IR 05000293/1988011

Insp Rept 50-293/88-11 on 880314-18.No Violations or Deviations Noted.Major Areas Inspected:Emergency Operating Procedures,Including Comparison of Plant Specific Guidelines & BWR Owners Group Guidelines with Emergency Procedures

ML20154F934
Person / Time
Site:	Pilgrim
Issue date:	05/17/1988
From:	Lange D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154F931	List: ML20154F928 ML20154F934
References
50-293-88-11, NUDOCS 8805240135
Download: ML20154F934 (17)

Text

____ -________

.

-

,

.

U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-293/88-11 Docket No. 50-293 License No. DPR-35 l

Licensee: Boston Edison Corpany ECO Boylston Street Toiifo~n, Massachusetts 02199 Facility Name: Pilgrim Nuclear Power Station Inspection At: Plyrouth, Massachusetts, _

Inspection Conducted: March 14-18, 1988 Inspectors:

W. Kennedy, NRR Team Leader D. Florek, Sr. Operations Engineer, DRS, RI C. Sisco, Operations Engineer, DRS, RI G. Thomas, Nuclear Engineer, NRR R. Gruel, Operator Licensing Examiner, PNL L. Meyers, Research Psycholegist, BCL Approved by:

D.' Lange, Chi gTd / 3

,

,

SKR 5ection

[

B

/7h_

/ de e hspection Sumary: Inspection on March 14-18, 1988 (Report No. 50-293/88-11)

Aress Inspected: Special announced team inspection by 2 regional inspectors, H eadquarters personnel and 2 centractors of the emergency operating pro <:edures (EOPs) and quality assurance measures. This included a cerparison of the Plant Specific Guidelines and BWR Owners Group Energency Procedure Guidelines (EPGs) with the E0Ps; cor.parison of Pilgrim Writer's Guide with the E0Ps; walkthrough of selected E0Ps and Satellite Procedures; E0P evaluation using simulator scenarios; qualifications of E0P responsible individuals, review of ECP training progran; review of E0P verification and validation, and review of E0P Quality Measure PDR 880517 O

ADOCK 05000293 DCD

- _ _ _ _ _ _ _____ - ____ _____ ____________ - _

-

.

"

2-Results: No violations or deviations were identified in the inspection. The inspection concluded that the E0Ps were implerrented in acccrdance with the Revision 4 of the BWR Owners Group EPGs and the plant's Procedures Generation Program; however, 4 unresolved items were identified. One unresolved item involved a sequence of actions in an E0P different from that specified in the EPG (See Section 4). A second unresolved item concerned the inspectors'

inability te evaluate the adequacy of the procedures supporting the E0Ps, called satellite procedures, due to the incerrplete status of the facility walktitrough (See Section 8). The third unresolved item concerned procedures and training associated with containment venting (See Section 4 and 8). The fourth item concerned the lack of continued involvement of QA in the E0P procedures program (See Section 11).

l l

l

_ _ _ _ - _ _ _ _ - _ _ _

.

.. ,

'

l

"

DETAILS Persons Contacted BEco and BEco Contractors

• J. Alexander, Operations Section Manager

• H. Balfour, License Training Section Manager

• F. Barresi, Nuclear Training Development R. Barrett, Operations Department Manager

• R. Bird, Senior Vice President, Nuclear

• C. Brennion, Senior S&SA Engineer

• R. Brune, Human Factors, HPT

• M. Davis, Consultant, Engineer, Ciel Consultants In J. Fulton, Assistant Vice President Engineering

• J. Gerety, Senior S&SA Engineer

• R. Grazio, Field Engineering and Regulatory Affairs Manager

• R. Hamilton, Compliance Division, Manager

• K. Highfill, Station Director B. Horsman, Reactor Operator

• J. Howard, Vice President, Nuclear Engineering and QA

• G. Humes, Reactor Operator C. Leonard, Nuclear Operations Supervisor

• P. Mastrangelo, Chief Operations Engineer J. Mattici, QA Audit Division Manager

• W. Olsen, Nuclear Watch Engineer T. Phipps, Reactor Operator S. Powers, Reactor Operator S. Rogers, Executive Consultant OEI M. Santiago, Senior Training Specialist

! * F. Sche 11inger, Quality Engineering Division Manager

• J. Schilder, Senior Consulting Engineer, OEI R. Swanson, NED Manager K. Taylor, Nuclear Watch Engineer

• T. Trepanier, Senior Operations Engineer

• E. Ziemianski, Nuclear Training Manager U.S. Nuclear Regulatory Commission

• T. Kim, Resident inspector

• D. Mcdonald, Project Manager, NRR

• C. Warren, Senior Resident Inspector

• denotes those present at the exit meeting held on March 18, 1988. The inspectors also contacted licensed operators, engineers, technicians, and other personnel in the course of the inspectio . Inspection Objective / Approach This inspection was performed to determine whethe*, the Pilgrim Emergency Operating Procedures (EOPs) had been prepared in accordance with the current Procedure Generation Package (PGP) and whether the E0Ps and associated

.

>

b i

.

..

-

satellite procedures had been adequately implemented in the plan The specific areas inspected include the following:

- Review of the technical qualifications of E0P developers

-

Comparison of the EPG, PSTG technical basis with the E0Ps

-

Comparison of the writer's guide with the E0Ps

-

Review of the E0P verification and validation

-

Walkthrough of selected procedures in the plant

-

Review of training on the E0Ps

- Exercising Procedures in the simulator

-

Review of the E0P quality assurance measures 3. Qualifications of Individuals Responsible for E0P Development A review was conducted to determine if the E0Ps were developed and reviewed by a multidisepline team of technically qualified individual The licensee development team consisted of BEco personnel from the Engineering an Training organization, augmented with consultants from Operations Engineering, Inc. (0EI), Human Performance Technology (HPT),

and Ciel Consultants, Inc. OIE, as consultants to the BWR Owners Group on the development of the EPGs, provided engineering expertise in the development of the plant specific technical guidelines (PSTGs) and the validation effort. HPT provided Human Factors consulting and CIE assisted in the verification proces A review of the technical background of the team as well as interviews with the team members determined that the members were well qualified and a multidisciplined tea The inspector reviewed the Onsite Review Committee meeting minutes #87-136 and determined that the E0Ps were reviewed in accordance with Technical Specification . Comparison of Plant Specific Technical Guidelines, BWR Owners Group Emergency Guidelines and E0Ps This review included a comparison of the plant-specific technical guidelines (P-STGs) with Revision 4 of BWR Owners Group Energency Procedure Guidelines (EPGs) and a comparison of the E0Ps with the P-STGs. Plant specific values in the E0Ps were also assesse .1 EPG/P-STG Review No safety-significant deviations were found between Revision 4 of the EPGs and the P-STGs. However, since Revision 4 has not been formally reviewed

.- ,

-5-by the NRC, the future Safety Evaluation Report on Revision 4 may indicate the need for licensee action on the P-STGs and the E0P .2 P-STG/EOP Review All E0Ps and those portions of satellite procedures which contained steps based on the P-STGs were compared to the P-ST The following differences were note The licensee's review process had also identified some of these findings as indicate E0P-1: RPV Control Severai action steps within the RPV Level and F sure sections of this procedure had not been linked by appropriate marking to the appropriate note. The licensee stated that this concern had been previously identified and was under revie E0P-2: Failure to Scram A decision step (presented in a box) within the RPY Level section of this procedure regarding reactor power level did not provide direction for the condition of power level not being able to be determine Such direction is provided in an "override" statement which pertains to the next ste The licensee stated that this concern had been previously identified and was under revie Inconsistencies were noted in procedure branchin The licensee stated that those inconsistencies had been identified and were under revie E0P-3: Primary Containment Control Primary containment venting was allowed by procedure after torus pressure exceeds 11 psig but before reaching the Primary Containment Pressure Linit (PCPL; 48 psig) irrespective of resultant reactivity release rate. Procedure 5.4.6 stated that venting, irrespective of resultant reactivity release rate, was appropriate only when the primary containment pressure is above the PCPL (or when drywell or torus hydrogen concentration was above 6%). The licensee stated that they will revise the procedures to remove the inconsistency and instruct operators to vent before_ reaching the PCP PSTG steps PC/H-2.1 (suppression chamber spray), 2.2 (torus or drywell vent), 2.3 (purge), and 2.4 (drpell spray) were reordered in the E0P in the order of: 2. 2, 2. 3, 2.1, 2. The licensee had not previously identified this potential safety-significant deviation. Either analysis of the acceptability of E0P sequence or procedure revision to match the PSTGs is require This is an unresolved item (50-293/88-11-01).

__ _ _ _ _ _ - _ _ _ _ _ _ _- _ _ , _ _ _ _ .____ - -_ _ __ _ _ _ _ _ _

.

1 .

.

.

"

-6-4.3 Satellite Procedures Review 5.3.23: Alternate Rod Insertion  ;

An instruction regarding reset of alternate rod insertion was missing from this procedure. The licensee stated that this omission had been previously noted and is under revie .4.6: Post Accident Containment Control (Venting)

The procedure directed using both a small vent path (1 or 2 inch valves) and a large path (through 8 inch valves) for containrent ,

ventin In some scenarios it may not be necessary to open both sets of valves if after opening only the 2 inch or the 1 inch valves the the containment pressure is controlled appropriately. The licensee agreed to revise the procedure or justify not revising i A caution contained the words "If at all possible, ... shall ...".

This statement did not provide clear direction to the SR The licensee agreed to revise the procedure or justify not revising i Step 2 of Attachment A of this procedure stated that the E0P is applicable when primary containnent pressure reaches 2.5 psig, as opposed to above 2.5 psi The licensee agreed to revise this statemen The caution statement about rupture of the ductwork with venting did not include notification of health Physic The licensee agreed to rovise the procedure or justify not revising i Step 2 of Attachment A of this procedure was missing a statement regarding opening the appropriate valves as necessary to perform the ste The licensee agreed to consider revising this stateren !

Step 3 of Attachment A of this precedure did not provide cicar direction to the operator on the value of primary containment pressure to terminate torus ventin The licensee agreed to revise the procedure or justify not revising i The items concerning containment venting will be collectively included as part of unresolved items 50-293/88-11-0 See Section 8 for additional containment venting item ,

5. Comparison of E0P Writer's Guide With E0P All E0Ps were reviewed to determine if they fc11 owed the guidance provided

'

in the licensee's Writer's Guide. The licensee verbally committed to evaluate the following comrents, and to rodify the E0Ps or the Writer's Guide at, appropriat l

r P

- , .- , _-

- - - , , - - , ,-,.-,_,-.-r,_-. -.-.--,_,--,-+--,,,-,---,--g.---. _ , , - _ , . _ . , , ,

_ _

.-

-7-5.1 Cautions, Notes and supplemental Information

- Blocks of supplemental information are used in E0Ps 01, 02, 06, and 09. The Pilgrim Writer's Guide does not provide guidance as to what information is to be placed within supplemental information block .2 Logic Terms and Conditional Statements In E0P-03, Drywell Temperature, second action block, the BEFORE statement does not follow the format stated in the writer's guide. This also occurs in E0P-0 The term EXCEPT is used several times in E0P-04 and 0 The use of this term places exceptions after an action step. In these statements, the operator is told do something which he or she may go ahead and do before reading the rest of the statement which includes the exception .3 Action Steps Throughout the procedures there are action steps which state something "IS REQUIRED." However, this construct, its format and use are not addressed in the writer's guid Some of the steps in the sample flowcharts are long and complicate For example, in E0P-04, "Reset the secondary containment isolation and restart reactor building H & V, defeating high drywell pressure and 1cw RPV water level isolation interlocks if necessary." This step contains many action Furthermore, this step does not explain under what conditions it would be necessary to defeat the high drywell pressure and 1cw RPV water level isolation interlocks. Another example of a step that is too long is from E0P-01, "Irrespective

,

of whether adequate core cooling is assured, terminate injection l into the RPV from sources external to the primary containment UNTIL primary containment water level and torus pressure can be

'

maintained below the MPCWLL." In E0P-02, near the end of Reactor Power, there is a BEFORE statenent whose action reads, "BORON INJECTION IS REQUIRED."

This action statenent does not follow the format for BEFORE statenents, In E0P-02, in the next instruction block, the two numbered actions are prefaced with the word "either". The word "either" implies that the operator can perform either step 1 or step However, this may not be the cas This construction is not addressed in the writer's guid , _ - - - - - - _ - - - - - - - - - - . - - - - - - - -

.

-

.

.

-

5.4 Referencing and Branching Throughout the procedures the phrase "appropriate section of Procedure..." is used to refer the operator to another procedure. More specific directions appear necessary, The writer's guide specifies a number of methods to refer the operator to other procedure However, there are reference statements which do not follow any of the methods in the Writer's Guide. For example, in E0P-01 the phrase "enter and concurrently execute Procedure 2.6.1..." is used. In E0P-02 the phrase "Insert control rods using one or more of the methods detailed in Procedure 5.3.2.3..." is use .5 Flow of Information In E0P-02, path A is difficult to follow and some method is needed to help indicate the direction of flo .6 Miscellaneous In E0P-03 Torus Water Level, in the first action step, the acronym PASS is used; this acronym is not defined in the Pilgrim Writer's Guid In E0P-03, Drywell Temperature, the first six-Sided symbol does not contain a ccma after the IF or AND statements. Also, in the last two BEFORE symbols a coma is not placed after the before statement, In E0P-03, Hydrogen and Oxygen Concantrations, when Hydrogen concentrations are referred to the format is inconsistent. The first instance a decimal is used, i.e., 1.0% and in the remainder instances no decimals are used, i.e., 5% and 6%.

5.7 Satellite Procedures The Attachments to 5.7.3.2 are very difficult to rea . E0P Verification The verification program at Pilgrim was reviewed and compared to the E0P Verification Program description submitted in the PGP. Tha contractor who performed the verification, and cognizant plant personnel, were interviewe A variety of documents were reviewe The documentation included:

- Completed and signed verification forms

- Interim report on discrepancies

- List of open verification items

- Operator comments

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

-

. The documentation appeared thorough and complete and the licensee's discrepancies were well defined and describe . E0P Validation The validation program at Pilgrim was reviewed and compared to the Validation Program Description submitted in the PG To perform this review the contractors (Ciel Inc. and Human Performance Technologies Inc.)

who performed the validation were interviewe A variety of documents were reviewe The documentation included:

- Completed and signed validation forms, checklists, and questionnaires

- Resumes of participants

- Scenarios used during the validation process

- Copies of E0Ps showing which paths / steps were validated For each scenario the paths / steps for each E0P used were traced on copies of the E0Ps using a color cod At the end of validation this method showed how much of each E0P had been validated both through the simulator exercises and the talkthroughs. An examination of a sample of these E0Ps showed that all paths / steps had apparently been validate The documentation appeared thorough and complete and the licensee's discrepancies were well defined and describe . Walkthrough of Emergency Operating Procedures and Satellite Procedures Inspectors, with facility licensed operators, walked through portions of the following procedures in the Control Room and in the plant to assess whether the procedures were capable of being perforced when required. The procedures walked through included both the E0Ps and the satellite procedure E0P-02 RPV Control E0P-03 Primary Containment Control 5.3.26 RPV Injection During Emergencies 5. Primary Containment Venting and Purging 5.3.23 Alternate Rod Insertion The inspectors assessed the consistency of terminology between the plant labels and procedures, access to the equipment, clarity of instructions, availability of information to conclude the action should be taken and overall useability of the procedur During the walkthrough the inspectors identified several items that needed facility actions to correc These are detailed in Attachment C and summarized belo The inspectors identified concerns relctive to plant labeling (either missing, inadequate or not consistent with procedure nomenclature), the availability / control of jumpers / tools required to perform selected E0P actions, the clarity of procedures to direct operators to a specific location to perforn the required task, accessibility of equipment, and completeness of procedur _ _ _ _ - _ - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ___ ____ _______ _-_____

.

'

.

.

" -

10-

,

A number of the E0P-related items identified by the inspectors had also been identified by the facility review process and actions were being taken to address the observed problems. However, the facility review of the satellite procedures was still in progress even though the procedures '

were approved and issued, i.e., they had not yet finished their own walkthrough of the satellite procedures. Furthermore, the operations management agreed to assure that the plant labeling was consistent with the E0Ps and satellite procedures. Therefore, pending further NRC review folicwing completion of the facility walkthrough of the satellite procedures and the licensee actions to correct the identified deficiencies, this item will retain unresolved (50-293/88-11-02).

One item identified during the walkthrcugh of the E0Ps was an apparent need for additional training on when to initiate and when to terminate venting of the containment in accordance with the intent of the EPGs and the procedures. Items concerning centainment venting will be considered

'

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

containment venting item . E0P TRAINING A representative of the Pilgrira Training Center (a lead instructor, heading up the Phase II E0P trainirg) was interviewed to determine if the

.

current E0P training program matched that described in the Training

!

Program Description in the PG A nutber of training related documents were also reviewe This *

documentation included:

-

Administrative records .

-

Student records  !

-

Lists of training objectives

- Lists of perfereance and cognitive standards  :

-

Exam results

-

Exams

- Unit, Course and l'odular Guides

' -

Homework lessons

- Scenarios used during siculator training l All docurentatien appeared ccrplete and thoroug Hewever, the training I program description included in the PGP is no longer applicable. This .

progran freferred to as Phase I) was executed, but had seme difficulties which the licensee believed may have contributed to an original unsuccess- ,

ful validation. As a result, the licensee revarped the training progra The licensee needs to prepare a revised Training Progran Description fer i their current ECP training and submit this description as a part of a revised PG The training representative stated that they were preparing i

a new training program description which would address previously l I

. identified weaknesses.

I

!

. ._

_ _ _ _ _ _ ___ m __ _ _- - . .._. _ _.,..,___, _ _.,_.______, __.____ _ ___ ______ _

_

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __

.

'

.. ,

,

"

-11-The training program, Phase II (80 hours9.259259e-4 days <br />0.0222 hours <br />1.322751e-4 weeks <br />3.044e-5 months <br />), was a combination of classroom and simulator training. As of the inspection, about 50% of the operators had been trained in Phase II. Pilgrim plans to have all operators trained by May 198 . E0P Evaluation Using Simulator Scenarios A shift operatiag crew in the fine' stage of operator training on E0Ps was observed in the Pilgrim simulator to determine if 1) the operators are familiar with their responsibilities and required actions during an emergency, 2) the E0Ps and E0P satellite procedures can be performed by the minimum staff 3) operators do not physically interfere with each other while performing the E0P, and 4) transitions from one procedure to others are appropriately directed by the E0P The shift operating crew consisted of 2 SR0s, 3 R0s, an STA and a shift clerk. This crew size is larger that that required by the Pilgrim Techni-cal Specifications, but specified in the administrative procedures. The crew was exposed to three NRC generated evaluation scenarios which required entry into several E0Ps (i.e. E0P-1, 2, 3, 4, 6 and 7) and their apprcpriate satellite procedures ( .1.5, 2.1.6, 5.3.21, 5.3.23, 5.3.26,5.4.6,5.7.3.2).

Operators did not physically interfere with each other during their conduct of the scenarios, and transitions were appropriately designate Some procedural usage problems were encountered during the conduct of the scenarios, but these problems were attributed to the level of operating training (i.e., the operators had not completed their E0P training).

The inspector concluded that the E0Ps and E0P satellite procedures could be performed by the crew.

l 11. E0P Quality Assurance Measures

'

A review was conducted to determine if Quality Assurance Measures are adequate to ensure that high quality E0Ps are developed, implemented and maintained, i The QA measures associated with the development of the E0Ps were found to be acceptable, based on discussions with the Quality Engineering Division Manager and Senior Quality Engineer. However, it was concluded that a programatic approach to ensure the continued quality of the E0Ps through aud,ts of the maintenance of the E0Ps did not exist in the area of auditing of the E0P progra In subsequent discussions with the Vice President, Nuclear Engineering Division and Quality Assurance management BEco comitted to revise the

.

1988 Internal Audit Schedule to include an annual audit of the E0P l progra This audit will be performed as a Safety Syster Audit in the I fourth quarter of 198 The procedura11 ration of continued quality l assurance measures is an Unresolved Item (50-293/88-11-04).

. ~ , -_ .

_ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ . _ _ - _ _ _ _ _ _ _ . _ - _ _ _ _ . . _ _ _ _ _

~

.

-.

...

.

'

!

-

-12- ,

!

l 12. Exit Interview An exit meeting was held on March 18, 1988 to discuss the inspection scope  ;

and findings as detailed in this report (see paragraph-1.0 for attendees).

Written inspection findings were not given to the licensee. The facility i did not indicate that proprietary information was utilized during this  !

!

inspectio :

r

!

!

I i

!

L i

{

t

?

I f

'

i I

,

'

i i

t i l

l

i

'

'

t

r i i

.

'

l

....

'

'

.

'-

Attachment A i i

Documents Reviewed

Plant Procedures Pilgrim Nuclear Power Station Plant Specific Technical Guidelines, Revision 3 l Appendix to the Pilgrim Nuclear Power Station Plant Specific Technical Guidelines .

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

Revision 2, Dated October 15, 1987  !

Procedure 1.3.4-13 E0P Verification Program, Revision 1 Dated October 16, 1987 Procedure 1.3.4-14 E0P Validation Program, Revision 0. Dated July 10, 1987 Pilgrim Nuclear Power Station E0P Training Program Surmiary Description Attachment 4 to BECo 1.etter 87-185 E0Ps E0P-01 RPV Control, Revision 0. Dated November 18, 1987 E0P-02 Failure to Scram, Revision 0, Dated November 18, 1987 E0P-03 Primary Containment Control, Revision 0, Dated November 18, 1987 i

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

,

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

I E0P-06 RPV Flooding, Revision 0, Dated November 18, 1987 l E0P-07 Alternate RPV Depressurizaticn, Revision 0, Dated November 18, 1987  ;

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

'

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

i E0P Satellite Procedures Procedure 5. Primary Containment Venting and Purging Under Emergency Conditions, Revision 17 Dated September 3, 1987 Procedure 5.3.21 Bypassing Selected Interlocks, Revision 4 Dated October 14, 1987 '

Procedure 5.3.23 Alternate Rod Insertion, Revision 1 .

Dated December 4, 1987  ;

Procedure 5.3.26 RPV Injection During Emergencies, Revision 0 Dated August 30, 1987 i

l

.,.-. -- -, .-. . _ . - _ . .

. __ ________ - __ ___ ____ - . . ___

.

'

- .

• -

Attachment B Coments with Respect to the Pilgrim Proce$ ires. Writer's Guide Note: These comments were a result of a comparison of the Writer's Guide ,

with guidanco given in NUREG-089 ; Cautions and Notes Cautions and notes provide operators with critical and useful information concerning steps or sequences of steps in E0Ps. The discussion of cautions and notes in the Writer's Guide lack some specific (a)Section III.A.13 states that "notes shall be ... placed within the  !

respective flowchart element, located innediately preceding or following the associated text." Notes should be read and comprehended by the operator prior to the step (s) they refer to, not after. Notes should only be placed immediately prior to the step, not following it, as suggested in the guidanc The phrase "following the associated text." should be delete (b)Section III.A.12 discusses "supplemental information". However, the writer's guide does not define supplemental information or how it .

differs from notes. The writer's guide does not tell the writer when  !

to use supplemental information instead of notes or vice vers (c) There is no guidance provided as to the use of capitalization in ,

caution and note statement !

(d) When cautions and notes contain multiple topics the importance of any i one topic is obscure l

. Logic Statements Logic statements are used in E0Ps to describe a set of conditions or a i sequence of actions. Because logic statements can be confusing, it is ,

important to provide explicit guidance for their us [

'

(a) Table 1 includes the word EXCEP In logic statements using EXCEPT, the conditions follow the actions which may lead operators to perform i the actions before reading the conditions. An approach should be used where all conditiers are read prior to the actions such as in a  :

Note or Caution (which ever would apply); or word the statement to c specify only the actions to be taken and not exceptions. For i example, in Example 11 on Page 11 of the Writer's Guide, the 1

"sources" to be used could be specified instead of listing the *

exceptions, i

I I

, . . _ . . __ .

. . _ _ , . _ _ . _ _ . _ _ _ _ _ . . _ .

_ - _ _________ _

.

.' .

"

-2- Attachment B (b) Using the logic term THEN at the end of an action to instruct the operator to perform another action in the same step runs actions together which may be overlooked or may be confused with logic statements. For example: "Do A. THEN B. THEN C, THEN D." should not be used. The writers' guide sheuld state that THEN will not be used to run action steps together. Further, the word "then" should not be used other than as a logic term to avoid operator confusion as to its meanin In the following example, "If A. THEN B and THEN C" the

"and" and second "then" should not be use . Flow charts Flow charts can be a valuable means of presenting important information to operators and nust be formatted and written efficiently and effectivel The writer's guide states that concurrent flows of steps shor.1d be spaced to "achieve a balanced presentation." This is ambiguous guilance. For example, it could mean that a short flowpath containing a foi steps should be stretched out to balance out a concurrent long flow conk ;ning many steps for appearance sake. As another example, it could mean that certain symbols in cuncurrent flows should be placed side by side to achieve overall visual balanc . Emphasis Techniques The proper use cf emphasis techniques rekes the procedures easier to understand. The use of uppercase letters i; discussed on page 20 of the Writer's Guide, but the use of all caps versus the use of initial caps and lower case is somewhat ambiguous. For example, it is clear that the word START is all caps, and section designators are upper and lower case, because examples are given. But, the writer's guide does not make it clear for each application whether all caps are to be used, or initial caps onl . Divisions, Headings, Numbering It is important that a consistent method of section heading and step numbering be used throughout E0Ps. The use of overall headings and an alpha-numeric numbering systen for each step is usually needed so that operators can keep track of where they are in the procedure and know how to move easily and quickly to other parts of the procedur The flow charts have a system of titles and a numbering system to identify procedures and overall headings for flow sequences. However, there is no alpha-numeric numbering system for sections or syrbols within the flow chart. This makes it difficult to refer to a section or symbol and an operator may not be able to keep track. For example, if one operator wants to indicate a particular step to another operator there is no easy to way to verbally refer to the section or syrbol.

l

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

..

..' .

.

"

-3- Attachment B

' Tables / Figures / Printed Aids Figures and tables assist operators to make decisions and to locate informatio (a) The writer's guide states that the units used on the axes of graphs on page 15 should correspond to those of associated control room instruments, but the same guidance is not given for tables discussed on page 1 (b) Because unnecessary information may clutter figures and tables and confuse operators, all figures and tables should contain only information that is needed by operators and is relevant to the tex . Location Information for Equipment, Controls, Displays It is important that the operators know where to find all of the instrumentation and controls that are referenced in the E0P The writer's guide (on page 29) provides criteria to determine if

~

location information should be put in a step. However, this guidance does not state the basic format for the information statement er provide an exampl . Formatting Writers should be given sufficient information in the writer's guide to produce procedures that are consistently formatte The writer's guide states that for boldface type a slightly larger type size should be used. This larger type size should be specified. The guide also mentions varying thicknesses of lines to be used in the flow chart The guide should provide guidance on thickness size .

'

~ .

.

Attachment C NRC Observations in Walkthrouch of E0Ps and Satellite Procedures Control Rocm Indicator TI-9019 did not have a label to indicate it was for drywell temperature. The facility was in process of correctin . Relays in general (and specifically RPWP1) had labels which were masking tape with information written on it. These labels were inadequat Facility operations management agreed to assure all labels fe E0Ps/

satellite procedures were correct and consisten . Relay Terminals used as jumpering locations in panel C170 v v e not clearly marke . Procedure 5.4.6 did not direct evacuation of the reactor building prior to initiating containment venting although it did contain a caution that venting may result in rupturing some lines in the reactor buildin . Procedures have no description or different word description than plant labels. Several examples were noted. A few examples were: E0Ps refer to torus temperature whereas plant label refers to bulk torus temperatur .3.23 referred to "l10-302-8" with no description. Whs a the plant label has a clear description of this valve. In procedure e.4.6 the 2" drywell vent valve A0-5043A was referred to in the plant label as 2" drywell vent exhaust valve f2 A0-5043A. (Facility actions are discussed in coment 2 above.)

l Procedure 5.3.23 required the operator to increase flow using valve FCV-302-6A(B). Actual o>erator practice was to use controller FC-340-1 to increase system flow witiout any procedure direction to this controlle . At the RPS test channel switches, in one channel the switches were located above the labels and the other channel the switches were located below the label . A label was missing on the 8" drywell purge exhaust valve ( . In procedure 5.3.26, the location of the spool piece to be inserted is between two valve The valves are located on two plant elevations (different rcoms) and were not within eyesight. The location in the plant is not specified in the procedure. Instruction was not provided in the procedure or 1ccally on how to install the spool piece or the additionally necessary step to connect the local instrumentatio . The location of vent valve 3/4 YT-120 was abeut 20 ft overhead and use cf a ladder was required to operate the valve. The facility reportedly evaluated the need to operate this valve and had initiated actions to change the procedure to not use this valv _ . . _ _ _ - . _ . . _ . _ _ . . _ . . . . . .