Text

Insp Rept 50-293/88-11 on 880314-18.No Violations or Deviations Noted.Major Areas Inspected:Emergency Operating Procedures,Including Comparison of Plant Specific Guidelines & BWR Owners Group Guidelines with Emergency Procedures
	ML20154F934
Person / Time
Site:	Pilgrim
Issue date:	05/17/1988
From:	Lange D; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
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ML20154F931	List: ML20154F928; ML20154F934;
References
	50-293-88-11, NUDOCS 8805240135
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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, _

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:

D.' Lange, Chi

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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

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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

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

! * 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

- Exercising Procedures in the simulator

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Review of the E0P quality assurance measures

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.

E0P-1: 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.

E0P-2: Failure to Scram

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.

E0P-3: 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 ,

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. !

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. ,

5. Comparison of E0P Writer's Guide With E0P

All E0Ps were reviewed to determine if they fc11 owed the guidance provided

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in the licensee's Writer's Guide. The licensee verbally committed to

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,

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

l into the RPV from sources external to the primary containment

UNTIL primary containment water level and torus pressure can be

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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

- Interim report on discrepancies

- List of open verification items

- 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.

E0P-02 RPV Control

E0P-03 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 '

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

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an unresolved item (50-293/88-11-03). See section 4 for additional '

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:

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- Lists of perfereance and cognitive standards :

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- Unit, Course and l'odular Guides

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- Scenarios used during siculator training

l All docurentatien appeared ccrplete and thorough. Hewever, the training

I program description included in the PGP is no longer applicable. This .

progran freferred to as Phase I) was executed, but had seme difficulties

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 i

their current ECP training and submit this description as a part of a

revised PGP. The training representative stated that they were preparing i

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a new training program description which would address previously l

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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.

l 11. E0P Quality Assurance Measures

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A review was conducted to determine if Quality Assurance Measures are

adequate to ensure that high quality E0Ps are developed, implemented and

maintained,

i 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

aud,ts of the maintenance of the E0Ps did not exist in the area of

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

l program. This audit will be performed as a Safety Syster Audit in the

I fourth quarter of 1988. The procedura11 ration of continued quality

l 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 i

did not indicate that proprietary information was utilized during this !

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inspection.

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Attachment A i

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Documents Reviewed

Plant Procedures

Pilgrim Nuclear Power Station Plant Specific Technical Guidelines, Revision 3 l

Appendix to the Pilgrim Nuclear Power Station Plant Specific Technical

Guidelines .

Procedure 1.3.4-10 Writers Guide For Emergency Operating Procedures, ,

Revision 2, Dated October 15, 1987 !

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

E0P-01 RPV Control, Revision 0. Dated November 18, 1987

E0P-02 Failure to Scram, Revision 0, Dated November 18, 1987

E0P-03 Primary Containment Control, Revision 0, Dated November 18, 1987

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E0P-04 Secondary Containment Control, Revision 0, Dated November 18, 1987 ,

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l E0P-05 Radioactivity Release Control, Revision 0, Dated November 18, 1987 '

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E0P-06 RPV Flooding, Revision 0, Dated November 18, 1987

l E0P-07 Alternate RPV Depressurizaticn, Revision 0, Dated November 18, 1987 ;

E0P-08 Steam Cooling, Revision 0, D ned November 18, 1987 ;

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E0P-09 Prinary Containment Flooding, Revision 0. Dated November 18, 1987

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i 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 '

Procedure 5.3.23 Alternate Rod Insertion, Revision 1 .

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 ,

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.

(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 .

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. !

(d) When cautions and notes contain multiple topics the importance of any i

one topic is obscured. l

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2. Logic Statements

Logic statements are used in E0Ps to describe a set of conditions or a i

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 i

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 i

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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(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.

l

, _ _ _ _ _ _ _ _ _ _ _

..

..' .

.

"

-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.

.

'

~ .

.

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.)

l

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.

_ . . _ _ _ - . _ . . _ . _ _ . . _ . . . . . .

ML20154F934

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