View source for 3F0888-08, Responds to Follwoup Items Noted in Insp Rept 50-302/88-09. Corrective Actions:Permanent Book Marks Placed in Control Room Emergency Operating Procedures (Eops) & Number of EOP Sets Increased to Three

{{Adams
| number = ML20207F112
| issue date = 08/11/1988
| title = Responds to Follwoup Items Noted in Insp Rept 50-302/88-09. Corrective Actions:Permanent Book Marks Placed in Control Room Emergency Operating Procedures (Eops) & Number of EOP Sets Increased to Three
| author name = Widell R
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ADMINISTRATION &amp; RESOURCES MANAGEMENT (ARM)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F0888-08, 3F888-8, NUDOCS 8808180219
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 38
}}

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wl ee?ut gQjfo Florida Power C 0 f4 P O R A T I O N August 11, 1988 3F0888-08 U. S. Nuclear Regulatory Comission Attention: Document Control Desk Washington, D. C.        20555

==Subject:==
Crystal River Unit 3 Ibcket No. 50-302 Operatirq License DPR-72 Inspection Report 88-09

==Dear Sir:==

Attached is Florida Power Corporation's (FPC) status and disposition of the items identified in the subject report. It should be noted that no violations or deviations were cited by the Inspeccion Team. 'Ihe response contains detailed action, taken or planned, on the nine (9) Inspector Follow-up Items (IFIs).
As background, FPC would like to provide the following information.                            In January of 1988, FPC ccmpleted two major tasks:                          the Control Board Design Review Modifications,             and the implementataon of revised Emergency Operating Procedures (DDPs) based on a Human Factors Writer's Guide. As a result of these two task ccepletions, FPC expected some "fine tuning" would be required in both the E0Ps and the Main Control Board Iabeling.
Upon the Inspection 'Ibam's arrival in March 1988, FEC furnished the Team with a list of discreparx:les that had been internally identiried but not deermd to require immediate correction.                             'Ihis list corresporded to approximately one-half of the Inspection Report items. Many of these items had corm ctive action initiated prior to the Team's visit.
                     'Ihe Inspectors corriucting this inspection wre bc,th knowledgeable arxl thorough. As a result of their inspection, they tound items similar to those that we had fcund. Although the total number of items appear large, we feel the quality of the procedures reviewcd was good arrl the procedures adequate to handle abnormal events. A majority of the cccments rade were enhancements to mduce reliance on operator training and experience. It is our understartling the Inspection 'Ibam had drawn similar conclusions and thus treated che items fcund as IFIs.
8808180219 880811 PDR G
ADOCK 05000'JO2 PNV 7 }[
Post Office Box 219
* Crystal River, Florida 32629
* Telephone (904) 795 3802             I I A Florida Progress Company

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t L. S. Nuclear Regulatory h inaion 3F0888 August 11, 1988 Page 2 It is hoped that FIC's timely resolution to the identified items will be viewed as both proactive and responsive and not indicative of major problems. FPC is ccanitted to providing our Operations personnel the best EOPs possible and looks forward to further discussions at our meeting scheduled for August 24, 1988.
Should you have any quwtions, please contact this office.
V     truly yours, I               T t> ) '.
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Rolf  2. Widell Direc mr, Nuclear Operations Site St4 port WIR: mag Att.
xc:       Regional Administrator, Region II Senior Resident Inspector l
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FIfRIDA F0WER CCRKEATIN RESPNSE DEPECTIN REKEP 88-09 IFI 88-09-01 Placekeeping deficiencies were identified duriq control room walk-throughs of the E0Ps. Operators typically use loose sheets of paper or their fingers as I           placekeeping aids. Additionally        when questioned on the problem of l           placekeepirg, the cperators indicated that they would remove the individual l           procedures form the noteNoks and place them on the desk. This is undesirable, particularly when one considers that the E0Ps are not stapled ard can easily becczne intennixed, separated, or lost. Tais is an indication of a placekeeping deficiency. The     licensee has carnitted      to  resolve these placekceping deficiencies.
FIORIIR F0WER WRPORATIN (FPC) ACTIN FPC has placed pennanent book marks in the Control Rocan Dnergency Operating Procedure (EOPs) . FPC has also increased the number of E0P sets in the Control Rocra to three.
IFI 88-09-02 Currently, the licensee has no dmument in place to cross reference operator action points for plant parameters to where they cocur in proccdures.                             The licensee has ccanitted to inplanent an E0P cross reference docunent.
FFC ACTIN FPC agrees an EOP cross reference document would be beneficial and ccanmits to inplement the E0P cross reference by June 30, 1989.
IFI 88-09-03 Correction of technical discrepancies contained in DDPs as outlined in Apperdix B of Inspected Report 88-09.
FM ACPIN Reference Enclosure 1 for line-for-line item ccrnments. The procedural changes frcra Enclosure 1 will be implemented by October 31, 1988, unless otherwise stated. This provides time for verification on the simulator.
IFI 88-09-04 Correction of human factors discrepancies contained in E0Ps as outlined in Appendix C of Inspection Report 88-16.
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1 FPC ACTIN Reference Enclosure 2 for line-for-line item ccanents. The procedural changes frcan Enclosure 2 will be inplemented by October 31, 1988, unless otherwise stated.
l IFI 88-09-05 Correction of labeling discrepancies between EDPs and panel indications as outlined in Appendix D of Inspection Report 88-09.
FM ACTICH FPC agrees that ccmponents should be uniquely labeled and delineation made in the E0Ps should be such to avoid any ambiguity.          For this reason Unique Equipnent Identification Numbers (Tag Numbers) are assigned to all equipnent.
These Tag Numbers used in the E0Ps should agree with the Equipent Iabeling used in the plant. To ensure this goal is met FPC utilized Quality Program pe.h to perform a ccanparison of all EOPs against in-plant equipnent labeling.
The ncanen:lature discrepancy performed by the inspection team in many cases ccmpared the short furx:tional description used in the E0Ps against the control board labeling. A review of these discrepancies was performed item by item and the response is detailed in Enclosure 3.
IFI 88-09-06 Li nsee needs to re-perform EDP table top review and procciuru walk-throughs to upgrade the V&V program.
FPC AC_Mtf FN's Quality Pr q ans Department has performed a table top review arxl procedure walk-through for all E0Ps.       This provided personnel, worldng for different management and not intinately familiar with the EDP's,             the opportunity to identify inconsistencies between equipnent label designation and the nctnenclature within the procedures.
IFI 88-09-07 Li nsee will review SOTA training and upgrade if necessary.
F M AcrION The training of all ScrAs has been reviewed, by the Nuclear Operations Training Department an:1 the Nuclear Safety Supervisor, and found to be adequate. In order to respond to the specific concerns dia, ism in the Inspection Report, all SOTAs were given a walk-through, on the use of VP-540, Runback Verification Procedure, ard VP-580, Plant Safety Verification Procedure, by a qualified Senior Reactor Operator. These walk-throughs were completed satisfactorily and documented. The SOTA Requalificatico program provides further assurance that the level of training of all SOIAs is adequate.       As of July 29, 1988, each qualified ScrA has spent 30 hours on the B&W sinnlator in Lynchburg, Virginia.
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Each qualified SOIA also will spend or has spent 120 hours in classrecen requalification training during the periods of May 16 through June 3 or August 1 through August 19, 1988.         Su-ful cxxpletion of these requalification I         prograre will provide. conclusive evidence of the adequacy of the training of all SorAs.
l m 88-09-os Licensee needs to formalize the program for ongoing evaluation of E0Ps.
FPC RESPCNSE AI-402, Writers Guide for Abnormal, Verification and Emergency Operating PIr.mdure does provide an on-going E0P evaluation process.             'Ihis, in conjunction with the cperator annual E0P review and the biannual sinulator reviews, is FPC's formal on-going E0P evaluation.
m 88-09-09 Re-validation of the E0Ps when the plant specific sinulator is operational.
FFC RESPOEE FPC will re-evaluate its E0Ps on its plant specific sinulator within one year frun the date the sinulator becaes fully operational.
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1 APPENDIX B TECHNI;AL CCt@ENIS
          'Ihis appendix contains technical ocenents, observations, and suggestions for EOP inprovenents made by the NRC inspectors. Unless specifically stated, these ocenents are not regulatory requirements. 'Ihe licensee agreed to evaluate the cxmnents and take appropriate action. 'Ibese itans will be reviewed during a future NRC inspection.
: 1. AP-360, Ioss of Decay Heat Removal, Revision 1 NRC Conoem
: a. Step 3.2; containment integrity shculd be established under any condition that involves the potential for a significant release of radioactive material fran the fuel and not just for the leak into the RB.
FPC Actions
: a.   'Ihis procedure has been revised to incorporate the rm ->1=rded change.
NRC Concern
: b. Step 3.3; 'Ihe licensee should consider isolation of the RCS, if a leak is determined to exist, as the initial step in leak location thereby preventing a further inventory loss frcxn the RCS.
Connections to the RCS can then be reestablished one at a time, while maintaining inventory and coolig.
FK Actions
: b.   'Ibere is currently no list of RCS isolations in AP-360.         FPC feels that due to the many different RCS conditions that could be encountered during CHR, (eg. Vent, drain or other branch line              i connection status) that RCS isolation can best be acccmplished by the      i operators who are aware of the current tenditions.                         l NRC Concern                                                                     !
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: c. Step 3.4; For entry into this proccdure, the reactor coolant system        I would have to be less than 280*F with pressure less than 230 psig.         j
                     'Ihis kulld provide for little OISG cooling to be available. 'Ihe most     ;
likely coolig method would be via the spent fuel cooling system as         l M w' M in step 3.5.         'Iherefore, the step 3.4 method of cooldown,   !
which would apparaatly only apply after attenpts to establish other methods for cooldown have failed and a plant heatup is occurring, should be placed later in the procedure.
FK Ac' .,gg l
l               c.   'Ihis procedure has been revised to incorporate the recomenled l                    ChaMe t
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1 NRC Concern                                                                   j
: d. Step 3.4; RCPs will only be available over a narrow range of            )
potential application of procedure AP-360. Under scme a:)nditions, it   !
is not W for the RCS to be filled and vented for the OFSGs to           l be useful. Under two phase conditions, the OPSGs can provide a      )
valuable tenporary cooling function without feedwater being available   i due to the heat capacity of the cx>ntained inventory.
FPC Actions                                                                   j
: d. FPC agrees with the reccanendation to remove the requirment to have the RCS vented. However, we feel the RCS should at least be filled to ensure that Natural Circulation can be establishe:1. Step 3.4 of AP-360 will be revised accordingly.            FPC also agrees that technically under two phase conditions, the OISGs can provide a tenporary cooling function without feedwater being available if adequate OPSG inventory exists.       FPC feels the key here is the tenporary nature of such heat removal and the procedure appropriately   1 directs the operator to pursue obtaining a reliable cooling method where possible to prevent an uncontrolled heatup.
NRC Concern
: e. Step 3.7; 'Iha step directs the closure of reactor building sunp valves DIV-42 < rd DN-43. Considering the conditions for entry into this pro dure, there appears to be no reason why these valves were open (neither the procedure nor plant conditions require it).
                'Iherefore this step appears to be unne ssary.
                'Ihis step also directs IPI cooling by injecting from the bur into the RCS. As presently directed by the procedure, it appears that the LPI will became deadheaded if there is no outlet frm the RG.
                'Iherefore the procedure should direct operators to provide a discharge path frm the RCS if mary (e.g. , manually openiry the ICRV to assure cooling water flow through the RCS) .
FFC Actions
: e. FIC agrees that the probability of these two valves being open at the beginning of the transient is small.        'Ibere are hcwver certain conditions such as maintenance activities that could cocur during an cutage that may nmitate these valves being open.          'Ib avoid any possibility of inadvertently drainirg the Ber to the RB Sump FEC feels it is m oly to ensure these valves are closed.         FEC agrees that a discharge flow path will be required and the procedure will be revised to use the PORV accordingly.
NRC Cong m)
: f. Step 3.9; 'Ihis caution applies to IPI cooling with the RB sunp in use. It is not applicable to water frce the BBr.

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      .                                                                                                                            i FPC Actions
: f.      The caution on page 11 of AP-360 applies to Step 3.10 not 3.9. The                               .j caution is correct for step 3.10. Cautims precede steps to which                                    l they apply.                                                                                       1 NRC Concern
: g.      Step 3.9; The intent of this step is not clear.                              It apparently assumes that DI . is not available fra the IHrr and that HPI is supplying the flooding water via the EMST. If HPI and IMST are not available; there appears to be no source for flooding the RB. By the time this step is entered, it appears to assume that tne IMST is unavailable; therefore, if this is correct, it cannot be a source of water.
FPC Actions
: g.      The following provides the logic naw=ary to explain why FPC desires to keep this acticn within Step 3.9.                    In the early stages of the prrvwtwe the IMST is looked at as a source for DI or HPI cooling.
The requirements on the BHST as a source for these punps precludes                                 ,
its use when level reaches approxinately 2.5 feet. At this level the WI suction would be required to shift to the RB Sunp.                          If the IMST is already drained to as low a level as allowed by Technical Specifications then the BWST level may be too low to allow either starting of the HPI/GI cooling from this source or any long term reliance. The BWST may be used by gravity feed to supplement RB sunp level by itself or in cambination with the other three sourms to provide Wate sunp level for DI suction. FPC therefore views the deletion of the BHST frm an RB Sung flood sc'2rce as a induction in quality of the procedure and disagrees with the r=>-- -rded change. -                              l NRC Concern
: h.      Step 3.10; This step should be preceded by a caution warning operators to be aware of and watch for irdication of MI punp cavitations due to low RB sunp level.
FPC Actions
: h.      This procedure has been revised to incorporate the rhe:rded change.
: 2. AP-380, Engineered Safeguards Actuation, Revision 8 NRC Concern 4                      a.       IRA investigations consistently identify loss of injection capability during transfer to the recirculation mode                        as a significant contributor to core melt probability.                   AP-380 step 3.29 addresses switching of HPI suctions from the IHrr to the ' REP p.mp discharge side. If for scne reason the DHR punp(s) was (wn) not developing head, inmediate MJP punp damage could result. - Because this opnration is critical, the licensee should revise the procedure to hx:lude a

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caution statement prior to step 3.29 to warn the cperators to ensure sufficient reactor building stmp level prior to WR recitu11ation initiation and proper mR operation prior to individually switching HPI suctions. %e same ocenent also holds for EP-240, Inadequate Core cooling, steps 3.5 and 3.6 and any other location in the procedures where the same conditions exist.                             ;
FPC Actig m                                                                 ,
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: a. Se procedure has been revised to provide additional cautions on transferring HPI suction fran ths BWST to the IPI discharge (now Step 3.32). %e procedure has also been revised to ensure adequate RB Simp level prior to transferring IPI suction to RB sunp (now Step 3.34).
NRC Concern
: b. Conflicting instructions should be resolved arri corrected.        For exanple, AP-380 steps 3.39 and 3.14 are similar in that the IORV is    l to be opened, yet 3.14 addresses only the RG pressure limit of 2300    '
psig. Step 3.39 instructs the operator to open the EORV before      l exceeding 2300 psig whereas 3.14 uses a pressure greater than 2300     l psig. VP-580 step 2.1, requires that RCS pressure be greater than or equal to 2300 psig, and uses the FORV or high point vents for pressure control. See also EP-290 step 3.3.
FPC Actions
: b. Se procedure has been revised to utilize the high point vents if the EORV is inoperable. To address what the inspection team has called a conflict the following information is provided:
: 1. Step 3.14 states     "If,  at any time while performing this procedure RG PRESS is >2300 psig 2HEU open the EORV to lower RCS PRESS to = 100 psig above OISG ERESS".
             %is step is the operator action to be taken to maintain RCS pressure 5 2300 psig as a result of repressurization which may occur followirg an ECCS actuation.
: 2. Step 3.39 specifically deals with the establishment of HPI/IORV Coolirq (see Note pruwHng Step 3.38) . %is step has the operator open the PORV to prevent exceedirq 2300 psig.
We wording used in Step 3.14 is only slightly different than that used in Step 3.39.        @is is due to the fact that they are         I acccanplishirq different objectives.      FPC cx>ntends both steps are '
ampatible and no conflict exists.
NRC Concern
: c. Step 3.10; 2e licensee should consider replacing "IE IORV is l_QF open, M close RCV-11" by "If EORV is closed, M close and recpen        l RCV-11". Se negative statement is not ocnsistent with the Writer's Guide.
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l FFC Actions
: c. The procedum has been revised as follows:
             "H the IORV is gg required to be opened 21g2f close RCV-11 POIN block."
NRC Concern                                                                                    ;
: d. Step 3.16; High point vent operation should be addressed if PORV operation is not obtained or does not provide the desimd results.
FPC Actions
: d. Procedure revised.
NRC Concern
: e. Step 3.18; The car: ment regarding preference of RCP-1B should be a note prior to the instruction to start one RCP.
FPC Actions                                                                                    i
: e. Procedure revised.
NRC Conmrn
: f. Steps 3.20 and 3.24; Step 3.14 could have resulted in opening of the pressurizer vent if the IORV is not available. Steps 3.20 and 3.24 should address this possibility.
FPC Actions
: f. Procedure revised.
I NRC Con m                                                                                      I
: g. Step 3.30; 'Ihis step should be performed earlier in the proccdure so                     i that chemistry results will be available prior to the use of the                          1 sunp.                                                                                     !
FPC Actions
: g. Procedure revised.
NRC Cbncem                                                                                     j
: h. Step 3.33; the action taken as a result of step 3.33 should be ccarpleted after the requirements of step 3.34 have been satisfied.
1 FPC Actions                                                                                    '
: h. Procedure reviscd.
NRC Concern
: i. Step 3.34; 'Ibe procedure should ensure that high point vents are closed.
FPC Actions
: 1. Procedum revised.
NRC Conoem
: j. Step 3.35; A step shcx11d be ack3ed to deal with the possibility of insufficient coolirg as a result of actions taken in steps 3.34 and/or 3.35.
ZPC Actions
: j. FPC disagrees with this rew erdation since the vendor supplied guidance (B&W Ibchnical Basis Document, Chapter IV Section B Step 2.A.5.2) states IPI flow of greater than 1000 gpt/ train will remove Decay Heat and once verified to have occurred for > 20 minutes HPI should be secured. The verification of IPI flow rates precludes the-possibility of insufficient cooling anci remedial actions would only acki needless bulk to the procedure.                                    ;
NRC Concern
: k. Step 3.36; A step should be added to deal with containment pmssure increasing following termination of spray.
1 FFC Actiogg
: k. Procedure revised.
i NRC_Conoem                                                                   j 1
: 1. Step 3.37; The direction under this step is unclear in that when the    l SSOD is notified that VP-580 is ccepleted, AP-380 requires a transfer to OF209, Plant Cooldown.      This exit point may be inappropriate in that all the actions required under AP-380 may not have been            ;
ocmpleted.                                                              l 1
FFC Actions
: 1. Procedure revised.                                                      .
1 NRC Concern
: m. Step 3.39; The caution prior to step 3.38 states HPI coolirg must be established prior to any opening of the IORV. Yet step 3.39 requires opening the ICRV prior to exceeding any of several conditions. The conflict should be resolvcd.
EEC Acticts
: m. Procedure revised.
: 3. AP-450, Emergency Feedwater Actuation, Revision 10 NRC Concern
: a. Step 3.20 is based on knowing hot well levels. We wide range hot well level gage in the control rom is out of service. Control rom operators indicated it had been inoperative for "a long time" aM there were no inmediate plans to return it to service. The licensee indicated that readings frun local indicators of hot well levels could be obtained in less than five minutes aM, at this stage of the procedures, this would not be a highly time critical step. Either the defective instrument should be repaired, or the procedure should explicitly indicate that hot well level should be determined locally.
FEC Actions
: a. An engineering evaluation is beirrJ perforTned on CR-3s control board hotwell level to either fix or remave it. We do not feel that requiring the operators to use local level is beneficial.          The procedure gives the proper baM aM the operators can obtain this information from any accurate source.
: 4. AP-513, Ibxic Gas, Revision 4 NRC Ccnoern
: a. Step 2.2; This step requires that the cperator ensure that danpers, including AHD-2 and AHD-99, are closed.       Operators are not sure whether a blue status light will illuminate if both MD-2 aM ARD-99 close gr if only AHD-2 closes. This urderstaMiny is aggravated by the incorrect labeling on the light.
FFC Actions
: a. The procedure has been revised to nore clearly delineato operator actions. Agreement with MCB labelling rxu exists.
NRC Concern
: b. Step 3.9; 7his step directs operation of a potenticmeter, however, there are no instructions on which way to turn the potenticmeter to achieve the desired result. Since the potenticmeter is labeled with numbers, the procedure should provide information (e.g., turning the potenticneter toward 10 will increase flow) that would tell the operators the effect each direction of the potenticneter would have on flow.
FPC Actions
: b. The MCB has been relabeled to provide this reccmnendM information.
: 5. AP-525, Continuous Contml Rod Motion, Revision 0 NRC Ccncern Step 3.8; The procedure reference to technical specification 3.1.1.6 for safety rods and 3.1.3.5 for regulating rods is ira unuct. Safety rods are di===ed under 3.1.3.5 and regulating rods are discusse2 urr%r 3.1.3.6.
FPC Actions This p ocedure has been revised to incorporate the r m erded              i ciarge..
: 6. AP-530, Natural Circulation, Revision 6                                   j NRC Concern Step 3.24; The reference to Enclosure 2 for the natural circulation       ;
cooldown curve is incorrect. The correct curve is Enclosure 1.
FPC Actio.us 1
This procedure has been revised to inwrporate the accrinended             I charge.                                                                   !
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: 7. AP-580, Reactor Trip, Revision 8 NRC Concern
: a. Step 2.3; The operator is instructed to initiate emergency boration by starting CAP-1A or CAP-1B, opening CAV-60, and establishing maxinn letdown. This may provide a slow response. The licensee should consider a more rapid boration if needed, soch as by use of   i HPI frcan the BWSr.
                                                                                     ]
FPC Actions
: a. This procedure has been revised to inwrporate the r - rded           j cinnge.
NRC Concern
: b. Step 2.11; This step instructs the operator to close the block orifice bypass valve. This is incorrect if emergency boration is underway.
FPC Actions
: b. The requirement to mximize letdcAn in Step 2.3 has been deleted.
Therefore there is no longer a conflict in AP-580. If emergency boration is required, it will be performed in EP-140.
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: 8.       AP-660, 'Ibrbine Trip, Revision 4 NRC OcnogID Step 2.3; 'Ihis stop directs closure of the Elvs.                                          Closure of more than one MIV requires a mandatory reactor trip. 'Iherefore this step should direct operators to trip the reactor and refer them to the reactor trip pt -Mire (AP-580) .
FPC Actions FPC has reviewed this h asnt and has revised the procedure.                                                 'Ihe operator is now directed to ENSURE the 'Ihrottle and Governor Valves are closed and IF NCrf then trip the 'Ibrbine locally. We feel under these conditicos that there is adequate time for the operators to locally trip the turbine rather that closing the MIVs and tripping the reactor.
: 9. AP-990, Shutdown frcan outside the Control Room, Psvision 2 1RC (bncern a.
                                      'Ibers   were no calibration stickors on scoe of the instruments on the RSP. If these instruments are not in proper calibration there is a significant possibility for confusing and tr!slaaMg the operator at the RSP. 'Ihe inspection team found no calibraticn stickers on RC-5B-T14-2 or RC-4B-T14 2, and could not find docurentation that these had (3                                  been recently calibrated. 'Ibe resident inspectors will follow up on V                                   this itan.
FPC Actims
: a.                 Although both of these          instruments were properly calibrated, calibration stickers were installed to reduce any ocnfusion to the cperator.
NRC (bncern
                 'o .
                                     'Ibe  pressurizer level instrument on the RSP is not tarperature wi g sated.        In the control roca there are two instruments, one u.mpsated and one ren-ocatpensated.        'Ibe wigsated instrument is I
trod unless the unit is in cold shutdtwn. If the unit is not in cold shutdown this would leak to a significant difference between the
                                     % sated instrument in the shul rean and the non-ocatpensated instrument cn the RSF. There is nothig in the procedures, or in the RSP labeling that warns the operator of this potential difference. A                                 ,
note to this effect should be included in the procedure and a label                                  I aMut to the RSP.
FPC Actims
: b.                 'Ihis proruttre has been revised to irmiporate the rmwended
  /G                                change. A label will be added to the BSP to alert the cperators of V                                 the prtper ccupensation by 8-31-88.
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NRC Concern                                                                    l
: c. Step 3.6; 'Ibe procedure requires isolation of letdown from outside of   I the control rocan to be performed at the RSP.       However, transfer of l control for these valves frcan the main control board to the RSP does not evw,m until step 3.12.         'Ihe procedure should be revised to   i provide cperations personnel the n==Jy information to isolate letdown if they are at the rennte shutdown panel prior to step 3.12.     )
i FPC Actions
: c.    'Ihis procedure has been revised to incorporate the reccanended          !
change.                                                                  l NRC Con In i
: d. Step 3.21; 'Ihe procedure states that if letdown cannot be established   j then decrease make-up flow.      'Ihe details column states this can be  1 acocmplished by minimizing or isolating seal injection.           During '
procedure walk-throughs, cperations personnel indicated they would use MN-31 to acccrplish this action.           'Ibe procedure should be clarified as to the preferred method for decreasing make-up flow.
FFC Actions
: d.    'Ihis procedure has been revised to incorporate the r m ' w nded change.
: 10. EP-140, Emergency Reactivity Control, Revision 4 liRC Concern
: a. Step 3.5; 'Ihis step states "IF RB is occupied, 'HH evacuate RB."
Walk-throughs of the procedure indicated scoe confusion among the operators as to how to determine if the RB Evacuation Alarm should be sounded.     'Ihis should be resolved, and the procedure changed to clearly reflect the required action.
FPC Actions
: a. FPC disagrees with this finding. 'Ibe confusion was not in how to determine if the RB alarm should be sounded, this is done whenever the RB is occupied. 'Ihe confusion was in how to determine if the RB was evv' Tied. Op-417 requires the operators to maintain a log of all people in the RB in redes 1 thrugh 4.         In modes 5 & 6 it can be   ;
asm = 4 that the RB is occupied. No procedure change is required.        l l
NRC Concern                                                                    !
l                                                                                            1 1             b. Step 3.6; 'Ihis step directs the operator to stop all deboration. 'Ihe   j licensee should consider closing all connections to the RCS except       i those connected with boration that is underway. 'Iben the operator can selectively open connections and determine the scurce of the dilution.
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1 FPC Actions
: b. This procedure has been revised to incorporate the r - nded dW98-
: 11. EP-290, Inadequate Core Cooling, Revision 6 NRC Concern
: a. Steps 3.8 and ' .9   Referen s to clad temperature are of no use to the operator and E.hould be renovM.        It is sufficient that the operator be instructed to reference the proper IOC region and react accordingly.
FPC Actions
: a. The reference to clad tenperature has been deleted frcan steps 3.8 ard 3.9 as rav - nded.       The curve used to determine the region of operation of Inadequate Core cooling provides reference to Clad Tecperature. Since operator training includes the effects of clad taperature on Hydrogen fonration it is felt this information reinforces the seriousness of core conditions.
NRC Concern
: b. Step 3.14; Ihe RCP start permissives should be provided here to be consistent with other proc M ures.
FPC Actions
: b. The inclusion of all RCP start permissives is felt only to add unmary bulk to the procedure.
The method used for determinirg that these permissives are met is providM by status lights adjacent to the start switch for the punp.          The start permissives are labelled on an escutcheon plate for each RCP.
NRC Conoem
: c. Step 3.15; The licensee should consider scprclucing this caution on the following facity pages because of the generality of the instruction.
FPC Actions I             c. This procedure has been revised to incorporate the rectaneMed dW90
* l NRC Conoem
: d. Step 3.17; Operators have indicated they do not perform D4-308 and have no need for information frun that procedure.         The licerceo should consider deleti29 this referen in EP-290.
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FPC Actions
: d. The procedure has deleted the requirement to refer to m-308 and has replaced this with direction to notify Chemistry to refer to m-308.
Imc Concern
: e. Step 3.18; Guidance should be provided that the best indication is the one listed last in the step.
FPC Actions
: e. This precedure has been revised to incorporate the Ins-a N change.
: 12. EP-390, Steam Generator 7bbe I.eak, Revision 5 1RC CG K=rn
: a. There are several steps within the procedure whidi require the operators to monitor and maintain parameters based on current plant cranditions. These parameters include subcooling margin, fuel pin ocmpression limits, CfrSG levels and steaming requirements, and emergency cooldown limits. These items have been incitxled within the procedure as encicsures or tables on the facing pages.          Tb be consistent throughout the procedure when a reference to these parameters is made the apprcpriate table or enclosure should be annotated within the step. Exanples of this deficiency can be fcnnd in steps 3.15, 3.18, 3.27.
FPC Actions
: a. This procedure has been revised to incorporate the recamended change.
rac Cencern
: b. Step 3.7; 'Ibe r cedure requires the operator to open one or more HPI valves to maintain pressurizer level.        The proocdure shculd be revised to incit>3e the use of MN-24 first, thus rcducing the possibility of thermal shock.
fTC Actions
: b. This procedure has been revised to incorporate the reccamended            j change.                                                                   l tmC cencern
: c. Step 3.19; The proccdure requires the operator, if RCPs are not           i operating, to maintain RCS pressure above the natural circulation         !
curve and increase cooldown to less than or equal tc 50 degrees per       '
hour. The wording of the cooldcwn requirements appears confusing and should be revised.
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FPC Actions
: c.   'Ihis procedure has been revised to incorporate the r-fried change.
s t_o m u
: d. Step 3.19; 'Ibe procedure requires the operators to refer to AP-530, Natural Circulation, Enclosure 1. To reduce the rumber of procedures the operator would be required to be in at once, a copy of Enclosure 1 fran AP-530 should be ircluded in the procedure.
IEC Actions
: d.   'Ibe present logic established for Cryrital River Emergency Operating Procedures requires the concurrent use of the Natural Cjroulation       <
procedure whenever Reactor Coolant Purtps are lost. When develcping the current set of procedures guidance was developed to determine when information was to be replicated in all appropriate procedures or when agrupriate procedures wo.ald reference the use of acklitional procedures.      'Ihe Natural Circulation condition was deemed best handled by a sepamte procedure that would be invoked on loss of forced cx:ovection.
NRC Concern
: e. Step 3.36; Duriry pro dure walk-throxhs, operations perm nnel were      i unsure as to what the normal steaming requirements for an OISG with both a t&w leak arri steam leak would be. 'Ihe procedure should be revised to include the steaming requirements for an OISG in this        i condition.                                                              j FFC Actions
: e.   'Ihis procedure has been revised to inJorporate the r m .+rded change.
NRC Concern
: f. Step 3.36; 'Ibe procedure states that if a steam leak is identificd in the same OISG that has a tube leak, arri the steam leak is in the reactor building then allow the CISG to steam to the reactor building. A statement should be included in the procedure to inform
.              operators that due to the stam leak, localized tatperature increases cxxtld cat:se instrument errors.
FPC Accions
: f.   'Ihis procedure has been revised to incorporate the r h . tended charrJe.
7
: 13. VP-540, Runbeck Verification Procedure, Revision 1 NRC Omoern
: a. Step 1.3; these details are too general. The first detail, referring' to SIS 3.1.3.1, is essentially repeated'in step 1.4 whi& provides specific and uneful guidance for control red aligruent.             Therefore         '
this detail should be deleted in step 1.3.             The remaining dehils dealing with the STS limit for RCP operation need to be clarified                    j, sucts that the person pwn. awing the verification knows what needs to                  j be verified in ea& of the STS sections listed.              For example, STS 3.3.1.1 addresses the operability of the RPS.            The intent of this step    (i.e.,      whether the verifier should be Weck 1rq all RPS instnments or specific instruments) is not clear.                                      !
E Ith
: a. FPC disagrees with this finding. Step 1.3 asks the user to determine if there are any power level restrictions placed on the plant due to the runback conditions. Step 1.4 is looking at proper control rod                      ;
positions.         Although they refer to the same is, they are after                  )
different results. The action for step 1.3 says to "Verify Rx power is < TS limit for plant conditions".        In the details it refers to TS             ,
This TS has specific power levels that mast be adhered to 3.3.1.1.
under different conditions (e.g.         under 3 RCP operation, the hich              7 flux trip mast be set at 79.9%).
NRC Concer7)
: b. Step 2.2; Ihis step requires referents to STS 3.3.1.1.             The reason for reference to this FIS is not clear.             The step needs to be clarified to specify what should be verified.              The same crzsnent applies to the DE7IAIL section of this step. The verifier is referred to Ocuputer Group 59, however, there is no guidance as to what in ocmputer Group 59 is to be verified.
FPC Actions
: b. FEC disagrees with this finding. TS 3.3.1.1 is the proper TS to refer to if heat balance power minus NI power is > .8%. This is all the 'nformation naariari to the experienced operator to obtain the-desired results. For the ir@ienced operator the detail colten includes cceputer group 59 whicts is a normally displayed ccuputer group and has sufficient informatica naariari to perform t.his calculation. The details also refer to SP-312 which is the prmarkra that performs the calculation and explains how to use TS 3.3.1.1.
The finding appears to be more of a training issue and will be resolved urder IFI 302/88-09-07.
NRC Concem
: c. Step 3.1; This step directs the observation of radiation monitors for trends. This step should direct the observation of the radiation                       !
monitor recorder since trends are not easily determined on a monitor.                  ;
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FPC Actions
: c. This procedure has been revised to incorporate the roccanenied change.
NaC concern
: d. Step 4.2; This step refers to AI-500, Step 2.4 as a means of deterTainity the reporting requirements,         Step 2.4 applies to the h=ntation of a reactor trip or shutdown and therefore does not appear to yply to a plant utnback.
FPC Acticns
: d. This procedura has been revised to incorporate the reocemerded change.
: 14. VP-580, Plant Safety Vorification Procedure, Revision 3 NRC Concern
: a. There appears to be no specific temir stion or exit criteria              i delineatal within the procedure.         The li ensee should revise the procedure to include these items.
TEr_Id:k!De
: a. VP-580 is sqposera tc be a dymmic prccedure with continuous verification    that   plant    conditions   cre   maintained  adequately addressed in four (4) critical safety areas.                As such the verification procedure is not teminated until the EP or AP that invoked it is ccepleted ard the plant control is stable and in accordance with an Cperating Procedure.       Temination of the VP urder  i these ccrditions is therefore a mnagment decision resting with the        '
Shift Supervisor.
NRC Concern
: b. Step 1.'/; The licensee should examine this instruction for accuracy particularly with respect to the inequality sign and operater instructions for SGIR.
Er7 Actions
: b.   'Ihis procedure has been revised        t>  incorp rate the reccrmended ename.
NRC Conmrn 1
: c. Step 2.8; The licensee should consider the following verding for the last itas te be.tter reflect expected response:       NHIN orSG MESS is i
lowered, 'JEN verify Tc, incore TDE5, aM Th lower."
_                                        e

FTC Actions
: c.   'Ihis proceitre has been revissi to incorporate the r h urided dange.
NRC 0:noern
: d. Step 2.11; Recording of P-T data should be more often during transient conditions. (One of the SorAs indicated plottirg should not be initiated until the plant has stabilized - an incorrect decision since the information is most rwv1ari when the plant is in a transient condition.) Ionger term plottin;; should also be considered sirne the information is useful in following plant state during the entire p m a.                                                            '
IEg Actions
: d. FEC disagrees with this finding. Any specified time frame determined for plotting data points would not be meaningful for all postulated scenarios.    'Ibe SOIA, Shift Supervisor as well as the control board operators must be aware of the primary plant Pressure 'remperature status. For transients which result in rapid changes to these parameters continuous monitority is required.          Scne management discretion is required to establish a plotting trcquency. It should be noted that the requirement to ma:nally plot the Pressure-
                  'Iimparature relationship exists only after three (3) independent autcuatic plotting systems failure.
NRC Conmrn
: e. Step 3.5; 'Ihis step appears inconsistent, and is scaethiJg that ordinarily wculd be done by the operating personnel. 'Ibe licensee uhould examine this stop to determine if the SOTA is expected to perform this step.
FFC Actions
: e. FPC agrees. 'Ihis step will be deleted. We feel that this is already m'rvmlished in AP-250 Radiation Monitorirg Actuation ard should rut be performed by our SOIAs.                                               ]
tec Concern
: f. Stop 4.3; 'Ihe hotwell level instrumentation orovided on the main control board zwads in inches ard the IDP references feet.
FPC Actions                                                                    :
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: f.   'Ibe safety grade instrumentation on the Main Control Board reads out     l in inches while local hotwell level reads out in feet.              'Ihe  l
!                 procedure has been revised to include the required level in bcf.h         i units.                                                                    l l
4 NRC Concern
: g. Rage 9; 'Ihis figure should be inproved by showing acceptablo regions and by providing contrast between the plotted inforation and the grid lines.
FPC Actions
: g.  'Ihis pr M im has been revised to              irc.v-c @ rate the reocnended change.
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                                            - 20

APPENDIX C WRITER'S GUIDE AND HUMAN FACIORS DISGEPANCIES The following am short descriptions of discrepancies between the Writer's Guide and EDPs or of discrepancies identified in the IDPs. The licemee agreed to evaluate these h.sts aM take apprcpriate action. These items will be reviewed during a future NRC inspection.
: 1. General Problems NRC Cbncem
: a. A large number of labeling inconsistencies betveen the procedures and control rocan instrunentation and controls were identified. These are listed in Appendix D.
FPC Actions
: a. A detailed response of the discrepancies noted will be provided in the Appendix D response.
NRC Cbnoern
: b. There are only two copies of the IDPs and APs in the cxantrol rocn.
An additional copy could be provided for use when multiple procedures are being performed, for use by the SorA when performing VP's, aM as a back-up for the current copies.
IEC Actions
: b. An additional copy of the EPs, APs and VPs has been assigned to the Control Rocan as r-Med.
NRC Concern
: c. Instructions to perfom the sune actions appear at a nunber of locations within the IDPs. Frequently these instructions are worded   ,
differently. Furthemore, scanetimes the actual steps to be taken are  I inappropriately different.        The  licensee should examine all procedures ard ensure consistency. An exarple of this is given below urder AP-380. Additional exarples may be fouM in AP-580 step 3.3      l ard EP-290 step 2.1.                                                  ;
FPC Actions
: c. During the review of the procedures for response to this audit the    l cx:osistency of adions was reviewed. Several revisions were nMe as    I a result of that review.      The specific ocenents of the audit team i will be addressed below:
AP-380    -
This procedure has been revised to incorporate the i                 Iwv=mded change.
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4 AP-580/EP-290     'Ihe difference between Start Full HPI used in AP-580
                                                                  ~     ~
and Ensure Fbil_HPI in EP-290 is subtle but r           w y. In AP-580, Reactor Trfp, the word Start is utilized because HPI is not expected to be actuated at this point in nost anticipated scenarios.            In EP-290, Inadequate 03re Cooling, plant conditions are anticipated to have degradai fran a condition in which HPI has already been actuated, either autenatically or manually.        'Ihe use of Ensure is defined by the Writer's cuide to either verify full HPI or to initiate full HPI.
NRC Concem
: d. IDPs often imppropriately reference other proceddres as information sources without irdicating the specific steps or pages to be referanced. 'Ibe step or page location should be specified whenever practical. Sm exanples are given in AP-380 below.
FPC Actions
: d. Our IDPs give the operator the procedure number and title, ard whenever possible the section nunber of referencol procedure. Where our EDPs reference other E0Ps we try to give the operators actual step numbers. We revied cur EOPs for this type of inadequacy and corrected where applicable.
HBC_Qoncern
: e. Graphs and figures often do not contain grid lines, are scnetimes unclear, and occasionally contain extraneous information not needed by the operatcr.       'Ibese difficulties should be resolved ard the procedures corrected.       Exanples are AP-380, page 39, which has no grid lines, EP-290, which has no grid lines ard contains references to clad tarperature thich are of no imediate use to the operator, ard EP-220, Enclosure 1, which contains hardwritten infomation and has no grid lines.
FPC Actions
: e.   'Ihese procedure have been revised to inxrporate the recamended charges on Grid lines. Since operator trainirq incitdes the effects of   clad   terperature     on Hydrogen formation it is        felt this information reinforces the seriousness of core condicions and FPC disagrees with its removal from the Graph. Refer to response on Item 11.a of AFperdix B.
: 2. EP-290, Inadcquate Core Cooling, Revision 6 NRC Con m
: a. Step 3,8; 'Ihe caution located before this step should be clarified.
i FTC ActiGD6                                                                     !
: a.   'Ihis procedure has been revised to incorporate, the rm-me-ded charge.
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: 3. AP-380, Engineered Safegtntds Actuatico, Revision 8 NBC 0:reem
: a. Step 3.15; his step references AP-5'10 but does not indicate what steps intle AP are applicable.          %e specific steps should be included in the reference.
FTC Actiagg
: a. A F380 and AP-530 have been revised to remove the need for simultaneous use. his revision should satisfy the concern raised by the inspection team.                                                               l NRC Concern
: b. Step 3.19; he intent of this action is that AP-530 should be used for subcooled natural circulation and AP-380 should be continued for inadequate snh,mling margin. We wording should reflect the intent.
FTC Actions
: b. This procedure has been revised to incoq orate the recomended change.
NRC Concern
: c. Similar actions are indicated in different steps, but are not consistent with each other. For exanple:
(1) Step 3.3; his step contains instructions to "Start full HPI" ard step 3.38 is to "Establish full HPI".        2e actions of several of the steps are identical, although the wording is different.
(2) Other actions differ.      For exan1ple, "Duure greater than or equal to 2 MJPs and their cool:mg water ptmps are runnirg" versus "Start soccnd MJP and its cooling water punps and Ensure               )
HPI flow is greater than 500 gpn."                                            ;
(3) Step 't.3 is follcwed by 3.6 which has the operator balancirg flce in the four injection lin'es.          Step 3.38 has no                  i corresponding action.                                                         !
l FPC Actions i
: c.    (1) mis procedure has been revised to incorporate the rm        vM change.
I (2) his procedure has been revised to incorporate the rootmended                   ;
charge. We two pronedure steps will read consistent with Step 3.38 havire the ailitional requirement of HPI flow gruter than                i 500gpm. his additional requirment is needed to ensure adequate Nat removal capability for HPI/FORV coolirg (Note Step 3.38 is the guidance for establishing HFi/PORV coolirg.)

t (3) This procedure has been revised to incorporate the     r*>- aded ChaMe NRC Cercern
: d. Step 3.21 refers to EP-390 but does not indicate which steps in the EP are applicable.       The specific steps should be included in the liference.
FPClat.ima
: d. This procedum has been revised to incorporate the rn)- arded change.
: 4. AP-450, Emergency Feedwater Actuation, Revision 10 NRC Conoem
: a. Step 3.8; The sub-step saying "GO 70 AP-330" is located before the sub-step starting HPI. This would prevent HPI fran starting for an unknown period of time.
FPC Actions
: a. This procedure has been revised to incorporate the rey- +rded change.
NRC Conoem
: b. Step 3.12 refers to OP-605 Section 9.0. There is m Section: 9.0 in OP-605. This section is referred to in a number of h steps in this ard other procedures.
FPC Actions                                                                        ,
1
: b. This procedure has been revised to incorporate the ra> - arded                 !
chame. All the mPs have been reviewed and corrected for this type             1 of cross referencim errors.
NRC Concern
: c. Step 3,14 contains two logically separate steps, with some of the details referring to one step and same the other.         This is not         i mnsistent with the Writer's Guide.                                            1 l
FPC Actions                                                                        i i
: c. FPC disagrees with this concern. This step does not contain two               I logically separate steps. The step directs the operator to take certain action if EFW is available and this action is then followed with IF EFW IS N2r available then perfom altermte actions. This is consistent with the Writer's Guide direction on providing directions when expected conditions are not met.
: 5. AP-460, Steam Generator Anation Actuation, Revision 5 NRC Ccmoem
: a. Step 3.6; 1his step contains two separate actions. 7he first action requires response if both emergency feedwater and main feedwater are not available.      The second action requires response if emergercy feedwater is not available. The Writer's Guide states that only one idea should be presented in an action step.         The step should be revised to be consistent with the requirenents of the Writer's Guide.
FPC Actions
: a. FPC disagree with this concern. The logic of this step is for the operator to ensure that a feed source is available to the OTSGs. The subsequent IF_IOT statements provide contirgencies if those feed sources are not available. This is in accordance with the EP/AP Writer's Guide Section 3.4.5.1.
NRC Concern
: b. Throughout the procedures the Once-Ihrougt Steam Generators are referred to as OTSGs.      On the main control rocm boards these are referred to as Steam Generators (SIM GDI) . On the RSP they are referred to as OISGs.
FPC Actions
: b. Ihe use of OTSG and Steam Generator is inter %@le throughout FPC th w nts. B&W is the only vendor in the industry that uses the once Through Steam Generator Design (OISG). The normal reference to this cottponent throughout the FWR industry is Steam Generator which is more generic. FM sees no problem with continued use of both tems interthangeable for the following reasons:
: 1. OTSG is an approved abbreviation for Once Through Steam Generator.
: 2.    'Ihere exists no possibility for operator confusion since CR#3 only has two steam generators, both of the same design. The only requirement to avoid confusion is to designate khich primary loop OTSG is being referrai to. When nq11 red to differentiate this is acocr:plished in the procedure and on the lhin Cbntrol B mrd.
: 3. Steam Generator (SIM GDI) is only slightly less descriptive since its only shortcming is that it doas not provide design type.                                                            l imC Concern
: c. Step 3.19 indicates that MSV-55 is located on DFDP-8A.           It is actually located on D m P-8B.
l F N Actions                                                                 !
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: c. This procedure has been revised to ircorporate the re-ierded           J charge.                                                                !
                                                                                         )
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NRC Corrern                                                                     1
: d. Step 3.27 instructs the cperator to "trickle feed OPSG."               No ,
quantitative definition is given to tell the operator what flos would ecostitute a reasonable "trickle." When queationed about this, the operators inlicated that a flow of less than 100 gp" 9            1*   be reasonable.     'Ibe precedure should be changed to defJE      .    .le" quantitatively.
IE' Acticos
: d.    'Ihis procedure has been revised to incoriorate the recceended change.
: 6. AP-513, 'Ibxic Gas, Revision 4 NRC Concern In stg 3.12 the operator is referred to AH-35-FR to verify the proper flow. ' Itis recorder is labeled ND-32-FIR on the back parel.
FTC Actions
             'Ihis procedure has been revised to incorporate the rax. r+rded change.
: 7. AP-530, Natural Circulation, Revision 6 NRC Cbnoem
: a. Step 3.3t 'Ibe logic statanent Wen icy.uluod as a recurring step on the facing pages was not capitalized and underlined.
FPC Actions
: a.    'Ihis procedure has been revised to incorporate the rec.umaded            ,
change.                                                                  !
NRC Concem
: b. Dulosures 1, 2, ard 3; the graphs do not contain grid lines and contain hardwritten information.
,                                                                                             i FPC Actions                                                                      i l
: b.    'Ihis procedure has been revised to incorporate the ray-1 arded change.
: 8. AP-990, Shutdown frce Outside Control Rocn, Revision 2 NRC Conoem                                                                       1
: a.    'Ihe "B" "REIAYS DIEIK:IZED" light on the RSP is covered with a green lens cap, while the "A" light has no lens cap.       Since plant color conventions call for a red indicator to indicate energization, this       !
discripancy should be corrected.
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                                                                                         )
FPC Actions
: a.   %e RSP lens cap has been corrected per the re-.-.--rdation.
NRC Concern
: b. No steam tables were available in the RSP rocan.
FPC Actions
: b. Steam Tables have been provided in the RSP room.
: 9. AP-1075, (SIC. AP-1076) Violent Weather, Revision 9 NRC Concerns
: a. Si.ep 1 refers the operator to Enclosure 1 for definitions of entry corviitions. mis list is    relatively short and should be included on the entry condition page,
: b. In several steps (e.g., 3.3, 3.4, 3.5, and 3.6) the operator is instructed to perfom an action (such as ensure SF Pool Missile Shields are in place). Se procedure does not indicate who should be contacted an3/or responsible for performing these tasks,
: c. In step 3.4 the procedure instructs the cperator to perform pre-start checks on each EEDG.       It does not inh. him to do this task concurrently, so the Writer's Guide would indicate that the remainder of the procedure would not be cxmpleted until the IEDG pre-#M checks are cxrpleted,       his is clearly in error.       Most of the subsequent steps should be initiated innediately and performed concurrently with ccepletion of the rest of the procedure.          me procedure does not indicate that any of these steps should be performed concurrently, which would extend the time required to ocmplete this precedure.
: d. Enclosure 2    lists members of the violent weather preparation cxmanittee, but not their telephone numbers.   %ese numbers shculd be provided in the enclosure.
FPC Actions FPC agrees with the observations made correrning the Violent Weather procedure. Upon review of the ccaments it has been determined that this procedure does not easily lend itself to the EP/AP format and in fact is
,            a procedure largely performed by nonoperations perra nel. FPC will revise the procedure by 6-30-89,        into the format of the Emergency Plan Procedures which will easily ace-      Mte the myriad of tasks that can and should be performed concurrently.
i APPENDIX D
                                }KHENCIA'IURE DISGEPANCIES IDENTIFIED BY NRC EDP 1NSPECTION TEAM Procedure /
Steo e     Procedure Nanenclature          Label on Eauirmnent         Discosition AP-330/
3.5        WDP-5A and M7f-5B               DW Transfer Punps WTP6A, 6B Procedura Revised AP-330/      SW Surge Tank                   Nuc. Serv. Clg. Water Surge Ocnnent 2 3.3                                        Tk. Isvel AP-360/      IPI Suctions frcan RB Stmp      dip-1A, RB Supp, DIP-1B,    Ocunent 3 3.7, 3.10                                  RB Sunp AP-360/
3.7        LPI Control Valves              DHiE-1B Dis, DHIE-1A Dis    Ccanent 3 AP-360/      IPI Suctions fran IMST          DFIA EHST Suct. , DIP-1B    Ccanent 3 3.7                                        IMST Suct.
AP-360/      LPI Disciurge to RCS            DIP-1A LP Inj. , DIP-1B IP  Ccunent 3 3.7, 3.10                                  Inj.
AP-360/
3.8, 3.11 HPI Suctions frau BWST           BWST to MUP                 Cament 3 AP-360/      LPI Discharges to HPI           DN-1A to MJPS, DN-1B to     Otanent 3 3.11       Suction                        MJPS AP-360/
3.13       CFF Outlets                     CET-1A Outlet Iso.          Comnent 3 AP-380/      MJP suction valves frun 3.3        EMST MN-58                           MN-58 Hi Press. Suct.       Corrected MCB MN-73                          MN-73 EMST to MJP            Ocnnent 3 All HPI Valves MN-23                           MN-23 HP Inj. Iccp A        Ocnnent 3 MN-24                          liN-24 HPI Iccp A            Ocnnent 3 MN-25                           MN-15 HPI Icop B            Ctanent 3 MN-26                           MN-26 HPI locp B            Ctanent 3 AP-380/      A arrl B HPI Channels 3.6        RC1                             HP 1 RC1                    Corrected MCB RC2                             HP 1 RC2                    Corrected MCB etc.                            etc.
AP-380/      RC4                             HP 1 RC4                    Corrected MCB 3.7        RCS                             HP 1 FC3                    Corrected MCB RC6                             HP 1 RC6                    Corrected MCB l
                                                                                        )
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A       Procedure /
Steo #    Prooechire Ncmenclature       Label on Ecuirnant           piscosition s AP-380/      A ard B RBI Channels 3.8       RB1                           RB ISO RB1                   Ocnnent 3 et al., for six references total AP-380/      BSV-3                         IE lER Inlet Iso.            L= sit 5 3.9       BSV-4                         BS HIR Inlet Iso.            C%mnent 5 AP-380/      RCV-11 (not identified)      RCD-1 to RCV-10               Corrected MCB 3.10      RCS-13 PZR Spray Block       lY.T-1 to RCV-10              Corrected MCB MN-38 A Istdown Cooler        Iso, to PGiE-1A              Cumsit 3 Inlet Isolaticn MN-39 B Istdown Cooler       Iso. to MJHE-1B      ,        Ocnnent 3 Inlet Isolatico MN-498 C Istdown Cooler      Iso, to M1HE-1C               Ctanent 3 Inlet Isolation MN-49 Intdown Isolation      High 'Dep Bypass              Ocnnent 6 DN-3 (not identified)
AP-380/      RCV-11 PCRV Block            See 3.10                      Corrected MCB        '
3.14       PORV                         DFDP 4B                       Cwusit 7 RCT-1 Rel b f RCV 10          03rrected MCB
    ^
PZR Vent (not identified)                                  Procedure Reviari RCV-11 KRV Block Valve       See above                     Corrected MCB AP-380/      MJP Reciros.                  MJP's Recirc.                 Cu sit 3 3.17                                                                                       !
MJP Recirt. Valves j
AP-380/      CFV-5                         CET-1A Outlet Iso.            02 ment 3 3.23      DFV-6 (Sic CEV-6)             CFT-1B Cutlet Iso.            Cu sit 3 AP-380/      LPI Sucticn 3.29          DN-34                      DIP-1A 5 6r Suct.             Cumsit 3 DN-35                      DIP-1B Bier Suct.             Cu. sit 3 DIP-1A                        Di Removal Punp A             Cumsit 3 dip-1B                        Di Removal Punp B             Coment 3             l IPI discharge to HPI Sucticos                                                                         ;
1
:                        DN-11                      dip-1A to MJPS                Ccmmnt 3 HDV-12 (Sic DN-12)          DIP-1B to MJPS                CtmTnt 3 HPI Suctions fran 56r NN-58                       Hi Press. Suct.               Cbrrected MCB MN-73                       B 6r to MJP                   Cwusit 3 AP-380/      IPI Suctions fran BUT 3/32         D N-34                      dip-1A B6P Suct.              02nent 3 DN-35                       dip-1B B 6r Suct.             Cumait 3 AW380/       EFW-56                        EFV-56                        Procedure Revised 3.35       EFW-53                        EFV-58                        Procedure Revised EFW-55                        EFV-55                        Procedure Revisad EFW-57                        EEV-57                        Procedure Revised 29 -

1 0-Procedure /
Steo #    Procedure Ncnenclature . Tahal on Eauinnent         Discosition AP-450/
pg. 1     OISG Invel               Stm. Gen. Inl.             Cumaart 3 3.12      FW-39B Startup (bntrol   IW-39B SU W Vlv.           Ocnnent 3 pg. 13    M W Flow                 W to Stan. Gen.            Ocnnent. 3 3.15      EN                       EEV                        Ocnnent 3 3.2       CDE-3 Inlet              Disch. Iso.                Ocnnent 3 3.23      E N Control Valves       EEV Control Valves         Typing Frrer AP-460/
pg. 1     CrTSG Press.             Stm. Gen. A/B Press.       Ocnnent 3 RJ. 8     Snhling Margin           Saturation Margin          Corrected MCB 3.19      M -55, DPDP-8A           M -55, DPDP-8B             Procedure Pavised 3.21      SU Control Valves        Stm. Gen. B SU W Vlv.      Cumant 3 3.23      CTTSG Invel Charg        Stm. Gen.                  Ocnnent 3 3.26      EFI-2 I.evel             EF Tank Invel              Otanent 3 3.29      A SU Block               A SU W Block               OcmTnt 3 B SU Block               B SU FW Block              Ctenent 3 3.30      ASV-5/204                ASV-5 and ASV-204          Procedure Revised EEW Control Valves       EEV-55 through 58          Cbmment 3 AP-513/     Heating A Vcatilation    control Ocmplex HVAC       Procedure Revised 2.1       Control Encl                                                          ,
AP-513/     NID-2                    D2 CC Rel. Air Danper      Procedure Pavised 2.2       N:D-99                   Closed AP-513/
3.9       "CC Dup Override"        Daup Override              Procxdure Revised AP-513/     "AH-193-FC"              Cntrl. Ocrplex Recire. Procedure Revised 3.9                                Duper AP-513/     AH-35-FR                 'Ibp of Recorder:          Ocnnent 9 3.12                               Control Ccmplex Supply Air RB & AB Air Sys.
Bottan of Recorder:
Supply & Exh. Air                            !
Monitoring NI-032-FIR A-Control Ccmplex Air Supply AP-513/
3.9       "CC DEmp Override"       Danper Override            Procedure Revised AP-513/
3.12      AH-35-IR                 ND-32-FIR                  Procedure Revised AP-530/
2.2       65% Invel                50%/30"                    Corrected MCB AP-530/
3.3       HPI Valves               HPIloopA,BHPInj.IcopA      Ctanent 3 Procedure /
Steo #      Procedure Ncanenclat11re Tahal on Eaulnnent        Disoosition AP-530/
3.26        MFW Block                Main W Block              Carnent 3 AP-530/
3.26        IL Block                 Io Inad W Block           Ocune.nt 3 AP-530/
3.26        Startup Cbntrol          SU W VLV                  Ccanent 3 AP-530/
3.26        Cross-Tie                W Disct1. Crosstie        Ocnnent 3 AP-530/
3.26        SU Block                 SU N Block                Ccanent 3 AP-770/
3.4         ES 480V                  480V ES B.ls A,B          Catment 3 AP-770/
3.5         ES-MCC-3AB               ES-MCC-3a2                Walkdown revealcd correct label AP-770/       Seal Injection Control   RC Punp 'Ibtal Seal Inlet Ocnnent 3 3.6         Valve                    Flow AP-770/       Seal Injection Block     RC PP Seal Su; ply        Ocnnent 3         ,
3.6         Valve AP-770/       SW Raw Water Press.      Nuc. Serv. Sea Wtr. Punp  Cartnent 2 3.7                                  Disch. Pressure AP-990/       CED Bkr. A               F
* No. 1                 Corrected MCB      !
3.2         CRD Bkr. B               Foeder No. 2              Corrected MCB      '
3.6         Istdown Isolation Valve  Istdown Clr. Iso.         Ocnnent 3          i 3.8         RCV-11 PORV Block Valve  RCI'1 Block Valve         Cbrrected MCB 3.12        "AB" and "non-safety"    Transfer switcti "AB" and Ocnnent 3 control                  Transfer SW non-safety 3.14        "Voltage Mj"             VP Mjust                  Procedure Revised 3.16        MJP Suction Valves       NST HP Suct, and WST      Corrected MCB      ,
to MJP                                       l AP-990/                                                                             i 3.16        HPI Valves               HP Inj.                   Ctanent 3          I 3.19        MN-53                    MJPP Recirc. 53           Ctanent 3 MN-257                   MJPP PP Recirc.           Ctanent 3 3.23        RCP Seal Return          RCP Bleed Iso.            Cwucut 3 Seal Isolation           RB Bleed off Iso.         Ocnnent 3 EP-390/
3.3 page    MN Block Orifice         MN-51 also MJ-3-MIC no    Ocnnent 3 5 of 35     Bypass                   mention of Block Orifice Bypass s
Procedure /                                                                                l
__ Strio #  P W W W =anclature            Tahal on Eendr= ant        Disposition           .
EF-390/
3.5 page  n=nant same as above          Ocamnent same as above not 02mnant 3             ,
5 of 35                                 labeled Block Orifice Bfpass EP-390/
3.7 page  n =nant same as above         Ctzunant same as above not Otanent 3 7 of 35                                 labeled Block Orifice Bypass EP-390/
3.7 page  MJP Suction Valves            58 - Hi Press. Suct.       Corrected MCB 7 of 35   MN-58, MN-73                  73 - INTP to MJP           Ozanent 3 None/       MN 23 Iabel differs           MN 23 irxlicates HP Inj. Corrected MCB None      frun MN 24, 25, & 26          Icop A other are HPI Imop A-B f
EP-390/
Varicus   Reference to OTSG*            Steam Generator on labels  Cu . eat 3 EP-390/     Per Spray ICEN                RCP-1 SPR Cntr1. RCV-14    Cbrrected MCB 315                                     RCT-1 Relief RCV-10        Corrected MCB EP-390/     65% Invel                     level Select Pushbutton    Cbrrected MCB Various                                 50%/30"                                          ,
EP-390/     E V-55, E V-56 EFP            RCSG - Should have been    Corrected MCB 3.25      Supply                        Deleted                                          ,
FD-390/     Same Cu. sit as Step          Same Carmnent as 3.15      Corrected MCB 3.27      3.15 VP-540/     2 Radiation Monitors          1) No labels on recorders  Corrected MCB         !
3.2                                     2)   Recorder scale in     An ergineering        ,
linear, 0-100, meter  evaluation is face is logarithmic,  beirq conducted        l 0.1-107 @ , no        to correct this        j correlation between   disngsmy               j the two.                                     i
: 3) Monitors labeled as'                           l A-1 PM3 25 (ADV       Ctanent 11             i EV-25)
A-2 PM3 27 B-1 PM3 26 B-2 RM3 28 (AIN MSV-26)
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      *0rSG As on Control Board for L Chan. EFIC Act. Bypass 1
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i Procedure /                                                                        i Steo #     PrMwe N=nclature       I,alal on Fauirment         Disoosition        l l
VP-540/     RCP Seals and Dunpsters  1) RC-19A, m-1(A)          Corrected MCB 3.4                                    RC-19B, FR-1(C)
RC-19A, M-2(B)
RC-19B, PR-2(D)
: 2) No labeling on           Corrected MCB dungster integrators
: 3) Recorder labeled:       Corrected MCB HC Punp Seal Imakage RC-134-FIR (Dunpster Clics)
VP-540/
3.4       RCDP Level              RC Dm. Tnk. Isvel           Cu=. eat 3 VP-540/
3.4       M1r Level               MJ Tank Isvel               Ctenent 3 VP-540/     TG Sunp Isvel           RB Sunp A Isvel             Ctruent 3 2
3.4                               RB Sunp B Isvel             O.sment 3 3.4       Relief Valve Tailpipe   R205 Press. Relief Vlv. Corrected MCB
                 ' Amps .                          RCV-8 out Temp.
R206 Press. Relief Vlv.-9 cut Temp.
R207 Press. Relief Vlv.                       .
RCV-10 out Tenp.
Note: 'Ihis labeling is not in a31.veirent with the oNillter points.
VP-580/
i      3.4       RMIr-1                  RM-L1                       Otm1 ment 12 YP-580/
4.3       EFI-2                   EF 'Ibnk                    Procedure Revised i VP-580/
4.3        EPI-2                  EF 'Ibnk                    Procedure Revised I

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4 CO MENTS
: 1. Procedure revised.
: 2. SW Surge Tank used in the procedure is a shortened version of Nuclear Services Closed Cycle Cooling Water Surge 'Pank.        FPC feels the short concise wording used in the EOP will not result in any operator confusion.
: 3.    'Ihe NRC Inspection Team's Ctmparison of Pro dure Nomenclature vs. Main Control Board Ncanenclature failed to include the Equipnent Identification Number (Tag Nunber) which is the unique identification schme utilized at Florida Ibwer Corporation. 'Ibe namenclature delineated in the report was abbreviated functional descriptions of the equipnent being operated.
Exanples are provided below to demonstrate the scope of the disparity.
AP-360 Step 3.7 INsInxTIa S                            teIAIIs IF BWST is available,           Start LPI cooling by:
AND IPI is available,           1._ Close IPI suctions frtra
             'HIEN start IPI coolirg,             RB sunp AND GO 'IO Step 2.12 in this procedure                 o DN-42       o D N-43 2._ Open LPI suctions frun BUT o DN-34       o DN-35
: 3. Start:
_ DIP-1A or DIP-1B
_ DCP-1A or DCP-1B
_ RWP-3A or RWP-3B Ihe nmenclature provided in the EDP is maant to provide the operator with a corrise description of the task being ao g lished.                  'Ihe Equipnent Identification (Tag Number e.g. , DN-42) provides the unique labelling to prec1tde operator error durirg equipnent manipulation.
As can be seen from the above exanple, Step 1 under "details" the operator is directed to "Close IPI suctions frun RB sunp" followtd innediately by the Equipnent Identification of DN-42 and DN-43.            'Ibe first portion of the instruction provides a functional description of task goal, i.e.      'Ibe IPI punps suction will be isolatal frun the RB sunp. 'Ibe Equipment Tag Nunbers (DN-42 and DN-43) provide the unique identification of equipnent to be operated and preclude operator error. It should be noted that the IPI is the nmenclature used for Decay Heat Removal during an Engineered Safeguards actuation ard as such IPI and Di are interthangeable as the Decay Heat system is a dual function systan.
Since the ncunenclature for the IDPs was developed by Operators for Operators it       i 1s left revisions to the procedures would degrade their quality.                       l

      ,o a
Charging the Main Control Board to corr =spc.wi exactly to prwwhne ncanenclature   r is felt unwarranted for the following reasons.
: 1. The Equipnent Identificat3cn (Tag Number) uniquely describes the equipment and prevents operator confusion.
: 2. The changing of Control Board labelling is Resource intennive due to the following requirunents
: a. All control board labels are hmented by Controlled Drawings that would require updating
: b. The replacement of existing control switch escutcheon plates requires (in many cases) switch renoval which would render equipnent inoperable
: c. Due to switch runwal the at haaq=nt testing requireents to ensure prtper reconnection of switch would require PRC approved test procedures
: d. Main Control Board Switches are located in high density areas which could make renoval and replacanent of switches physically difficult and increase the vulnerability to damage of nearby controls.
Because of the difficulty involved in relabellirg FPC would like to limit that activity to only those situations which would positively benefit opCrdtion. Thost items marked with this ccianent number were deaned as no significance to plant operation.
: 4. Corrected MCB                                                                .
: 5. It appears the Inspectors looked at the mimic for valve position (this mimic only gives valve position and is not where the operator perforns the IDP step referenced) . The control station referenced in the procedure is labelled as described in the procedure.
: 6. It appears that the Inspectors mistook the High TWperature Bypass control switch for MN-49 as the actual control switch.                                1
: 7. DIOP 4B is the power supply to the ICRV. All major valves on the main control board have this infonnation to aid cperator diagnosis of failures.
: 8. This nust be a typographical error since the label on equipment is EEV-55     l through 58 which correctly appears in the Inspector's ccarment on AP-460      I step 3.30.                                                                    I
: 9. In response to this observation two things became obvious. AH-35-FR was a     l typographical error that should have been AH-32-FIR and the procedure is      l being revised accordin;6y.        The Inspectors observation of Iabel cm      '
Equipt.ent lists all labnlling on the recorder, which includes information    ;
on the assignment of t% four (4) pens of a nulti-pen recorder. The            !
oorrect Equipnent Identificaticr. Number AH-32-FIR appears directly below the recorder and is wrat is used by the operator. This tag nurber now agrees with the proced.tro.
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: 10. A walk down of the Main Cbntrol Board on this procedure stg did not yield verification of this finding. 'Ibe MCB was labeled ES-MCC-3AB.
: 11. 'Ihe monitor labeling provides ocklitional information.         For Exanple: A-1 MC-25 (AIN MSV-25) A-1 starxis for the A-1 Steam Line (A CISG), MG-25 is the equipnent tag f, AW denotes Atmospheric Dap Valve, NV-25 is the equipnent tag n.mber of the AW.           'Ihe procedure only provides enou@.
informatics) to ensure the operator goes to the correct location to obtain the data.    'Ihe additional infomation at the location of acquisition is important but is not een to be written in the proceduru.
: 12. A review of plant reference material reveals an inconsistent usage of FMIr-1 arti BM-L1. A review of all EP/AP and ncmenclature on Main Cbntrol Board is being performed by Quality Programs. A review among operators reverled absolutely no confusion would exist in equipt. ant identification.          If Quality Prograns also considers this discrepancy to be a concern the issue will be runddressed.
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