ML20234D253
| ML20234D253 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood, 05000000 |
| Issue date: | 09/10/1987 |
| From: | Hasse R, Hopkins J, Phillips M, Rescheske P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20234D179 | List: |
| References | |
| 50-454-87-32, 50-455-87-30, 50-456-87-28, NUDOCS 8709220028 | |
| Download: ML20234D253 (9) | |
See also: IR 05000454/1987032
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O.S. NUCLEAR REGULATORY COMMISSION
REGION III
Reports No. 50-454/87032;50-455/87030;50-45g/87028
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Docket Nos. 50-454; 50-455; 50-456
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Licensee:
Commonwealth Edison Company
Post Office Box 767
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Chicago, IL 60690
Facility Name:
Byron Station, Units 1 and 2
Braidwood Station, Unit 1
Inspection At:
Byron Site, Byron, Illinois
Braidwood Site, Braidwood, Illinois
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Inspection Conducted:
August 10-17, 1987
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Inspectors:
R. A. Hasse
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J. A. H kins
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P. R. R scheske
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Approved By:
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, Chief
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Operational Programs Section
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Inspection St.. mary
Inspection on_ August 10-17, 1987 (Reports No. 50-454/87-032(ORS);
50-455/87-030(0RS); 50-456/87-028(DRS))
Areas Inspected:
Special announced safety inspection to detemine if Emergency
Operating Procedures (E0Ps) were prepared and validated in accordance with the-
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approved Procedures Generation Package (PGP).
The inspection was conducted in
accordance with Temporary Instruction 2515/79.
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Results:
One violation was identified against 10 CFR 50 Appendix B,
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Criterion II - Failure to implement a quality assurance program to provide
control over activities affecting the quality of systems (i.e.-EOP) consistent
with their importance to safety (Paragraph 2.b(1)).
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8709220028 870916
ADOCK 05000454
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DETAILS
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1.
Persons Contacted
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Commonwealth Edison Company (Ceco)
Byron Station
- R. Querio, Station Manager
- E. Zittle, Regulatory Assurance
- J.
Langan, Regulatory Assurance
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- A. Britton, Q. A. Inspector
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- M. Scudder, Operations Department
- G. Bowers, Operations Department
- R. Pleniewicz, Production Superintendent
- D. Brindle, Operating Engineer
E. Cope, Procedure Writer
Braidwood Station
- E. Fitzpatrick, Station Manager
- K. Bartes, Shift Foreman
- P. Barnes, Regulatory Assurance Superintendent
- C. Bearden, Procedure Writer
- G. Masters, Operating Engineer
- D. Obrien, Assistant Operations Superintendent
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Production Training Center
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K. Gehlring, Braidwood Simulator Manager
D. Selph, Simulator Instructor
U.S. NRC
- P. Brochman, Senior Resident Inspector, Byron
- W. Kropp, Senior Resident Inspector, Construction, Braidwood
T. Tongue, Senior Resident Inspector, Operations, Braidwood.
T. Taylor, Resident Inspector, Braidwood
Other persons were contacted as a matter of' routine during this
inspection.
- Participated in the exit interview held by telecon Augus+- 17, 1987.
2.
Emergency Operating Procedures
Emergency Operating Procedures (EOPs) have undergone significant changes
as a result of the 1979 accident at the Three Mile Island facility. The;
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new 50Ps are required to be' symptom-' oriented.rather than event oriented.
Generic' Letter 82-33, " Requirements For Emergency Response -Capability"'
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(Supplement 1:to NUREG-0737) requires all licensees.and applicants to'
submit-to the_NRC for approval a Procedure Generation Package (PGP)
describing their plan for developing the upgraded.EOPs. The PGP consists
of the following four parts:
Plant-specific Te'chnical. Guideline (P-STG) - the technical basis
for the new E0Ps
Plant-specific Writers Guide (P-SWG) - the details of the specific
methods to be used by the licensee in preparing the E0Ps
A description of the program for verification and, validation (V&V)'
of the E0Ps
A description of the program for training operators on the E0Ps
The purpose of this inspection was to' determine if'the licensee's.
E0Ps had been prepared and va'lidated in accordance with their NRC
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approved PGP.
This was accomplished by a detailed' comparison of
a sample of E0Ps against the approved PGP.
a.
Documents Reviewed
The following documents at the Byron and Braidwood Generating
Stations were reviewed during this inspection:
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(1)
EP-0, " Reactor Trip or= Safety' Injection," Revision 2.
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ES-0.0, "Rediagnosis," Revision ~2.
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(3)
EP-1, " Loss of Reactor or Secondary Coolant," Revision.2.
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(4) EP-3, " Steam Generator Tube Rupture," Revision 2.-
(5)
ES-3.2, " Post-SGTR Cooldown Using Blowdown," Revision 2.
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(6)
FR-S.1, " Response to Nuclear Power Generation /ATWS,"
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Revision 2.
(7)
FR-C.1, " Response to Inadequate Core Cooling,"-Revision 2.
(8) ST-1 through 6, " Status Trees," Revision 2.
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(9) B0A PRI-5, " Control Room Inaccessibility," Revision 2.
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(10) Byron and Braidwood E0P Step Deviation Documents,
Revisions 1, 1A,~and 2.
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(11)' Byron Generating Station Units 1-and 2 PGP.
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(12) Westinghouse Owners Group (WOG) Emergency Response
Guidelines.(ERG), High Pressure Version, Revision l'.
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Inspection Results
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The inspectors determined that the licensee's E0Ps were generally
prepared, verified, and validated in accordance with'the PGP.
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However there were weaknesses in the E0Ps quality. control program,
Verification and Validation (V&V) program, and Deviation' .
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Documentation. 'These weaknesses are discussed in the following
paragraphs:
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(1) Plant-Specific Technical Guidelines (P-STG).
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The P-STG provided'the controlled technical basis for theiE0Ps
and the E0Ps should be consistent with'that basis. .The P-STG
were inspected to ensure.that the E0Ps were properly translated'
from the P-STG. The licensee used the Westinghouse Owners Group.
(WOG) Emergency Response Guidelines-(ERG), High.. Pressure.. Version,
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as the generic technical guidelines to develop plant-specific
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E0Ps. Due to the similarity between the Byron and Braidwood'
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Stations, the inspectors reviewed E0Ps from one station and then.
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did a " cross check" on a sample of the other stations.EOPs.
The inspectors found two examples where the Control Room E0Ps-
did not match the approved E0Ps,' Revision'2.
(a)
In BwFR-S.1 pages 9 and 10 were duplicates of pages 7 and 8.
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This example occurred only at the Braidwood Station.
(b) In Step 14 of BwFR-S.1 and-BFR-S.1 the Response Not-
Obtained column returned the operator to Step.6 (Steam Dump.
Isolation) vice Step 4 (Initiate Emergency Boration oflRCS)
as required by the-ERGS.
This example occurred at both
stations.
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Example "a" occurred due to the quality assurance method used
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to check the E0Ps against the approved draft document.. The
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licensee stated that a "page check".was done and-each EOP had
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the correct number of pages in the proper _ sequence. JHowever, .
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since the spacing of material changed from draft.to . final,'all-
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of the material formerly on four pages was placed on two pages.
Example."b" occurred because a previousLrevisionito the
procedure added and deleted several steps which changed the.
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numbering sequence. As a result, the procedure user would be
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referred to the wrong step in the procedure. Revision 2 also
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added and deleted steps, but the numbering sequence was.not
changed in: step'14 Response Not Obtained column.
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A QA program consists of all the planned and systemstic actions
necessary to provide adequate confidence that a system,
component, or structure will satisfactorily perform its
function.
The E0Ps provide the operator with direction to
mitigate the consequences of an accident and as such are
considered a system necessary to protect the health and safety
of the public.
Due to inadequate quality controls, the licensee
failed to ensure that the final printed revision of the E0Ps
matched the approved draft document and that all of the
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consequences of adding / deleting steps in the E0Ps had been
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fully examined.
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This failure to apply a quality assurance program to provide
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control over activities affecting the quality of systems
(i.e. E0Ps) consistent with their importance to safety is
considered a violation of 10 CFR 50 Appendix' B, Criterion II.
(454/87032-01; 455/87030-01; 456/87028-01)
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Additionally, the inspectors noted that at Braidwood, part of
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Step 12 of EP-1 was not consistent with the same step in the
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Byron E0P.
A review of the deviation documents revealed that'
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during the simulator validation of Revision 2 of the E0Ps the
additional part was added to assist the operator in aligning
the non-safety electrical busses.
Discussions with the licensee
revealed that their intention was to include this step in both
stations E0Ps.
Although not an example of the above violation.
the inspectors were concerned because the intent was clearly to
add this step; however, the Braidwood E0Ps were not reviewed to
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see if this had been done.
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As a result of the above violation and inspector concerns, the
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Braidwood Station conducted a step-by-step comparison of.the
Braidwood to Byron E0Ps.
Eight technical deficiencies were
identified:
(i) Step 10.a(2) of ES-3.3, " Post-SGTR Cooldown with Steam
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Dumps," the first statement in the Response Not Obtained
(RNO) column directs the operator to go to step 11.
Step 11 will dump steam from the ruptured S/G.
This action-
contradicts the previous direction in step 10.a(2) RNO
" ...do NOT release any steam from the ruptured SGs." The
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licensee has changed the RN0 to direct the operator to
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consult the Technical Support Center (TSC) to determine.an
alternate cooldown method.
Note that this procedure,
ES-3.3, can only be entered well after the RCS has been
cooled down and depressurized to minimize the leak, ECCS
flow has been terminated, and the TSC has been consulted-
about the appropriate Post-SGTR cooldown method.
(Byron I and II)
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(ii). Step'11 of FR-C.1' checks.all RCPsLstopped but gives no-
direction in the RNO column if they are' running.
The RNO.
column should direct the . operator: to stop the RCPs.
(Braidwood only)
(iii):The RCP trip criteria on the Operator Action Summary sheet-
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for BCA-2.1, " Uncontrolled Depressurization of All SGs,"
' calls for tripping RCP.s if. controlled RCS cooldown is:in
progress.
This should read Controlled RCS Cooldown NOT
in progress.
(Braidwood only)
(iv) Step 17.b of EP-1 RNO-column directs the operator t'o shut
the appropriate 480V Bus feeder on 1PM06J.
Since this is
a Byron II procedure, the reference panel should be'2PM06J.
(v) Step 12.a of ES-3.2 directs RCS dep' pressurization.by using
normal spray valves.
The valves are labeled IR/455A or
IR/4558 vice the correct IR/455B or IR/455C.
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(vi) BCA-0.0, " Loss of All A.C. Power, Table A, page 41 of 56,
Distribution Panel 2 DC05EA is listed as DC 212 Rear.
This should be DC 211 Rear.
(Byron II only):
(vii) In BCA-0.0, Table D, page 56.or 56, the.second valve-
listed is 2SX2101A, " Motor Driven AF Pump 2A 011 Cooler-
Outlet Isolation Valve." This should be listed-as
2SX2103A,'" Motor Driven AF Pump 2A Oil Cooler Inlet'
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Isolation Valve."
(Byron.I and Braidwood. ; Nomenclature
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at Byron II)
(viii) Step 3.e 1) d) of BwCA-0.1, " Loss of All AC Power Recovery
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Without SI Required," opens centrifugal. charging pump.
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(CENT CHG) miniflow isolation valves CV8110 and 8116 for
". A" CENT CHG pump and CV8111' and 8114 for "B". CENT CHG
pump.
The correct listing is CV8111 and 8114 for "A"
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CHG pump and CV8110 and 8116 for "B" CENT.CHG pump.
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(Braidwood only)
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The~ licensee has corrected all of the above' deficiencies by
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using Temporary Procedure changes or " Typo Changes (at Byron
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only).
The procedure revisions are expected to be completed
by the end of September, 1987.
All of the identified deficiencies indicate a generic weakness'
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in the quality controls exercised during the editorial and
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printing process of the operating and abnormal' procederes.
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A very minor clerical error (e.g. not changing the numuering
sequence in all required steps) can become'a major safety-
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issue if that error returns the operator to the wrong place in-
the procedure and the operator consequently performs actions
which aggravate the accident.
The licensee's program to ensure-
that all current and future operating and abnormal procedures
are identical to the approved procedures appears to be
deficient as noted by the above examples and the violation.
Since the lack of an adequate QC program could impact any
procedure revisions, the licensee needs to determine that all'
the operating and abnormal procedures are free of printing and
editorial errors.
This will be tracked as part of the response
to the above violation.
(2) Plant-Specific Writers Guide (P-SWG)
The purpose of the writers guide was to ensure the utility of
the E0Ps by providing administrative and technical guidance
detailing their preparation.
Utility of the procedures can be
measured by their readability, completeness, and convenience of
use.
The inspectors noted the following concerns in this area:
(a) In the Byron and Braidwood Status Tree ST-1, "Subcriticality,"
a negative sign was missing on the " Yellow Path" for the
Intermediate Range Startup Rate, i.e. "More negative than
-0.2 DPM."
Discussions with licensed operators indicated
some confusion existed as to the correct value.
The licensee
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stated that a temporary change would be immediately initiated
to correct the Status Trees at both stations.
(b) The poor print quality of the Status Trees left many plant-
specific parameters difficult to read.
Discussions with
licensed operators reinforced the need for a better' quality
document to improve readability.
The licensee had agreed
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to review this concern during subsequent E0P revisions.
(c)
In Step 9.b of EP-1 the Response Not Obtained column resets
Safety Injection (SI) per Operating Abnormal Procedure B0A
PRI-5," Control Room Inaccessibility." Only specific steps
in the approximately 100 page procedure are used to reset
SI.
The P-SWG suggests incorporating steps fmm other
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procedures if the information can-be included without
appreciably increasing the original procedures length.
The licensee had agreed to either reference the specific
part of B0A PRI-5 or to add the additional information to
the step during subsequent revisions of the E0Ps,
(d) Several other problems were identified.
EP-1, Entry Conditions or Symptoms, stated that an
entry condition is step 17 of FR-C.2 vice step 18.
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The addition of step 1.d, " Verify Steam 0 umps in the
Steam Pressure Mode," of EP-1 is not documented in
the EP-1 deviation documents.
However a similar step
is documented in EP-3, Revision 1.WOG 1 deviation
documents.
(both stations)
The deviation justification for Step 6.d of EP-1
Revision 1A WOG 1 references Step 29.d of EP-0
Revision 1A WOG 1 vice Step 29.b.
(both stations)
The above deviations are additional examples of the generic
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weaknesses in the licensee's quality control of the printing
and editorial process described in Paragraph 2.b(1) of this
report.
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(3) E0P Verification and Validation (V&V)
The purpose of the V&V effort was to ensure the technical
adequacy and useability of the E0Ps.
The inspectors reviewed
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the validation documentation for ES-3.2 and FR-C.1.
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documentation for Revision 2 (current revision)' stated that no
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additional validation was required since no technical. changes
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had been made.
The inspectors agree with this statement;
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however, no validation documentation could be found.for previous
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revisions to these procedures.
Discussions with the licensee
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indicated that the validation procedure may have been by
reference to the validation of the WOG ERGS.
This may be
acceptable if there are no differences between the Byron and
Braidwood stations and the ERG reference plant that would affect
these procedures.
The inspectors only sampled a fraction of
the V&V records and found that documentation inadequate.
This
raises doubts about the completeness of all of the V&V records.
If the revisions did not require a V&V effort the licensee must
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so document.
This is considered an Unresolved Item pending
documentation by the licensee that these procedures have been
adequately verified and validated with appropriate documentation.
(454/87032-02; 455/87030-02; 456/87028-02)
(4) Operator Training
The inspectors observed four Senior Reactor Operators (SRO)
during routine requalification training on the Braidwood
Simulator at the Production Training Center to evaluate the
useability of and operator familiarity with the Byron /Braidwood-
E0Ps. The training session c6nsisted of several transients
which exercised the following E0Ps:
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During these transients the training staff would " freeze" the
simulator when the trainees got to a new or revised step in the
procedure. The training staff would explain _the actions in the
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step, locate the necessary instrumentation and controls, and
discuss the basis for adding the step.
The training staff would
then " backup" the simulator and continue the transient in real
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time.
The operators appeared to be familiar with their
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responsibilities and required actions during the emergencies,
both individually and as a team. .The inspectors identified two
concerns during the training session.
(a) In Step 4.b of EP-3, stopping feed flow to the ruptured
steam generator (s), the inspectors determined that
additional guidance for the operators was necessary.
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Discussions with the training. staff and licensed operators
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indicated that listing plant specific isolation valves
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would assist the operators. The licensee had agreed to
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address this concern during subsequent revisions of the
E0Ps.
(both stations)
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(b) Step 9.f of EP-3 opened a fire protection containment
isolation valve.
However the valve number or designator
was not listed in the E0P.
(Braidwood only)
The inspectors conducted a control room and simulator walkdown-
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to determine if the instrumentation and controls labeling were
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consistent with E0P terminology.
No differences were identified.
(5) Review of PGP
The licensee transmitted the PGP to the NRC via a letter dated
March 26, 1985.
In response to the NRC comments,-the licensee
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committed to incorporate changes in the PGP by January 31, 1987
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(documented in a letter to the NRC dated September 16,1986).
The inspectors reviewed the change control documentation and
the PGP against these commitments and verified that the changes
had been incorporated into the PGP.
3.
Unresolved Items
Unresolved Items are matters about which more information is required
in order to ascertain whether they are acceptable items, violations,
or deviations.
An Unresolved Item disclosed during the inspection is
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discussed in Paragraph 2.b (3).
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4.
Exit Interview
The inspectors held an exit interview with licensee representatives
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(denoted in Paragraph (1)) via telecon on August 17, 1987. . The licensee
stated that the likely informational content of the report would contain
no proprietary information.
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