IR 05000346/1989006

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Insp Rept 50-346/89-06 on 890131-0209.No Violations or Deviations Noted.Major Area Inspected:Adequacy of Emergency Operation Procedures.Numerous Technical & Human Factor Deficiencies Identified
ML20246H827
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 05/01/1989
From: Kellogg P, Peebles T
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20246H800 List:
References
50-346-89-06, 50-346-89-6, NUDOCS 8905160207
Download: ML20246H827 (54)


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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Licensee: Toledo Edison Company Edison Plaza, 300 Madison Avenue Toledo, OH 43652 Docket No.: 50-346 License No.- NPF-3 Facility Name: Davis-Besse Unit 1 Inspection Conducted: January 31 - February 9, 1989 Inspection Team Leader: 6 / s%4

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fe #/ P. Kellogg Date Signed Inspection Team Members: G. Bryan J. DeBor D. Kosloff W. Lyon G. Salyers G. Wilford Approvedby:/ # T.A.Peebles, Chi 6f Date Signed Operations Branch Division of Reactor Safety Region II SUMMARY Scope: This special, announced inspection was conducted in the area of review of the adequacy of Emergency Operation Procedures. TI 2515/92 was used in the performance of this inspectio Results: No violations or deviations were identified. Although numerous technical and human factor deficiencies were identified, the Emergency Operating Procedures were found to be adequate for continued operatiot of the facility. The licensee committed to review the deficiencies and take prompt corrective action to resolve the PDR ADOCK 0500 Q i J

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DETAILS Persons Contacted Licensee Employees

 * G. Bradley, Licensing Representative
 * M. Derivan, Senior Nuclear Specialist
 * R. Flood, Manager, Plant Operations R. Gaston, Licensing Engineer
 * G. Gibbs, Performance Engineering Manager
 * P. Hildebrandt, Engineering Director W. Johnson, Plant Maintenance Manager
 * J. Kasper, Operations Superintendent
 * J. Magers, Nuclear Licensing Associate Technologist
 * T. Meyers, Director, Technical Services
 * D. Miller, Senior Engineer Quality Assurance
 * J.-Moyers, Manager, Quality Verification
 * R. Rishel, Quality Verification Supervisor E. Salowitz, Planning & Support Director R. Schrauder, Licensing Manager
 * D. Shelton, Vice President Nuclear
 * L. Storz, Plant Manager
 * L. Simon, Senior Performance Technologist
 * R. Simpkins, Operations Training Supervisor
 * S. Wise,-Requalification Training Supervisor
 * A. Zarkesh, Independent Safety Engineering Supervisor The team contacted other licensee employes including engineers, technicians, operators and office personne NRR Attendees
 * G. Lapinsky, E0P Coordinator
 * T. Wambach, Project Manager NRC Region III Attendees
 * M. Phillips, Section Chief
 * P. Bryon, Senior Resident Inspector
 * Attended exit interview Note: A list of abbreviations used in this report is contained in Appendix . E0P/ Generic Technical Guidance (GTG) Comparison The original E0Ps at Davis-Besse consisted of 63 event-based procedures that were developed prior to initial criticality in 1977. In 1984, the licensee converted a portion of the original event-based E0Ps (EP-1202-01)

to the new Plant Specific Abnormal Transient Operating Guidelines (ATOG) Part 1 procedures. The new Plant Specific ATOG Part 1 procedures were based on the guidelines contained in the Davis-Besse Plant Specific ATOG

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Parts 1 and 2 that were developed by the Babcock and Wilcox owners' group for Toledo Edison Compan Once the Plant Specific ATOG Part 1 procedures, the EPs, were developed, the licensee conducted a comparison of them to the Plant Specific ATOG Part I which contains the procedural guidelines. The results of this comparison are presented in the "EP/ATOG Deviation Document, EP-1202-01 Rev. 0" that was completed in 1984. This document contains sections corresponding to each major section of the EPs. Each section identifies differences between the EPs and the AT0G and explains the reasons for these difference i The Babcock and Wilcox owners' group conducted a comparison of the Davis-Besse Plant Specific ATOG to the Oconee Unit 3 ATOG. The results of-this' comparison were documented in " Abnormal Transient Operating Guidelines (ATOG) Comparison of Davis-Besse Unit 1 to Oconee Unit 3, 12-1153/13-00" dated October 26, 1984. This document contains sections correlating to each major heading of the Davis-Besse Plant Specific ATOG  ! Part 1, Procedural Guidelines. Each section identifies differences between the Davis-Besse version and the Oconee Nuclear Station Unit 3 version previously reviewed by NRC and explains the reasons for the differences. In addition, this document provides composite flow charts that use the logic diagrams from the Plant Specific ATOG Part I as a  ; base. These logic diagrams have been modified to show differences with respect to the Oconee Nuclear Station Unit 3 versio In October 1985, the Babcock and Wilcox owner's group issued "The B&W Owners' Group Operator Support Committee Emergency Operating Procedures Technical Bases Document (TBD)." The TBD provides a mechanism for pre-senting the current analytical bases for abnormal transient response and current recommended methods for diagnosing and mitigating the consequences of abnormal transients at Babcock and Wilcox plant In March, 1987, the licensee conducted a verification and validation program on the EPs using the new TBD and the plant-specific ATOG Parts 1 and 2 in order to verify j that the EPs were technically accurate. As a result of this verification and validation program, the licensee issued a revision to the EPs and changed the overall E0P number to DB-PF-02000. The results of the 1987 verification and validation program are documented on Procedure Development Form J The NRC reviewed the scope of emergencies and other significant events covered by the Davis-Besse E0Ps. It was the teams' judgment that the procedures cover the broad range of events listed in Regulatory Guideline 1.33, Section The quality assurance department consists of quality verification section, quality systems section, and the quality control section. The quality systems section performs their functions of the verification and validation process of the procedures as the procedures are being written. The quality verification section conducts procedure audits, surveillance, and performance based reviews. With regard to the DB-PF-2000 Emergency Procedures the quality assurance group was involved in the review process for the last two revisions. For the DB-0P-02500 Series abnormal procedures, the quality assurance department has been conducting procedure audits since 198 I _ _ _ _ _ _ _ _ _ _ _ _ i

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The quality. assurance department will be included in future changes of procedures. This involvement will include several types of procedures audit There were no violations or deviations noted in this are . Independent Technical Adequacy Review of the E0P The NRC inspectors used the Oconee ATOG, the Emergency Operating Procedures TBD, and the Davis-Besse ATOG as the basis for this review of the E0P I The NRC inspectors determined by review of the procedures listed in Appendix A of this report that technical guideline step sequence and peacekeeping requirements were met and that entry and exit points were correct except as noted. The general priority of treatment and order of steps was maintained except as noted in Appendix B of this repor The team found that if accident mitigation was required it would not be necessary for operators to remove pages because of the self contained nature of the EP and the presence of two copies in the control room plus a copy in the shift supervisor's office. Transfer from the EP to the . abnormal operating procedures is well defined in the EP, and could be  ! easily followed by the operators. The team found that peacekeeping did not appear to be a significant problem as two copies of the abnormal operating procedures are also provided in the control roo The inspectors verified that entry conditions into the E0Ps were properly and clearly identified and could be easily followed by the operator The licensee's use of notes and cautions was generally clear except as noted in Appendix B of this repor The licensee's treatment of tube failure in once-through steam generators (OTSGs) is organized differently than was specified in the bases materia In pursuing this difference, the inspectors encountered a problem generic to the Davis-Besse E0Ps. Only one copy of a historical deviation document exists, and this is not maintained under document control. This is a loose-leaf notebook which contains material generated as early as 1984. The licensee had not dated or specifically identified many of the pages. The licensee has agreed to place this document into the Davis-Besse  ! document control syste The above document contains the statement (Item 1, Symptoms, page 2):

" Tube ruptures are defined in the symptoms as leaks greater than the available make-up capacity. Leaks within the make-up capacity are covered by a separate Abnormal Procedure." This is consistent with the Davis-Besse procedures. However, this approach introduces the problem that symptom oriented guidance may not be provided when operators are not actually in the EP. The inspectors determined that the licensee depends upon operator training, judgement, and understanding to transfer into the EP from other procedures when conditions such as a loss of subcooling

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' occur. This transfer to the EP is key to proper application of-the approved generic guidance, and needs to be reinforce The licensee has j agreed to make,the following changes: 1. Training will include a specific training subject area that emphasizes loss of subcooling margin, loss of heat transfer,'and

    . overcooling conditions, etc. as situations where use of the EP is ,

required if such conditions are encountered while in other procedure .;

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2. Guidance similar to the information contained in item I will be included in the next update of the E The inspectors have concluded that this will meet the intent of the generic guidelines. This item is identified as an Open Item 346/89006-0 pending incorporation of the changes in the training program and E With the exception of this item, the inspectors were able to verify that the priority of accident mitigation appeared to be maintained in the E0P The OTSG tube failure treatment also contributed to EP transfers in which both the EP and abnormal operating procedures were in use. The team performed a review of this area and determined that this was consistent with the bases guidanc The team inspected Control Room drawings to verify that management controls were effective and that plant changes were reflected in interim and final drawings in a timely manner. The team inspected a sample of l drawings and all were up to date (including DCNs as part of the drawing). j There was no backlog of drawing changes. Licensee policy requires that  ; drawing changes be incorporated within 48 hours of identification of the  !

  ' completion of the work associated with a DCN .    )

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There were no violations or deviations noted in this are l Review of the EOPs by Inplant and Control Room Walk-throughs The team conducted walk-throughs of the emergency and abnormal procedures ,

   (listed in Appendix A) in the control roos, in plant, and at the photo
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mockup of the control room located in the training buildin The EP and the recent vintage Davis-Besse formatted abnormal operating procedures appeared to be generally consistent between the plant labeling l and the nomenclature used in the procedures. Those discrepancies noted j are enumerated in Appendix C of this report. However, the team determined I the older vintage abnormal operating procedures were characterized by  ! I numerous, discrepancie In view of the large number of discrepancies and the scheduled August 1989 completion of the conversion process, the team documented technical discrepancy items in the attached Appendix B aa only a sample of labeling discrepancies in Appendix l The team found indicators, annunciators and controls referenced in the  ! E0Ps to be available to the operators. Two sets of controlled E0Ps were maintained in the control room. On a sample basis, the team verified these procedures to be of the latest revision and chang l

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l While the results of these walk-throughs were generally acceptable, several l discrepancies in the areas of technical content, writer's guide adherence, and human factors were noted. Technical and human factors discrepancies are identified in Appendix B while discrepancies between procedure nomenclature and plant labeling are noted in Appendix C. The licensee has committed to evaluate and resolve the discrepancies identified in the aforementioned appendice Appendix B discrepancies will be identified as Open Item 346/89006-0 Appendix C discrepancies will be identified as Open Item 346/89006-0 During this inspection, the team did not inspect in depth the aspects of the validation and verification program that were applied to the development of the E0P l There were no violations or deviations noted in this are . Ongoing Evaluation of the E0Ps The team reviewed procedures and records and interviewed licensee personnel to determine whether the licensee has an acceptable program in place for continuing evaluation of the E0Ps. The Babcock and Wilcox Safety and Performance Improvement Program determined that all B&W plants should have a Deviation Document that lists and resolves differences between the TBD and E Additionally, the owners' group decided that the each licensee should have a procedure that addresses how to maintain the EP and its technical base In order to comply with the owners group findings, the licensee developed NG-EN-00319, " Control of Emergency Operating Procedures and Technical Basis." This procedure was in the draft review cycle at the time of the NRC inspection. The purpose of the procedure is to: a. Identify responsibilities for maintenance and. updating of the technical basis document; b. Specify the nuclear engineering department's responsibility for determining the applicability of the technical basis document to Davis-Besse and making recommendations to procedure writers; and c. Proceduralize the technical verification and validation program for the I procedure writer The licensee will use procedure NG-EN-0319, when it is finalized, in conjunction with Davis-Besse Procedure Preparation and Maintenance, DB-DP-00003 and the procedure change request proces There were no violations or deviations noted in this are . EOP User Interviews The NRC inspection team conducted interviews of operational personnel and determined that the current E0Ps satisfy their needs. The operators felt _ _ _ _ _ _ _ _ _ _ _ _ _ __

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the E0Ps were adequate and compatible with the level of knowledge of the typical operator and the operations staff was confident'that the E0Ps would function effectively during an actual event. The following is a summary of the main points made by the operators during the interviews: The symptom based procedures reduce the operator'r need to memorize entry conditions as they were presented on the old event based procedure Due to a lack of a site specific simulator for E0P training, the operators felt the detail contained in the E0Ps was at the right level. The E0Ps are designed to be a single flow path set of instructions without a great deal of cross referencing to concurrent task The team noted, during walk-throughs, other areas which require licensee , attention. These areas are: I The team observed that some operators were uncertain of the meaning of items explained in'the Writer's Guide (e.g. " refer to" vs "go to"; step sequence mandate.y or optional; verify / check; etc.). The licensee should provide training in sections of the Writer's Guide to all operators, not just those assigned as procedure writer The team observed confusion on the part of some operators when the E0Ps were performing leak isolation steps. The confusion existed l due to the procedure giving specific instructions for leak isolation, j while it remained silent in the restoration of the systems following i the determination that it was not the source of the lea The following steps in the procedures usually assumed that the restoration had taken place (i.e. shutting valves that had been previously shut) l but this was not state The team identified these deficient areas to the licensee. Resolution of these issues will be identified as Open Item 346/89006-0 ; There were no violations or deviations noted in this are . Exit Interview The inspection scope and findings were summarized on February 9, 1989, with those persons indicated in paragraph 1. The NRC described the areas inspected and discussed in detail the inspection findings listed belo Although proprietary material was reviewed during this inspection, no proprietary material is contained in this report. Specific technical issues and human factors discrepancies are identified in the attached Appendix Nomenclature differences between installed equipment or instrumentation and the E0Ps are identified in Appendix Those items on which dissenting comments were received from the licensee are identified by a marginal asterisk in the detailed discussion in these appendice At the conclusion of the inspection, the following Open Items were identified: j

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Item Number Status Description / Reference Paragraph , 0I.50-346/89006-01 Open Operator training concerning EP l entry for OTSG tube failure from other abnormal procedures (paragraph 3) OI 50-346/89006-02 Open Correction of technical l- ' discrepancies contained in the' E0Ps as outlined in Appendix B (paragraph 4) OI 50-346/89006-03 Open Correction of human factors discrepancies contained in E0Ps as outlined in Appendix C (paragraph 4) OI 50-346/89006-04 Open Evaluation of training requirements for identified areas of confusion (paragraph 6) The licensee was requestesd-to submit a written response describing how these items would be resolve Attachments: . Appendix A: Procedures Reviewed Appendix B: Technical and Human Factors Comments Appendix C: Nomenclature Deficiencies Identified by NRC E0P Inspection Team Appendix D: List of Abbreviations l _ - _ -

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APPENDIX A PROCEDURES REVIEWED NUMBER TITLE REV DB-PF-02000 RPS, SFAS, SFRCS Trip, or SG Tube 1 Rupture DB-OP-02500 Turbine Trip 4 DB-0P-02502 Cooldown Without BWST and No Off-site 4 Power DB-0P-02503 Depressurization of the RCS with only 12 Safety Grade Equipment DB-0P-02504- Rapid Shutdown 2 DB-0P-02505 Loss of Neutron Flux Indication 1 DB-0P-02506 Condenser Tube Leak 4 DB-0P-02508 Control Room Evacuation 5 DB-0P-02509 Reactor High Startup Rate 1 DB-0P-02510 Loss of Reactor Coolant System Boron 2 DB-0P-02511 Loss of Service Water Pumps / System 7 DB-0P-02512 Loss of RCS Makeup Pump 0 DB-OP-02513 Pressurizer Systems Abnormal Operation 0 DB-0P-02514 Loss of Turbine Plant Cooling Water' 2 Pump (s) DB-0P-02515 Reactor Coolant Pump and Motor Abnormal 6 Procedure DB-0P-02516 CRD Malfunctions 0 DB-0P-02517 Circulating Power Pump Trip / 3 Circulating Water System Failures DB-0P-02518 High Condenser Pressure 5 DB-0P-02519 Serious Control Room Fire 0 DB-0P-02520 Load Rejection 3 DB-0P-02521 Loss of AC Bus Power Sources 4 DB-OP-02522 Small RCS Leaks 0 DB-0P-02523 Component Cooling Water System 4 l Malfunctions DB-0P-02525 Steam Leaks 0 l DB-0P-02526 Steam Generator Overfill 0 DB-OP-02527 Lost of Decay Heat Removal 3 DB-0P-02528 Loss of Instrument Air 0 l DB-0P-02530' Fuel Handling Accident 2 DB-OP-02531 Steam Generator Tube Leak 0

 'DB-0P-02532 Loss of NNI/ICS Power  0
 'DB-0P-02534 High Airborne Activity or Radiation 3 Levels   j
 .DB-0P-02535 High Activity in the Reactor Coolant 0 i System DB-0P-02536 Toxic Gas and Liquid Release 6 DB-0P-02538 High Radiation  0 DB-0P-06903 Plant Shutdown & Cooldown 0 DB-OP-06910 Trip Recovery  16
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APPENDIX B TECHNICAL & HUMAN FACTOR COMIENTS This appendix contains technical and human factors comments, observations .nd suggestions for E0P improvements made by the NRC. Unless specifically stated, these comments are not regulatory requirements. However, the licensee agreed in each case to evaluate the comment and take appropriate action. These items will be reviewed during a future NRC inspection as noted in paragraph COMMENTS AND OBSERVATIONS l General Observations on Procedures l

 * Davis-Besse has no controlled set point document which provides operator action parameter values which are contained or referenced in the DB-PF-02000 and DB-0P-02500 series procedure All parameters as defined above will be listed and the basis for the listed value given in the Set Point Documen (See NUREG 0800 Section 3.3.2.1) The team selected specific alarm tile procedures to determine whether the alarm tile procedures transferred the operators to the abnormal procedures and thence to the EP when appropriate. Based on this sample, it appeared that the abnormal procedures in the old format did not transfer to the EP but relied instead upon safety system activation to establish EP entry conditions. Again based upon this sample, abnormal procedures in the new format successfully transferred to the EP without reliance upon safety system activatio Many_of the procedures contain a mixture of discussion and instructions. The instructions should generally be located first, and should be concisely worded. The use of a facing page format with brief instructions on the left and detail on the right is often useful. Operators generally indicated they like a discussion section at the end of each procedure. The discussion material is valuable and should be readily available in the Control Roo It should be provided as an addendum to each procedure, as a separate document organized by procedure, or as the last section of the procedur It should not be included within the text of the procedur The Davis-Besse procedure formats do not appear to provide good guidance for a continuing item that should apply throughout a section or several sections of the procedur Recognition that certain cases require specific responses is adequate some of the time, such as use of the loss of subcooling margin procedure whenever this is encountered. Other cases are not as well define For example, a note of the type " Start the diesel compressor if air pressure is less than 95 psig" is a continuing item which would be applicable to the entire Loss of Instrument Air procedure. The

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current format does not provide a reminder to the operators of this continuing condition.

1 The practice.of identifying alarm tile location throughout procedures is not uniformly applied. The licensee should evaluate the placing of alarm tile locationc in the procedures and uniformly apply the polic . Writer's Guide: The team concluded that the quality of the abnormal procedures varied widely from procedure to procedure and appeared to depend heavily upon the originator and the procedure vintage rather than application of the Writer's Guide, validation and verification or technical and administrative review processes. The team recommended that the licensee review the requirements applicable to the abnormal procedures and, if necessary, upgrade performance standards to those requirements, Paragraph 2.3.6.h of the guide prohibits the use of " Notes." The EP contains." Notes" (e.g. Note 1.4.1). The licensee should revise the EP to eliminate notes or the prohibition against notes should be remove Paragraph 2.3.6.g of the guide requires that cautions and warnings i be in the action column of the EP. The EP should be revised to remove cautions and warnings from the details column (e.g. Caution Substep 6 on EP pg.24).

3. AB-1203.01 (DB-0P-02500) Turbine Trip General: There were numerous discrepancies between the plant component identification and E0P nomenclature. The licensee should resolve these discrepancies in the next revision of this procedur Paragraph 3.6 Detail: Typo, seletion vs selectio Step 5.4.12.a: Although this alarm may come in on a loss of feed, it's primary purpose is to indicate a feed line break. The licensee should revice the last paragraph of this step to indicate this conditio Attachments 1 & 2: At present, some paragraphs in these Attachments list valve number, then control switch name and number and others list switch number first, then name and valve number. The licensee should revise the Attachments to list component identification in a consistent sequence throughou Attachment 1, Step 4: The use of " Verify OPEN or OPEN" is in conflict with the writers guide definition of " Verify" and should be revised to be consisten . AB-1203.03 (DB-0P-2502), Cooldown Without the BWST and No Off-Site Power General: The procedure should be rewritten and formatted to conform to the writers guide. The sources of borated water need to be

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I prioritized, and in each case provide the operator with an accurate valve line up or if needed a breaker line up in order to perform the task. The operator should be provided with a~ list of segmented Tc from 552 deg. to cold shut down so he can predict'when a given coolant source will be depleted. Step II.2 instructed the operator to add-3446 gallons between 582F and 546F and II.4 to add 4668 gallons between 280F and 140F, but there is no reference of how much to add between 546F and 2S9F. The Clean Waste Monitor Tanks should also be mentioned as a source,'there are two tanks containing 23,000 gallons each of borated wate . AB-1203.04 (DB-OP-02503)' Depressurization of the RCS With Only Safety Grade Equipment General: The procedure opens with the following disclaimer:

  "This procedure is written strictly as a guide for the operator and is in no way intended to be detailed in actions to be taken. No real detail can be provided since the plant conditions at the time of this type of situation are themselves unpredictable."' TS 3. requires.a 2 hour shutdown if diesel generator essential power is not operable on one side and any safety grade equipment is not operable on the other side. Assuming that the plant is operating within TS requirements, the team concluded that plant conditions should be predictable and that the procedure should be revised to eliminate need for the disclaime The only entry to this procedure which the team could identify was from EP step 4.16.4 (with the plant stable and subcooled with adequate heat transfer and no major boundary failures).       That step refers to DB-0P-02521, Loss of AC Bus Power Source Step 3.11.3 o then refers to this procedur Since the procedure is admittedly vague and consists largely of blank pages or non-directive information, the team recommended that the licensee consider eliminating.the procedure and the worthwhile content be transferred elsewher Step 2.3.4: This step does not tell the operator how to control pressure. The. licensee should revise the procedure to add some direction such as " Operate the AVVs to ...".

I Step 2,5, lines 2 and 3: This step requires the operator to line up per specified procedure. Use of " Refer To" is appropriate here and ' I should be considered for us l

Step 3
The information in this step was also applicable to i procedure DB-0P-06903, Plant Shutdown and Cooldown. Therefore, it appears that step 3 could be eliminated with the exception of the Refer To step The licensee should evaluate this step and revise as necessar Step 3.3.3: The step refers to the wrong internal reference. The licensee should revise the step to reference step 2.6, not _ _ _______________________ _ -

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.         i AB-1203.08 (DB-0P-02505), Loss of Neutron Flux Indication     i No comment AB-1203.12 (DB-0P-2508), Control Room Evacuation General: This procedure has no table of contents. The' licensee should provide a table of contents consistent with the Writers Guide, Step 3.4.3: This step instructs the equipment operators to operate remote valves. The licensee should revise the step to specifically call out the atmospheric vent valve . AB-1203.16 (DB-OP-02510) Loss of Reactor Coolant System Boron Step 3.1: This step refers to an old procedure number. The licensee should revise this step to use the correct designatio Step 3.5: This step starts "If the RCS is at pressure, (off decay heat), ..." and step 3.6 starts "If the RCS is on decay heat, ..."

The licensee should revise the step to reference whether the decay heat system is on or off the reactor coolant syste General: Organization and prioritization Section 4.2 item 1 ends  ! with the statement "In cases where immediate boration is required, diverting the suction of the make-up pump to the BWST should be considered." The licensee should consider moving this to the front of the discussio Enclosure 1 item 8: This item states "Close off all make-up lines to the deborating demineralizers." The licensee should provide specific instructions for this actio * Enclosures 1 and 2: These enclosures. represent a reversal in format from the general approach. Various causes are presented first, and each is followed by a remedy. The licensee should consider revising the format to be consistent with the approach of skipping a procedural step if it is not applicable, Enclosure 2 item 2: This item contains the statement "..., look for an alternate means of borating." The licensee should provide specific guidance for this actio Enclosure 2 item 3: This item is cumbersome and needs to be revised. For example, "... DW66, DW Iso Valve to MU System, PW 29, PW 1so Valve to MU System, WC 3526, CWBP Bypass Iso." During walk-throughs, several operators indicated they tend to treat each list entry as a separate item, and it was difficult to pick out WC 3526 due to the abbreviation not being immediately recognize . AB-1203.17 (DB-0P-2511), Loss of Service Water Pumps / Systems Steps 1.1.1, 2.1.1, 3.1.1, 4.1.1, 5.1.1,and 5.1.2: See General

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E Comment I Step 1.3.4.c: This step directs the operator to take manual control of the CCW heat exchanger temperature control valve (SW 1424, SW 1429 or SW 1434). Manual operation of the valve is accomplished by sliding a metal collar along the valve stem until it engages two pins on the manual operator. The metal collar on SW 1429 could not be moved by hand. The licensee initiated a Work Request to correct this deficienc c. Step 3.4.3, Discussion: This step states that loss of a SW pump may ' cause loss of the MDF It would be more accurate if the step stated that "... loss of SW flow may cause loss...". The licensee should revise the step to indicate that loss of flow is the causative facto d. Steps 3.4.5, and 4.4.5, Discussion: These steps state "SW Pump may be manually operated to replace SW Pump 3 in case of an emergency."

This sentence appears to be in error. The licensee should revise or remove-the sentenc e. Step 6.0: This step describes operator actions for a SW pipe rupture due to a seismic event. Neither this step nor any othe step in the procedure addresses operator actions required if the SW tunnel is flooded. USAR subsection 9.2.1.2, " System Description," for the SW system states that when the flood level in the SW tunnel' increases beyond elevation 576, the SW pump area will be affected via the common drain system for the tunnel and the pump room. The USAR states that a sump level alarm will advise the operator of the condition and the drains will be sealed to protect the SW pump The inspectors verified that the sump level alarm was functiona The USAR states the essential equipment in the SW tunnel and valve rooms will not be adversely affected due to flooding. The licensee documented the deficiency with a Potential Condition to Quality Report. Additionally, the licensee took steps to provide for increased operator awareness of potential flooding, as well as compensatory measures necessary to protect the pump roo Tue procedure should be revised to include steps necessary to seal the drains and protect the SW pump are f. Step 6.3.1.b: This step requires manual operation of valves SW 43 and SW 44. These valves are in horizontal pipe about 15 feet above the room floor, and can only be reached with a ladder (not installed) or by climbing on other equipment to the SW pipe and then crawling along the pipe about ten fee Later, step 6.4. informs the operator, indirectly, that there is enough time to bring in a ladder for access to the valves. The licensee should evaluate access requirements for these valves. Step 6.3.1.b. also requires that valves SW 14 and SW 15 be manually close Thece valves are locked open and the procedure should be revised to so indicat . AB-1203.18 (DB-OP-02512), Loss of Reactor Coolant System Make-up a. Step 3.1.1: The use of the term " verify" both make-up pumps 1 and 2 5 _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - . _ - _ _ -

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  .off, does not accurately describe Ehat the operator has to d The-y  '
  ' operator should evaluate;the;make-up pump operating status, rather-g   than simply verifying pumps are off. 'The licensee should evaluate L the-desired operator action and. revise the procedure as necessary.to '

T clarify this ste Step 3.1.12, Details: The instruction states that'once pressurizer

  ' level is correct: for the existing ~1evel, place LIC-RC-14 in AUT However, this does not take into account the need to adjust thei
  ' level. controller setpoint. .'If this.is not done, MU 32, make-up flow control' valve will go open to try to achieve normal operating' levels as illustrated on Graph CC-4.3 (located on panel),. Pressurizer Level versus. Reactor Coolant System Temperature. 'The licensee should'

evaluate this' instruction and revise as necessar ' Step 3.1.15: This instruction does not' refer to'the Emergency Plan, but, the Attachment 1 Flowchart for Loss of Make-up Pump (s) does refer the' operator to the Emergency Plan. The licensee:should revise the procedure and'or flow chart such that they are the sam Step 3.1.18: The instruction tells the operator to commence a

  " Controlled" shutdown, but the Attachment 1 Flowchart for. Loss of Make-up Pump (s). instructs the operator to commence a " Rapid"
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shutdown. The licensee should revise the procedure and or flow chart such that they are consistent, ' Step 3.2.1, Details: The instruction states that the. operator is not to use the Make-up 6420. controller bypass as a throttle valve unless

  " absolutely necessary," but MU6420 is not discussed in the actions steps. The licensee should evaluate revising this instruction to be a note or caution rather than a simple statement, since the use of the' bypass could result in valve damag Step 3.2.5: This instruction which refers to a " leak" is not consistent with Step 3.2.6 that refers to a " leak" or " valve failure." The licensee should revise this step to address the valve failure concern as well as the leak concer Step 3.2.6: This step concerning the verification of an " isolable" leak or valve failure should come before Step 3.2.5 which provides the operator with instructions for what to do when the leak is not isolable. The licensee should consider switching Steps 3.2.5 and 3. l Step 3.2.8: The instructions in this step are not the same as Attachment 2: Flow Chart for Loss of Normal Make-up Flow Path. The

_ flow chart and the step are.both ambiguous with regard to which pump to start. This instruction should be revised to instruct the ) [ operator to start the unaffected make-up pump if the failure ' location is not common to both make-up pump Attachment 1: Flow Chart for Loss of Make-up Pump (s): Step 3.1.15 does not match the text instruction because it instructs the operator to refer to the emergency plan. The licensee should revise

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I the text instruction and/or the flow chart to be consistent.

, Attachment 1: Flow Chart for Loss of Make-up Pump (s): Step 3.1.18 ' does not match the text procedure because it instructs the operator to conduct a rapid shutdown versus a controlled shutdown referred to in the tex The licensee should revise the text and/or the flow chart to be consistent, Step 3.2.5: This step is not consistent with Attachment 2: Flow ) Chart for Loss of Normal Make-up because it does not mention a  ! radiological hazard that is identified in the flow chart. The text and/or flow chart steps should be revised to be consisten . Attachment 2: Flow Chart for Loss of Normal Make-up Flow Path: Step 3.2.5 is inconsistent with the text step because the flow chart identifies a radiological hazard that is not discussed in the tex The text step and/or flow chart step should be revised to be consisten I

            ' Attachment 2: Flow Chart for Loss of Normal Make-up Flow Path:

Step 3.2.5 instructs the operator to take actions based on a leak that is not isolable before the step 3.2.6 that instructs the operator to determine if the leak or valve is isolable. The verification of leak or valve isolable should precede actions taken when operator determines that the leak cannot be isolated. The flow chart and or step should be revise to be compatibl Attachment 2: Flow Chart for Loss of Normal Make-up Flow: Step 3.2.8 logic flow into Step 3.2.9 is inconsistent with the text procedure. The logic flow line should bypass step 3.2.9 and enter directly into 3.2.10. The licensee should revise the steps and/or flow chart to be consisten Step 3.2.4: This instruction does not take into account the new control room operated valves MU 6409 and MU 6408 that can be used to isolate alternate make-up injection flow paths. These valves could reduce or eliminate the need to isolate the leak or valve failure locally. The licensee should evaluate the effect of the new valves and revise the procedure as necessar Steps 3.2.5, 3.2.6, 3.2.7, and 3.2.8: These steps do not clearly lead the procedure user to a rapid identification of the make-up system problem and corrective actions. These steps should be reevaluated as a group and revised as necessary to indicate more clearly the method to be use . AB-1203.19 (DB-0P-02513), Pressurizer System Abnormal Operation 1 Step 4.4.4.4.2: The 2300# setpoint for a Reactor Trip has been changed to 2355#. The step should be revised to reflect this setpoint chang Step 4.4.3.c (page 12): The PORV Block Valve was closed in step 4.4.3.b. The licensee should evaluate revising this step to include

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opening the PORV Block Valv Step 4.4.3.d (page 12): Same as item b abov Detail 4.6.3.c.1 (page 16): This step compares two of the three level indicators. The licenree should evaluate revising the step to compare all three indicators as this would be a more appropriate operator action. Also the switch reads LT instead of L Step 4.7.3.a the second bullet: This step attempts to balance make-up flow with losses from the RCS. The licensee should revise the step to include "RCP Seal Leakoff."

, Note 4.7.3.c: This step instructs the operator to change pzr level to 180 inche inches is an outdated setpoint. The licensee should evaluate revising this step to read "200," the normal operating z leve Step 4.7.3.d: This step attempts to add borated water to account for contraction due to cooldown while maintaining pressurizer inventor The licensee should evaluate revising the step and the chart to add 1000 gallons of borated water from the 28% power Tc down'to cold .: shutdown. That amount should be added at approximately every 15 to 20 degrees incremen . AB-1203.20 (DB-0P-02514), Loss of Turbine Plant Cooling Water Pump (s) General: This procedure addresses only a pump proble It should also address correction of a control valve problem. The procedure is wordy due to mixing text with instructions. It should use concise instructions that are separate from descriptive material. The license should evaluate revising this procedure to cover valve problems as weil as to remove the discussion material to another locatio Step 3: This step contains the words "High Level Cooling Water Tank." This is unnecessarily long. Use "HLCWT." This is defined in Step If it is to be defined, it should be defined at the first usage, Step 3.1: This step references the pump discharge valve. This valve, which must be operated locally, should be identified. The step should be revised so that it is written as an instructio Step 3.2.1: This step contains a numbar of instructions. The licensee should revise this step to contain only one instructio Step 3.4 item 1: This item requires an immediate transfer to !. DB-PF-02000. The licensee should consider revising the procedure l such that item 1 & 2 are performed prior to exiting the procedur . AB-1203.21 (DB-0P-02515), Reactor Coolant Pump and Motor Abnormal Procedure

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. Title: The old title number, AB-1203.21 is used on the title page of    !

this procedure, but, the new number DB-0P-02515 is not used. .The  ? new procedure numbers should be used in order to be consistent with 't other upgraded abnormal procedure !

*' Step 1.3.1, Details: The reactor coolant pump seal injections flow     i indicators for each of the four pumps are identified by. computer     l point, rather than control room instrument number In order to be
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consistent with other abnormal procedures, the control room' i instrument numbers, FI-MU-30-C for 1-1 pump, FI-MU-30-D for 1-2-pump, FI-MU-30A for 2-1 pump, and FI-MU-30B for 2-2 pump should be used in the detail sectio Symptoms, Step 1.1.1: Same comment as ! Symptoms, 2.1.1: Same comment as Step 2.3.2: The reactor coolant pump seal injection flow meter j instrument numbers are not listed in the Details section of the  ! ste In order to achieve consistency with the presentation of seal  ; return temperature instrument numbering, the instrument numbers for seal injection flow meter numbers should be liste i Symptoms, 3.1: Same comment as ] Symptoms, 3.1: The symptoms for loss of component cooling water to- , all reactor coolant pumps can apply to component cooling water i

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faults, as well as specific faults in component cooling water to the reactor coolant pumps. This can mislead the operator to investigate the reactor coolant pump cooling water problems instead of evaluating the source of the problem which may be loss of component cooling water system. The licensee should evaluate placing a note or caution preceding the symptoms section that references the ,

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component cooling water malfunction procedure, DB-0P-0252 Symptoms, 4.1, 5.1.1 and 6.1.1: Same comment as . AB-1203.23 (DB-0P-02516), CRD Malfunctions  ! General: This procedure is limited to single rod problems; the team was unable to identify a procedure which covered multiple rod equivalents. The licensee acknowledged the problem and indicated that a revision had been initiated prior to this inspectio Additionally, a standing order covering the multiple rod drop case had been issue I Step 4.1.3.b: This step does not contain the " Refer To" item in the l action column that is contained in the detail column. The licensee should revise this step to place the " Refer To" entry in the action colum Step 4.1.3.f: The GO TO instruction in 4.1.3.e carries the operator to Attachment 2 with no return path. The licensee should evaluate if this transfer should be a " Refer To" in order to continue with

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step f-if time exceeded.30 minute ') Note 4.1. It appears that the note should precede 4.3.1.g or j be inserted in the.beginning as a general not ) 1 Caution 4.1. Same as abov ' f. Step 4.1.3.k detail: The term "Asymetry Bypass Switch" is not used y at the cabinets nor at the control room panel. The licensee should ' revise the step to use the correct terminology or modify the switch labe Step 4.1.3.k: The modules in the cabinets are labeled by core location, not rod number. An ID matrix is located in cabinet 4 but not in all cabinets. The licensee should provide this table in each cabinet or label the modules in some other manner to provide for ease of identificatio . 1 Step 4.1.3.m: This step is ambiguous and should be clarified to indicate whether the phrase "for remaining rods" applies to those in the group or all rod Step 4.1.3.n: The GO TO transfer to 4.1.3.k causes an improper shift in TS LCOs 'and initiates a procedure loop. At sub step n, the rod bypass switch is already in bypass; thus, step k will always be not applicable and the operator will proceed to step 1 which shifts LCOs from 4 to 12 hour group average computations whi:h is incorrect. Thereafter, the procedure loops, n to k to n et The licensee should revise this step to remove the loo Step 4.2.3.c: This step instructs the operator to remove the rod programmer fuses. When the team went to the cabinetc to check this step, safety groups 1-4 programmer fuses were already pulled. The team determined this was in accordance with approved plant drawing This procedure should be revised to reflect this lineup, Step 4.2.3.c Detail: The cabinets are not labeled with cabinet numbers shown in the procedure. The licensee should add ID labels to these cabinet . Step 4.3.3.c: The licensee should clarify the meaning of "is actually repositioned." This caused confusion during walk-throughs and only after much thought did the operator conclude that it covered the case where indication was operable but the rod was out of positio . AB-1203.24 (DB-0P-2517), Circulating Water Pump Trip / Circulating Water System Ruptures Steps 1.1.2. and 2.1.2: These steps list computer point alarms F090 and F091, " CIRC WTR PIPE I and/or 2 FLOW" as symptoms for using this , procedure. When these computer points were called up, the control ' room CRT that normally displays computer alarms indicated that they l were invalid points. The operators called the points up on another i '

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i control room CRT and the display indicated that the points were inactive and would not provide an alarm. The licensed operators in 1 the control room could not recall these points ever being operational. The Instrument Index lists the " service description" for the instruments that would actuate these alarms (FSL 736/737) as

 " deleted." Steps 1.1.2. and 2.1.2. also list computer point alarm L147, "CLNG TWR SCRN OUT LVL." The instrument that would actuate this alarm is LSL 807 which senses the level in the circulating water canal. The canal is full. However, when this point was called up, the control room CRT display indicated that the canal level was lo This computer point was set so that it would not provide an alarm on the control room CRT, although it would print on the control room alarm printer. These indications should be repaired or replace Step 2.4: This step describes operator actions if there is uncontrolled flooding caused by a rupture of circulating water piping. Neither this step nor any other step in the procedure addresses operator actions required if the SW tunnel is floode Uncontrolled flooding of circulating water in the condenser pit that reached an elevation of about 578 would flood the SW tunnel and the SW pump room without operator action. This omission should be     j corrected. It appears that this omission was caused by the error     'I described in c. belo Step 5: This step utocu. es the reasons for the procedural action The procedure states that flooding the condenser pit to elevation 582 would not affect essential areas. This concept is consistent with USAR subsection 3.6.2.7.2.13, " Circulating Water System," which states that "There are no paths for water to escape belew El. 585."'

However the inspector observed an opening (about six square feet) between the condenser pit and the SW tunnel at about elevation 57 The USAR postulates that a large circulating pipe rupture could fill the condenser pit to elevation 585 in 71 seconds. The licensee documented this error in the USAR with PCAQR 89-0083. Additionally, the licensee took compensatory measures to protect the service water pump room. The licensee should evaluate this condition and take appropriate corrective actio . AB-1203.26 (DB-0P-2519), Serious Control Room Fire General: The Serious Control Room Fire procedure has not been tested with a full operating staff. A full operating staff in the context of this procedure includes the: o Shift Supervisor

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o Assistant Shift Supervisor o Reactor Operator 1 o Reactor Operator 2 o Equipment Operator 1 o Equipment Operator 2 o Administrative Assistant o Shift Technical Advisor o Instrument and Control Mechanic

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o Electrician o Chemistry Tester

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o Five Member Fire Brigade The procedure requires operator tasks in the first six attachments that are extensive, drastic, and require complex communications coordination. The licensee should evaluate the performance of these tasks and walk-through the procedure with a full operating staf . AB-1203.28 (DB-0P-02521), Loss of AC Bus Power Sources Step 3.12.2: "...per Step 3.11.1 above..." should be "...per Step 3.12.1 above...". ) Step 3.15: "

      ... shutdown the the temporary..." should be "... shutdown the temporary..." Step 4.4: This step lists ten valves to be locally checked. These valves should be listed in order of importance and locatio Step 4.10: This step lists valve MU 6419 as a valve to clos MU 6419 is an electric motor operated valve which will have no power at      t this point in the procedure. Therefore the procedure should indicate that MU 6419 must be manually close . AB-1203.29 (DB-0P-02522), Small RCS Leaks Step 3.7 Detail: It appeared that all information afte'r the second bullet should be contained in a not Step 3.14 Actions: This step leads the operator observing indication to identify the source of a leak. With a leak, observing. indication and welk-through are both desirable and not mutually exclusive. The licensee should revise this step to require both actions concurrently, Step 3.20 Action: The detail side indicates the intent is to verify      ,

the equipment has operated properly. The statement on the action l side merely refers the reader to the procedure for a list of equipment which should be operating; the requirement for verification was missing and should be state . l Step 5.0, first paragraph, line 6: The step is too encompassing as  ! stated. The phrase "...or SFAS actuation, ..." should be limited to l SFAS 2 and abov Attachment 1: The procedure directed that all valves listed be l closed. No mention is made of reopening valves on unfaulted l systems. During the walk-through, the operator indicated that the intent of Attachment 1 leak isolation was to restore unfaulted systems to service. This intent was confirmed with the licensee's training staff and operations management. The procedure should be revised to make restoration of unfaulted systems a directiv ______ __- __-_______ - _ - _-__ -

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19. AB-1203.31 (DB-OP-2523), Component Cooling Water System Malfunctions Step 1.3.2.3: This step requires manual operation of valves (SW 232, SW 233, SW 234, SW 236 and SW 237) that are in a potentially contaminated area. The licensee needs to establish a policy balancing the risk of minor contamination with the need to operate such valves quickl Step 1.3.14.1.5: This step states that valves CC 5097 and CC 5098 should both be open. Either valve may be opened but both valves should not be opene Step 1.3.14.1.6: This step directs the operator to monitor CCW surge tank levels. This step should be placed earlier in the procedure, Step 2.1.2: This step had the computer alarm point designation reversed for the CC RET LINE I and 2 RAD HI alarm Step 2.3.3: This step should indicate the location of valve DW 6 *

' Note 4.3.8: This step states that valve CC 1567 B is located in
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CTM It is no Step 5.3.2.d: This step should have "2-2" instead of "2-3." Step 6.1.2: This step does not list computer alarm point Z 122, CC pump 3 of Step 6.3.3.4, Details: This step should have "...line up the Backup SW Pump..." instead of "...line up line up the Backup SW Pump . . . ." Step 6.3.3.9, Details: This step should have computer point T 068 listed instead of T 063 for CCW heat exchanger 1 outlet temperatur The inspectors also noted numerous other minor nomenclature and and editorial errers in this procedur . AB-1203.33 (DB-0P-02525), steam Leak General: The procedure lacks specific direction, and is confusing in several points. The procedure needs to be rewritte , Step 3.2: Directions should specify as to what action is to be taken by the operator if the steam leak is not a " Safety or Personnel Hazard". Where does he go if it is a MSSV lifting? Step 3.2.2: The step needs to be formatted differently in order to clarify the "IF" "THEN" actions to be take Step 3.2.2: The step needs guidance on specific actions to take if SFRCS has not isolated the lea :

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, Step 3.2.3 Detail: The phrase " Restore" control power with HIS "

should appear above SG 1 - AF 608 and SG 2 - AF 599. These. valves will not operate without control powe Step 3.4: This step needs to provide better guidance on plant cooldown for a leak in the CTMT annulus. Consideration should be given to opening the AVVs on the affected SG if it can be identified-and cooldown as rapidly as possible. Note that allowing the AFW Pump to block (fill) the break also fills the SG thus lengthening the time to blow dry, Step 3.7: The last line in the paragraph contains a typo. The sentence reads " continue with 3.7." It should read " continue with 3.8."

21. AB-1203.34 (DB-0P-02526) Steam Generator Overfill Step 2.0: Since the symptoms are not mutually exclusive, the OR gating between steps appears to be inappropriate. The licensee should evaluate the OR gate and revise as necessar Step 3.9.1, Detail: The information here should be entered as note, caution, or warning to conform to the Writer's Guide. The licensee should evaluate the information and revise as necessar . AB-1203.35 (DB-0P-02527), Loss of Decay Removal System General: The teams review has not addressed generic letter 88-17 aspects and impacts upon this procedure. The licensee indicated that portion of the procedure will be rewritte l This procedure needs to be rewritten to provide more specific

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guidance to the operators. The procedure in its present form does not completely address all possible scenarios. The situations that are addressed are not covered in detai Table of Contents: The procedure has no table of contents. The licensee should provide a table of contents consistent with the Writers Guide, Step 1.0: List fluctuating pump motor current as a potential sympto Step 1.4: The instruction lists one uncompensated pressurizer level instrument, LI-RC-14-4, but does not list the other meter LI-RC-14-3. Both instruments should be listed in this instructio I Operator Action, 3.0: Caution 3.1 refers to action step 4.1.2, but ' ' caution and notes should not have action steps embedded in the !

        ! Step 3.1.2: Designate the valves to be manipulated.

L Step 3.1.2: The last sentence should be a CAUTION and should appear near the front of the procedure. It is applicable throughout the L procedur _ _ _ _ _ _ _ _ _ _ _ -

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L ' Step 3.1.3: This instructs the operator to verify CCW flow to the l-DH coolers. There are no flow meters with which to comply with this  ! instructio Give specific guidance as to the available  ! instrumentation and valve position indication that is required in Checking the CCW system for flow thru the DH cooler , 1 Step 3.1.4: This, in part, states "IF a rupture has occurred, THEN attempt to isolate the rupture ...." This is not sufficient guidence. One approach would be to trip the DHR pump (s) and. isolate everything (valves should be specified). Then an un-isolation could l be done one item at a time starting with the DHR system. There should probably be an applicable LOCA procedure or it should be built into this procedur Step 3.3.1: Restructure the step. The number of qualifiers in step 3.3.1 makes it confusin NOTE 3.3.1: The note is inaccurate; in particular the reference to unnecessary and excessive depletion of the BWS . Step 3.3.2: The initials OSTGs should be OTSG Step 3.3.2.b.4: The statement cautioning the operator not to exceed seal injection temperature of 120 F is a caution, not an actio The cautions should be identified separate from the action step Step 3.7: Note 3.7 comes after the action step. The note should  ! precede the action in this ste Discussion, 4.1.2.b, Step 1 to 25: These action steps are included in Discussion section. Action steps should not be included in the discussion sectio . AB-1203.36 (DB-0P-2528), Loss of Instrument Air General: The licensee should evaluate placing a caution near the front of this procedure that indicates the air pressure at equipment may be lower than indicated at the air compressor header (Note the trip during the fall of 1986.) Step 3.1: This is the initial action of this procedure. It is written in text format and consists of one sentence. It reads as follows: "IF ... AND ... have NOT ..., THEN ..., ... AND MANUALLY start ... AND ...." inis arrangement should be improve References to other procedures in this step c uld be provided in the DETAILS column to reduce instruction complexity, Step 3.4: This instruction begins " Send an operator to ensure ... is closed by checking position indication on ... IF NOT THEN MANUALLY isolate ... by closing or verifying closed ...." All instructions are packed into text format. The logic steps should be separated to reduce the chance of mistake and the wording should be edite I _- - ._ . _ _ _ _ _ _ - - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ -

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l Step 3.5: The valves should be listed.in the ACTION (See also item e., below.) Steps 3.5.1 - 3.5.3: The valves should be addressed in the same order as introduced in step Step 3.7: Ensuring that filters are "in service und operating properly" is not a satisfactory instruction. The licensee should revise the instruction to provide concise steps with acceptance criteria for placing the filters in servic NOTE 3.9: This note contains actions to be taken and should be an l action ste Steps 3.12.1 and 3.12.2: These should be combined to ensure both are performed prior to going to the E0 Step 3.14: This is not a suitable instruction. The DETAILS  ! identifies Attachment 2, but fails to identify Attachment 3, which  ;

 .may1be the list to use under some circumstances (see item k, below). CAUTION 3.15: This should be a NOTE if it is retained. Since the following ACTIONS appear to be prioritized, rewording the procedure as recommended shoulo allow rapid passing of items where no action is needed. The NOTE should probably be shortened and should. address simultaneous addressing of problem . Step 3.15: Either Attachment 2 or Attachment 3 would be suitable for this listing with the addition of a column to indicate the action. Only one Attachment should normally be used to avoid later confusio . Step 3.17.5: This step should use " slowly open" when appropriat This comment applies to other locations in the procedure as wel Step 3.18: This references MU 3. This is a "left-handed" valv The licensee should identify this characteristic AT THE VALVE and in the procedur Step 3.19: See item 1, abov Step 3.21.1: The " DETAIL" is an ACTION that is to be followed   '

i during the time natural circulation is used for cooling the reacto This should probably be addressed within the step 3.21 referenced procedure. The last bullet under DETAILS does not seem appropriate for the conditions present. The licensee should evaluate these conditions and revise as necessar Step 3.22: The second sentence of DETAILS is an ACTION and should be addressed as such.

l Step 3.26: This does not recognize that this would cause loss of l decay heat removal if the DER system was in operation. Also note l the large number of ACTIONS included in the DETAILS section, j

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. Step 3.35.4: This incorrectly references valve CD 176. The correc ,

valve is CD 7 i Step 3.35.5: This incorrectly references CD 6 This should be CD 963.

< Attachments 2 and 3: A noun /name column should be adde Providing valve numbers is insufficient for operators to locate valve . AB-1203.38 (DB-0P-2730), Fuel Handling Accident I General: This procedure has no table of contents. The licensee should provide a table of contents consistent with the Writers Guid . AB-1203.40 (DB-0P-02531), Steam Generator Tube Leak Step 3.8: The detailed discussion is incompatible with the definition of a steam generator tube leak as defined by Emergency Procedures (DB-PF-02000, Step 1.4). The detailed discussion implies that the operator would only have a tube rupture if the leak rate exceeded the. capacity of 2 make-up pumps. However, if the operator 1 had only 1 make-up pump available, he would have a tube rupture if he exceeded the capacity of 1 make-up pump. Therefore, the definition of tube rupture vs. tube leak should be a function of make-up availability. The licensee should evaluate this definition and revise as necessar I NOTE 3.10: This note is ambiguous because it instructs the operator to assess whether or not a steam generator tube has " reasonable i leakage." The ambiguity should be removed by clarifying the volume of leakage that constitutes a reasonable leakag ;

      ' Step 3.28: This step instructs the operator to cooldown to less than 500 F in the cold leg, but, it does not instruct him to cooldown to cold shutdown. This step should be revise to instruct the operator to cooldown the plant to cold shutdown, Steps 3.29, 3.34, and 3.40: An action step to exit this procedure is located on the Details side of the page, in addition to being on the Action side of the page. The action instruction for exiting this procedure should be combined within the action steps, Step 3.35: The transfer to this step is from step 3.25 where either pressurizer spray or RCPs are unavailable. Thus, one can reach step 3.35 with RCPs available and pressuri.:er spray unavailable. The depressurization test of Th of 520 F appears to apply to the case of no RCPs. The licensee should examine the appropriateness of this test and should correct the step if found to be incorrec .0 Discussion: The statement that this procedure is designed for Steam Generator tube leaks within the capacity of the make-up system (2 pumps, 1 line) is not consistent with the tube rupture definition in the Emergency Procedures. Tube rupture versus tube leak should

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be a function of te wr-up availability, which is defined by 1 or 2 pump Attachment 4, Step 2 NOTE: This note should be located before the applicable instructions in Step . AB-1203.41 (DB-0P-02532), Loss of NNI/ICS Power Table of Contents: The Table is incomplete. There is no mention of section 3.1.2 and section 3.4.3, but there is a 3.1.3 and a 3. The licensee should correct the table of content b SYMPTOMS for Loss of ICS AC Pwr: Add the following Annunciator Alarms if they are found to be correct after checking the electrical print "ICS Input Mismatch 14-6-B," "ICS Input Transfer," and

 "ICS In TRAC 14-3-C." The alarm tiles are a more readily available source of information to the operator than the computer would be in the diagnosing of an ICS failure, Step 3.1.2.c.: Add "by using HS 15" to the procedural step. This will give the operator guidence'on how to transfer PZR temperature to TE2 ! Details in Step 3.1.2.b and 3.1.2.c: Rewrite the detail to inf rm the operator which pressurizer level indication to use. Thi. will aid the operator in performing his tas Step 3.1.2.g: Make the step and meter indication match. The step   ,

J refers to MUT LI MU 16-2 in inches, but the meter actually reads in percen ! Step 3.1.2.j: Supply the operator a complete list of all NNI switches that he is expected to operate. As the procedure exist ,

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there are several switches to operate and the operator has no guidanc Step 3.1.2.m: Reword the step to reference the Post Accident , Monitoring Panel for temperature indication. Remove the reference to  ! Natural Circulation since the RCPs are running and have not been stoppe Step 3.1.2.m: Use the Post Accident Monitoring Panel for indications of Th and Tc. The existing procedure uses computer points T720, T729, T801, and T841 for indications of Th and Tc. The computer display may be needed for other information at that time. Also the PAM Panel is more accessibl Add step after 3.2.1.h.4: Add a new step to read " Verify bypass flow of 11 to 15 gpm by observing flow increase on FI 6425." This would be consistent with step 3.1.2. Detail of step 3.2.1.h : Change the detail to read "18 inch" auto transfer of Mull back to the MUT is disabled by loss of NNI X D This will identify which transfer the operator is to be aware o :

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k. Step 3.2.1.n.1: Reworded the step to reference the Post Accident Monitoring Panel'for temperature indication. Remove the reference to Natural Circulation since the RCPs are running and have not been stoppe . Step 3.2.1.n.1: Use the Post Accident Monitoring Panel Th and Tc indications and not the computer points for these temperatures. This step uses computer points T720, T729, T801, and T841 for' indications of Th and Tc. The format should be changed to agree with step 3.1. m. CAUTION 3.3.1.b: The caution contains a typo. It should read FI-MU7, oot MU-F1 n. CAUTION 3.3.1.b: This step contains an action statement. Take out the statement'"The operator should ensure that two purification demineralizers are in service to avoid exceeding 70 gpm through a

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single purification demineralized."

o. Step 3.3.1.d: This detail is the only place in the procedure that identifies panel location. Make the procedure consisten p. CAUTION 3.3.1.e.1: The caution contains two typos which should read FI-MU 34 and FI-MU 3 ~

For the High HU flow alarm, give the tile location (2-6-0). l

* q. Step 3.3.1.g.2 detail: This the only place in the procedure that references the TS. Make the procedure consisten l l

r. Step 3.3.2: The first bullet contains a typo, it should read NNI-Y not NNI- s. CAUTION 3.4.2.a: Remove the statement "The operator must take immediate action to reduce reactor power to restore rod index and Tave." The statement is incorrect as written. The addition of Boron will cause reactor power to decreas t. Step 3.4.2.a: Remove the detail, it is not necessar * u. Step 3.4.2.b.3: Evaluate if this step is needed. If it is needed, change the step to read " Throttle MU-19, seal injection supply to provide 12-16 gpm RCP seal water flow as read on FI-MU 19." FI-MU 19 is located on the panel next to the controller the operator is controlling, the present procedural flow indication are on the back panel, v. Step 3.4.2.b.5 detail: Evaluate if MU-4 or MU-6 has maintained power in this section of the procedur If MU-4 or MU-6 has maintained power then use MU-4 or MU-6 for let down control. They can be controlled from the control board instead of out in the plant. If MU-4 or MU-6 can be used, then delete step 3.4.2. w. Step 3.4.3.b: Verify that F736 is not supplied from NNI Y DC. If F736 is a good indication, change the step to read "If the Batch l

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Controller. Display and computer point F736 are not available." If computer point F736 is a good indication, then it would not be necessary to operate a throttle valve out in the plan Step 3.4.4, the last bullet: This statement is inappropriate and needs to be removed from the tex Step 3.5.1.a: The detail references contacting the NNI/ICS system engineer. The reference should be consistent throughout the procedur Generic comment: The wording in the detail sections gets confusin Simply list the instruments that have failed and which ones the operator is to us . AB-1203.13 (DB-0P-02534), High Airborne Activity or Radiation Levels Step 3.5.2: Specify to whom Health Physics reports the results of the survey or grab sampl NOTE 3.5.4: Replace REPS with RWPs and C&HP with Chemistry and R The Titles have change Step 3.5.4: Remove REPS and insert RWPs. The title has change . DISCUSSION: Remove the discussion and incorporate the necessary information into the body of the procedur ATTACHMENT 1 B.3: Remove the phrase "using linear interpolation," and insert the phrase " default to the next highest reading." This ,

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would greatly simplify the operators actio ATTACHMENT 1 Table 1: Break the table down into 10% rates. This would result in a faster and more accurate response by the operato ATTACHMENT 1 Table 2: Break the table down into 10% rates. This would result in a faster and more accurate response by the operato ATTACHMENT 2 A: Background: This is not a background, this is part of the procedure and should not be delineated as " Background." ATTACHMENT 2 A.1.a: Rewrite the formula to incorporate the conversion for converting CFM to CC. (28317 cc/ft3). This would remove a procedural step, clarify the procedure, and reduce the possibility of an erro Give a conversion factor to put ATTACHMENT 2 Release in the same units as the Emergency Plan in which it is to be used, General comment: The procedure is accurate, but there is a lot of unnecessary information in the procedure, and it is not organized in a user friendly manner. The procedure needs to be purged of discussion type of information and to undergo a complete rewrit _ _ _ _ _ _ _ _

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' 28.'AB-1203.30 (DB-0P-02535), High Activity in the Reactor Coolant System

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' General: The format of this procedure is inconsistent with many of the other procedures. Rewrite to provide a concise set of instructions for the operators, with supplemental information where needed to provide a perspective, Step 1.1: Provide alarm identification Step'3.2.1: Rewrite the step to eliminate double negative Item 4: The last paragraph is not neede . AB-1203.14 (DB-OP-2536), Toxic Gas and Liquid Release l . Step 3.3 Personnel Actions: Change the heading title. This section should not be specific to individual positions since it should be understood that the Shift Supervisor has the responsibility for overseeing the procedur Step 3.3.2.1: Add two new step (1) Announce over the gaitronics that a toxic gas condition exists and warn plant personnel to stay clear of the are (2) Sound the initiate emergency procedures alarm from the control room to assemble the first aid team IF' an injury has occurre Step 3.3.2.5: State a method in the procedure of identifying and locating the chemical supplier, Step 3.3.2.7: EI 1300.01 no longer exists. The facility needs to provide a new reference to the E Pla Step 3.3.2.8: Guidance is needed to quantify what is meant by larg Step 3.3.2.9: Guidance is needed to quantify what is meant by smal , i Step 3.3.4.3: Change the step to read " Emergency Director," instead

        ' of the EDO, the title has been change Step 3.3.5.1: Change the step to r'ead " Emergency Director," instead of the EDO, the title has been change i Step 3-.3.6: Change the step to read Emergency Director, instead of   !

the Emergency Duty Officer, the title has been change Step 3.3.6.4: Guidance is needed to quantify what is meant by large, Step 4.3: Remove the step, the system has been physically remove j Step 4.4: Delete the first paragrap _ _ __ _ _ ____________ -

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. Step 5.2.2: Remove the statement in parentheses. The EP designates who can relieve the S Step 5.2.2.1: A new reference to the E Plan is needed. EI 1300.01 does not exis Step 5.2.2.1: Remove the NOTE, the Emergency Plan dictates how to assemble and evacuate peopl Need new procedural references in steps 5.2.2.2, 5.3.2, 6.2.2.1,.and    l 6.2.2.2. due to the new numbering syste . DB-0P-06903, Plant Shutdown and Cooldown Page 11 is missing from the procedure. Both copies received from-document control were missing page 11. The bound controlled. copies in the NRC Residents Office also had page 11 missing. The last step on page 10 is 3.20, and the first step on page 11a is 3.28. Steps 3.21 thru 3.27 are apparently missing. Evaluate the effect of the missing.page and correct as necessary to ensure correctness and completeness of the procedur NOTE 4.4.14: The note contains a typo, the Turbine Trip is in 4.4.14, not 4.4.1 NOTE 4.4.15: The NOTE should require " Verify all Turbine Stop Valves or Control Valves closed." NOTE 4.4.18e: The note contains a typ The note should read
 "4.4.18.g." NOTE 5.4.13: Split the first note. The note contain RPS actions and SFRCS actions. Combine the SFRCS actions with the second note of step 5.4.1 NOTE 5.4.13: Relocate the note. The first half of NOTE 5.4.13 really applies to step 5.4.1 Step 5.4.16: Include a "Go To" statement directing the operator to DB-PF-02000. The step reads " Trip the Reactor". Since all the control rods are already in, an operator may not realize he is to go to DB-PF-02000, Step 5.4.27: This step contains a typ The step should read
 " depress the 400# Trip Block Push Button". Step 6.4.11: The step should state "if applicable." The RCPs may have been stopped in step 6.4.1.b.5.d page 5 Step 6.4.19.f: Why not use incores to input Tsat? Which indication is being used for 20 deg. sub cooling, the Tsat meter or the vent line temperature? The Vent line temperature is going to indicate a    i superheated temperature IF a void is formed and the void is    '

compressed and the temperature detector is in the void area, thus

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decreasing the indicated degree of sub coolin Step 6.4.19c: This. step has the operator maintain pressure within P-T limits, step 6.4.19.e says if <20F sub cooled to increase pressure

;        until 20F sub cooling is achieved. Does this mean that you can P-T lit its can be violated?

Step 6.4.19: Steps b and g conflict. Step b increases MU by starting the second MU Pump. Step g maintains pressurizer level <85 inches. If , 84 inches was being maintained in the pressurizer and subcooling was -l lost which drew a bubble in the head causing pressurizer level to

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increase to 95 inches, WHICH would have priority, getting the pressu-rizer level'back to 85 inches or increasing MU with the second MU Pump? Step 6.4.19: If'2 Make Up Pumps are started delivering 500 gpm total flow.and the Pressurizer level at 85 inches water would be discharging into the containment sump in 11.5 minutes. Decay Heat Cooling is functioning properly with 3000 gallons a minute flow. The core could be cooled if Decay Heat Cooling flow were directed through the heat exchange It would be more appropriate to direct flow through the Decay Heat Exchanger, than perform step 6.2 NOTE 6.4.22: Applies to 6.4.2 Place the note in front of part . CAUTION 6.4.22: Delete the caution. The purpose of the caution is not clear, and it is misleading at this point in the procedur ; The Caution Reads "If MSIVs are closed, avoid SG overfill during-  ! fill operations. DO NOT go to wet layup levels until Step 6.4.28."

! l CAUTION 6.4.27 says to vent the SG using AVVs if necessary if the > MSIVs are shut. The T.S. for SG 1evel is 18" to 345" in mode Mode 5 isn't entered until step 6.4.2 Step 6.4.33: Delete the step. The s.uction check valve in each of the Decay Heat lines has been replace Step 7.4.1: The step contains a typo "THR" should be " TRIP." Step 7.4.3: Change the last sentence to read "THEN return to MFW  ! feeding by performing the following." The following steps are the action necessary to transfer to MF i i Step 7.4.4: Combine step 7.4.2.c with step 7. j l Place step 7.4.5 after step 7.4.1. Step 7.4.5 is used to recover a dry SG and step 7.4.1 addresses a dry SG. Step 7.4.2 is for cool down of an isolated SG with level and pressur Add a new step instructing the operator to reopen AF-6451 (AF-6452) prior to step 7.4.5.k. AF-6451 (AF-6452) AFP flow control valves i

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were closed in step 7.4.5.h. Otherwise he will not get any flo Add.a new step instructing the operator to reopen MS-106 (MS-107) prior to step 7.4.5.n which instructs him to shut MS-733 and MS-72 MS-106 and MS-107 were. shut in step 7.4. Step 8.4.2.f: This step should reference the J-H portion of the curve CC 1.14 of DB-PF-06703 NOT the A-C portion of the curv Step 8.4.2.f: The second paragraph should reference the G-H portion j of the curve CC 1.14 of DB-PF-06703 NOT the A-B portion of the curve

' NOTE 8.4.2.F: Delete the note or respond to the following remark There is no A-C portion of curve CC 1.14. If curve A-C existed, is     ;

that a maximum or a minimum pressure? Is the limit with or without the Decay Heat System? What is the importance of the 35F delta T Step 8.4.2.I: . Steps 2 and 7 conflict. Step 2 has.MU increased by starting the second MU Pump. Step 7 pressurizer level maintained.at

  .<85 inches. If 84 inches was being maintained in the pressurizer and subcooling was lost which drew a bubble in the head causing pressurizer level to increase to 95 inches, WHICH would have priority: getting the-pressurizer level back to 85 inches or increasing MU with the second HU Pump? Evaluate and revise the procedure as necessar Step 8.4.2.i.6: The step has a typo, "Trin" should be " Trip"
* Neither DB-PF-02000 "EOP" nor DB-OP-02531 "SG Tube Leak" provide adequate guidance for a plant cool down on Natural Circulation with a SG Tube Leak (Rupture) present. Davis-Besse AT0G Part I, step 11 of the Steam Generator Tube Rupture section addresses this issu Correct this discrepanc . DB-PF-02000, RPS, SFAS, SFRCS Trip, or SG Tube Rupture General Comments
* The EPs contain parameter values which serve as operator action points. The EPs do not provide guidance to the operator if the parameter. values are valid under adverse containment condition Define adverse containment conditions and state the definition in the EP for operator referenc Provide in the text of the EPs the instrument readings (values)

the operator is to use for adverse containment condition Example. Maintain pressurizer level >20 inches. (>45 in. ACC) The EP bases document is out of date. The last entry provides the bases for revision 5 to EP 1202.01, a precursor to the present EP, DB-PF-02000 revision 2. The bases document should be updated to the latest change of the current EP and maintained curren l

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. Only one copy of the EP bases document exists. It has not been processed through the normal' review cycle nor has it been promulgated as a TE or DB document. As a result, the' document is not readily available nor can it be assumed to be authoritative. The bases document should be formalized and distributed as necessar . As discussed with several technical personnel, there is a potential problem as to the correct temperature measurement to represent the reactor coolant system under a wide range of conditions in several sections of the E The generic guidance as described in the TBD was intended to be followed. This concern is reflected by the last paragraph of 4.11 which states "if neither Tsat meter is available then adequate SCM is verified by ensuring.RCS temperature and Pressure are above and to the left of the SCM Line of the P/T display (or manual plot)." This is a correct statement if the incore T/C are used as input, but it' is not clear the operator will always do this (although this was the apparent intent based on the discussion in prior paragraphs).

This and similar statements located through the EP should be modified to show that incore T/Cs shall be used. Finally, the guidance is step 8.14.3 should reflect the correct measurement to us . DB-PF-02000, Section 1, Symptoms Step 1.5: The Technical Bases Document (3/7/88) states: "The emergency procedures must be used by the operator anytime a condition exists that requires a reactor trip. This includes the case where an automatic reactor trip has occurred or the case where conditions exist for reactor trip but the reactor trip has not occurred." This information is in part provided in response to the NRC review of the reference Oconee ATOG. Step 1.5 allows the operator to enter the E0Ps at his or her discretion if a manual trip is required. Reword this step to accurately reflect this inten Entry into the E0P at operator discretion is an option as long as entry is required consistent with the above paragraph. Such optional entry should continue to be provided. The problem is with the examples provided in step Step 1.4.2 Detail: This step defines maximum MU flow as " full" MU flow through a single MU injection lin Although full is not defined, it appeared to mean flow from all operable MU pump Clarify " full."

33. DB-PF-02000, Section 3, Innediate Actions Step 3.2 Detail: This instruction contains grammatical error Correct the gramma ! 25 i _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ I

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34. DB-PF-02000, Section 4, Supplemental Actions Step 4.3.4: Step 4.3.3.e is a condition of no NNI X AC or DC, and it transfers the operator to step 4.3.4 if NNI has no power. But steps 4.3.4.a and 4.3.4.c appear to require use of NNI X powered indicators. Evaluate if this is an incorrect transfer, and if so, revise the procedur Step 4.8.2: Item c uses a line designation MU 6421 and MU 6419 at che end of the first paragraph. The last line uses only MU 641 If this is an errer, then correct the erro Step 4.8.3 h. Details: This step states that "If manpower is available, flow may be controlled using MU 216, MU 19 Bypass."

Since MU 19 is an air-operated valve that fails open; MU 19 or MU 214, MU 19 isolation valve, must be closed to allow NU 216 to

   . control MU flow. If flow is not to be controlled it may be appropriate also to include a step to close MU 19 or MU 214 manually.

(. Step 4.9.4 d. Details: This step states that "LPI' flow is an indication of a larger LOCA." The word " larger" should be replaced by "large." Specific Rule 4, Step 4.5: This step was.added by restricted change TR 88-5559 which will be.in effect until the next refueling outage in early 1990. The current page 172 which includes this step is placed in front of the procedure and the old page remains in the body of the procedure. Discussion with licensee personnel revealed that'the licensee's procedure for controlling procedure changes does not allow a restricted change to be placed in the body of the procedure. This is not appropriate for a change to DB-PF-02000 which will be in effect for at least a yea Step 4.10.6 (SUPPLEMENTARY ACTIONS): This step requires entry to a locked room. The inspectors observed that the operator had difficulty unlocking the doo It appeared that the difficulty was caused by a worn loc * Step 4.11 Action: Since selection of the temperature input to the SCM meter can be critical to the success of this step, a caution should be inserted similar to the following: CAUTION: SCM temperature input shall be selected from the RTDs provided that SCM is adequate and either natural cir. or forced RCS flow exists. Otherwise, temperature input shall be selected from the incore thermocoupl * Step 4.11 Detail, second paragraph: The second sentence is true only with flow past the RTDs. Revise the detail to read: "Provided there is flow past the sensor, RTDs are more accurate than incore thermocouple." Step B.7. (Attachment 1): This step appears to be redundan _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ -

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. Step C.2. (Attachment 1) directs the operator to close SW 336 but does not provide the name of the valv ~

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35. DB-PF-02000, Section 5, Lack of Subcooling Margin Step 5.7: The procedure states "If ICC exists (superheated using Incore T/Cs), THEN 00 TO Section 9, Inadequate Core Cooling....;" The Oconee AT00 statements 6.1 and 6.2 include the statement " IF, at any time during the transient . . . THEN go to ICC section. . . ."

 (where the temperature sensors that were used in ATOG have-been replaced by the more recent TBD information, in part as a result of the NRR review of ATOG). The instruction omitted the qualification that the transfer was to occur at any time superheat existed, which raised the possibility of waiting in the subcooled treatment until step 5.7 was reache Such a period of waiting in this section would be in violation of the NRR acceptance of the basis for the E0Ps. Operator. training would make such mistakes unlikely, but the omission of the qualifier can lead to misunderstanding. This possibility should be corrected, Step 5.15: Although this step postulated full MU flow through a single line, MU flow was actually lined up to discharge through both injection lines from step 5.2 and rule 2. Either the lineup must be changed prior to step 5.15 or the final two lines of this step must be revise . DB-PF-02000, Section 6, Lack of Heat Transfer Step 6.3.1.a: This step uses " Verify" and the identical step 6.6. uses " Ensure." Should be consisten Step 6.3.1 (a - h) is identical to step 6. These steps differ from the combination of steps in Specific Rules 1.2, 1.3, and Differences involve MU 6420, MU 6421, MU 6419, CC 1460, and guidance if only one HPI train is available. These differences should be reviewed to assure they are reasonable, and the procedures should be changed to provide consistency, if necessar A number of other comments, provided below, address MU/HPI cooling, particularly differences between one portion of the procedure and another. These comments should also be applied to Specific Rules 1 and 2, and all differences should be either removed or found to be reasonabl Step 6.3.1.b: Thi< step states " Start the non-running CCW pump to supply essential cooling." There are three CCW pumps and one is generally running with one racked out. Revise the procedure to indicate "non-running" verses " standby." CAUTION 6.4: This CAUTION addresses the PORV and states "... do NOT close the PORV Block Valve." An earlier step that verifies the PORV block valve is open should be added to the procedur Step 6.4: Revise this step to indicate if the RCPs are running, use

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L Th, and if the RCPs are not' running use the incores on the PAM - panel.> The step,;as written,; instructs the operator to monitor hot leg l' ' temperature' .or, 'if. hot leg temperature indication is. lost, to E . monitor incore T/C temperature; This is a generic. issue'that has-not been resolved. Incore T/Cs' will always reflect core condition ~ This!is'not't' rue of'the, hot' leg temperature. . It maylnot be clear

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"that hottleg' temp'erature indication'is not reflecting' core conditions. It.would be' acceptable t'o monitor both7 but if.at any-time the.incores indicate a problem, an appropriate response should be take . Steps 6.4.1.and 6.4.2
The 600 F test used.by the licensee'is not the-same test as provided in the bases material,.but within the
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depth of this audit', it appears sufficien It should'be confirmed that'this test meets the needs of the bases material for the existing Davis-Besse plant configuration, or the procedural step should be changed to agree with the. test provided in the base material'. These steps are poorly organized and confusing.. It would be clearer if a simple test of 600 F could be used without decisions regarding secondary. heat transfer and restoration of feedwater, which appear to be unnecessar The DETAILS statement that "If feedwater is restored to at least one SG prior to 600 F Th, MU/HPI cooling is no longer required at 600 F Th" appears to be incorrect. Restoration of feedwater without restoration of heat transfer will not halt the temperature increase, and MU/HPI cooling would still be require Using'a simple 600 F in contrast to the present test would appear to make little difference in use of MU/HPI cooling. If sufficient feedwater is restored to arrest a heatup, then the temperature increase will stop almost immediately, and MU/HPI cooling will be

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averted; if not, then MU/HPI-cooling will probably-be required in any event. This'should be reviewed and documentation provided for this deviation from the ATOG, or this step should be revised to agree with ATO Step 6.4,~ DETAILS entry: Revise the step to indicate if the RCPs are running to use Th r.nd_if the RCPs are not running to use the incores on the PAM panel in determining when 600 deg. F is reached The last statement "If the PORV lifts do NOT close the PORV block valve" should probably be a NOTE or CAUTION on the ACTIONS pag Give operator guidance if conditions were to evolve where the PORV failed to re-close at the expected closing setpoin Step 6.4.1: The step references restoration of heat transfer. Other locations in the procedures provide restoration criteria in the DETAILS. The information is not provided here. The licensee should address whether it is needed to be consisten Step 6.5.1: The step states "IF closed, open RC 11, PORV Block" where as 6.6.4 states " Verify open RC 11, PORV Block." These are identical actions, be consisten _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ __

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. Step 6.5.5: The step states " Verify open MU 6421." There is no comparable step in the sequence 6.6.7 to 6. Address.whether this is an error and, if so, correct the erro CAUTION 6.6.5: Locate the caution before step 6.6.5 since the operation could cause a loss of SC . Step 6.9 and the immediately following steps should address the case of failure of the PORV or the PORV block valve to open. Review the affect on accident mitigation for this component failure mode and revise the procedure if necessar Step 6.13.1 (ACTIONS). refers to "RCPs" whereas step 6.13.1 (DETAILS)

refers to RC Pumps. Be consisten Numerous steps in this procedure involve opening the PORV and the PORV block valve. Sometimes the PORV is to be opened first and sometimes the block valve. Review the guidance on the operation of the valves and revise the procedure to be consisten . DB-PF-02000, Section 7, Overcooling Step 7: Consider whether reference should be made to allowable pressure / temperature conditions early in the overcooling procedur Step 7.17: The licensee is to consider the plant-specific feedwater l capability at Davis-Besse, and see if additional ACTIONS should be -) taken. For example, there are other feedwater pumps that are electrically driven which may be useful or in us Step 7.28: Insert the phrase "AFW to" after the wore. " isolate" in order to clarify the statemen I 38. DB-PF-02000, Section 8, Steam Generator Tube Rupture ') Step 8.3.1, Details: The abnormal procedures referenced in this step are referenced by the old number system rather than the new 02500 series numbering that was used in Step 8.3.1 Actions ste The new abnormal procedure numbering system should be used consistently across procedure step Step 8.14: This step appears to potentially take a long time for certain large tube ruptures or simultaneous tube rupture and RCS leak. An alternate possibility is that the leakage rate gradually reduces pressurizer level to the condition of loss of SCM. If this is correct, the SGTR may have been releasing radioactive material for a corresponding long time. The licensee is to consider this possibility and, if it is correct, modify the step accordingly, Step 8.14.2: This caution, located on the page beyond step 8.14, address a part of the above observatio Step 8.17.3: See Step 8.14 commen l l w_ -. . _ _ . _ _ . . _ . _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _ _ _ __-

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, Step 8.20'4: This step instructs the operator.to immediately open
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(,   the.PORV.and other ventLvalves when the pressurizer goes solid as indicated by a sudden rapid increasing of RCS pressure. If.this

_ y ; should occur with an isolated steam' generator that is also filled-solid,.the potential. exists for opening steam generator safety

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valves. .The. licensee is to consider this possibility and modify thei

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procedure accordingly'if such a challenge'to the safety valves-ca oCCure Step 8;20.10: .A check should be made for-water in.the' emergency sumps prior to shifting'LPI pump suction ~ Shifting of the pump: suctionslshould be done.one pump at a time, with reasonable assurance obtained that the first pump is operating properly b~efore

 : transfer of the secon Section 8: The: licensee should review this treatment of SGTR with .

respect to, boron control due to potential RCS dilution from backflow 1 from the steam generator with the rupture. Procedure modifications should be'made if found necessar Flow Chart, Section 8: The new procedure numbers are not referenced in Steps 8.15, 8.19, and 8.20. Procedure number references should be the'same as the procedure numbers in the text for this-instructio :39. D'B-PF-02000, Section 9, Inadequate Core Cooling Step 9.7: The transfer to section 11 may occur with a subcooled condition. Section 11 is for a saturated RCS and is not the appropriate transfer locatio . DB-PF-02000, Section 10, Large LOCA Step 10.0: The meaning of the sentence "End conditions may not coin 4de with entry conditions in existing procedures." was not cle- Revise the sentence,

      ' Step 10.2: Substitute the word " Verify" for " Reverify." . Step 10.3: In the second line,   change the phrase " balance in plant" to " balance of plant."

41. DB-PF-02000, Section 11, Transient Termination Following an Occurrence that leaves the RCS Saturated with SGs Removing Heat Change Table 3 CTMT Wide Range Level to read in elevation instead of feet.,The meter on the Post Accident Monitor Panel indicates level in elevation. This would eliminate a calculation that the operator'would have to mak I

 . NOTE 11.6_.1: 'The licensee should expand this note to indicate that SGs should be steamed as necessary to prevent them from becoming a heat sourc . - - _ _ _ _ _ _ _

,. __ ._ __ _ - _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _ _ .__ v . e ..

. Step 1'1.10: Consider. referencing the details of step 5.7 into step 11.10 for isolating possible steam leak Step 11.12.4: Reference the RCP starting criteria. This would reduce the possibility of operator error in a high stress situatio Step 11.14: Recommend inserting DB-0P-06903 Limits and Precautions of 10 deg./hr for shutdown cooldown on Natural Circulation, Step'11.15: Recommend the facility specify a limit for cooldow . DB-PF-02000, Section 12, Transient Termination Following an Occurrence that Leaves the RCS Being Cooled by MU/HPI Cooling Step 12.4: Attachment 4 for the Determination of Core Outlet Temperature is used to calculate inadequate core cooling conditions, but is not referenced in this step. Reference Attechment 4 in this ste . DB-PF-02000, Section 13, Transient Termination following an Occurrence that may Require Pressurizer Recovery or Solid Plant Cooldown with SG(s) Removing Heat and RCS Subcoole Step 13.3: A CAUTION regarding prevention of overpressure should probably be included prior to performing these step _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _
    -

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APPENDIX C NOMENCLATURE DISCREPANCIES IDENTIFIED BY NRC E0P INSPECTION TEAM

          ,

LABEL ON EQUIPMENT IS THE CONTROL BOARD LABEL UNLESS OTHERWISE IDENTIFIE OTIER LOCATIONS ARE IN-PLANT EQUIPMENT ITEM (I), BREAKER OR ELECTRICAL CONTROL PANEL (E), AND LOCAL CONTROL IF AN ADDITIONAL LOCAL CONTROL WAS PROVIDED IN ADDITION TO AT THE PLANT EQUIPMENT ITEM AND/OR AT THE ELECTRICAL PANEL (L).

DIFFERENCES BETWEEN NOMENCLATURE ON THE ELECTRICAL PANELS WITH AN ADDITIONAL ZERO IN THE LETTER / NUMERICAL IDENTIFICATION ARE NOT ALWAYS LISTED SINCE THIS IS GENERIC TO ALL ELECTRICAL PANEL PROCEDURE STEP /PAGE PROCEDURE NOMENCLATURE LABEL ON EQUIPFENT 02000 5.1 CTMT Lighting Panels L79D1 CNTMT LTG PNLS L79D2 & and L79D2 L79D1 CTMT Lighting Panel L49D1 CNTMT LTG PNL L49D1 TC Lift Pumps BEARING LIFT PUMPS 5.1 CTMT H2 Purge Fan 2 H2 DILUTION SYS BLOWER

TG Turning Gear Oil Pump TURNING GEAR PUMP 6.1 CTMT Lighting Panels L79D3 CNTMT LTG PNLS L79D3 & and L79D4 L79D4 PRI Water XFER Pump 1 TRANSFER PUMP PRIMARY WATER 1 TG Lift Pumps BEARING LIFT PUMPS 6.1 CTMT H2 Purge Fan 2 H2 DILUTION SYS BLOWER

H2 Recombiner HYDROGEN RECOMBINATION STARTER 02000 TABLE 2/1 EVS-1 EVS Fan 1 CTMT EMER VENT SYS 1 CONTROL ROOM EMER VENT TRAIN 1 EVS-2 EVS Fan 2 EVS 2 CTMT EMER VENT SYS 2 CONTROL ROOM EMER VENT TRAIN 2 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ -

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

PROCEDURE STEP /PAG PROCEDURE NOMENCLATURE LABEL ON EQUIPMENT 02000 TABIS 2/1 (continued) CV 5011A CTMT Air Sample CV 5011A CONTAINMENT AIR SAMPLE CV 5010B As above CV 5011B As above-CV 5010B As above CV 5011C As above CV 5010C As above CV 5011D As above CV 5010D As above CV 5008 CTMT Purge Out CV 5008 CTMT PURGE OUT CV 5005 CTMT Purge In CV 5005 CTMT PURGE IN CV 5009 Pen Rm 4 Purge Out CV 5009 PENT RM 4 PURGE OUT CV 5004 Pen Rm 3 Purge In Cv 5004 PENT RM 3 PURGE IN HV 5301A-H CTRM HVAC HV 5301A-H, 61A B CONTROL ROOM HVAC HV 5311A-H CTRM HVAC HV 5311A-H, 61A & B CONTROL ROOM HVAC HV 5716 A&B Aux Bldg NE & HV 5716 A&B Aux Bldg SE Hdr Out NE & SE HEADER OUT HV 5715A&B Aux Bldg West & HV 5715 A&B AUX BLDG Com Header Out WEST & COM HEADER OUT TABLE 2/2 EDG 1 Emer Ds1 Gen 1 EMERGENCY DIESEL GENERATOR DH 7B BWST Outlet Line DH 7B Box to left is labeled "FROM HPI ' FILL N2 SUPPLY MU PMP TEST" l E: DH 07B BWST OUT VLV B

2 I _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _

       -_ _ __ -

~ , .:.

)

_ .

-

PROCEDURE STEP /PAGE PROCEDURE NOMENCLATURE LABEL ON EQUIPMENT 02000 TABLE 2/2.(cont) CS 1530 CTNT Spray Disch CS 1530 CTMT SPRAY DISCH I: CS 1530 CTNT SPRAY DISCH CS 1531 CTMT Spray Disch CS'1531.CTMT SPRAY DISC I: CS'1531 CTMT SPRAY' DISCH E: CS 01531 CS PMP 2 OUT VLV CAC 1 CTNT Air Clr Fan 1 No identifier label (NL)'CTNT AIR CLR FAN CAC.2 CTNT Air Clr Fan 2 .NL CTNT AIR CLR FAN 2

     ,

CAC 3 CTNT Air Clr Fan;3, NL CTNT AIR CLR CH 1 FAN 3, CH 1 CAC 3 CTNT Air Clr Fan 3, NL CTNT AIR CLR FAN 3, Ch 2 CH 2 CV 5038 CTMT H2 Purge Exh CV 5038 CTMT H2 PURGE EXH SW 1424 CCW HX 1 SW Out SW 1424 NL BOX TO Iso Vlv RIGHT "TO SERV WTR RETURN HEADER" I: CCW HEAT EXCHANGER 1-1 OUTLET CONTROL VALVE CV 5037 CTMT H2 Purge Ex CV 5037 CTMT H2 PURGE EXT CF 1545 CFT to Sample Sys CF 1545 CFT TO SAMPLE i SYS I: CF 1545 CFT TO SAMPLE SYS j SW PMP 1 Service Water NL SERVICE WATER Pump 1 PUMP 1 CF 1542 CFT TK Vent Iso Vlv CF 1542 CFT VENT WST GAS

     ._-- _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
. _ _ - _ _ _ _ - - _  .-_ _ _ _ _ ...
 ...
 .
 . PROCEDURE  STEP /PAGE PROCEDURE NOMENCLATURE LABEL ON EQUIPMENT i

02000 TABLE 2/2 (cont) ' CF 154/. CF TK.1 Fill Iso CF 1544 NL BOX TO i Vlv LEFT "FROM HPI FILL N2 SUPPLY MU^PMP TEST" SW 1434 CCW HX 2 SW Out SW 1434 NL BOX TO V1v LEFT "T0 SERV. WTR RETURN HEADER" CV 5090 CTMT H2 Dil Blwr NL CV 5090 BOX BELOW 1 Iso Vlv "CTMT H2 PURGE FAN 1" SW PMP 2 Service Water NL SERVICE WATER Pump 2 PUMP 2 l CCW PMP 1 CCW Pump 1 NL :CCW PUMP 1-CF 1541 CF TK 2 Fill Iso CF 1541 NL B0X TO Vlv RIGHT "FROM HPI FILL N2 SUPPLY MU PMP TEST" HPI PMP 1 HPI Pump 1 NL HPI PUMP 1 CV 5065 CTMT H2 Dil Blwr CV 5065 NL BOX BELOW 2 Iso V1v "CTM T(s) H2 PURGE ! FAN 2" HP 2C HP Inj 1 Vlv HP 2C NL CCW PMP 2 CCW Pump 2 NL CCW PUMP 2 HP 2D HP Inj 1 Vlv HP 2D NL HPI PMP 2 HPI Pump 2 NL HPI PUMP 2 DH 9B CTMT Eeer Sump V1v DH 9B NL SHOWN DOWN-Trn 1 STREAM OF " EMERGENCY I SUMP" HP 2A HP Inj 2 Viv HP 2A NL SW PHP 3 SW Pump 1, Ch 1 SW PMP 3 SERVICE WATER PUMP 3 CH 1 HP 2B HP Inj 2 Vlv HP 2B NL

,     CCW PMP 3 CCW Pump 3, Ch 1 NL CCW PUMP 3 CH 1 DH 9A CTMT Emer Sump DH 9A NL Vlv R Trn 2

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

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

.-
     ,
..

PROCEDURE STEP /PAGE PROCEDURE NOMENCLATURE LABEL ON EQUIPMENT i 02000 TABLE 2/2 (cont) SW 1429 CCW HX 3 SW Out, SW 1429, CH I ' V1v, Ch 1 SW PMP 3 SW Pump 3, Ch 2 SW PMP 3 SERVICE WATER

     ' PUMP 3 CH 2 SW 1429 CCWW HX 3 SW Out SW 1429 CCW HEAT Vlv,-Ch 2  EXCHANGER 1-1 OUTLET
     . CONTROL VALVE CV 5070 CTMT VAC Rlf Vlv C7 5070 CONTAINMENT Iso  VAC RELIEF VALVE ISOLATION-E: CTMT VACM RELIEF VLV L: CTMT VACM RELIEF VLV CV 5071 - CV 5079 AS ABOVE RC 1773B CTMT Drain Header RC 1773B CTMT DRAIN READER I: RC 1773B CONTAINMENT DRAIN HEADER ISOLATION VALVE RC 1719B CTMT Vent Header RC 1719B CTMT VENT HEADER I: RC 1719B CONTAINMENT VENT HEADER ISOLATION VALVE RC 232 Quench Tank Return RC 232 QUENCH TANK RETURN I: RC 232 QUENCH TANK INLET ISOLATION VALVE RC 229A Quench Tank Outlet RC 229A QUENCH TANK OUTLET I: RC 229A QUENCH TANK OUTLET ISOLATION VALVE RC 240B PZR Sample RC 240B PZR SAMPLE MV0240B RC PRZR SMPL VLV 2
      - _ _ _ - _ _ _ _ _ - _ _ _ _ _

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

.O e
 .

PROCEDURE STEP /PAGE PROCEDURE NOMENCLATURE LABEL ON EQUIPMENT

         .
           .

l SG 1 LVL SG 1 Lvl Hi/Lo NL SG 1 LEVEL HI/LO STPT Slet SETPT SELECT SG 2 LVL SG 2 Lvl Hi/Lo NL SG 2 LEVEL HI/LO STPT Slet SETPT SELECT 2000 TABLE 2/3 CC 1467 CCW from DH Clr 1 CC 1467 NL NEARBY BOX Out V1v "DH COOLER 1" CC 1469 CCW from DH Clr 2 CC 1469 NL NEARBY BOX Out Vlv "DH COOLER 2" DH PMP 1 LPI/DH Pump 1 NL LPI/DH PUMP 1 DH PMP 2 LPI/DH Pump 2 NL LPI/DH PUMP 2 02512 LRC-RC-14 LRC-RS-14 02510 LOSS OF REACTOR COOLANT SYSTEM BORON Enclosure 1 1 MU 39 Batch Flow Controller Only part of controller is associated with MU 39 and the designation is small on the control boar DW 66 DW Iso Valve to MU DW 66 DEMIN WATER System INLET TO BATCH CONTROLLER AND MAKE UP TANK 4 PW 29 PW Iso Valve to MU PW 29 PRIMARY WATER System INLET TO BATCH CONTROLLER MAKE-UP TANK 9 PW 28 Pri Water Iso to PW 28 PRIMARY WATER purification demins INLET TO PURIFICATION DEMIN ISOLATION 02510 Enclosure 2 DH 30 DH Pump 1-2 Suction DH 3d DH PUMP 1-2 l from SFP Cooling System SUCTION FROM SF POOL l COOLING SYSTEM ' SF115 SFP Outlet to DH SF 115 SFP OUTLET TO Removal System DECAY HEAT REMOVAL i

             '

SYSTEM l l

_ _ _ _ _ _ _ - _ .

R

:. :.
-       \

P -

,

PROCEDURE STEP /PAGE PROCEDURE NOMENCLATURE LABEL ON EQUIPMENT 1.'l DH 33 DH Pump'l-1 Suction DH 33 DH PUMP 1-1 from Purification Demin- SUCTION FROM MU?P eralizers SYS DEMIN 1.3 DH 32 DH Pump 1-2 Suction DH 32 DH PUMP 1-2 from Purification Demin- SUCTION FROM MAKE UP eralizers AND PURIFICATION SYSTEM 3 WC 3526 CWBP Bypass Is WC 3526 CLN WSI BOOSTER PUMPS BYPASS i

    (Designation from 1

- electrical supply in plant. A ladder would be needed to reach the valve and none was available.)

02527 TI-DH-8B(A) TI-DH-8B1 FIDH2B FYIH2B FIDH2A FYIH2A

      ,

_ _ _ _ _ _ _ _ _ _

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

. .

a

 .
 .

APPENDIX D LIST OF ABBREVIATIONS AB Abnormal Procedures (old format) AC Alternating Current

 'AP  Alarm Procedures (old format)

AFW Auxiliary Feedwater DB-1 Davis-Besse. Unit 1  ; A0P Abnormal Operating Procedure ' APSR Axial Power Shaping Rods ATOG Abnormal Transient Operating Guidelines B&W Babcock & Wilcox l BWST Borated Water Storage Tank CAS Central Alarm Station CCW Component Cooling Water CFR ' Code of Federal Regulations CRD Control Rod Drive CST Condensate Storage Tank CTMT Containment Building DC Direct Current DCN Design Change Notice DPM Decades per Minute EDG Emergency Diesel Generator E0P Emergency Operating Procedures as described in RG 1.33 , EP DB-PF-02000 (A Particular Procedure in the DB-1 E0Ps) j EPG Emergency Procedure Guidelines 1 ES Engineered Safeguards FW Feedwater GPM- Gallons per Minute

. GTG  Generic Technical Guidelines HP  High Pressure HPI  High Pressure Injection ICC  Inadequate Core Cooling ICS  Integrated Control System I&E  Instrument & Electrical INPO  Institute of Nuclear. Power Operations LCO  Limiting Condition of Operation LOCA  Loss of Coolant Accident LPI  Low Pressure Injection MFIV  Main Feedwater Isolation Valves MSIV  Main Steam Isolation Valve MSI  Main Steam Line Isolation MOV  Motor Operated Valve MPC  Maximum Permissible Concentration NLO  Nor.-licensed Operator NNI  Non-Nuclear Instrumentation NRC  Nuclear Regulatory Commission OG  Owners Group OP  Operating Procedure l
           ;
       - - _ _ _ _ _ - - _ - _ _ _ _ _ _ _ - _ _ _ - - - _ -
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PGP Procedure Generation Package POR Power Operated Relief Valve PSIA -Pounds per Square Inch Absolute PSIG Pounds per. Square Inch Gauge P/T Pressure / Temperature PWG Procedure Writers Guide PZR Pressurizer QA Quality Assurance RCP Reactor Coolant Pump RCS Reactor Coolant System RCSI Reactor Coolant System Inventory RG- Regulatory Guideline RPS Reactor Protection System RV Reactor Vessel RX Reactor SER Safety Evaluation Report SFAS Safety Features Actuation SFRCS Steam and Feedwater Line Rupture Control System SG Steam Generator SPDS Safety Parameter Display System SRO Senior Reactor Operator SS Shift Supervisor SSA Shift Supervisors Administrative Assistant STA Shift Technical Advisor SW Service Water TBD Technical Basis Document TE Toledo Edison Company TMI Three Mile Island TS Technical Specifications USAR Updated Safety Analysis Report UV Under Voltage

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