statement,
c.
In E0P-03, Hydrogen and Oxygen Concantrations, when Hydrogen
concentrations are referred to the format is inconsistent.
The
first instance a decimal is used,
i.e.,
1.0% and in the
remainder instances no decimals are used,
i.e.,
5% and 6%.
5.7 Satellite Procedures
The Attachments to 5.7.3.2 are very difficult to read.
6.
E0P Verification
The verification program at Pilgrim was reviewed and compared to the E0P
Verification Program description submitted in the PGP. Tha contractor who
performed
the
verification,
and
cognizant
plant
personnel,
were
interviewed.
A variety of documents were reviewed.
The documentation included:
Completed and signed verification forms
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Interim report on discrepancies
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List of open verification items
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Operator comments
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The documentation appeared thorough and complete and the licensee's
discrepancies were well defined and described.
7.
E0P Validation
The validation program at Pilgrim was reviewed and compared to the
Validation Program Description submitted in the PGP.
To perform this
review the contractors (Ciel Inc. and Human Performance Technologies Inc.)
who performed the validation were interviewed.
A variety of documents were reviewed.
The documentation included:
- Completed and signed validation forms, checklists, and questionnaires
- Resumes of participants
- Scenarios used during the validation process
- Copies of E0Ps showing which paths / steps were validated
For each scenario the paths / steps for each E0P used were traced on copies
of the E0Ps using a color code.
At the end of validation this method
showed how much of each E0P had been validated both through the simulator
exercises and the talkthroughs.
An examination of a sample of these E0Ps
showed that all paths / steps had apparently been validated.
The documentation appeared thorough and complete and the licensee's
discrepancies were well defined and described.
8.
Walkthrough of Emergency Operating Procedures and Satellite Procedures
Inspectors, with facility licensed operators, walked through portions of
the following procedures in the Control Room and in the plant to assess
whether the procedures were capable of being perforced when required. The
procedures walked through included both the E0Ps and the satellite
procedures.
RPV Control
Primary Containment Control
5.3.26
RPV Injection During Emergencies
5.4.6
Primary Containment Venting and Purging
5.3.23
Alternate Rod Insertion
The inspectors assessed the consistency of terminology between the plant
labels and procedures, access to the equipment, clarity of instructions,
availability of information to conclude the action should be taken and
overall useability of the procedure.
During the walkthrough the inspectors identified several items that needed
facility actions to correct.
These are detailed in Attachment C and
summarized below.
The inspectors identified concerns relctive to plant
labeling (either missing, inadequate or not consistent with procedure
nomenclature), the availability / control of jumpers / tools required to
perform selected E0P actions,
the clarity of procedures to direct
operators
to
a
specific
location
to
perforn the
required
task,
accessibility of equipment, and completeness of procedure.
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A number of the E0P-related items identified by the inspectors had also
been identified by the facility review process and actions were being
taken to address the observed problems.
However, the facility review of
the satellite procedures was still in progress even though the procedures
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were approved and issued,
i.e.,
they had not yet finished their own
walkthrough of the satellite procedures.
Furthermore, the operations
management agreed to assure that the plant labeling was consistent with
the E0Ps and satellite procedures.
Therefore, pending further NRC review
folicwing completion of the facility walkthrough of the satellite
procedures
and
the
licensee
actions
to
correct
the
identified
deficiencies, this item will retain unresolved (50-293/88-11-02).
One item identified during the walkthrcugh of the E0Ps was an apparent
need for additional training on when to initiate and when to terminate
venting of the containment in accordance with the intent of the EPGs and
the procedures.
Items concerning centainment venting will be considered
an unresolved item (50-293/88-11-03).
See section 4 for additional
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containment venting items.
9.
E0P TRAINING
A representative of the Pilgrira Training Center (a lead instructor,
heading up the Phase II E0P trainirg) was interviewed to determine if the
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current E0P training program matched that described in the Training
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Program Description in the PGP.
A nutber of training related documents were also reviewed.
This
documentation included:
Administrative records
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Student records
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Lists of training objectives
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Lists of perfereance and cognitive standards
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Exam results
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Exams
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Unit, Course and l'odular Guides
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Homework lessons
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Scenarios used during siculator training
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All docurentatien appeared ccrplete and thorough.
Hewever, the training
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program description included in the PGP is no longer applicable. This
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progran freferred to as Phase I) was executed, but had seme difficulties
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which the licensee believed may have contributed to an original unsuccess-
ful validation.
As a result, the licensee revarped the training program.
The licensee needs to prepare a revised Training Progran Description fer
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their current ECP training and submit this description as a part of a
revised PGP.
The training representative stated that they were preparing
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a
new training program description which would address previously
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The training program, Phase II (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />), was a combination of classroom
and simulator training.
As of the inspection, about 50% of the operators
had been trained in Phase II.
Pilgrim plans to have all operators trained
by May 1988.
10.
E0P Evaluation Using Simulator Scenarios
A shift operatiag crew in the fine' stage of operator training on E0Ps was
observed in the Pilgrim simulator to determine if 1) the operators are
familiar with their responsibilities and required actions during an
emergency, 2) the E0Ps and E0P satellite procedures can be performed by
the minimum staff 3) operators do not physically interfere with each other
while performing the E0P, and 4) transitions from one procedure to others
are appropriately directed by the E0Ps.
The shift operating crew consisted of 2 SR0s, 3 R0s, an STA and a shift
clerk. This crew size is larger that that required by the Pilgrim Techni-
cal Specifications, but specified in the administrative procedures.
The
crew was exposed to three NRC generated evaluation scenarios which
required entry into several E0Ps (i.e. E0P-1, 2, 3, 4, 6 and 7) and their
apprcpriate satellite procedures (i.e.
2.1.5,
2.1.6,
5.3.21, 5.3.23,
5.3.26,5.4.6,5.7.3.2).
Operators did not physically interfere with each other during their
conduct of the scenarios, and transitions were appropriately designated.
Some procedural usage problems were encountered during the conduct of the
scenarios, but these problems were attributed to the level of operating
training
(i.e.,
the operators had not completed their E0P training).
The inspector concluded that the E0Ps and E0P satellite procedures could
be performed by the crew.
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11.
E0P Quality Assurance Measures
A review was conducted to determine if Quality Assurance Measures are
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adequate to ensure that high quality E0Ps are developed, implemented and
maintained,
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The QA measures associated with the development of the E0Ps were found to
be acceptable, based on discussions with the Quality Engineering Division
Manager and Senior Quality Engineer.
However, it was concluded that a
programatic approach to ensure the continued quality of the E0Ps through
not exist in the area of
aud,ts of the maintenance of the E0Ps did
auditing of the E0P program.
In subsequent discussions with the Vice President, Nuclear Engineering
Division and Quality Assurance management
BEco comitted to revise the
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1988 Internal Audit Schedule to include an annual audit of the E0P
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program.
This audit will be performed as a Safety Syster Audit in the
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fourth quarter of 1988.
The procedura11 ration of continued quality
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assurance measures is an Unresolved Item (50-293/88-11-04).
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12. Exit Interview
An exit meeting was held on March 18, 1988 to discuss the inspection scope
and findings as detailed in this report (see paragraph-1.0 for attendees).
Written inspection findings were not given to the licensee.
The facility
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did not indicate that proprietary information was utilized during this
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inspection.
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Attachment A
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Documents Reviewed
Plant Procedures
Pilgrim Nuclear Power Station Plant Specific Technical Guidelines, Revision 3
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Appendix to the Pilgrim Nuclear Power Station Plant Specific Technical
Guidelines
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Procedure 1.3.4-10 Writers Guide For Emergency Operating Procedures,
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Revision 2, Dated October 15, 1987
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Procedure 1.3.4-13 E0P Verification Program, Revision 1 Dated October 16, 1987
Procedure 1.3.4-14 E0P Validation Program, Revision 0. Dated July 10, 1987
Pilgrim Nuclear Power Station E0P Training Program Surmiary Description
Attachment 4 to BECo 1.etter 87-185
E0Ps
RPV Control, Revision 0. Dated November 18, 1987
Failure to Scram, Revision 0, Dated November 18, 1987
Primary Containment Control, Revision 0, Dated November 18, 1987
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Secondary Containment Control, Revision 0, Dated November 18, 1987
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Radioactivity Release Control, Revision 0, Dated November 18, 1987
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RPV Flooding, Revision 0, Dated November 18, 1987
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Alternate RPV Depressurizaticn, Revision 0, Dated November 18, 1987
Steam Cooling, Revision 0, D ned November 18, 1987
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Prinary Containment Flooding, Revision 0. Dated November 18, 1987
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E0P Satellite Procedures
Procedure 5.4.6
Primary Containment Venting and Purging Under Emergency
Conditions, Revision 17 Dated September 3, 1987
Procedure 5.3.21
Bypassing Selected Interlocks, Revision 4
Dated October 14, 1987
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Procedure 5.3.23
Alternate Rod Insertion, Revision 1
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Dated December 4, 1987
Procedure 5.3.26
RPV Injection During Emergencies, Revision 0
Dated August 30, 1987
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Attachment B
Coments with Respect to the Pilgrim Proce$ ires. Writer's Guide
Note:
These comments were a result of a comparison of the Writer's Guide
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with guidanco given in NUREG-0899.
1.
Cautions and Notes
Cautions and notes provide operators with critical and useful information
concerning steps or sequences of steps in E0Ps.
The discussion of
cautions and notes in the Writer's Guide lack some specifics.
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(a)Section III.A.13 states that "notes shall be ... placed within the
respective flowchart element, located innediately preceding or
following the associated text." Notes should be read and
comprehended by the operator prior to the step (s) they refer to, not
after. Notes should only be placed immediately prior to the step,
not following it, as suggested in the guidance.
The phrase "following the associated text." should be deleted.
(b)Section III.A.12 discusses "supplemental information". However, the
writer's guide does not define supplemental information or how it
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differs from notes. The writer's guide does not tell the writer when
!
to use supplemental information instead of notes or vice versa.
(c) There is no guidance provided as to the use of capitalization in
,
caution and note statements.
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(d) When cautions and notes contain multiple topics the importance of any
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one topic is obscured.
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2.
Logic Statements
Logic statements are used in E0Ps to describe a set of conditions or a
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sequence of actions.
Because logic statements can be confusing, it is
,
important to provide explicit guidance for their use.
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(a) Table 1
includes the word EXCEPT.
In logic statements using EXCEPT,
the conditions follow the actions which may lead operators to perform
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the actions before reading the conditions. An approach should be
used where all conditiers are read prior to the actions such as in a
Note or Caution (which ever would apply); or word the statement to
c
specify only the actions to be taken and not exceptions. For
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example, in Example 11 on Page 11 of the Writer's Guide, the
1
"sources" to be used could be specified instead of listing the
exceptions,
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I
, . . _ . .
__
.
. . _ _ , .
_
. .
.
. .
. _ _ . _ _
_
_ _ . . _ .
_
_ - _ _________
_
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-2-
Attachment B
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(b) Using the logic term THEN at the end of an action to instruct the
operator to perform another action in the same step runs actions
together which may be overlooked or may be confused with logic
statements.
For example: "Do A. THEN B. THEN C, THEN D." should not
be used. The writers' guide sheuld state that THEN will not be used
to run action steps together. Further, the word "then" should not be
used other than as a logic term to avoid operator confusion as to its
meaning.
In the following example, "If A. THEN B and THEN C" the
"and" and second "then" should not be used.
3.
Flow charts
Flow charts can be a valuable means of presenting important information to
operators and nust be formatted and written efficiently and effectively.
The writer's guide states that concurrent flows of steps shor.1d be spaced
to "achieve a balanced presentation." This is ambiguous guilance. For
example, it could mean that a short flowpath containing a foi steps should
be stretched out to balance out a concurrent long flow conk ;ning many
steps for appearance sake. As another example, it could mean that certain
symbols in cuncurrent flows should be placed side by side to achieve
overall visual balance.
4.
Emphasis Techniques
The proper use cf emphasis techniques rekes the procedures easier to
understand. The use of uppercase letters i; discussed on page 20 of the
Writer's Guide, but the use of all caps versus the use of initial caps and
lower case is somewhat ambiguous. For example, it is clear that the word
START is all caps, and section designators are upper and lower case,
because examples are given. But, the writer's guide does not make it
clear for each application whether all caps are to be used, or initial
caps only.
5.
Divisions, Headings, Numbering
It is important that a consistent method of section heading and step
numbering be used throughout E0Ps. The use of overall headings and an
alpha-numeric numbering systen for each step is usually needed so that
operators can keep track of where they are in the procedure and know how
to move easily and quickly to other parts of the procedure.
The flow charts have a system of titles and a numbering system to identify
procedures and overall headings for flow sequences. However, there is no
alpha-numeric numbering system for sections or syrbols within the flow
chart. This makes it difficult to refer to a section or symbol and an
operator may not be able to keep track. For example, if one operator
wants to indicate a particular step to another operator there is no easy
to way to verbally refer to the section or syrbol.
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, _ _ _ _ _ _ _ _ _ _ _
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-3-
Attachment B
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6.
Tables / Figures / Printed Aids
Figures and tables assist operators to make decisions and to locate
information.
(a) The writer's guide states that the units used on the axes of graphs
on page 15 should correspond to those of associated control room
instruments, but the same guidance is not given for tables discussed
on page 17.
(b) Because unnecessary information may clutter figures and tables and
confuse operators, all figures and tables should contain only
information that is needed by operators and is relevant to the text.
7.
Location Information for Equipment, Controls, Displays
It is important that the operators know where to find all of the
instrumentation and controls that are referenced in the E0Ps.
The writer's guide (on page 29) provides criteria to determine if
location information should be put in a step. However, this guidance
~
does not state the basic format for the information statement er
provide an example.
8.
Formatting
Writers should be given sufficient information in the writer's guide to
produce procedures that are consistently formatted.
The writer's guide states that for boldface type a slightly larger type
size should be used. This larger type size should be specified. The guide
also mentions varying thicknesses of lines to be used in the flow charts.
The guide should provide guidance on thickness sizes.
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Attachment C
NRC Observations in Walkthrouch of E0Ps and Satellite Procedures
1.
Control Rocm Indicator TI-9019 did not have a label to indicate it was for
drywell temperature.
The facility was in process of correcting.
2.
Relays in general (and specifically RPWP1) had labels which were masking
tape with information written on it. These labels were inadequate.
Facility operations management agreed to assure all labels fe E0Ps/
satellite procedures were correct and consistent.
3.
Relay Terminals used as jumpering locations in panel C170 v v e not clearly
marked.
4.
Procedure 5.4.6 did not direct evacuation of the reactor building prior to
initiating containment venting although it did contain a caution that
venting may result in rupturing some lines in the reactor building.
6.
Procedures have no description or different word description than plant
labels. Several examples were noted. A few examples were:
E0Ps refer to
torus temperature whereas plant label refers to bulk torus temperature.
5.3.23 referred to "l10-302-8" with no description. Whs a the plant label
has a clear description of this valve.
In procedure e.4.6 the 2" drywell
vent valve A0-5043A was referred to in the plant label as 2" drywell vent
exhaust valve f2 A0-5043A.
(Facility actions are discussed in coment 2
above.)
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7.
Procedure 5.3.23 required the operator to increase flow using valve
FCV-302-6A(B). Actual o>erator practice was to use controller FC-340-1 to
increase system flow witiout any procedure direction to this controller.
8.
At the RPS test channel switches, in one channel the switches were located
above the labels and the other channel the switches were located below the
labels.
9.
A label was missing on the 8" drywell purge exhaust valve (2.
10.
In procedure 5.3.26, the location of the spool piece to be inserted is
between two valves.
The valves are located on two plant elevations
(different rcoms) and were not within eyesight. The location in the plant
is not specified in the procedure.
Instruction was not provided in the
procedure or 1ccally on how to install the spool piece or the additionally
necessary step to connect the local instrumentation.
11. The location of vent valve 3/4 YT-120 was abeut 20 ft overhead and use cf
a ladder was required to operate the valve. The facility reportedly
evaluated the need to operate this valve and had initiated actions to
change the procedure to not use this valve.
_ . . _ _ _ - . _ . . _ . _ _ . . _ .
. . . . .