ML20247N344
| ML20247N344 | |
| Person / Time | |
|---|---|
| Site: | Quad Cities  |
| Issue date: | 09/14/1989 |
| From: | Stols R COMMONWEALTH EDISON CO. |
| To: | Murley T Office of Nuclear Reactor Regulation |
| References | |
| 0280T, 280T, NUDOCS 8909260197 | |
| Download: ML20247N344 (22) | |
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Address Reply to. Post CICciiB37767~
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i, September 14, 1989 Dr. Thomas E. Murley, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Washington, DC 20555
Subject:
Quad Cities Station Units 1 and 2
" Status Update of Corrective Action Commitments to Emergency Operating Procedures (EOP) Inspection NRC Docket Nos. 50-254 and 50-265 References (a): Letter from G.M. Holahan to Cordell Reed dated December 5, 1988, transmitting Inspection Report 50-254/88-200; 50-265/88-200 (b): Letter from I.M. Johnson to T.E. Murley dated February 24, 1989, transmitting Response to Inspection Report 50-254/88-200; 50-265/88-200 Dr. Murley:
Reference (a) transmitted the results of the Quad Cities Emergency Operating Procedures Program Inspection conducted by the NRC's Office of Nuclear Reactor Regulations (NRR) during the period of July 18-29, 1988.
Reference (b) transmitted the corrective action plan to resolve the concerns identified during the inspection.
The attached provides the status to the actions initiated in response to the identified concerns.
The submittal of the corrective action status was requested by T.M. Ross, Quad Cities Project Manager. ' Attachment "A" provides an overview of the corrective action plan and Attachment "B" provides the status of the specific concerns.
If there are any further questions, please contact this office.
Very truly yours, f
R. Stols Nuclear' Licensing Administrator im cc:
A. B. Davis, Region III Administrator T.M. Ross - Project Manager, NRR p39 R.L. Higgins - Senior Resident Inspector Quad Cities e
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8909260197 890914 PDR ADOCK 0500o254 G.
PNU
ATTACHMENT'A CORRECTIVE ACTION OVERVIEN In July 1988, the NRC's Office of Nuclear Reactor Regulation (NRR) conducted an inspection of the development and implementation of the Quad Cities Emergency Operating Procedures (EOP). The NRC 1ssued the Inspection Report (50-254(265)/88-200) in December, 1988.
Commonwealth Edison submitted a corrective action plan to the NRC in February, 1988.
This submittal provides a status of the implementation of the corrective actions.
In response to the NRC's inspection, Quad Cities implemented an extensive corrective action plan to enhance the E0P Program. The cornerstone to the development of an effective E0P Program is the establishment of administrative controls. Quad Cities Station developed administrative procedure, QAP 1100-13 Control of the Emergency Operating Procedures.
This procedure delineates the requirements of the overall program incorporating the guidance of NUREG-0899 as well,as the concerns identified by the NRC. The Administrative Procedure was submitted to the NRC in the February,1989.
Consistent with the Administrative Procedure. Quad Cities developed a Plant Specific Writer's Guide (PSNG) and a Plant Specific Technical Guideline (PSTG).
These documents translate the BWR Owner's Group (BWROG) Emergency Procedure Guidelines (EPG) information into plant specific requirements.
The PSNG and PSTG for Quad Cities was developed in November, 1988 and October, 1988, respectively.
The development of the PSTG included a comparison to the l
BHROG EPGs and any deviation was corrected or technically justified.
Following the development of the PSTG and PSHG, the E0P flowcharts were produced. A comparison of the PSTG and the flowcharts' was performed to ensure the PSTG requirements were properly translated into the flowcharts and, ultimately, that the EPG requirements are incorporated into flowcharts. The flowcharts were then verified and validated.
The first phase of the verification and validation process was the tabletop review. This review consisted of simulating a wide-range of accident scenarios designed to exercise all possible paths of the flowcharts. The flowcharts were upgraded to incorporate the comments.
The next phase to the verification and validation process was the plant walkdown.
The purpose of l
the walkdown was to assure that required operator aids are identified to
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perform the required tasks. This walkdown was performed for the flowcharts as well as the auxiliary procedures.
For the April, 1989 procedure revision, thirty-seven (37) aux 111ary procedures, in addition to the flowcharts, were j
included in the walkdown.
The final phase of the verification and validation process required a simulator demonstration. A crew of SRO and R0 licensed personnel, attempted to implement the flowchart in various accident scenarios.
The crew is observed by individuals with E0P development, training and human factor experience as well as operating staff management. Comments from the phase were incorocrated in the flowcharts.
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The On-Site Review Committee performed a final review and approval of j
the procedures prior to implementation. As part of this review, the Committee was required to ensure that required training is completed prior to implementation of the EOPs.
Training requirements were determined by the QGA Committee based on the extent of the E0P revision. The QGA Committee consists of the Training Supervisor, E0P Coordinator, Assistant Tech Staff Supervisor, Computer Technician, Licensed Training Instructor and Operating Engineer.
The training requi czents range from " Required Reading" packages to Simulator training or a combination of the various types of training.
Attachment "B" provides the status of the corrective actions associated with the NRC identified concerns.
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ATTACHMENT B
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STATUS OF CORRECTIVE ACTIONS 1
l RELATING TO EMERGENCY OPERATING PROCEDURES PROGRAM CONCERN:
(1)a. Ihe development of the Emeroency Ooeratino Procedures (EOPs) was not adeouate in that:
Ihe licens.ne_did not darmloo a revised Plant Specific Technical Guide-l (PSTG) and Plant Soecific Writer's Guide (PSHG) orlor to the l
dayslanment and tralementation of stanjficant revisions to the E0Ps I
in accordance with the cuidelines of NUREG 0899.
i Reinonie:
The PSTG and PSHG have been rewritten in accordance with QAP 1100-13 (page 3 of QAP 1100-13). After their development, the draft QGA procedure was' developed and is in the process of verification and i
validation. Page 4 of the QAP states that "The proposed modifications shall be made to the QGAs in accordance with the approved PSTG and writer's guide" to prevent any future deviation from this methodology.
Status:
The PSTG and PSHG were developed in October, 1988 and November, 1988, respectively, utilizing guidance provided in NUREG-0899.
The PSTG and PSHG were implemented in the development of the April, 1989 Quad Cities General Abnormal Procedures (QGA).
Quad Cities Administrative Procedure QAP 1100-13 " Control of Emergency Operating Procedures" requires that, if a change to QGAs is identified, the PSIG and PSNG will be reviewed and revised, as appropriate. This will ensure that the development of QGA revisions is based on the information contained in the PSTG and PSHG.
This item is comolete.
CONCERN:
(1)b.
The licensee failed to develoo and imolement an adecuate verificatlOD and validation orocram for the EOPs.
The verification And_y.alidation prooram performed did not orocrammatically address the necessary at.triknigs and was cerformed in an informal manner which severelv limited the effectiveness of the effort.
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t Resoonse:
A formal verification and validation is being performed on the April 1989 revision of the QGAs.
It is being performed in accordance with QAP 1100-13 as described on page 4.
Status:
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A formal verification and validation process has been developed for j
the QGA procedure revisions.
The verification and validation process 1
is contained in QAP 1100-13 " Control of Emergency Operating Procedures" dated August, 1988.
The verification and validation process includes the essential elements described in NUREG-0899, such as:
A comparison of the Emergency Procedure Guidelines (EGPs) to the I
PSTG A comparison of the PSTG to the flowcharts which delineates the implementation of required actions Tabletop exercises in using the QGA procedures
- Walkdown of the QGA and Auxiliary Procedures to verify the procedures can be performed e.' Implementation of the procedures during simulator scenarios.
This verification and validation method was performed as part of the approval process for the current revision of the QGA procedures implemented in April, 1989.
This item is closed.
CONCERH:
(1)c.
The licensee had not orovided trainino acoroor.iate to the scone of E0P revisions on a timelv basis to the licensed ooerators.
Resoonse:
In accordance with QAP 1100-13, page 6, appropriate training will be dictated by the QGA committee and the on-site review will verify that training has been completed prior to implementation of the procedure.
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Administrative Procedure QAP 1100-13 dated August, 1988 requires that the QGA Committee determines the training requirements for QGA procedure revisions. The QGA Committee recommendation for training may include any or all of the following methods for training:
" Required Reading"
. Classroom training Plant Walkdown training Simulater training Prior to the final approval and subsequent implementation of the QGA.
procedure revision, the training requirements are verified complete.
The QGA Committee dictated that a two day classroom training session be conducted for the April, 1989 revision to the QGA procedure prior to implementation. Classroom training for all licensed personnel was completed on April 7,.1989.
In addition, all operating crews (with the exception of one individual) have received simulator scenario training on the April, 1989 revision to the QGA procedures. This training _was completed on May 26, 1988.
Training for the one Reactor Operator will be completed in November, 1989.
This item is romplete.
CONCERN:
The maintenance of the EOPs and PSTGs was not adecuate in that:
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(2)a.
Ih.t_.11ctosee did not anorooriately control and m lnta).ILihe PSTGs and sucoortino calculations un-to-date as a design basis document.
Response
Calculations are controlled as described in QAP 1100-13, page 2.
The PSIG is controlled as described on page 3.
The PSTG and calculations are reviewed and approved and are retained and tracked as plant records.
Status:
Administrative Procedure QAP 1100-)3 defines the requirements for the control and mairitenance of the PSTG and supporting calculations.
Control mechanisms for revi'w, approval, and retention of the PSTG e
and calculations were implemented during the development of the April, 1989 revision to the QGA procedures.
This item is comolete.
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CQEERti:
(2)b.
Jhe licenige did not con. trol _the_ny_lij.quS_of the EOPs in accordance with administrative orocedures for distribution.
B112001g:
QAP 1100-5 (Temporary Procedures and Temporary Changes to Permanent Procedures) was revised to clearly assign to the originator the responsibility of distributing QAP 1100-T14 (Temporary Procedure Change Notice Sheets) to specific manual holders.
QAF 1100-T6 (Temporary Change to Permanent Procedure Request /
Temporary Procedure Request) was revised to require originator to sign off verifying that " notice sheets have been prepared'for existing procedures and will be distributed to-the. appropriate manual holders".
Stain:
During the course of'the audit, the NRC identified that a temporary procedure change was not distributed to the controlled copy of the QGAs located in the Technical Support Center. As a result, Quad Cities Station has revised Administrative Procedures, QAP 1100-5, Temporary Procedures and Temporary Changes to Permanent Procedures and QAP 1100-T6, Temporary Change to Permanent Procedure Request /
Temporary Procedure Request.
These changes were issued in December, 1988 and August, 1988.
The change to the procedures clearly identified responsibility for temporary procedure changes.
QAP 1100-13, Control of Emergency Operating Procedures, requires that permanent changes be distributed in accordance with the stations procedure program. The Station Procedure Program is
. described in QAP 1100-2, Station Procedure Distribution.
This item is comolete.
CONCERN:
(2)c.
The licensste_provided insufficient DRnQnnel re.iDVLCes to maintain the technical and human enaineerino basis of the EOPs.
Resoonse:
An E0P Coordinator has been assigned and functions in conjunction with a multi-discipline E0P Committee to coordinate matters
,concerning the EOPs.
Human engineering matters are being handled by CECO human engineering personnel.
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Status:
The E0P Coordinator is currently assigned to the Operating Department to provide for better functional control of E0P and operating procedures. The E0P Committee currently consists of the Training Supervisor, E0P Coordinator, Assistant Tech Staff Supervisor, Computer Technician, License Training Instructor and an Operating Engineering. Responsibilities for this Committee have been defined in QAP 1100-13, Control of Emergency Operating Procedures.
During the verification and validation process for the April, 1989 revision of the QGAs, personnel trained in Human Engineer 1pg participated in the Simulator validation phase.
In addition, Human Engineering personnel have been involved in the EOP labeling effort.
This item is comolete.
CONCERN:
The licensee orovided inadeauate manaaement oversiaht of the EOP-develoosent orocram in that:
(2)d.1. Eeriodic utdits of_tht_10E_ development Droaram Were not oerformed by the Ouality Assurance Denartment.
Responte:
As previously addressed in the response to the Notice of Violation i
issued in Dresden Inspection Reports 50-237/88012; 50-249/88014, and the failure to audit the E0Ps prior to June 1988 was an oversight.
Quality Assurance missed the recommendation in NUREG-0899 for Quality Assurance overview of the E0P Program and had independently concluded that the involvement of the NRC licensed Senior Reactor Operators within Quality Assurance in the implementation, training, and simulator use of the E0Ps offered adequate coverage.
When notified of NRC concerns in this area at Dresden in June 1988, Quality Assurance took aggressive action to address the issue at all the Commonwealth Edison Nuclear Stations. At Quad-Cities Station, research into the E0P development process began immediately.
The Quality Assurance Audit Schedule was revised on July 1, 1988, to include an Audit of the E0P Program. A comprehensive Audit of the E0P Program was conducted July 11-15, 1988. Audit team personne1' included a technical advisor, with significant experience in the E0P development process, and NRC licensed Quality Assurance personnel from both Quad-Cities and Dresden Stations.
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The results of the Quality. Assurance Audit (QAA 04-88-52) were discussed with members of the NRC E0Ps Team during their inspec-tion.
The Quality Assurance Audit identified many of the same concerns brought out in the NRC Inspection Report.
Quality Assurance is monitoring the upgrade of the EOPs Program via follow-up of this Audit.
To ensure continued coverage of this area, the 1989 Quality Assurance Audit and Surveillance Schedules for all Commonwealth Edison Stations contain requirements to assess the E0Ps Program.
Status:
A comprehensive audit (QAA 04-88-52) of the E0Ps was conducted during the period July 11 through 15, 1988. A dedicated audit to the E0P Program was conducted since the 1988 Audit Schedule did not require an assessment of the Program as part of a normally scheduled audit.
The audit resulted in four (4) findings, two (2) observa-tions and two (2) open items. Quality Assurance has monitored the E0P Program development via the follow-up of the audit deficiencies.
The audit was closed on May 17, 1989.
The 1989 Surveillance and Audit Schedules include the requirements to assess the EOPs. The E0P Program was scheduled to be reviewed as part of a May, 1989 audit; however, since the 1988 Program audit was closed in May, 1989, the assessment of the Program was deferred to October, 1989.
Selected aspects of the E0P Program will be conducted as part of the " Operations" audit.
The annual E0P Program surveillance will assess the usability of the Procedures during Simulator training. The surveillance is scheduled to be completed by the end of October.
This item is somolete.
r COEEM:
(2)d.2. Correctlye actions for deficiencies in the E0P development oroStam were not imD13mented followina the licensee's review of Informat1RD l
Matjce 86-64 because an inadeouate evaluation was nerformed.
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addition. the licensee's utilization of other information notices was questionable due to the lack of manacement review.
Resoonsg:
Information Notices from 1981 through 1987 have been reviewed to determine adequacy.
The review was to determine if the initial response was adequate, inadequate or not applicable.
The Information Notices from 1978 through 1981 with responses that i
were deemed to be inadequate will again be reviewed and responded to following development of an action plan.
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Information Notices from 1978 through 1981 are still being reviewed for adequacy. Similarly, those responses which are considered to be inadequate will be responded to again.
This adequacy review is scheduled to be completed by May 31, 1989.
Recent changes in the method of review of this type of operating experience (OPEX) has resulted in a significant increase in management review.
Information Notices and other forms of OPEX information are initially screened by Regulatory Assurance personnet.
Following this screening, the information is reviewed by cognizant station personnel and a response is formulated.
This response is then reviewed by the appropriate department head and upper station management. When the response is approved, any items that need tracking to ensure completion are entered into a computer tracking system to ensure timely resolution.
Status:
Information Notices 1978 through 1981 Quad Cities Regulatory Assurance completed the review of Information Notices for this period.
The review included a determination for adequacy of responses and corrective actions.
Four (4) Information Notices required additional actions or detailed research prior to closure.
Three (3) Information Notices from this period currently remain open.
Information Notices 1982 through 1987 Review of the Information Notices for this time period was performed by Contractor personnel to identify potentially inadequate responses.
Of five hundred and ten (510) Notices from this time period, two hundred and forty (240) were identified as requiring additional research by station personnel to enhance the response or to verify appropriate actions have been implemented. Currently, the station has completed their review and research of seventy-six (76) of the Notices, six (6) of which currently remain open.
CONCERN:
(2)d.3. Corrgttive actions for labelina deficiencies. identified by orevioul HRC inspections. were inadeauate because ongoina labe11no efforts warg_not evaluated orior to tne implementation of the corrective actions.
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Response
Commonwealth Edison Human Engineering personnel have been contacted to address the issue of labeling. Guidelines resulting from human factors input will be incorporated into QAP 300-17, Control Room Labeling and Color Coding by March 30, 1989.
The changes will be implemented in accordance with this procedure.
Status:
Commonwealth Edison Human Engineering group has conducted a review of QGA related instrumentation labels. Administrative Procedure QAP 300-17 " Control Room Labeling and Color Coding", will be revised to incorporate the guidelines developed by Human Engineering.
The procedure will be implemented as part of the ongoing Control Room labeling program.
CONCERN:
The technical basis of the EOPs was deficient in that:
(3)a.
The licensee did not orovide a method for combustible aas control in ibe EOPs bantuse the hydroaen control provisions of the Primary Containment Control cuidelines were not'incorocrated.
In addition.
fhe licensee did not orovide a justification for this significant deviation.
Resoonse:
A Hydrogen Control procedure has been developed and is being incorporated into the April 1989 revision of the QGAs.
Status:
The Hydrogen Control Procedure, QGA 200-5, has been developed and implemented. The procedure was issued for use on April 10, 1989.
This item is comolete.
CONCERN:
(3)b.
Ihe licensee altered the BHROG Emeroency Procedure Guidelines (EPG) loaic for Reactor Pressure vessel (RPV) floodina because installed crimary containment water level instrumentation EAs not available.
The licensee did not effectively utilize olant soecific eautoment fs orovide an alternate method _of level indication and did not orovide a lyfficient technical justification for this significant technical deviation.
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Response
The technical justification for this technical deviation will be i
revised and upgraded by April' 10, 1989.
Additionally, a modtftcation
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is being pursued at Quad Cities Station which would install primary 1
containment water level indication to accomplish our full QGA upgrade to revision 4 of the E0Ps.
Status:
The technical justification for the deviation for Reactor Pressure Vessel flooding was completed on May 5, 1989.
The Station is currently pursuing the installation of containment water level indication. The modification request was reviewed in May, 1989 by Station Management and is currently undergoing Engineering review.
CONCERN:
(3)c.
The licensee incorrectiv calculated the crimary containment oressure -
limit and oressure sunoression oressure limit because a HQB: conservative assu'otion for the_ pressure basis of the m
CAltitlBtlQnLyA1_1tt1111ed.
In addition. the_UrtD$ee had based all the calculations uoon a orevious revision of the EPGs.
Resoonse:
The Primary Containment Pressure Limit and the Pressure Suppression Pressure Limit have been recalculated to reflect more conservative values for the April 1989 revision of the QGAs. The calculations were performed using Revision 3 calculations due to the absence of revision 4's calculations.
Sla.tu:
The Primary Containment Pressure Limit and the Pressure Suppression Pressure Limit were recalculated. The revised calcul'ations were reviewed and approved on October 21, 1988. The revised values have i
been incorporated into the April, 1989 revision of the QGAs.
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calculations were performed in accordance with the methodology contained in EPG Revision 3 since EPG Revision 45 did not include any additional guidance to perform the calculations.
This item is comolete.
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CQEERN:
(3)d.
The licejlige_.did not revise the calculations of the PSIG follow _ Lng Plant modificej;1ons which affected the bai.is of the_ calculations _,.
EQr_JtLitmplit _the_cAlGl411QnLfor_the_cQld_And. bot shu_tdown baron HightLMr.t not rte 131d.fol]pwingEdLf_lcatloattg_the_ Standby
.Liauld Control (SLC) systenj and the calculation for the flow Itagaglio0_Eter level (ESHL) was not revised followino a modification in the nuclear fuel desion.
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Resoonse:
Calculations for the SLC shutdown weights were revised to reflect the modificattor, to the SLC system and the FSHL limit was revised to reflect the modification of the nuclear fuel design. These were revised in accordance with QAP 1100-13.
This procedure also describes on page 1, the method in place to review the impact of plant modifications on QGA procedures.
Status:
Calculations for the SLC cold and hot shutdown boron weights and flow stagnation water level were revised on October 21, 1988. The new values have been incorporated into the emergency procedures.
Administrative Procedure QAP 1100-13, Control.of Emergency Operating Procedures, has been revised to assure that plant modifications shall be reviewed for impact on the QGAs.
The revision to QAP 1100-13 was implemented in August, 1988.
This item is comolete.
CONCERM:
(3)e.
Jhe licentee deviated from the loalc of the BHROG EPGs durina their orocess of incorocratina PSTGs into flowchart EOPs.
Specifically.
the loatt of the BHROG EPGs with resoect to the reautrements for a reactor sgram: the rJtautrements fot_tontrol of RPV inJg.c. tion: and the i
methodology for orimary containment ventina were incorocrated into the EOPs incorrectiv.
Response
QGA 100-1, 500-7-2 and 00P 1600-13 have been upgraded for the April 10, 1989, procedure implementation. To prevent recurrence of this problem, deviations from the EPG require technical justification and committee review prior to approval as described in QAP 1100-13, (page 5).
Functional accuracy of these deviations are also checked during the verification and validation process.
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0280T:14
1titus:
The deviation from the BHROG EPGs logic for the requirements for a reactor scram contained in QGA 100-1, RPV Level Control; control cf RPV injection. contained in QGA 500-7-2, ATHS Level Control /
Depressurization; and methodolgy for primary containment venting contained in QOP 1600-13, Post Accident Venting, have been corrected.
The revisions to the QGAs and QOP were implemented in April, 1989 and March, pitT, respectively.
The Administrative Procedure, QAP 1100-13, Control of Emergency Operatting Procedures, has been revised to include controls to prevent recurrence of this concern. As part of the verification and validation process, a comparison of the EPG and PSTG as well as the PSTG and Flowcharts re?)lrements is performed to identify any deviations. Any identified deviation requires either correction or a technical justification.
This process will ensure that the flow-charts represent EPG methodology. QAP 1100-13 has been implemented in August, 1988. The verification and validation process for the April, 1988 revision of the QGA included this comparison.
This item is'comnlete.
CONCERN:
IRIbnial_ justification for significant chanaes to the EPCs was not provided.
For examole:
(3)f.1. Ihe licenitL_d tnQi.. maintain the EOP curves 1[Lthe PSTG.
As a result. the justification for eubsecuent chanoes to the curves was not available.
Resoonse:
QAP 1100-13, page 3, directs the preparation of technical justifications for any changes made to the QGA curves.
The curves are being maintained with the PSTG and this requirement will be incorporated into a revision of QAP 1100-13 by May 3, 1989.
Status:
The current revision of the PSTG includes the QGA curves. The QGAs and PSTG'are currently maintained in a controlled file.
l A procedure change request to Administrative Procedure QAP 1100-13.
Control of Emergency Operating Procedures, has been issued to i
include *.e requirement of incorporating the QGA curves in the PSTG.
The revision to the Administrative Procedure will be implemented by September 30, 1989.
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CONCERN:
(3)f.2. -Ibe licensee incor.gorated additional steos into the E0Ps whith_werf not in the PSTGs.
As a result. these chanaes represented deviations l-from the EPG loaic which were not iustified.
B11DDate:
Deviations from the EPG require technical justification and committee review prior to approval as described in QAP 1100-13, page 5.
Changes to the procedure are incorporated by first reviewing the PSTG for. required changes as described in QAP 1100-13, page 3.
Status:
The' administrative controls detailed in QAP 1100-13 require that a comparison of EPG to PSTG and PSTG to Flowcharts be performed as part of the verification and validation process.
This control will L
ensure that any deviation will be identified, and corrected or L
justified These controls were incorporated into the August, 1988 l
revisionboQAP 1100-13 and the controls were implemented during the l
review and app'roval of the April, 1989 revision to the QGAs.
l This item is comolete.
I CONCERN:
(3)f.3. The._ licensee deleted ano11 cable iniection subsystems from RBOG EPG Contingency Procedure No. I without techn,.tcal justification.
Et1RQait:
The Fire System has been added to the list of injection systems for the April 1989 revision of the QGAs.
Status:
The fire water system has been added to the aval:Lble options for injection systems in April, 1989 revision to the QGAs.
1 To ensure that the flowcharts.are consistent with the EPG requirements, a comparison of EPG to PSTG and PSTG to Flowcharts is required to ensure deviations are corrected or justified.
This control was linplemented in the August,1988 revision to QAP '100-13, Control of Emergency Operating Procedures.
This item is complete.
l CONCERN:
(3)f.4. Ihe licensee did not orovide monitorina for secondary contatomtat radiation levels in all areas reauirina Dersonnel access durt.D2_AD Accident.
0280T:16 1
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I 211ponse:
l Technical justification will be provided for areas which are not j
equipped with radiation monitoring by April 10, 1989.
1 Tetatus:
The technical justification for the deviation from the EPGs, i.e.,
areas which are not equipped with radiation monitors, was developed
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in April, 1989. The justification discusses that radiation monitoring is available for a representative sample of the plant areas.
Personnel access during accident conditions will be controlled in accordance with the Station Emergency Plan (GSEP) which requires that a group be established in the Operational Support Center to evaluate the radiation hazards and assure that teams are properly equipped to perform local tasks when dispatched.
This item is comolete.
CONCERN:
The human factors enoineerino outdance of the E0Ps was deficient in thilt *
(4)a.
lhe PSHG orovided inadeouate outdance concernino the imolem_entatioD of_the PSTG into the EOP flo_wthart forJnat and the PSHG was not ytilized for the development of the E0Ps.
Besconse:
The PSHG was revised and now includes directions for the implementa-tion of the PSTG into flowchart format. This guidance is being used to develop the April 1989 revision of the QGAs.
Statui:
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The PSHG was revised in November, 1988 and includes direction for l
the conversion of the PSTG requirements into a flowchart format.
l The April, 1989 revision to the QGAs was developed in accordance with the guidance contained in the November, 1988 revision to the l
PSHG.
This item is rpmn111g.
GXG BH:
(Ob.
Jhe inspection team ident.ified numeroys examoles of ID6410 Mitt jmp]pmeE1JLtiOD of the PSHG bec8use tt)e licenige had not effectively implemented a verification and validation procram.
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Resoonse:
The verification and validation process is being used, in accordance with QAP 1100-13, to verify compliance with the PSHG.
Status:
The PSNG was revised in November, 1988.
The April, 1988 revision of the QGAs was developed in accordance with the revised PSNG.
In addition, a verification and validation program was developed and incorporated into QAP 1100-13, Control of Emergency Operating Procedures.
The process includes simulation of the procedures to ensure usability by the Operators.
Finally, prior to revising a QGA, a review of the PSHG is required in order to identify if any PSWG revisions are needed.
This requirement is included in the QAP 1100-13 which was implemented in August, 1988.
This item is complete.
CONCERN:
The orocedural adecuacy of the EOPs was deficient in that:
(5)a.
Jhe licensee did not revise the ongrational orocedure for containmtat igrav control and the calculational basis of the EOPs after the sorav flow limits were revised by the vendor.
Response
The operational procedure and calculational basis.for the containment spray control are being revised to reflect the vendor information.
These revisions will be complete by April 10, 1989.
Status:
Operating Procedure QOP 1000-8, Post Accident Containment Spray, has been revised to reflect the vendor revised flow limits, i.e.,
spraying the drywell with one pump only.
The procedure was issued in April, 1989.
The calculations to support the QGAs were approved on October 21, 1988.
This item is comolete.
CONCERN: Ihe licensee did not orovide adeauate orocedures for complex ooerator Actions necessary for the accomplishment of the EPGs.
For examole:
(5)b.1. Erottdure.did not orovide for the alternate control rod insertion technioue of hydraulic control rod ventino.
0280T:18
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Response
A procedure is being developed to accomplish alternate control rod
' insertion via venting of the control rod drive hydraulic control unit.
This procedure will be developed by April 10, 1987.
Status:
Auxiliary Operating Procedure, QOP 300-24, Insertion of Control Rods by Venting the Control Rod Drive Over-piston Area, was developed to provide direction for alternate control rod insertion technique of hydraulic control rod venting.
QOP 300-24 was issued in February, 1989.
In addition, the April, 1989 revision to QGA 100-3, Reactor Power Control, directs the operator to the auxiliary operating procedure for implementation.
This item is comniete.
CONCERN:
(5)b.2. Several orocedures lacked soecific information necessary for the correct performance of the operator tasks.
Resoonse:
l The verification and validation process described in QAP 1100-13, page 4, is being used to identify procedural weakness and prevent this situation from occurring in the future.
Status:
Thirty-seven (37) auxiliary procedures are referenced in the April, i
1989 revision of the QGAs.
Prior to implementation of the current 1-revision to the QGAs, the auxiliary procedures were subject to walk-down by Operating personnel to identify any weaknesses in the I
auxiliary procedures. The auxiliary procedures were revised to resolve the walkdown comments.
The auxiliary procedure revisions were completed prior to the implementation of the current revision to the QGAs on April 10, 1989.
l The verification and validation process contained in QAP 1100-13 requires that procedure performance is verified to assure that the revision can be implemented.
This requirement is contained in the August, 1988 revision to the QAP 1100-13.
These item are comolete.
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CONCERN:
(5)c.
Jhe licenstg_lmRifEtated an ineffective methodoloav for alargilng_and monitorina_.the EOP entry conditiqns which allowed an entry conditio3 to be missed.
Et.ipQnit:
The alarm setpoints.for area high temperature have been changed to coincide with the QGA entry conditions.
Status:
As indicated in the "Responst", the alarm setpoint for high area temperature has been changed to be consistent with the QGA entry condition.
.This item is comolete.
CONCERN:
(5)d.
The 11ctalet_jaalemented an ineffective method to_ ensure that special lools nectitary for the performance of the EOPs and operator aids posted on olant instrumentation and control canels remained available and were accurate and un-to-date.
Response
A surveillance procedure is being developed to control and maintain special tools and operator aids that are required for QGA use.
This will be developed by April 10, 1989.
Status:
A surveillance procedure, QOS 010-6, QGA Operator Aid and Tool Semi-annual Inventory, has been developed to assure that special tools and operator aids posted on plant instrumentation and control panels necessary for the implementation of the E0Ps remain available and accurate. This procedure was reviewed and approved in August, 1989.
The first bi-annual inventory has been scheduled for September, 1989.
This item is comolg.tg.
CQEIRH:
Several significant deficiencies were noted durino the EOP accident icenarios.
These included:
0280T:20
t (6)a.
Jhe_lttente.e_d_13Lnot maintain an adequa.te_oyerview of the control room activities and as a result. did not implement all the requited AC.tlons of the EOPs in the time reautred_bgray3e the coerators had diffity]ty_)Attroretino and [tnolementino lhe E0Ps.
The insge.ttlon leJm cortCluded thtt_1tilLdsficiency was the result _of overiv complex p.rstedures. ooor readability of the EOPs. and inadeouate operator training Resoonse:
Following the QGA audit, all operating crews were observed during execution of the QGA procedures at the simulator facility.
The crews were observed by the Assistant Superintendent of Operating, the Production Training Center and the Regional NRC Inspectors.
This overview of E0P execution demonstrated acceptable E0P usage and adequate E0P training. Possible problems with complex procedures and poor readability are being guarded against due to the verification i
and validation process being used for the April 1989 revision.
Status:
The verification and validation process requires that procedure revisions withstand a walkdown by licensed personnel as well as a table top exercise to assure that the procedure revision is usable by the Operating crews. These requirements are contained in the August, 1988 revision of QAP 1100-13.
The verification and validation process was implemented for the April, 1989 revision to the QGAs.
In addition, the Assistant Superintendent of Operations observed all i
crew simulator evaluations. Operator proficiency in QGA utilization L
is verified during this observation, thereby, assuring adequate training has been achieved.
1989 crew evaluations were completed on i
May 26, 1989.
]
These items are comolete.
CONCEB.N:
}
(6)b.
The licensee did not imolement the directed actions of the E0Ps with i
resoect to low oressure ventino of the crimary containment and the gmeroency deoressurization of the RPV due to misinterpretation of the EOPs and a lack of confidence of the licensed operators in the effectiveness of the crimary containment ventino orocedure.
The I
losoection team concluded that these difficulties were the result of irladtouate enoineerino evaluation and ooerator trainino on the basis of the crimary containment vent oath and the emeroency deoressurization orocedure.
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4 Resoonse:
The containment venting procedure has been revised to account for the failure of the SBGT train that is in service during high pressure containment venting. A technical evaluation has been conducted which verified the ability of the containment vent valves to close at high containment pressures.
The firm that conducted this evaluation has been contacted to also address the ability of these valves to open under these conditions. Classroom training on containment venting will be complete by April 10, 1989.
Status:
The Post-Accident Venting Procedure, QOP 1600-13, was subject to walkdown by operators during the verification and validation process.
Comments from this walkdown were used to formulate procedure changes to ensure that the procedure is technically correct and incorporates human factor criteria to enhance operator.use of the procedure.
The enhancement included placing notes and cautions in the procedure that describe adverse effects, e.g., SBGT failure and high does rates of venting. so that the operators are aware of consequences that should be considered.
Following the procedure revision, the station license holders were trained on the procedure and the procedure was implemented on April 10, 1989.
Confidence in the ability of the containment vent valves to function properly is supported by an engineering evaluation that was performed by NUTECH.
The evaluation analyzed the 18", 6", and 4" butterfly valves associated with_the containment vent and purge system and evaluated how the valves would pe. form under loads imposed by a postulated design basis LOCA event. The evaluation utilized conservative analytical methodologies and worst case assumptions.
This item is comolete.
CONCERN:
(7).
The licensee did not orovide an effective method for oreventina grimary containment oressure increases because an adequait gnaineerina evaluation of the vent oath was not oerformed and orovisions were not orovided for ventino the crimary containment under all accident scenario.i.
Resoonse:
A technical evaluation has been conducted which verified the ability of the containment vent valves to close at high containment pressures.
The firm that c,onducted this evaluation has been contacted to also address the ability of these valves to open under these conditions. Manual operation of containment vent valves is being researched by the station Operations Department and the results of this research will be used to address this issue. Development of written guidance is expected by August 1, 1989.
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ItAlits:
The description of the engineering evaluation conducted for the.
containment vent and purge valves is included in the STATUS' for.
CONCERN (6)b.
To address the provisions for venting under_all accident scenarios, consideration was given to installing a modification for a backup air supply to allow local operation of the-valves. The valves are presently equipped with air accumulators;to l.
allow operation during conditions where the instrument air system is degraded.
The solenoids which control the air supply are fed from Reactor Protection System buses, which receive power via a MG Set,.
which is powered from the Emergency Diesel Generators during a loss of power conditions. It has been concluded that the types of accidents which would require high pressure venting would make local manual operation impossible due to the radiation dose rate. Also, radioactive gases would be released into the reactor building if the SBGT fails due to 1he high pressure venting.
Based on.the reliability of the system and the potential risks associated with local manual operation, it was determined that installation of a modification to provide local manual operation was inappropriate.
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