IR 05000424/1990008

Insp Repts 50-424/90-08 & 50-425/90-08 on 900507-18.No Violations Noted.Major Areas Inspected:Eop to Verify Util Technical Accuracy & That Specified Actions Could Be Accomplished W/Existing Equipment & Instrumentation

ML20043G453
Person / Time
Site:	Vogtle
Issue date:	06/12/1990
From:	Lawyer L, Peebles T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20043G449	List: IR 05000424/1990008 ML20043G448
References
50-424-90-08, 50-424-90-8, 50-425-90-08, 50-425-90-8, NUDOCS 9006200314
Download: ML20043G453 (78)

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UNITE 3 STATES he maag%

NUCLEAR REGULATORY COMMISSION,

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REoloN il 1 N. 'J-

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" ATLANTA, GEORGIA 30323.

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' Report Nos..:

50-424/90-08'and 50-425/90-08 q

Licensee: Georgia Power Company--

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'P. 0. Box 129_5'

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Birmingham, AL' 35201-

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Docket Nos.:

50-424 and'50-425'

License Nos.:

NPF-68 and NPF-81-

Facility Name:.Vogtle-1_and 2 J

Inspection Cond eted

May 7.- 18,.1990

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Inspector:

W 4[/

fo L/6"#We If Date S'igned i

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NRC Team Members:

R. Aiello l

J R. Baldwin R. Schin-

'R. Starkey.

Contractors:

P. Reagan, COMEX

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B A. Sutthof, AIC Approved by:

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'T. AT Peebles, Chief =

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-Operations Branch

D,1 vision of Reactor Safety

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SUMMARY.

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Scope:

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A^special, announced Emergency Operating Procedure (EOP) team inspection was

. performed.. - The purpose was to verify that the Vogtle E0Ps were technically

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accurate and.that their specified actions could be accomplished using existing

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-_ equipment, controls and instrumentation. The inspection evaluated the adequacy I

of the. lice.nsee's E0Ps' (including Abnormal Operating Procedures [A0Ps]),

conformance of--these procedures to the Westinghouse Owners' Group (WOG)

Emergency Response Guidelines (ERGS) and conformance to the approved writer's

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-guide. : The inspection included a technical adequacy review of the procedures,

control.

and inplant walkthroughs, simulator evaluation of selected.

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room pro _cedures,.a review of ongoing control of these procedures and interviews of

-ope'rators who-use the procedures.

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Results:

The overal11 assessment concluded that the E0Ps ' adequately covered' tha, broad 1 range' of' accidents and equipment failures necessary for safe shutdown of the

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- plant. The team identified weaknesses in the licensee's engineering evaluation

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ofc an undeveloped ERG. (paragraph 2), _ radiation monitor inappropriate-set point (paragraph: 4), nomenclature inaccuracy (paragraph 4),

procedural'

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tinaccuracy -(paragraph -3), verification and validation -(parat,raph 4),m rules.

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of. usage -(paragraph 7),: step' deviation-documents (paragraph 3) and level of-g

. detail in procedures (paragraph 4).

The team identified a strength' in the

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i application of a single writer's-guide to both-the. EOPs. and _ A0Ps ( Appendix. C,

= I). ~ The' team ~ reviewed.the ' draf t Safety Evaluation Report, (SER) on the

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licensee's Procedures Generation Package -(PGP) commitments and determined that

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- the SERchad been closed. Violations or deviations were not identified in this

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REPORT DETAILS

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Persons Contacted Licensee Employees

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• J. Aufdenkampe, Manager - Technical Support B. Carter, Shift Superintendent (SRO) - Operations-J. Covington, Plant Operator (RO) - Operations W. Dunn, Shift Superintendent (SRO) - Operations G. Frederick, QA Site Manager - Quality Assurance-J. Gasser, Shif t Superintendent (SRO) - Operations M. Gentry, Plant Operator (RO) - Operations R.< Hale,, Shift Supervisor (SRO) - Operations

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T. Hargis, Shift Superintendent (SRO) - Operations D.. Jenkins, Plant Operator (RO) - Operations R. Keadle, Plant Equipment Operator - Operations E. Kozinsky, Acting.0perations Superintendent (SRO) - Opera; ions

• W.' Kitchens, Assistant General Manager - Operations

• G. Lee, Operations Supervisor - Operations B..Matheson, Plant Operator (RO) - Operations-G.LMoore,- Shift Supervisor (SRO) - Operations-

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'M. Odom,'. Nuclear Chemistry Technician - Chemistry L, Ray, Simulator Instructor (SRO) - Training

• A. Rickman, Engineer - Technical Support

' J.' Robinson, Shift Supervisor (SRO) - Operations

R. Sammons, Plant Engineer - Operations D. Scukanec, Operations Training Supervisor - Training A. Smith, Plant Operator.(RO) - Operations

'R.' Snider, Shift Supervisor (SRO) - Operations R. Thompson,-Plant Equipment Operator - Operations

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L. 'Vannier, Plant Operator (RO) - Operations D. Vineyard, Shif t Supervisor (SRO) -- Operations

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S, Wilkerson, Simulator Instructor - Training Other licensee employees contacted during -this inspection included engineers, technicians, operators and' administrative personnel.

NRC Personnel

• K. Brockman, Chief, Section 3B, DRP - RII

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• P. Kellogg, Chief, Operations Programs Section, DRS - RII'

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• E. Merschoff, Acting Director, DRS - RII

• S. Shankman, Chief, Procedures and Training - NRR/DLPQ/HFAB F-NRC Resident Inspector

• J. Rogge, Senior Resident Inspector - Vogtle Nuclear Plant

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E0P/GTG Comparison f,

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The team reviewed the index of Vogtle E0Ps and A0Ps against the index of NRC approved WOG ERGS and the list of emergency procedures recommended by

~ Regulatory. Guide 1.33 for combating emergencies and other. significant y'

events.

The team confirmed that the licensee had developed sufficient O

procedures to deal with the spectrum of events addressed by the. ERGS,

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. Reg. Guide 1.33 and the UFSAR with the exception of ES-3.2.

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This latter procedure, Post-SGTR Cooldown using Blowdown, was the subject l

of-SDDs but those SDDs were found to be technically superficial.

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engineering analysis had been performed comparing Vogtle to-the Westinghouse ERG reference plant; thereby justifying the elimination of ES 3,2.

While the Vogtle UFSAR and PGP indicated GPC's intent to use the Westinghouse ERGS as technical guidance, the ERGS were not so used in the case of ES-3.2 and no 10 CFR 50.59 evaluation was performed on this change.

The licensee, upon notification by the team of this discrepancy promptly

. initiated a request (90-0186) to Vogtle engineering to evaluate the omission of ES-3.2 and prepare a 10 CFR 50.59 safety-evaluation. The omission of ES-3.2 without a 10 CFR 50.59 evaluation is identified as IFI 424, 425/90-08-01.

The licensee had made changes to individual E0P steps from those recommended by the= ERGS. This was done to adapt those steps to the plant configuration, in order to improve human factors or to comply with the writer's guide.

An NRC SER on the Vogtle Unit 1 and 2 procedures. generation package was

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issued in May 1986. The licensee had completed their review of the draft

.SER comments in March of 1986 and had justified to the NRC alternate means for accomplishing accident mitigation.

The team found that issues.

discussed in' draft SER had been fully resolved in.1986.

There were no violations or deviations noted'in this area.

,;

3.

Independent technical adequacy review of the E0Ps

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The team found that the prioritization of accident mitigation strategies in the procedures (including AOPs) followed the guidelines set down by the vendor in the ERG.

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The Vogtle E0Ps were not technically equivalent to the PSTG. The team's

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comparison of the PSTG to the ERG revealed that many deviations were not adequately justified or were only marginally justified.

In addition, the team evaluated deviations from the PSTG incident to the E0P walkthroughs.

.

Findings concerning these deviations are listed in Appendix B and were 4,

identified by the term "PSTG DEV".

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Procedure 10013 was used to write E0Ps from the ERGS. The SDD form used

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to document production of the E0Ps from the ERGS contained three major

. sections. ' According to the procedure, the ERG step was stated in Section

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.I.and the E0P step in Sction II.Section III, Justification, explained differences between the erb and E0P steps.

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The team found.that the 500 was lacking in detail, not well organized and, in some instances, technically deficient.

The significance of these weaknesses was that future procedure revisions may very likely be either t

technically incorrect or include unreviewed safety significant deviations from ;& ERGS.

Examples supporting this conclusion are detailed in Appensi< B at I.

Deficiencies in E0P SDDs are identified as IFI

'

424,42b/90-08-02.

The team did not identify situations in which a deviation was warranted

.i by the Vogtle plant specific design but for which no deviation was taken during development of the E0P.

Technical deficiencies were, noted in the E0Ps and art listed in Appendix B.

For example,- the minimum and maximum flow valuts for AFW in two

t separate steps of E0P FR-H.5 did not agree with the setpoint document (V8a), the value for containment radiation given in 'OP F-0.5 was an

order of magnitude higher than the value in the setpoint document (VI6a),

feed and bleed bypassed the core under certain circumstances (VII8d), use of a leaking pressurizer PORV was-unduly restricted (II3c).

These E0P technical deficiencies are identified as IFI 424,425/90-08-03.

Adverse containment values were found to be adequately provided in the i

E0Ps.

Operators believed that having the foldout pages copied to the back-side of each page was very helpful.

However, E0P foldout pages were not

' continuously monitored as required by the E0Ps.

For example, E0P ES-1.3 step 7 requires ECCS pumps to, be started as necessary.

When-

-

questioned how ECCS pump start necessity-would' be determined, a shift supervisor (SRO) was unable to promptly state the SI reinitiation criteria.

,

After some delay, the shif t supervisor did refer to the foldout page and was able to satisfactorily determine the required action for this step.

The team.found that ' drawings in the control room which were necessary or

,

useful in implementation of the E0Ps were adequate for that purpose.

There were no violations or deviations noted in this area.

4.

Review of the E0Ps and A0Ps by inplant and control room walkthroughs The team conducted control room and plant walkthroughs on the E0Ps and AOPs listed in Appendix A.

The walkthroughs were conducted to verify the following: that the procedures were useable and could accomplish the task in: hand,' instrumentation and controls were available when required for use-in a proce' dure and that the designations were consistent with the installed plant equipment and the E0Ps. Although the writer's guide stated that.

location information was to be included on all instruments and controls outside of the control room, this information was not included in the-E0Ps. Simulator validation identified the lack of location information as HED 1127, however, the E0Ps were not revised to address this item.

Indicators, annunciators and controls referenced in the E0Ps and A0Ps were found to be available for operator use except as noted in Appendix F

-.

,

'

A number: of weaknesses were identified in the administrative

' procedures controlling the verification and validation of the E0Ps.

The team found that there was no requirement for verification against the writer's guide, ' and no requirement for control room and local plant : walkthroughs of procedures.

While criteria were developed: to

-

determine when validation and verification of E0Ps was necessary, no

. specification was included for the type of verification and validation.

E0P verification -'and validation deficiencies are identified as IFI 424,425/90-08-07.

.

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While the results of the walkthroughs were generally satisfactory,.

-

many discrepancies in the areas of technical accuracy, writer's guide adherence, and human factors were. noted.

Technical and human factors discrepancies are. noted in Appendix B, writer's guide discrepancies in

,

Appendix C and nomenclature discrepancies in Appendix D.

Appendix B, C and D items are identified as IFIs number 424,425/90-08-08, 09 and 10.

There were no violation; or deviations noted in this area.

5.

Simulator observation The team' observed one crew of operators performing the following scenarios on the Vogtle simulator:

Loss of heat sink with steam line rupture. RCS feed and bleed

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Steam generator tube rupture with steam line break and ATWS

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Loss of.all AC power with RCP seal failure

Mode 4 LOCA with RWST failure-

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Mode 5 mid-loop RCS leak

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Mode 5 mid-loop loss of RHR

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The. Vogtle simulator. had not been accepted by the NRC as a certified simulator.

At the time of this inspection, the. simulator was being upgraded to be able to model mode 5 mid-loop operations and cold leg LOCAs.

The team noted some simulator limitations or lack of ficelity.

The -first was that the simulator had limited - ability to model an intersystem LOCA outside containment.

Additionally, during the Mode 4 LOCA, the RCS subcooling values displayed on the Plant Status Summary, Proteus, and ERF computer all were substantially different. Also in that scenario, with no RCPs operating, flow was indicated in RCS loops 3 and 4.

During the Mode 5 midloop loss of RHR, the RCS level indicators were not labeled as they would be in the plant.

In addition, that scenario was ended when.the simulator modeling beceme erratic.

During the scenarios, a number of technical deficiencies were noted with

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procedures.

For example: cross-connecting AFW was not addressed in E0Ps and operators stated that it should be.

Local valve locations were not in E0Ps. and A0Ps, and operators stated that they needed that information to decide who to send and where to send them, Also, locked valves were not so identified in procedures.

A0P-004 did not clearly state the required transition to A0P-019 to combat an RCS leak while in Mode 5 midloop - as a result the operators stayed in the wrong procedure during one scenario.

In some instances, valve numbers were not listed in procedures and that resulted in some problems for the operators ( Appendix B, VII8c).

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During the walkthrougM the team elso evaluated the location of the

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E0Ps and the AOPs in The control ronm.

These procedures were of the

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current - revision and were located ceveniently in the control room and the simulator and were'readily accessdie to the operators.

l The team found the correspondence between procedure nomenclature and equipment labeling, both inside and outside of the control room, to be

- very different. These differences were detailed in Appendix 0.

The team concluded-that 'the vast number of differences were causing confusion in the usage of the E0Ps and the A0Ps. E0P nomenclature differences from those of the equipment labels are identified as IFI 424,425/90-08-04,

During the walkthroughs the team noted that E0Ps as well as AOPs lacked the detail needed to accomplish -tasks required by the procedure.

A significant example of this was AOP 18019-C, Loss of Residual Heat Removal. This procedure switched modes a number of times but the steps

,

were not explicit enough to distinguish which mode of operation was

. required. It also did not provide required valve positions. In addition, procedures with -locally operated valves did not alert - operators to-requirements for keys, radiological hazards or equipment locations.

Further examples of these types of discrepancies are noted-in Appendix B.

'.Some main control room components were de-energized and not marked with a status information tag of any kind.

This included the SI accumulator isolation valves, reactor trip bypass breakers, and RHR hot leg suction valves, For example, power supplies for the SI accumulator isolation valves were de-energized, locked and hold tagged.

Procedure 00304-C required hold tags to be placed on the handswitch.

The ' team identified this deviation and operations promptly placed the required hold tags on the accumulator isolation valve handswitches. Absence of the main control room tags caused considerable operator delay in determining the actual

~

position of these valves. - Also, the operators were not sure if hold tags should be observed if an E0P directed them to operate a component.

Lack

.of operationally necessary detail in--EOPs ~is identified as IFI 424,425/90-08-05.

Communication systems to ensure satisfactory E0P performance within the plant were generally acceptable.

The steam generator blowdown radiation monitor's primary function is to alert' operators of a steam generator tube leak so they can enter abnormal operating procedures-and be aware of a potential tube rupture.

However, the team noted that the alarm setpoint of this monitor, RE-19, was set so high that it would not provide S/G tube leak early warning.

(Appendix B, II3a).

The background reading was about 5.0E-8 and the.

lowest alarm setpoint was 1.0E-5, about two and one half decades higher.

A more common alarm setpoint would be about two to five times background.

The existing alarm setpoint did not ef fectively support the abnormal or emergency operating procedures.

The high setpoint of the S/G blowdown radiation monitor is identified as IFI 424,425/90-08-06.

The -team identified a number of problems in the E0Ps that would have been found if adequate verification and validation had been conducted by the licensee.

For example, see Appendix B, V8a, V9c and V5 '

,

-

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., -

The' operators experitnced difficulties af ter transitioning from AOP-004 to ES-1.3 due to inadebuate procedural guidance.

Plant conditions di'fered from initial conditions assumed by ES-1,3 and, as a result, operecors experienced some confusion. For example, operators attempted to e,)en RHR suction from sump valves as directed (with no level in the coriainment t

sump), but they. would not open because there was no SI signal. The team noted that procedures gave no guidance on how to establish recirculation in Mode 5 if there was water in the sump.

These and other technical.

.

comments on procedures arising from the simulator scenarios are described in Appendix B.

The procedur.; did not cause duplicate operator actions-or cause operators to physically interfere with each other. For placekeeping, operators used two ribbons in each book of procedures. These placekeeping aids appeared to be adequate during the scenarios that were observed.

There were no violations or deviations noted in this area.

6.

Management Control of E0Ps and AOPs

"

The team reviewed the licensee's program for management control and ongoing maintenance of E0Ps and AOPs.

The team reviewed the licensee's system for ensuring that the E0Ps and A0Ps are' revised as operational experience, vendor _information, regulatory requirements - and. plant design changes require and found the system generally adequate. Howaver, no tracking system existed to ensure that-changes to procedures referenced by or referencing the E0Ps will be reviewed for their impact on the execution of the E0Ps.

,

The' Safety Audit and Engineering Review group (SAER) performs an annual audit of procedures - and procedure control, including a sample of operations procedures.

This audit includes review for. conformance to the relevant writer's guide as well as review of other procedure

documentation.

in addition, a sample of. procedures sent to the' PRB are reviewed, therefore a sample of all revised E0Ps and A0Ps are reviewed.

The team reviewed a -sample of 10 CFR 50.59 safety evaluations and environmental evaluation documentation for E0P revisions.

Several documents were incomplete. One procedure packet contained an environmental evaluation _ form thst. had not been completed, although the responsible

"

manager had 1 signed the procedure review request form indicating that the m

environmental evaluation had been completed and was attached. In another case, because.one of the E0Ps required by the WOG ERGS had not been u

= developed and because the team found the justification for this omission i

inadequate, the documentation addressing the 10 CFR 50.59 safety evaluation of this deviation was requested.

The team found that no 50.59 safety evaluation had been conducted. (paragraph 2).

,

There were no violations or deviations noted in this area,

'

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7.-

E0P user interviews

,

The team conducted interviews with 10 operations personnel.

Five of that group were SRO licensed operators, four were R0 licensed -

t operators and one. was a plant equipment operator.

The operators believed that the E0Ps were free of significant technical discrepancies.

They were confident that the procedures would be usable and effective in mitigating the consequences of an actual event.

l The E0Ps required a level of knowledge and training that was generally f

compatible with that of a typical operations department person.

'

Operators -were generally satisfied with the adequacy of: EOP -training-

-

and. believed = operations worked very closely with training. However, some

'

E0P steps required operator recall of infrequently performed tasks to either check the expected response or perform the required action.

In those cases, the operators consistently. expressed a need for more assistance in the E0Ps to identify the noun name, ID number and location of seldom used components. Also, the operators wanted locked. valves to be identified in the E0Ps.

The interviews as well as E0P walkthroughs with - operators revealed

weaknesses in the preparation of operators in. rules of. E0P usage.

'

Also, operators had difficulty in clearly stating -rules regarding entry conditions, action verbs, cautions and notes.

The rules of usage - for Vogtle E0Ps were not clearly defined.- Some information on how the E0Ps worked and definitions of some of the terms u;ed within the E0Ps were found in the= E0P and A0P writer's guide.

-

This information was ' used only by procedure writers, not users.

Lesson

-

h p'ans on the format of the E0Ps existed for licensed operator. training.

TLe team found lessori plans on rules of usage for - the E0Ps for

.

'

requalification training and for licensed -operator training to be the

'

same but not fully adequate for either case-The111censee reported that E0P.

.

usage was a specific item of critiques of operator performance in the

'I simulator during requalification training.

'

,

Within the existing licensed operator training lesson plans

contradictions were found, along with guidance that conflicted with the-writer's guide.

For example, the writer's guide stated that " Cautions and notes - shall not direct actions (page 21 of 65),"

Lesson plan LO-H0-37002-001-03-C stated that one function ' of notes was to "... remind you to perform actions that are not listed as steps in the E0P." The l

lesson plan also indicated that cautions could "... direct you to perform

an. action if a given condition occurs during the course of a procedure."

In addition, the lesson plan indicated that the continuous action contained in a caution

...is NOT in effect when the E0P

"

transitions the operator to another E0P."

However, the companion

'

instructor guideline LO-LP-37002-05-C stated as Objectives Ic and d,

" Preceding notes and cautions of a continuous nature are applicable even af ter a transition i s made."

The licensed operator lesson plans also failed to fully address important elements of the E0Ps For example, LO-LP-37002-05 lacked any explanation of decision or logic step structure.

b,

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,

a

'

i The ' result of incomplete and contradictory rules of usage for the E0Ps was that operators han conflicting understanding of. what the procedures meant and how they worred. ' For example, operators interviewed revealed i

'

conflicting definitions of critical action verbs such ' as " check,"

" verify" and " ensure."

Differing interpretations of when an exit from the RNO column was allowed were given by,different operators.

An SRO described the conditional step structure "IF, THEN" as a continuous action step. These dif ferences in operator interpretation ~ of. the meaning and use of the. E0Ps led to variation in operator performance of the E0Ps and potentially different accident mitigation-sequences.

The lack of an

.

E0P user's' guide is identified as IFI 424,425/90-08-11.

l

]

Operators stated in interviews that inclusion of E0P changes - in required reading -or. " current events" lectures during requalification

training, was all that they had ever received, although' a number of revisions to the E0Ps had been issued.

It was confirmed by operators

that changes.-to the E0Ps could be officially in place for. up. to six

weeks before an operator was made aware of the change with the resulting possibility that. an operator could be required: to use a procedure that included changes on which he had never.been trained.

There were'no violations or~ deviations noted in this area.

8.~

Exit Interview

!

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I

'

'

The inspection scope and findings were summarized on May 18,.1990, with

'i i-those persons -indicated in paragraph 1.

The NRC described the areas

inspected and discussed in detail the inspection findings listed below. -

l No proprietary, material was -included in this report.

No. dissenting i

comments'were received from the licensee, i

]

u

. Item Number-Description, Paragraph l

IFI 424,425/90-08-01'

E0P ES-3.2 missing with No 50.59 safety i

'

evaluation, paragraph 2

'

.

.

s l

IFI 424,425/90-08-02 E0P step deviation document deficiencies,

paragraph 3 i

IFI 424,425/90-08-03 E0P technical deficiencies, paragraph 3

'l

..s-p IFI 424,425/90-08-04 E0P nomenclature differs from component j

p labeling, paragraph 4

{

!

IFI 424,425/90-08-05 Lack of detail in E0Ps, paragraph 4 d

IFI 424,425/90-08-06 The S/G blowdown radiation monitor elarm was f

set high, paragraph 4 i

IFI 424,425/90-08-07 E0P verification and validation deficiencies, l

paragraph 4

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LE0P. technical:and human. factors comments,-.

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paragraph 4 and Appendix:B

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!IFI,: 424,425/90-09-09

E0P writer's guide comments, paragraph'4 and-

Appendix ~C-

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E0P nomenclature vs; component labeling-d

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observations, paragraph 4:and Appendix-D w;

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APPENDIX A.

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'

PROCEDURES REVIEWED E-0 Reactor Trip or Safety Injection REV 9

'

E-2 Faulted Steam Generator Isolation REV 4

E-3 Steam Generator Tube Rupture REV 8 i

ES-0.0 Rediagnosis REV 3 i

'

ES-C.1 Reactor Trip Response

~

REV 6 REV 8 ES-0.2 Natural Circulation Cooldown

'

ES-0.3 Natural Circulation Cooldown With Steam REV 4

!

.

Voiding (With RVLIS)

l ES-0.4 Natural = Circulation Cooldown With REV 4

!

Steam Voiding (Without RVLIS)-

i

.ES-1.4-SI Termination REV 7 i

,

ES-1.2 Post LOCA Cooldown and Depressurization REV 8

'

ES-1,3

. Transfer to Cold Leg Recirculation REV 7 a

E S-1.' 4 Transfer'to Hot Leg Recirculation REV 4

.

.ES-3.1 Post-SGTR Cooldown Using Backfill REV 5 p'

c ES-3.3 Post-SGTR Coo'1down Using Steam Dump REV 5 i

I ECA-0.0 Loss of All AC Power REV 5 l

'

ECA-0.1 Loss.of All AC Power Recovery w/o SI Required REV 8

.l

.

ECA-0.2 Loss of All AC Power Recovery w.SI Required REV 4

!

ECA-1.1 Loss of Emergency-Coolant Recirculation-REV 8

.i

..ECA-1.2 LOCA Outside Containment REV 1 I

,

.ECA-2,1 Uncontrolled-Depressurization of All Steam-REV 8

!

Generators

.ECA-3.1- 'SGTR With. Loss of Reactor Coolant Subcooled-

.REV 8

' Recovery Desired l

lECA-3.2 SGTR With Loss of Reactor Coolant Saturated-REV 7 t

Recovery Desired.

'l

'ECA-3.3 SGTR Without Pressurizer Pressure Control REV 6 FR-S.I.

' Response to Nuclear Power Generation /ATWT REV 4

)

'

,FR-S.2-Response to Loss of Core Shutdown REV 1-

!

J-

' FR-C '.1:

l Response to Inadequate Core Cooling REV 4~

- ;

FP-C.21

. Response to Degraded Core Cooling REV 4 l

'

FR-C.3-

-Response.to Saturated Core Ccoling REV 3 i

FR-H.1 Response to Loss of Secondary Heat Sink REV~11

,

FR-Hr2 Response to Steam Generator Overpressure REV 3 j*

, FR-H-3 Response to Steam Generator High Level REV 2

=

.

.c '

FR-H.4 Response to Loss of Normal Steam Release REV.2 Capabilities FR-H.5 Response to Steam Generator Low Level REV 3

%

FR-I.1; Response to High Pressurizer Level REV 5-FR-I.2

' Response to Low Pressurizer Level REV 2

'

FR-I.3 Response to Voids in Reactor Vessel REV 4 FR-P.-1 Response to Imminent Pressurized Thermal REV 7 Shock Condition

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Appendix A

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FR-P.2 Response'to Anticipated Pressurized Thermal REV 3-Shock Condition FR-Z.1'

. Response.to High Containment Pressure REV 3 FR-Z.2 Response to Containment Flooding REV 1 FR-Z.3 Response to High Containment Radiation Level REV 2 F-0 Critical Safety Function Status Trees-REV 6 A0P-001 Primary Sys Instr 0 mentation Malfunction REV 7 A0P-002 Nuclear Instrumentation System Malfunction REV 4 A0P-003 -

Rod Control System Malfunction REV 7 A0P-004 RCS Coolant System Leakage REV 6 t

A0P-005 Partial loss of Flow REV 4 A0P-007 Chemical & Volume Control System Malfunction REV 4

.

A0P-009 Steam Generator-Tube Leak REV 4

'

A0P-012-Turbine Runback REV 5 A0P-016 Condensate & Feedwater Malfunction REV 3 A0P-019 Loss of Residual Heat Removal REV 7 A0P-020 Loss.of Component Cooling Water REV 3 A0P-021 Loss of Nuclear Service Cooling Water Sys REV 4 A0P-022:

Loss of Aux Component Cooling Water-REV 4 A0P-023 Loss of Turbine Plant Cooling Water System REV 3 A0P-028 Loss-of Instrument Air-REV 7 A0P-032. Loss of 120V AC Instrument Power REV 2 A0P-031'

Loss of Class IE Electrical System REV 6 A0P-036-Seismic Event REV 3 10012-C E0P and A0P Writers Guide.

REV 8 10013-C; Writing E0Ps from the Westinghouse ERGS REV 7

,

10014-C Verification of Emergency Operating REV 0 Procedures 13009-1

.CVCS Reactor Makeup Control System REV 6 (emergency boration sections:4.6 & 4.7)

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APPENDIX B

-

.

TECHNICAL AND HUP.N FACTORS COMMENTS 1-

'

-This appendix contains technied and human factors comments and observations.

These comments are not explicit regulatory requirements. However, the licensee acknowledged the factual content of each of tnese comments as stated.

The licensee further agreed to evaluate each commert, to-take appropriate action and to document that action. These items will be reviewed during a future NRC l

inspection.

{

I.

General 1.

In numerous cases Sections I and II of the SDD. contained information other than the detailed ERG and E0P step. Section 2.3.1 of procedure 10013 indicated that Sections I and II were optional. As a result

the SDD forms were not completed in a consistent manner.

For example, the.SDD for procedure 19200-C, F-0.5, was Revision 3 and the procedure was Revision 6.

Section I of the SDD stated " ERG has not changed.

See previous step documentation."

However, a note on the page-stated " Original step documentation was - not in file.

This is a i

reconstruction for documentation."Section III included the statement

that "The E0P remains consistent with the ERG and the previous step i

justification is still applicable."

2.

Completed step documentation forms were allowed to be used as source f

documents when preparing a new E0P revision. WhenLthe-team retrieved i

SDDs for the E0Ps from document control, the result was of ten a i

confusing pile of hand written step deviation forms that presented I

an extreme challenge to determine with certainty that step deviations

'

were adequately justified.

For example, the SDD for an 11 page E0P (FR-I.1) was approximately one inch' thick and the SDD for a 27 page E0P (ECA-3.2) was nearly four inches thick.

The files in the l

I operations support of fice were compiled in a more organized manner.

But even those files proved to be faulted, e.g.

part of the documentation for E0P ES-1,1 was found stapled into the documentation i

for E0P ES-0.0.

II.

EEP comments:

1.

E-0 Reactor trip or safety injection a.

Step 3:

Two reactor operators indicated separately that this

step actually required two actions:

verification of power to AC emergency busses and verification of power to 480V busses.

)

.

b.

Step 19:

Two reactor operators indicated separately that this step required the same action as step 6 but was written differently, c.

Step 37b:

This step was not a substep to accomplish step 37, but a distinct subsequent action step.

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Appendix B

2.

E-2 Faulted steam generator isolation a.-

Step 3 RNO:

This step required searching for break locations

.that required a local, inplant search.

This step did not

dispatch an operator to look for the break, e

b.

Step 4:

This step did.not provide the numbers of the l

isolation valves used for shutting MSIVs, BFIVs, MDAFW pump

'

.

throttle valves', and TDAFW pump throttle. valves, c.

Attachment A page 6:

Under steam. generator 1 and-4 for, Unit j

1 the panel location was incorrect.

The. team ' also noted-

_'

that panel 1BCQPCP's. terminal boards were not labeled inside

this cabinet, but rather contained temporary hand printed '

'

labels.

'j l

d.

Attachment A page: The panels in Unit 2 - described in j

Attachment A were not labeled on the outside of the cabinets'.

'

3.

E-3 Steam generator tube rupture i

a.

Step 2:

This step required the operators to identify the-

ruptured steam generators.

The steam generator blowdowns

'

radiation monitor was an instrument to alert operators to a S/G tube leak,' provide a method -for identifying - the leaking

)

L S/G, and give advance warning of a potential tube rupture.

}

~

However, the-alarm setpoint for the S/G blowdown radiation

'

monitor, RE-19, was set to.high that it would not provide early warning-of a S/G tube leak. The background reading was.about i.l'

5.0E-8 and the alert alarm-setpoint was 1.0E-5~, about two and one-half decades higher. A more common alarm setpoint would be about two.to five times background, to alert the operators of an increasing level.

The existing alarm setpoint did not effectively support the ' abnormal or emergency operating procedures.

'

b.

Step Sa RN0:

This step required the operators to " restore power to block valves unless shut to isolate a leaking PORV."

y During this inspection, one unit had a leaking PORV with a

'

block valve shut that still had power to it.

An operator

.'

stated that the PORV was not required by TS to have power

,

1,'o removed from its block valve.

The stipulation "unless shut

'

to isolate a leaking p0RV" was not in the ERG.

It was not consistent with the TS requirements and was unduly restrictive in prohibiting the use of a useable PORV during a

'.

unit emergency.

c.

PSTG DEV Step Sc RNO:

This step required operators to open at least one block valve unless it was shut to isolate a l

leaking PORV.

This dif fered from the ERG, in that the ERG p

stated "unless shut to isolate an open PORV."

L

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

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Appendix B

As in step Sa RNO, this istep was not consistent with the TS requirements"and was unduly. restrictive in prohibiting the use

,

of a useable; PORV during a unit emergency. This step also did

{

not.. include arming COPS, which must be done to open a block i

valve.

- l!

.d.

PSTG.DEV Step 7a RNO 2: Thi; step required "if feed flow and i

level can not be maintained to at least one SG, then go to

,

FR-H.1.

Resp,onse to loss of secondary heat sink."

This j

'

substep was n~ot in the ERG, and was not consistent with the

.1 critical safety function status tree.

The. CSFST requirements

.j for a satisfactory heat sink were satisfied by having either level in or flow to at least one S/G, while this step-required both level in and flow to at least one S/G.

i e.

Step 11a RNO:

This statement was potentially confusing, in that it required operators to " verify diesel generators have

assumed the following loads" and failed to state that the following list of loads should be operating on -each train.

Thus while the list included "2 NSCW pumps", the ' intention

!

was that, during a loss of all offsite power, two NSCW pumps

in each train (a total of four) would be operating, f.

Steps 14, 17, and 18:

None of these steps addressed turning l

off the pressurizer heaters during cooldown or depressurization.

This comment was originated by operators I

during a simulator scenario.

,

g, Step 18 note:

This note contained information about potential voiding of the upper head during RCS depressurization.

It was not located before step 17, which

.

directed the operators to depressurize the RCS with maximum

available spray flow.

While the location of this step.

followed the ERG, it was inconsistent with similar notes that I

'

i were located before depressurization steps in other E0Ps and ERGS.

,

.

h.

Step 20b:

This step required that operaters check for a secondary heat sink before terminating ECCS flow.

For a heat sink, it required level in at least one S/G or " total feed flow to S/Gs greater than 570 gpm available."

A licensed l

operator ' interpreted "available" to mean pump and flowpath operable, but no actual flow required.

This was inconsistent with heat sink requirements of other E0Ps (including the CSFSTs), which included 5 percent level in at least one S/G or total feed flow to S/Gs greater than 570 gpm, This step followed the ERG in the use of the word "available".

The ERG background document-tated that, for the purpose of terminating ECCS flow, heat sink requirements could be satisfied with less than 570 gpm of feed flow if a faulted S/G was involved. Terminating ECCS with zero feed flow and a red path on CSFST heat sink appeared to be inconsistent with other requirements of the ERGS and E0Ps.

I

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Appendix B

'

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,

1.

Step 22c:

This step required operators to " set HC-0182 to maximum seal flow (HV-0182 - shut')."

This was 'nconsistent with control room indications.

<

J.

Step ' 32 first bullet:

The actions required by this step differed from equipment-labels.

This step required dispatching an operator to " transfer SJAE 'and SPE -to HEPA filters."

In the turbine - building, the operator needed to turn switches HS-2875 and HS-2876 from by pass to filter.

'111. ESP comments:

1.

ES-0.0 Rediagnosi s '

a.

Step 1 note:

This note appeared'to some licensed operators to conflict with the entry conditions.

b.

Step 2a RNO: At least one operator was confused about the exact meaning of this RNO.

The RNO.did not -include a

'

l specific list of devices intended to be used to accomplish

the isolation,

,

l-c.

PSTG DEV Step 3: The AER and RNO columns vere reversed l

from the ERG presentation.

Adequate j ur,ti fication for this deviation was not found in the.SDO.

,

.-

au 2.

FS9.1 Reactor trip response a.

Step 6b RNO:

This step directed the operator to check for a S/G tube leak or rupture, but f ailec' to provide a contingency action if a leak or rupture was iden'.ified, b.

Step 7a RNO:

This step failed to indicate that the listed loads should be verified on each affected train.

l'

'c.

Step 10a RN0:

This step was not a contingency to step 10a, but rather a subsequent conditional step.

~3.

ES-0.2 Natural circulation cooldown a.

Step lb:

This step did not make it clear that once an RCP was started to then transition to the appropriate plant procedure.

b.

Step 4 note:

This note contained no punctuation with the result that it was unclear.

c.

Step 4 caution:

This caution did not state the available alternate source of water for AFW, d.

Step 10:

This step contained an incorrect technical

,

'

specificatior, paragraph numbe _

_

_-

i

..

.

Appendix B

'

e.

Step 13:

Saae as Step 10 abo,N

.f.

Step 14 RNO:

Same as Step 10 above.

In addition, this step did not provide the required figure number.

i g.

Step 15d:

This step did not provide the number of the valves i

used to isolate the SI accumulators.

'

h.

Step 15d3:

This step did not correctly describe the HV-0943B hand switch,

<

i.

Step 20:

This~ step did not state how many CRDM fans had to be running.

j.

Step 20 RN0: This step did not state how many CROM fans were required to be inoperable.

4.

ES-0.3 Natural circulation cooldown with steam void in vessel

'

(with RVLIS)

a.

Step 2a2 RN0:

This step directed the operator to use steam dumps to establish subcooling.

Conditions for using ARVs

'

were not specified.

No guidance on preferentially - selecting the steam dumps over the ARVs was provided, b.

. Step 7:

The action of arming COPS (per _ note above step 10)

-was.not performed prior to having RCS temperature less than a

350 degrees F.

-The AER did not include arming COPS as an-action in this step, c.

Step 10b 'The' level of accuracy of main control panel RCS pressure instrumentation was inconsistent with checking the expected response of 365 psig.

5.

ES-0.4 Natural circulation cooldown with steam void in-vessel (without RVLIS)

a.

Step 6a: A licensed reactor operator was not completely sure of the meaning of the action " place letdown controls in manual."

The lack of specific guidance confused the operator.

b.

Step 15:

The action of arming COPS (per note above step 19).

was not performed prior to having RCS temperature less than 350 degrees F.

The AER did not include arming. COPS as an action in this step, c.

Step 19b:

The level of accuracy of main control panel RCS pressure instrumentation was inconsistent with checking the i

expected response of 365 psi g, a

'

,

..

f'

@

Appendix B

e I-d..

Step 21a:

This step directed the operator to dump steam from all S/Gs. Conditions for using-ARVs were not specified,

'

No guidance on preferentially selecting the steam dumps over the ARVs was provided, e.

Step 21b:

The number of required CRDM fans was not specified in the AER column.

Operators were not certain how

many. fans were. required and the desired-speed (high or low).

'Accordingly, the operators were not sure when the RNO was applicable, f.

Step 22a:

The level of detail was insufficient and also was

'!

inconsistent with E0P ES-0.3 step 13a.

Licensed operators were not certain how the term " entire-RCS" was to be

!

interpret <.ed in this step.

6.

ES-l'1 SI 'ermination c

.

a.

Step 6a:

Valve numbers were omitted, b.

Step 6e:

Valve numbers were omitted, c.

Step 12e RNO:

The location of a. local valve was not given.

d.

Step 16b2:

Control room recorders used the term L

" seal' leakoff":not " seal return".

,'

h

. e'.

Step 20 Caution: -Alternate water scurces were not (

stated.

f.

Step 21 Note: This note _did not advise the operator that these valves were locked.

The valves were not identified on the P&ID as locked valves, p

g.

Step 22a RN0: The procedure number for restoration of

offsite power was not stated, h.

Step 28a: The term "subcooling monitor" lacked specificity.

There was'more than one means' of, determining subcooling.

1.

Attachment A Step 4: The location of valves was not stated.

The open/close position indicator on the remote valve (

operator for valve 1-1208-V6-152 was missing.

l J.

Attachment C Step 2:

The seal injection supply temperature was actually read from the VCT outlet temperature indicator on the main control board, k.

Attachment C Step 3:

Same as Step 21 note above.

1.

Attachment C Step 9:

Same as Attachmeit C step 2 abov p

-

..

..

x

'

Appendix B

>

7.-

'ES-1.2' Post loca cooldown and'depressurization a.-

Documentation:

The procedure review. request form for-generation of revision 5 of this procedure indicated that an

'

, environmental evaluation had been. performed and that it was attached.

The environmental evaluation form attached had not been completed or ' signed.

Despite ' this, the responsible f

department head had signed the procedure review request form indicating approval.

=b.

. Step-4a RN0:

This step required operators to " verify diesel L

generators have assumed the.following loads."

It did not state that tne list of loads was applicable to each affected

train.

!

c.

PSTG. DEV, Step 9 third bullet:

This substep required "RHR pumps :- any injecting in SI mode."

This differed from the

.,

ERG,'which. required an RHR pump running.

If RCS pressure was j

O above RHR -pump discharge pressure, this difference would-l inappropriately cause the-operators to go to step 9. RNO,

-which transitioned to, step 18 and bypassed steps 10 through-17.

The step deviation document did.not address this j

deviation from the ERG.

.j

!

'd.

Step 14: _ This step was confusing for operators, who had

difficulty understanding how to get out of it.

The purpose

i of the step was to stop SI. pumps, one at a time, if certain

,]

subcooling conditions. were met.

If this ; step was - entered with no CCPs running, the table in substep b required "D0 NOT q

STOP - SIP".

An SRO statedithat in order to get out of step 14,.substeps c and e had to.be interpreted in ways that were

j not clearly stated.

Substeplc had to be interpreted to mean

.

j that required subcooling could not be satisfied-since no

'subcooling setpoint was stated in -the table. -Then substep a l

which stated "stop one additional SI pump" had to be followea in ' spite of the statement in.-the substep b table, "D0 NOT L

STOP SIP.-"

t

e.

Step.16c:

This step required valve HV-0182 to be shut, but I

there was no such control board indication, q

a f.

Step 16f:

This step required operators to maintain seal

flow, but gave no quantities,

)

g.

Step 21:

This-step required operators to verify adequate l

shutdown margin but did not state the plant condition.

j h '.

Step 25b:

Same as Step 16f.

,

,

! :

..;

m Appendix B

1 i.

Step 26b2:

Same as Step 16f.

-j.

Attachment A Step lb:

This step required a steam bubble in

"

the _ pressurizer, but__ did not not give operators sufficient

'

guidance in how to. determine when the bubble existed.

One operator stated that any indicated level less that 100

_

percent, such as 99 percent, would be adequate.

Operator i

action setpoints in E0Ps typically include allowance 'for instrumentation uncertainties.

k.

Attachment D Steps 1,

2, and 6:

These steps required

!

operators to determine various temperatures, but gave no I

'

'

guidance on where to obtain this information.

Licensed

<

operators had ' dif ficulty in locating the sources of the required temperature information-I

.

1.

Attachment D Step 3:

These local valves were locked, but_

that fact was not indicated, j

l m.

Attachment D Step 4:

The word " verify" used here was

confusing _for operators.

One operator interpreted it to I

require independent verification of the valve position, j

!

8.

ES-1.3 Transfer to cold leg recirculation l

a.

PSTG DEV. Step 1 caution: This caution directed that steps.

.

,

one through seven be performed without delay.

The ERG only

'

required steps one through three to be -performed without delay.

The E0P included three. steps (4, 5 and 6) not in the

,

ERG. Also, this bulleted caution item is a note in the ERG.

'

si Adequate justification for these deviations from the ERG was

,

not found in the SDD.

,

!

.

b.

Step 1 note:

The renuired r.otication was not well defined.

Operations personnel did not have a specific announcement

'

defined in advance to ensure all potentially high radiation

!

'

areas would be covered.

)

?

c.

Step 2b RNO:

The referenced procedure title was incorrect.

!

d.

PSTG DEV Step 3 caution:

A technical justification for the

.-

plant specific actions in this step could not be found in the i

SDD.

e.

PSTG DEV. Step 4:

Steps eig' and nine were additional

.

steps, not in the ERG.

Jus fication for these adoitional steps was not found in the 500.

9.

ES-1.4 Transfer to hot leg recirculation

m

'

&-

.

-

'x$

'

x e

%& _ [4

.

"

m llp'n 3

'

,

.

m

,

k b K. j,4

'-

Appendix B

', h '

h'

k$'

<

,,

t i

f ;id a.

Step 2e: Operators had difficulty reading 100 gpm of SI flow

[7 on the meter, due to the log scale markings.

,

m

~

,

s, w, 10. ES-3.1 Post-$GTR cooldown using backfill

.

ai s.

Step 3:

This step required operators to verify adequate EN<

shutdown margin, but did not specify. the plant condition.

+

Some operators stated they would use current plant conditions instead of xenon free cold shutdown conditions.

-

i.

b.

Step Sa:

This step required operators to maintain an RCS

cooldown rate of less than 100 degrees per hour.

This was

,

c, h stated differently than the TS cooldown rate limit of 100 degrees in an hour.

There was operator confusion on the meaning of this step, in that some operators stated they z

>

,

would use the TS limits, and others stated that the 3,

requirement of this step was different (and more restrictive)

, '

'

than the TS.

c.

Step 9:

Same as Step 3 above.'

,%

'

1._

d.

Step 11a first bullet:

This step required the operators to check RCS temperature less than 350 degrees, but did not

,

state which temperature (ie. T cold, T hot, or' I average).

o

Operators gave different answers as to which temperature was L

to be checked.

<

e.

Step 11a second bullet:

>This step specifieu an RCS

,

y temperature of 365 degrees, which was different than the 375

!

-

,

degrees specified by the setpoint document.

,

11.

ES-3.3 Post-SGTR cooldown'using steam dump i

a.

Foldout Page Step 1:

The term ~ "subcooling monitor" was

,

i misleading.

There was more than.one method to determine

-

subcooling, b.

Foldout Page Step 5:

The word " lower" was incorrectly used.

J.

The word " lowers" would be correct.

'

c.

Step 2a:

Same as Foldout Page Step 1 above.

,

Mj d.

Step 2b2) RNO:

Valve numbers were not specified.

.

e.

Step 4 CAUTION:

Alternate sources for AFW pumps were not

"

,

specified.

'

,,

f.

Step 5b RNO: The intent was to run the TDAFW pump, but that 3'

was not clearly stated.

,

,

H'

g.

Step 10: " Bypass valve" was singular rather than plural.

h.-

Step 12d.:

Same as Foldout page Step 1 above.

",-

'Ic

!b

.,{,

,

-

L:

-

,

o

'3

,

i

'

,

,

..

3.

gA4i

.

Appendix B

w. -.

IV.

ECP comments:

!

,

3.

ECA-0.0 Loss of all AC power

'

a.

Step $b: This step lacked an AER to ensure the diesel load I

was within acceptable limits.

!

. l'

!

"

b.

Step 5d3: This step implied there was only one LOP l

L sequencer'to reset.

There were two per unit.

l

.

c.

Step 14b:

The AER was not specific as to the batteries to j

. '

be monitored.

When asked during the walkthrough, operators

were unsure if this step included only class 1E batteries, i

.

d.

Step-15: -This step did not provide an AER and RNO for the

!

case that CST 2 is in service and CST 1 is either in st.indby

,

or not in service.

,

e.

Step 16: The level of accuracy of main control panol 5/G

.

pressure instrumentation was inconsistent with checking the

!

'

expected response of 265 psig.

f.

Step 22 RNO:

This RNO required maintenance to install

temporary heating to increase BAST room temperature.

During i

the walkthrough, a maintenance supervisor. was contacted to '

>

-

' determine how this would be accomplished. Maintenance had no approved plan to accomplish this task during implementation

of E0P ES-0.0.

Likewise, maintenance had no approved plan to I

install additiew ' emergency lighting in the control room, g.

Step 25: During the walkthrough, licensed operators d-expressed a - need to include either an appropriate reference or a list of essential 480v AC loads.-

'

' '

h.

Attachment A:

During the walkthrough of DC loads that may be -

i n,

shed during loss of all AC, dif ficulty _in correctly t

identifying breakers within certain. enclosures - was.noted.

For example, when the door to breaker IBD11 was opened, room lighting to the area of the breakers and labels was

'

substantially blocked.

Further, the noun nants for_ the

%

affected loads did not. match the nomenclature of operator. aid

,

OA 2-89-40.

Also, the labels were not placed in close

?-;

proximity to and well aligned with the breakers.

'l'

i.

Attachment C:

During the walkthrough, the ERF computer

points were checked using Attachment C.

Fourteen af the paints

'

were found on the containment isolation valve pap.

But, eight

,

m

'of the points had to be individually checked.

Absent sper.iftc

references to ERF page' names, this activity was tecious r.nd time consuming.

2.

ECA-0.1 Loss of all AC power recovery without SI required

,

om i

I

,

b

<

..

,t

,

Appendix B A

l

!

f, Step 29a RC:

The procedure number for restoration of

offsite poweF was not stated.

.

!

-

s g.-

Step 31a:

The annunciator window location was not stated,

.

h._.

Attachment C,1b: A specific PRZR level range was not given,

!

,

i,.

Attachment E,2:

This step 'did not state that seal injection supply temperature was actually VCT outlet temperature.

j.

Attachment E,5:

This step did not clearly define the alternate sources of AFW water supply.

'

7.,

ECA-3.1 ' SGTR with loss of reactor coolant subcooled recovery desired

,

a.

Step 3a:

This step directed the operator to verify-

!

instrument air normal. -There was no value or band listed in j

the procedure to define " normal".

b.

Step 3b:

This step did not state that there were two hand

'

switches that had to be operated in order to re-establish instrument air to containment.

c.

Step 4a RNO:

This step required the operator to retrace steps in order to veri fy loads that had sequenced.

In

-

addition, the-step did not prescibe the appropriate plant procedure when restoring offsite power.

d.

Step 7c: This step required samples to be taken, however, it i

did not state the type of samples required.

i e.

Step 7d2: This step did not direct the operator to go to the appropriate procedure.

f.

Step Ba RNO:

This step did not provide the numbers of the valves required for isolating the steam lines and feed lines.

It also did not require auxiliary feed isolation or isolation of TDAFW pump steam supply from the faulted steam generator.

-;

g.

Step 9a' RNO 1: This step was missing a percent symbol after the 27.

h, Step 9a RNO 2: This step contained a typographical error; it used FRH.1 instead of FR-H.1.

t 1.

PSTG DEV Step 10 note:

No step justification was available.

J.

PSTG DEV Step 17d:

Same as Step 10 note above.

k '.

PSTG DEV Step 19b RNO:

Same as Step 10 note above.

<

1.

PSTG DEV Step 19c: Same as Step 10 note above.

w b

,

-

,

.-. --

-.. -

-

_

-_.

_ _ __

_ _ - _ _ _ _ _ _ -

e

.

',

'

,

,

_

F

.

Appendix.B 14-I t

m.

Step 20a:- This step did not provide valve numbers for the valves that needed to be open.

.

I n.

Step'20e:

Same as Step 20a above.

!

o.

Step 20f:

This step required that the operator maintain RCP seal flow, however, it did not state the flow required.

This i

step's ' document justification form did' not present a full technical justification.

,

p.

Step 22:

This step did not state the PRZR level that was to

be maintained.

L q.

Step 25c:

This step did not state how to verify shutdown--

l L

[

margin.

.r.

Step 27a:

This step was inconsistent with previous steps in that it stated RCS subcooling based on core exit TCs instead of RCS subcooling monitor indication.

'

-s.

Step 27a' RNO:

This step contained an extra set of

parentheses, t.

Step 27c: This step did not provide the number of the valves to be used to isolate the SI accumulators, u.

Step 28b:

This step did. not p-ovide a procedure number, for stopping and placing the the. diesel generator in standby.

v..

Step 29:

Same as step 10 note above.

This step. required that valve LV-4415. be verified Thut, however, there was no

. designation for locating this valve.

$

w..

Step 30:

This step directed the operator to check RCP seal

'

injection flow " normal".

There was no value or band listed

in the procedure to define " normal".

x._

Step 34 RNO:

This step required monitoring of S/G pressure

<

at 1135 psig, this pressure was net readable on the pressure indication available, y.

Fold out page 2c: There was a typographical error, "is" was.

.I used instead of "in".

t

,

8..

ECA-3.2 SGTR with loss of reactor cociant saturated recovery desired

,

a.

Step 3a RNO: At least one operator was confused about the exact meaning of this RNO.

The RHO did not i nclude a specific list of devices intended te be used to accomplish the isolation, t

w

,

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

.-

,

s i

l Appendix B

.o

b.

Step 4 caut kn:

Operators were unaware of specific contingency ' clans to supply water to the CSTs.

They were

generally a are of potential water sources, such as the fire

'

mains, but had no approved procedure to accomplish this

activity.

c.

Step 17a RNO: Conditions for using ARVs were not specified.

I No guidance on preferentially selecting the steam dumps over the ARVs was provided.

-

d.

Step 17b: This step did not require closure of the spray

,

valve. associated with the nonoperating RCP.

If said valve

.

was not closed, sprays would be ineffective.

,

e.

Step 19a: The step d'.d not specify which valves to open.

Also, blowdown sample valves closed on high S/G 1evel, which.

could have occured following a tube rupture.

No RNO was provided.

l 9.

ECA-3.3 SGTR without pressurizer pressure control l

.a.

Foldout Page: VEGP considered the CSTs to be the only source of water to the S/Gs.

This step directed the operator to r

align. any available low pressure water source to the depressurized S/Gs.

These alternate sources of water were

not listed.

b.

Step 17: When an operator was dispatched to level one of the turbine building to transfer SJAE and SPE to the HEPA i

' filters, HV-2875B/C and HV-2876B/C were to be opened and HV-2875A and HV-2876A were' to be shut for the SJAE and SPE respectively, Actually there were two switches, HS-2875 and HS-2876, that. could be positioned to either Auto. Filter or i

Bypass.

By repositioning these switches, the above mentioned t

valves got repositioned.

This logic was not reflected in the r

procedure.

i c.

Step 18b2: The operator was to verify seal return from each RCP - normal.for RCS pressure. Normal was not defined. The RCP i

operating curves in procedure 13003-1/2 were not utilized for i

guidance, d.

Step 36:

The operators were required to check RCS temperatures less than 200 deg F.

If the RNO was not j

utilized in the previous step, the RCPs were required to be I

tripped.

The operator was not instructed to utilize the

'

incore TCs in lieu of the RCS loop RTDs if necessary.

l e.

Attachment B,

A4:

Valve 2-1208-U6-152 was missing an l

open/close indicator on the remote actuator.

.

L V.

FRP comments:

1.

FR-C.1 Response.to inadequate core cooling

!

.-

.

_

y

-

-

_

m$U*

fy}

'

[

Appendix B

,

L

,

IiL a.

Step Ba:

There was some confusion among a few of the operators with respect to verifying containment hydrogen l

analyzers in service.

Confirmatory guidance such as " power on" and "no alarm in" was not included.

Furthermore, 8a RNO did not fully describe how to place the containment hydrogen analyzers in service.

For example, procedure 13130, implemented several other procedures which were required to place this system in service.

This guidance was not listed in step Ba RNO.

,

b.

Step 18 RNO:

There was no CVCS or excess letdown direct relief path to the PRT.

m 2.

FR-C.2 Response to degraded core cooling a.

PSTG DEV, Step 8a:

This step required operators to check

.

'

accumulator 1 solation valves open.

There was no position indication for these valves available at the switches in the control room, since the electrical power was removed from the valve motors.

Operators were-confused about the meaning of

'

this step, and most stated that they would not close the motor breakers to determine the valve positions.

The ERG required operators to restore power to the valves to determine valve position, and this step did not.

The 500 justification for this step deviation, operator knowledge, was not adequate.

The operators were not. aware of other

'

valve position indicat1ons in the control room that could be used,

'

b.

Step 11 RN0:

This step required operators to start RHR pumps a

before aligning valves, contrary to good operating practice.

RHR pumps could suffer damage if run with the suction valves shut, c.

Attachment A:

Valve HV-8509A was incorrectly identified as CCP A Alternate Mini-Flow.

The valve was actually CCP B Alternate Hint-Flow.

Similarly, valve HV-8509B was incorrectly identified as CCP B Alternate Mini-Flow, d.

Attachment A:

This attachment took operators a long time to perform, in part because the valves were net listed in order of MLB position indication.

3.

FR-C 3 Response to saturated core cooling a.

Step 3c:

This step used the term block valves; it did not state what block valves were open.

b.

Step 3d:

This step did not provide the numbers of the valves to be used to shut the CVCS letdown and excess letdown isolation valves.

4.

FR-H.1 Response to loss of secondary heat sink

-

I_ -

.

,

.s t

i

,

.

.

,

,

Appendix B-

,

a.

Step 2 RN0; No procedural guidance was listed for the operator distatched to locally resto.re AFW flow.

.

b.

Step 7el:

This procedure. step required the operator to open SGFP discharge valves.

SGFP could have meant either MFP or AFW pump.

This step did not sufficiently describe which

valves to open.

'

c.

Step 13:

No provisions were established for the operator to go back and execute steps 1-9 if the caution statement was implemented.

d.

Step 13e RNO:

VEGP considered the CSTs to be the only source of water to the S/Gs.

This step directed the operator to align any.available low pressure water source to the depressurized S/Gs.

These alternate sources of water were not listed, e.

Attachment A:

Valve number 1204-U4-207, RWST Supply To ECCS, was listed as OPEN in lieu of OPEN/ LOCKED.

f.

Valve number HV-8508A and HV-850SB position indication was listed as MLB08 and MLB9 respectively. The actual position

'

indication was MLB09 and MLB10 for HV-8508A and HV-85088.

i 5.

FR-H.2 Response to steam generator overpressure

-

a.

Step 1 note:

This note required the operator to read S/G

pressure to greater accuracy than permitted by the meter.

-

b.

Step Sb:

This step required the operator to read S/G pressure to greater accuracy than permitted by the meter.

c.

Step Sc:

Same as Step Sb above, d.

Step 6a:

This step provided the number of the valves for the MDAFW pump that were to be throttled.

These valve numbers corresponded to the TDAFW pump throttle valves, e.-

Step 6b:

This step provided the number of the valves for the TDAFW pump that were to be throttled.

These valve

}

numbers corresponded to the MDAFW pump throttle valves.

~

f.

Step'7:

This step required the operator to read RCS hot leg

,

temperatures to a greater accuracy than permitted by the meters, g.

Step 7 RNO:

Same as Step 7 above.

6.

FR-H.3 Response to steam generator high level a.

PSTG DEV -Step 2a:

No step deviation justification was

!

'

available.

-

C

.

'

,

[

Appendix B

i b.

Step 2c:

Same as Step 2a above.

t c.

Step 3a: This step did not provide the numbers of the valves used to throttle the MDAFW pump.

d.

Step 3b:

This step did not provide the numbers of the valves

used to throttle the TDAFW pump.

i_

e.

Step 6: This step did _not provide the numbers of the valves r

for S/G steamline isolation nor for bypass valve isolation used to isolate the affected S/Gs.

f.

Step 7:

This step referred to the wrong S/G.

g.

Step 7 RNO: This step used incorrect grammar.

7.

FR-H.4 Response to loss of normal steam release capabilities a.

No comments 8.

FR-H.5 Response to steam generator low level a.

PSTG DEV Step 4:

The AER value for AFW flow was not the same in the setpoint document and the E0P.

The setpoint document gave a value of 30 gpm, but 50 gpm was used in the EGP.

b.

PSTG DEV Step 4 RNO:

The ERG limited maximum AFW flow rate in this case to 100 gpm.

The E0P used a value of 50 gpm.

Adequate justification for this deviation was not found in the 500.

9.

FR-I.1 Response to high pressurizer level a.

PSTG DEV Step 1: loe E0P AER was to " check if ECCS has

'

been terminated", but the ERG AER was to " check if SI has been terminated." Operators understood that ECCS means RHR, SI and CCP.

Adequate justification for this deviation from the ERG was not found in the 500, b.

PSTG DEV Steps 2 through 4:- These E0P steps corresponded approximately with ERG steps 2 -and 3.

However, the content

'

and sequence deviated from the ERG.

Adequate justification for this deviation from the ERG was not found in the SDD,

'

c.

Step 2b RNO:

The expected response of 90 gpm letdown flow

'

through the vessel head vent exceeded the range of the

.

instrument available to the operator, d.

Step 2c RNO:

Since main control board instrumentation for PRT pressure and level was not indicated to be post accident qualified, operators were uncertain how to successfully complete this RNO.

p g'l

~

m i

,

':

,

,

y on b

Appendix B

L

!

r 10.

FR-I.2 Response to low pressurizer level

i a.

Step 6b:

No guidance was included as to where to find seal

'

injection supply, RCP number one seal and ACCW supply

g temperatures. (ERF computer, PROTEUS computer, local, etc.)

11.

FR-I.3 Response to voids in the reactor vessel

,

L

,

!'

a.

Step 2:

This step did not state that 8 gpm was required for

)

each pump.

ll b.

Step 2c RNO:

This step did not provide a procedure number l

J x for establishing charging flow.

c.

Step 6a:

This ster did not provide the operator with the

,-

'

proper curve to bt:

used to comply with Technical Specifications pressure / temperature limits.

d.

Step 6b:

This step required the operator to read RCS (/

pressure to a greater accuracy than permitted by the meters.

i

e.

Step 9:

Same as Step 2 above.

f.

Step 17a:

This step did not state where to obtain hydrogen

.

concentration in dry air, i

,

V:

g.

Step 17a RNO:

This step did not provide a procedure number for lowering hydrogen concentration.

h.

Attachment E, Step la:

This step did not specify the meter l

,.

to be used.

1.

Attachment E, Step Ic:

Same as Attachment E Step la above.

J.

Attachment E, Step 2a:

Same as Attachment E, Step la above.

U k.

Attachment E, Step 3a:

Same as Attachment E, Step la above.

12.

FR-P.1 Response to imminent pressurized thermal shock condition n

a.

Step Id RNO:

This step was described as being confusing by operators, b,

Step 5 RNO:

ERG rules of usage directed operators to L

continue on in the procedure when a step could not be

"

accomplished.

As written, step Sa2 RNO would be performed ("Try to start one RCP... ) regardless of the RCS subcooling s

monitor value checked in Sal RNO.

c.

Step 8b:

This step required manipulation of two handswitches related to one valve.

Operators indicated that inclusion of the two handswitch numbers would make the step less confusin.

.

O Appendix B

'

d.

Step 12 RNO:

Same as Step 5 RNO above.

e.

Step 22:

This step sent the operator to the RNO column if

)

the RCS subcooling value was equal to or greater than approximately 34 degrees F.

If subcooling was less than 34 degrees F, the RNO would have directed the operator te return

,

to Step 15, which required use of normal pressurizer spray to depressurize the RCS.

13.

FR-P.2 Response to anticipated pressurized thermal shock condition a.

PSTG DEV, Figure 1:

This figure was titled "Cooldown limit

-

curve".

One axis of this graph was labeled

"RCS temperature", while the corresponding ERG graph w6s labeled

"RCS cold leg temperature".

This labeling difference provided an opportunity for operator confusion, and was not addressed in the step deviation document. An SRO incorrectly stated that enre exit thermocouples could be used for RCS temperature determination for this graph.

b.

PSTG DEV, Figure 1:

The curves on this graph included

-

adverse containment values.

The two inputs to the graph, RCS cold leg temperature and RCS pressure, did not include adverse containment values throughout the E0Ps.

The

,

application of adverse containment values here appeared to be inconsistent with the rest of the E0Ps.

The ERG graph did l,

not contain adverse containment values.

The step deviation

'

document stated that adverse containment values were used to include instrument uncertainties in incore thermocouples.

This justification-was inadequate, in that incore thermocouples were not used for determining RCS cold leg temperature or RCS pressure.

The licensee stated that the adverse containment values for this graph had been supplied by Westinghouse engineers.

c.

PSTG DEV, Figure 1:

The temperature and pressure axes of this graph were reversed from the ERG, which resulted in

'

curves that had a substantially different shape from those in the ERG.

The axes of this graph were also reversed from

'

similar graphs in the TS and in other E0Ps.

This difference provided an opr,ortunity for operator confusion, and was not addressed in the step deviation document.

14.

FR-S.1 Response to nuclear power generation /ATWT a.

Step 5:

This step lacked the contingency to allow RCS heatup

,

if emergency boration was not successful, as included in Step 10 RNO of this procedure.

15.

FR-S.2 Response to loss of core shutdown

m

,

.

'

.

.

. Appendix B

a.

PSTG DEV Stu 1 caution:

Adequate justification for this

, deviation frh the ERG was not found in the SDD.

b.

Step la RNO:

The RNO lacked specific guidance for operators to determine if the intermediate range channels hre undercompensated.

During E0P walkthroughs, licensed reactor operators were unable to promtly determine with certainty if

, ' -

the irs were undercompensated.

The RNO did not include meaningful expected responses for operators. The RNO did_ not specify a preferred method for boration.

The ERG background document required the plant specific means of boration to be

,

i defined.

During plant walkthroughs, at least one licensed operator wa's not sure if emergency boration was intended by this RNO.

'

16.

FR-Z 1 Response to high containment pressure a.

Step Sb:

This step required the operator to determine 40 gpm-of flow on FI-930.

The scale of that instrument was not suitable for reading a value of 40 gpm.

'b.

Step 12a:

This step required the operator to determine if current hydrogen measurement was available, but did not specify how.

It did not reference the applicable system operating procedure, 13130.

c.

Step 12a:

This step did not include use of the PASS for

,

'

'

determining containment hydrogen concentration.

d.

Step 12b:

This step required hydrogen concentration less than 6.0 percent in dry air prior to starting a hydrogen recombiner.

This setpoint was not consistent with control room. indication, which was labeled percent volume. Operators did not understand how to determine 6.0 percent in dry air, e..

Step 12b:

The 6 percent requirement of this step was not consistent with the 4 percent precaution of t,he system operating procedure for operating the hydrogen Tecombiner system, 13130.

17.. FR-Z.2 Response to containment flooding a.

StepLI:

The list of sources of containment flooding was not complete and accurate.

For example, AFW and main

'

feedwater were not. listed.

"ECCS", not a specific piping system, was listed.

No expected response was provided for

.the operator to accomplish this task.

18.

FR-Z 3 Response to high containment radiation level a.

Step la RNO:

This step required the operator to manually

!

shut a total of 22 dampers, fans, and valves found in three

'

locations in the control room area.

A senior reactor c

x

.

.

.

J

,

,

- - - - - _ -. -.. _ -.. ___

,

jy

-

.,

,

o

.

Appendix B

l

i

,

operator had difficulty locating four of the switches and '

indicated that a list of the~ switchet and their panel

!

locations would be extremely helpful.

VI.

CSFST Comments:

l 1.

' F-0 Critical safety function status trees

!

a.. Step 1:

CSFS trees displayed on the ERF computer were mode

. dependent.

The ERF was designed to display the high level.

CSFS trees-when in rode 0 and automatically switch to mode 0

,

upon detection of either a reactor trip or safety injection

!

signal.

Since the CSFS trees and associated setpoints were

'

mode ' dependent, it was essential for users to know the ERF computer mode was correct for the plant mode. The E0P did not

-

include an AER to verify that the switch was in mode 0.

,

2.

F-0.1 Suberiticality a.

No comments.

'i 3.

F-0.2-Core cooling.

'

a.

No comments.

,

4.

F-0.3 Heat sink

!

,

'

a.

No comments 5.

F-0.4 Integrity a.-

No comments.

[

<

6.-

F-0.5 Containment

a.

PSTG ' DEV The radiation level alarm setpoint for - the post

)

accident - containment ' radiation monitor was 100 mr/hr per the Setpoint Document.

The CSFST indicated a value of 1.0 R/hr.

No justification for this deviation was provided in the Step l

Documentation.

-7.

F-0.6 Inventory

,

a.

No comments.

VII AOP comments:

1.'

13009.CVCS Reactor makeup control system (emergency boration'

I sections 4.6 and 4.7)

a.

Section 4.6.1.3:

This step did not include a requirement to ;

,

t

>

-

~ -

,..

..

y

,

.,

>

g

,: s

,,

..

,.

!q g L e-

!

.

,

.

.

?

. Appendix B-

<

' '

!

!

[

note the tine of emergency boration start and the value on i

L the BA to bTender totalizer.

That -information was needed to j

determine wnen section 4.6.1.10 may be performed.

-

U b.

Section 4.6.1.4:

The number of signif..dnt digits for i

if charging flow rate exceeded the readability of the meter.

c.

Section 4.6.1.5:

The value of 30 gpm was below the range that could be accurately observed by the operator.

,

E d.

Section 4.6.1.6:

Same as Step 4.6.1.5 above.

-

I e.

Segtion 4.7.5b:

The value of 110 gpm for BIT flow was below

'-

the range that could be read on the meter.

2.

AOP-001 PM mary system instrumentation malfunction-failure of pRZR pressure instrumentation

'

a, No comments 3.

AOP-003 Rod control system malfunction a.

Step A4:

QPTR did not apply above 50 percent reactor power.

L Th.is step called for monitoring QPTR and reactor power rather than just reactor power.

b.

Step A18:

This step did not state that the P/A converter was locatec r. side the control room and that an operator must be dispat; c.

Step B8:

Same as Step A4 above, d

Step CS:

Same as Step A4 above.

e.

Step C26 NOTE:

Same as Step A18~above, d

- 4.

A0P-004 Reactor coolant leakage

.

"'

a.=

Symptoms:

This section required the operator to monitor Containment moisture rising, there are no instruments that and be read to determine whether containment moisture is rising, b.

Step Al RNO:

This step did not address midloop operations.

This step did not provide a transition to procedure AOP

-

18019-C when midloop operations were in progress.

'

i c.

Step A10 RNO:

This step could not be entered due to the structure of the procedure.

d.

Step B1 Note:

This note contained an incorrect acronym, psia instead of psig.

,

I

-

,..

t'

i.

• -

A I

'

Appendix B

f F

e.-

Step B2:

This step required monitoring of VCT level at 5.7 percent. This value was not readable on the' level indicator available.

,

.f.

Ster note B1:

T h',

note contained too much information, the third bullet directed the operator to transition to a procedure necessary if in midloop operations.

The importance of this note is crucial for proper transitioning.

This note would be better as a caution at the. beginning of the subs.ection.

,

g.

Step B5:

This step did not provide the operator with an g

option if RCPs were running.

h..

Step B5 RNO:

This step did not provide the. numbers of the valves used to shut the hot leg suction valves, i.

Step B6 RNO:

This step did not inform the operator that removal of a clearance was required or that keys would be needed'to accomplish the task.

J.

Step Bild RNO: This step did not state he method to be used to depressurize the RCS.

,

k.

Step B16 RNO:

This step did not state the means of depressurization to be used if letdown was not in service.

1..

Step' B17:

This step did not provide & listing of manual containment isolation valves required to be closed.

In addition, this step did not dispatch personnel to close.

containment and personnel hatches.

]

i'

m.

Step B18:

This step required CNMT fans to be started, however, it did not state the speed required.

n.-

Step PIB RNO:

This step required monitoring of CNMT pressure I

.less than 21'.5 psig.

This pressure was not readable on the

!

prersure. indication available on the main control board.

-

o.

Step B19d RNO:

This step did not provide valve numbers for-the SI accumulators used for isolation, it also did not i

provide valve numbers for the venting of SI non-isolable

'

accumulators,

>

p.

. Step B20:

This step did act provide the adverse containment PRZR level.

,.

q.

Step B21:

This ' step did not state the number of reactor coolant pumps required to be monitored.

r..

Step B22c3 RNO:

This step did not correctly represent valve i

HV-0943B.

.

-,

-

,-

,

.__ __ ___

_,

r

)

.

.

..

Appendix B

.

.

.

.,

n-

[

.s.

Step B26a RND: This step did not provide adverse containment

.

. values.

~

<

t.

Step B29:

Same as Step B26a RNO above.

u.

Step B30a RNO:

This step contained a typographical error, e

v.

Step B31:

This step did not direct what seal flow to

,

maintain.

,

i n

'

w.

Step B32:

This step did -not provide the procedure to l

continue the cooldown to cold shutdown.

l_

-5.

A0P-007 Chemical and volume control system malfunction-a.

Attachments B and C: These attachments directed operators to locally-operate valves that were locked, but did not identify l:

-

the fact that the valves were locked.

,

,

!

6.

A0P-012 Turbine runback

[

a.

Step 7 RNO:

The statement "no circulating water ptmp;

running" was included due to the " setback function".

That

!

function was no longer in effect.

!

b.

Step 9 RNO:

This step was worded differently than

.i similiar instructions in step 7 RNO.

7.

AOP 16 Condensate and feedwater malfunction

.a.

. Step la3:

This step was missing a percent symbol af ter the-50, b.

Step lel RNO:

The TDAFW pump does not start on a loss of a

MFW pump.

Step 1c1 RNO contained no instructions to manually start this pump.

c.

Step 4:

Procedure 13009 allowed emergency boration through either the normal path (the blender) or through the emergency-

. boration valve HV-8104.

Step 4 did not reference procedure -

13009.

8.-

A0P-019 Loss of residual heat removal a.

Step A2 RNO second bullet:

This step did not include the i-TDAFW pump as a means of RCS cooling, which was inconsistent with similar E0P steps,

,

L b.

Step A3 RNO:

This step directed operators to vent. the af fected RHR pumps.

During a simulator scenario, operators expressed concerns about venting:

difficulty in determining

"

when all air was vented due to unit configuration, and potential contamination of the Auxiliary Building or Fuel

,

...

_ _ - - _ _ _ _

o

,

.

.

Appendix B

l

!

.

Handling Building due to venting.

These concerns were addressed in the RHR system operating procedure,13011. This

,

step included no reference to venting concerns or to 13011.

c.

Step A6 RNO d and e:.These steps directed operation of

$

valves, but did not include valve numbers. This comment was

identified by operators during a simulator scenario.

d.

Step A6 note and Step A27 RNO:

This note gave directions to vent the reactor vessel by opening RHR suction vents to allow gravity flow. from the RWST.

In combination with step A27 RNO. operators were directed to gravity drain the RWST to the

'

RHR

.smp suction and out the RHR pump suction vent.

This flowpath would inappropriately cause the cool borated RWST

water to bypass the core.

The system operating procedure for RHR included directions for RWST gravity feed and bleed of the RCS - these directions

>

required using the RV head vents, not the RHR pump suction

>

vent.

The RHR system operating procedure, 13011, was not referenced by either step A6 note or step A27 RNO.

e.

Step A10:

This step directed operators to restart RHR, but

did not state on recirculation or injection.

This comment

.

was originated by operetors during a simulator scenario.

l f.

Step A12b:

The wording of this step was confusing and f

incomplete.

It required operators to maintain pressurizer level by using CCP or S/G AFW feed with SGBD bleed.

S/G feed and bleed would not maintain pressurizer level.

The intent

,

of the step was to maintain the RCS cooled and maintain pressurizer level. Alternate methods of RCS cooling, such as RCS feed and bleed, were not included.

.;

g.

Step A13: This step required that if S/P.s were available for.

cooling, operators were to verify at least two S/Gs greater than 17 percent NR.

This was inconsistent with TS requirements of 17 percent WR.

h.

Step A16:

This step ' required operators to control RCS

,

I pressure at 365 psig.

It did not give a control band.

l 1.

Step - A22 RNO:

This step required operators to align SI

accumulators to ' establish a flowrate per Figure 1.

Since

'

t there were no flow control valves for the SI accumulators, operators could be confused about 'the meaning of this step.

The step did not give clear directions to operators.

J.

Step A23b:

Same as step A13.

!

k.

Step BIS RNO:

This step required operators to start a CCP and then align valves as necessary.

This was not consistent

.

L

,

,

I y

{

r

[L [

S y

,y

. Appendix B.

.

L with good operating practice, as a pump could be damaged if k*

operated with its suction valve closed.

m 1.

Step BIS second bullet:

This substep was unclear and V

incomplete.

It required operators to establish an RCS feed b

path from the RWST by verifying valve alignment for operating L ",

pumps.

It did not rtate.which pumps or direct starting the m

pumps.

It' also did not irclude all available options, such

l as gravity feed.

M'

'

m.

Step B16a:

This step regi, ired operators to establish an RCS h'

bleed path by opening drain valves on at-least one RCS loop.

p It did not consider that the primary feed path of step B15, a

normal charging, was into loop 1.

As a result, if operators

~'

selected the first choice of drain path, loop 1 drain valves, the RWST water would inappropriately bypass the core, t

n.

Step B16b:

This step contained two incorrect valve numbers and one incorrect valve location.

It required an operator to

- open valve 1-1901-U4-002 in Room RA49.

The correct valve was 1-1204-V4-002 in Room RA04.

It took experienced licensed operators hours to identify this correct valve and location.

The step also incorrectly identified valve 2-1204-V4-002 as

-

valve 2-1904-U4-002.

9.

A0P-020 Loss of component cooling water a.

Step 5: This step did not state that there were both a HI/LO and a LO/LO level annunciator.

'

b.

Step 6:

This step did not give guidance on the term

" unexpected leakage".

a c.

Step 7:

This step did not state that an operator must be

"

dispactched to locally perform it, d.

Step 7c:

The local flow indicator had a scale of 0-100. The scale did not indicate whether rnis was percent or gpm. No guidance was given as to the location of these flow indicators, I

e.

Step 7d:

The location of the TI indicators was not stated.

f.

Step 9:

This step did not state that the. spent fuel pool h

temperature was a local indication only.

10. AOP-021 Loss of nuclear service cooling water system i

'

a.

Step 4:

This step did not direct the operator to go to the appropriate section of the. procedure listed, b.

Table 1:

The seismic fire protection header was not liste p 7py

.

.

,

y

, --.,

.c e

. y%

_

,P i

f

.a n p

[L

' Appendix B

'

6.

,

t c.

Step 2:

The AOP stated " supply header pressure greater than j

'<

90 psig".

The supply header pressure gauge in the control

'

room red lines at 70 psig.

+

,

'

>J

'

11. A0P-022 Loss of auxiliary component cooling water

!

a.

Step 5b RNO:

The seal return flow from each RCP was

-

+

• ,

typically 1 to 2 gpm for RCPs l' and 3 respectively. The RNO

stated approximately 3 gpm.

'

b.

Step 8:

There was some confusion when reading the proteus -

l

'

computer whether or not the RCP motor bearing and pump-

%,,

bearing were the same as the upper and lower radial bearings

-

,

respectively.

.

[ '" y c.

Step 9:-

There was no. procedural direction for the

.

L establishment of natural circulation in these steps.

!

[

d.

Step 15: There were no temperature alarms to verify for the

'

'

Waste Gas Compressor Package.-

'

-

,

l e,

Step 17:

There were no directions in either procedure 13214

'

.g

,

I ""

or procedure 13002.

'

L f

12. A0P-023 Loss of turbine plant cooling water systems a.-

Step 1 note:

-This note did': not. give the operator the

'a'

,

location of FI-7093,

-

'

b.

Step Alc RNO:

This step did not state that a key - was -

necessary for valve operation.

In addition, the step did not state the valve location.

'

i c.

Step A3a1 RNO:

This step was wordy and not easily

'

understood.

o y

,

g

.

d.

Step A3a RNO:

This part of the step was actually another

-

discrete step but it was not written as such.

,

e.

Symptoms Section B: This section required local readings for

,

pressure and level but did not provide the location of these

. g

.

L'

instruments.

,

m n

y" f.

Step B4b RNO:

This step required local verification of TPCCW flow using-FI-17373.

The actual flow from this flow 1j.%,

indicator was 500 -gpm; ' lower than the band given in this y

-

step.

1; 13. AOP-028 Loss of instrument air

,

a.

Step A4: This step-did not direct the operator to go to the appropriate procedure.

C t

b

I

-.

.-

g y

-

-.

,.g

'

"

Q

,

,

.s; j

"

Appendix B

,

j

.,

!

b.

Step A8 note: This note was not placed directly in front of

>

the step to G.nich it pertained,

'

e.

Step B6:

This step required monitoring of $/G pressure at 1085 to 1135 psig, this pressure was not readable on the i

pressure indication available.

"d.

Step B9:. This step directed the operator to shut ' down 3

,

g~.-

RCPs.

It did not have a note prior to it stating which pump to leave on.

,

-,1

.:

C.

e.

Step B12:

Thi s step did not provide the numbers of the

• .f '

valves required for placing the head vent system letdown path

!

'

in service.

,

>

S f.

Step B13:

This step did not direct the operator to go to the -

,

N appropriate section in the procedure listed.

p

g.

Step C4:

Same as Step B13 above.

'

!

o h.

Step C10a:

This step did not state that two operators were required to perform it.

It did not state that a key was.

!

,

required.

This step did not state that the handwheel for one

!

of the valves was locked on the other side and its operation

.#y

,

required entry into a locked high radiation area.

,i

-

.'

-1.

Step Cll:

Same as-Step B13 above.

.

ue J.

Step C16:

This step required i

• • rator to open HV-9378A P

or HV-9378B.

In order to reston,

'strument. air to the g

containment both of these handswitches J to be opened..

,

14. AOP-31 Loss of class 1E electrical systems

,

,

.

vo y

a.

Step.3 RNO a and b:

These substeps required local I

,

l-operations, and that fact was not indicated, b

b..

Step - 5:

This step required-. reading 290 amps on meters that

!

-lacked sufficient discrimination for that determination.

'

15.

A0P-36 Seismic event

,

E a.

No comments, t

VIII.

E0P Attachment comments:

-

F 1.

Starting a reactor coolant pump l

a.

Step lb:

This step did not state how to determine a steam E

bubble was in the PRZR.

.

t

.;

>

.

b.

Step 2a:

This step did not provide the annunciator light box i

[

used to locate the appropriate alarm.

S y

,

sf

p}. ybif,,

,

.

-

,

f4

,

'

ioa Appendix B.

,

h,

,,

p

,

c.

.'

c.-

Step 2b:

Same as Step 2a above.

(

d.

Step _2c:

Same as Step 2a above, f

e.

Step 2d:

Same as Step 2a above, p

(;

f.

Step 2e:

Same as Step 2a above.

[

g.

Step 29:

Same as Step 2a above, p.

h.

' Step 2h:

Same as Step 2a above.

1.

Step'21:

Same as Step 2a above.

j.

Step 2j:

Same as Step 2a above.

.?

T k.

Step 2k:

Same as Step 2a above, ei,

.e..

.

Step 21:

Same as Step 2a above.

1.

'

m.

Step 3:

This step did not provide the valve numbers of the n'

valves to be verified open to the thermal barriers.

D

'

n.

Step 6a:

Same as Step 2a above.

m.

Step 6b:

Same~as Step 2a above.

.o.

Step 6c:

Same as Step 2a above, c

p.

Step 6d:

Same as Step 2a above.

2.

Valve lineup for SI pump cold leg injection a.

No comments iJ 3.-

Establishing charging without instrument air a.

Step A3:

This step required operators to-. verify 'HV-8804B

closed. ~ This valve would - have no power and no position

, - -

.

indication in the control room at this time. There were no directions to operators as to how to verify the valve closed.

b.

Step A4:

This step required operators to verify HV-8SO98-e open.

As in step A3, this valve would have no power and e

there were no directions to operators as to how to verify the

~

valve position.

l l

c..

Step A8b:

This. step required operators to operate a locked valve, but did not state that the valve was locked.

d.

Attachment A steps B3 and B4: 'As in steps A3 and A4, these

,

steps required operators to verify the positions of valves

-

that would have-no power.

!L p

)$ '

'

'

"

h, l l. ' !( $'

'

i

'

,

zy

,

_ {

.(~ii t

r ' Y

;b

'

0+

,

,

,.

V i'Appendii B'

y.,

a; -

,

,

..

Up1<

i

-

The steps gast no directions to operators as to.how to determine

R'

the valve politions.

'

"

,4,.

_' Valve lineup for RHR pump cold leg injection eg

.

,

v a.-

.No comments.

'

-

[R,'

"

5.

RWST makeup from spent fuel pit using train A/B

e1 a.

These attachments required local actions that were not F.,

indicated as such.

.i-

'

-

t

'k-i fli,,

'6.

Establish safety-grade letdown

]

4'

a.

No comments

]

7'

Recovery of RCP Seal Injection

.!

,

+-

q.

i

~

l a.

The actions - required to. recover. RCP -seal injection are

["'

presented in a distinctly different form in A+'schment B1 to.

.

e A0P-007 than in the versions of this attachment included with

E0P s. =

t

'

<

t. : e ll

.

.

p

'

a i

.

k i

a

>

AS

,

g 4.,-

l

}.

g jb

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-i

,

b

,

Ll< t

'

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.

>

. !

L

>

,

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.

w.

,'l

'

,

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i l

APPENDIX C WRITER'S GUIDE COMMENTS

,

i

-

This appendix contains writer's guide comments and observations.

These comments are not explicit regulatory requirements. However, the licensee acknowledged the factual content of each of these comments as stated. The licensee further

agreed to evaluate each comment, to take appropriate action and to document that action.

These items will be reviewed during a future NRC inspection.

.

GENERAL COMMENTS-1.

Inadequacies in the E0P and AOP writer's guide The concept of. a combined writer's guide for both E0Ps and ' AOPs is a strength in the Vogtle procedures program.

However, the Vogtle E0P and AOP writer's guide did not thoroughly address each aspect of the

procedures nor did it define restrictively those aspects of the E0Ps that were addressed.

In addition, some of the guidance contained in the writer's guide caused increased operator difficulty in understanding the E0Ps.

j 1.

Incomplete E0P and AOP writer's guide i

!

Aspects of the.0Ps and A0Ps that were not addressed in the Vogtle E0P and AOP writer's guide had to be written according to - the l

preference and judgment of the writer. As a result, inconsistencies

l j'

were introduced into the procedures..The following aspects of the.

,

!

E0Ps and AOPs were not addressed in the writer's guide:

i

a.

Descriptions and examples of the different types of substeps-b.

Inclusion of both Unit 1 and Unit 2 instrument numbers

!

'

c.

Some method for reminding operators of cm.tinuous action steps d.

A method for indicating concurrent actions it

,

e.

Use of bullets other than for indicating sequence inconsequential actions f.

Form for transitions to procedure attachments I

g.

Form for inclusion of alternate expected responses L

h.

Definitions of the action verbs "depressurize",

"repressurize", " cool", " lock-out," and " recheck"

!

I

_

_

,

'

-

e

-

.

,

t

!

Appendix C.

'

The following uvects of the E0Ps and A0Ps were not defined restrictively in h e writer's guide-s

.a.

Distinct definitions and uses for " verify,"

" check,"

" determine," and " ensure"

'

b.

Placement of all notes prior to the steps to which _they apply, even if the note applies to the outcome of the step c.

Structure of continuous action steps and distinctions between the use of "WHEN, THEN"

"try,"

" monitor," " maintain,"

" control," and " complete" d.

Use of the term " initiate" EITHER as a transition term OR an action verb II.

EEP comments

!

,

l 1.

E-0 Reactor trip or safety injection

>

a.

Step 4 RNO:

This step used commas in a manner contrary.to

.

writer's guide requirements.

'

'

b.

Step 6' RNO:

This step included a transition structured contrary to writer's guide requirements.

c.

Step 17:

This step included verbs in expected responses,

'

contrary to writer's guide requirements,

'

d.

Step 20b RNO:

This step included embedded logic and a continuous action step structured contrary to. writer's ' guide

requirements.

-

e.

Step 20c' RNO:

This step included the term "-0R " 'and used '

bullets' in forms contrary to writer's guide requirements, f.-

Step - 22 note:

This note contained an action contrary to:

'

writer _'s guide requirements.

g.

Step 24:

This step included a logic term used contrary to a

writer's guide requirements.

h.

Step 25:

Same as Step 24 above.

1.

Step 26: Same as Step 24 above.

J.

Step 26b:

This step included the term "-OR " used contrary to_ writer's guide requirements, k.-

Step 29 caution:

This caution used logic terminology contrary to writer's guide requirements.

,

L

.f

.

-

-

.

.,

.,

.

.

a

.

.

.,

t

-

>

.

_

!

,

!

Appendix C

j 1.

Step _29a RNO:

This step. included a continuous action step

structured contrary to writer's guide requirements.

'

m.

Step 32 caution:

Same as step 29 caution above.

.

,

n.

Step _35a RNO:

This-step included a transition structured contrary to writer's guide requirements.

,

~

o.

Step 35b:

This step listed one valve number in a form

con't'rary to writer's guide requirements.

p.

Step 36 caution: LSame as step 29 caution above.

I q.

Step 36:

Same as Step 24 above, r.

Step 37:

Same as' Step 24 above.

_

s.

' Step 37b: This step was-not a substep to steo 37.

'

t '.

. Attachment A items '3 'and 4:

The setr,ints included were

representative of a plant lat,el, rather than readings on a-

'

scale.

u.

Attachment A item 6:

The setpoint included an acronym not on-

'

the approved. writer's guide list.

v.,

Attachment Ei Relief. path PV-456A was incorrectly shown on ERF as PV-_4568.

w..

Foldout' page:

Items 1,. 2 and 4 include use of logic structure ' contrary.. to writer's guide requirements.

Item 3 included use of. both

"-0R " and "AND" used contrary to-writer's guide requirements, i

2.

E-1 Loss of reactor or secondary coolant No comments.

3.

E-2 Faulted st'eam. generator isolation a.

Step 1 caution:

This caution did not describe the expected hazard, b.

Step 4-caution:

This caution contained action steps,-

contrary to the writer's guide.

4.

E-3 Steam generator. tube rupture

'

a.

Step lb RNO:. This step used a transitiva term, " continue to", that was not defined in the writer's guide.

b.

Step 7a RN02: -This step containd a typographical error:

i FRH.1 was missing a hyphen.

'

!

<

,

--

,,

,_

,

.

n

'

,

L r

.

.

Appendix C

c.

Step 29 cau.lon:

This caution contained an action statement that was contrary to the action of step 29.

III' ESP. comments i

1.

ES-0.0 Rediagnosis i

gv

>

f a.

Step.1: The high level step structure and use of logic j

(_

terms was contrary to the writer's guide.

.

b.

Step la RNO:. Transition terminology was contrary to the

writer's guide.

c.

Step 2:

Same as Step 1 above.

,

d.

Step 2a RNJ:

Same as Step la RNO above.

e.

Step 3:

Same as Step 1 above.

j f.

. Step 3 RNO:

Same as Step la RNO above.

-

g.

Step 4: Same as Step la RNO above.

}

2.

ES-0,1, Reactor trip response

.

i a.

Step 1 caution and notes:

These items included actions

contrary to writer's guide. requirements.

.;

lb RN0'. This step was a lo~gic step structured contrary b.-

Step

to writer's guide requirements, q

c.

Step Ic RNO:

This step included a transition structured to

'

writer's guide ' requirements and used

"-OR " in a manner a

contrary to writer's guide requirements.

d.

Step 2a RNO:. This step included two transitions structured r,

contrary to writer's guide requirements.

!

e.

Step 3 RNO:

This step included a transition structured contrary to writer's guide requirements and 'an. acronym not J

found on the approved writer's guide list.

,

f.

Step 4 notes:

Same as step 1 caution and notes above.

.

g.

Step 4b RNO:

This step included a transition structured contrary to writer's guide requirements.

l h.

Step.5 RNO:

This step was split between two pages, leaving

"l the portion on the second page without first and second. level step numbers, item 2 on the second page included commas used

,

contrary to writer's guide requirements.

'

i.

Step 6a. RNO:

This step included a continuous action step l

structured contrary to writer's guide requirements.

.

,.

-

-

,

.

.

.

Appendix C

j.

Step 7a RNO:

Same as Step 4b RNO above.

k.

Step 9 RNO:

Same as Step 2a RNO and step 6a RNO above.

1.

Step 10:

This step included logic terminology strucured

.

contrary to writer's guide requirements, m.

Step 10a RNO:

Same as Step 4b RNO above.

n.

Step 13:

Same as Step 10 above.

!

o.

Step 13b: This step is structured contrary to writer's guide requirements for expected responses, p.

Step 13 RNO:

This step included a transition and the term

"-OR " structured contrary to writer's guide requirements, q.

Foldout page:

Items 1 and 3 were logic terms structured contrary to writer's guide requirements.

Item 2 used the terms "-OR " and "AND" in a manner contrary to writer's guide requirements.

3.

ES-0.2 Natural circulation cooldown a.

Step 1 caution 1:

This caution, contrary to the writer's guide, contained action steps.

.

b.

Step 1 note:

This note contained action steps contrary to the writer's guide, c.

Step 1 caution 2:

Same as Step 1 caution 1 above.

d.

Step 2:

This step used an action verb not permitted by the writer's guide, e.

Step 6 caution:

Same as Step 1 caution 1 above, f.

Step 7:

Same as Step 2 above.

g.

Step 12 caution:

Same as Step 1 caution 1 above.

I h.

Step 18 note:

Same as Step 1 note above.

4.

ES-0.3 Natural circulation cooldown with steam void in vessel (with RVLIS)

a.

Step 1 caution:

Contrary to the writer's guide, a conditional action statement was placed in a caution. Also, an explanation of the additio1 of the third bullet was found in the SDD, however, the technical adequacy of the justification was not obvious, b.

Step 2 note:

The conditional action statement in the second I

bullet was contrary.to the the writer's guide.

j

1. -

'mz #. \\l' 1

.

",

c

'

ylh eY

,3 hh myp

,

M

' Appendix C

.6

,

.-

,

e c.-

Step 3b:

This step was contrary to the writer's guide rules for capita 1 H ation of verbatim equipment nameplates, o,

d.

Step 7a RNO:

This step was contrary to the writer's guide rules for capitalization.

Also, transition terminology was j,

contrary to the writer's guide,

,

i e.

Step 10 note: Contrary to the writer's guide, this note directed an action to be performed.

"r f.

. Step 12:

Contrary to the writer's guide, the multiple action steps' lacked action verbs.

• g.

Step 12a:

The step 12a and 12b sequence deviated from the ERG. Adequate justification was not given in the SDD,

,

'

5.

ES-0.4 Natural circulation cooldown with steam void in vessel (without RVLIS)

2,

.

'

a.

Step lb:

Contrary to the writer's guide, this action step lacked an action verb.

n*

b.

Step 10a RNO: This step was contrary to the writer's guide g

' rules for capitalization.

Also, transition terminology was

~

contrary to the writer's guide, c.

Step 10d1 RNO: This step v.s contrary to the writer's guide rules for capitalization.

$

d>

Step 15c:

This step was contrary to the writer's guide e!- -

rules for capitalization.

,

M-

!M e.

Step 19 note:

Contrary to the writer's guide, this step

directed an action to be performed.

.

(

f.

Step 19:

Contrary to the writer's guide, the multiple k?

action steps lacked action verbs.

m

?f g.

Step 22a:

Contrary to the writer's guide, this action step

- i, f ~

lacked an action verb.

rN 6.

ES-1.1 SI termination p

,

g No comments,

<

h.

7.

ES-1.2 Post-LOCA cooldown and depressurization m

N a.

Step 7 notes:

Contrary to the writer's guide, these notes J '

contained action statements.

b.

Step 14c RN0:

This step contained a typographical error:

,

one was spelled "on."

'

,

,

_fi s

g a '

,.

_

_-

_ _ - - _ - - - -

-

,sy f

n

,

.

m h c.

n

,

@

q

.

l Appendix C 7-

'

g-

'

c.

Step 19a RNO:

This step contained a ~ transition term,

-

"using", that was not defined in the writer's guide.

d.

Step 24a RNO:

This step contained a typographical error:

the word "from" was missing before

" emergency diesel generators."

e, Step 30 note:

Contrary to the writer's guide, this note contained an action statement.

8.

ES-1.3 Transfer to cold leg recirculation a.

Step 1, note:

Contrary to the writer's guide, this note directed an action to be performed, b.

Step 2:

Use of the ectiori verb " verify" was contrary to the writer's gside, c.

Step 2b RNO:

Transition terminology was contrary to the writer's guide.

d.

Step 2c RNO:

The multiple actions of this step were structured contrary to the writer's guide.

!

,1 e.

Step 3 caut' ion:

Conditional action statements were included I

in this caution contrary to the writer's guide.

Also contrary to the writer's guide was the use of bullets for

!

multiple steps that were directed to be performed in order,

,

f.

Step 3d: The multiple actions of this step were structured

,,

contrary to the writer's guide.

,

'

a g.

Step 3e: The AER action verb and the RNO conditional action statement were structured = contrary to the writer's guide.

b Transition terminology was contrary to the writer's guide.

h.

Step 3f: The action verb "close" was used contrary to the

"

writer's guide, i

i.

Step 3 :

Same as Step 3e above.

.)

s.

.

>i J.

Step'3h:

Same as Step 3f above.

l

,

m --.

-:. 4.,

k.

Step 31:

Same as Step 3d above.

l.

Step 4:

Same as Step 3d above.

!

'

9, m.

Step 4a RNO: This conditional action statement was

'

structured contrary to the writer's guide.

Also,

!

g capitalization was contrary to the writer's guide.

>

,#;

n.

Step 5: The multiple actions of this step were structured contrary to the writer's guide.

T

,,

b',

y, L

-

.5 l

,

i

!.

Appendix C'

o.-

Step Sa RNO:

The conditional action statement was structured ' contrary to the writer's-guide.

Also,

capitalization was contrary to the writer's guide.

l

p.

. Step 6: The multiple actions of this step were structured contrary to the writer's guide, q.

Step 6 RNO: The conditional action statement was structured centrary to 'the writer's guide.

Also, capitalization was contrary to the writer's guide, t.

.

r.

Step 8 RNO: The conditional action statement was structured

contrary to the writer's guide.

Also, transition terminology i

was contrary to the writer's guide.

)

s.

Step 10 note:

Contrary to the writer's guide, this note directed an action to be performed.

a t,

Step 10: The multiple actions of this step were structured contrary to the writer's guide, i

9.

ES-1.4 Transfer to hot leg recirculation l

i

a.

Step 1 RNO first bullet:

This - step directed the operator to j

perform a step in the reverse order. This provided. potential

confusion for the operator, in that actions were to -be j

performed from bottom-to top and with different action words

,

than those that were written.

j b.

Step 1 RNO first and second bullets:

These subteps started f

with gerunds instead of action verbs, which was: contrary to

,

L the practice in other E0P steps,

,

c.

~ Step 2 RNO first bullet:

Same as step 1 RNO first-bullet.

'

R d,

Step 2 RNO first and second bullets:

Same as step 1 RNO

first and second bullets.

e.

Foldeut Page:

An excess foldout page was printed with this

pocedure, such that two foldout pages were facing each other.

..

-

L,'

10.

ES-3.1 Post-SGTR cooldown with backfill

>

a.

Step 1 notes:

Contrary to the writer's guide, these notes i1

.

contained action statements.

s

>

N 11.

ES-3.3 Post-SGTR cooldown using steamdump

'

No comments.

,

y V.

ECP comments

1.

ECA-0.0 Loss of all AC power

>

m p n y,

,e

.i l\\

Jl

_ y

-

-

.

q-qg

'

s.

.

,

j.

-

w jil'x Appendix C

.

p~ '

a.

.The symptoms and sntry conditions paragraph was structured contrary to the writer's guide.

>

>

b'

~ Step 5 note:

This note contained conditional action statements contrary to the writer's guide.

'

'

c.

Step 6 caution:

Same as Step 5 above. Also, the second bullet

)

>

g J

of the caution referred to an action on the' prior page contrary

-

to the writer's guide.

,

[

d.

Step 22 RNO 4:.Actinn-verb usage was contrary to the

~

writer's guide.

O e.

Step 26:

The action verb " verify" was used contrary to the

.i-writer's guide.

>

"

2.

ECA-0.1 Loss of AC power recovery without SI required No comments, 3.

ECA-0.2 Loss of'all AC power recovery with SI required o

a.

Step 4:

This stap used logic terminology structured contrary to writer's guide requirements, b.

Step 4b RNO:

This step included a transition structured contrary to writer's guide requirements, c.

Step 6:

Both AER and RNO columns included valve numbers s

y structured in a

manner contrary to writer's guide T'

requirements.

,

E s :-

d.

Step 7 caution:

This caution included actions contrary to writer's guide requirements.

s e.

Step 7 note:

This note included actions and logic structured if contrary to writer's guide requirements.

f.

Step 7b:

Same as Step 4 above.

.

,

[

g.

Step 8 cautions:

Same as Step.7 caution above, m As h

h.

Step 8a RNO:

Same as Step 4b RNO above.

V

,

i.

Step 9:

Same as Step 4 above.

J.

Step 10 cautions:

Same as Step 7 caution above.

k.

Step 11:

Same as Step 4b RNO above.

4.

ECA-1.1 Loss of emergency coolant recirculation

,

.

'

-A

.o.

.

..

,

4-

i Appendix C

a.

Step 1 cautions:

These cautions included logic and actions structured cietrary to writer's guide requirements._

,

.

.

b.

Step 1:

This step included logic terminology structured

!

contrary to writer's guide requirements.

c.

Step 2:

This-step included a transition structured contrary j

-

to writer's guide requirements.

=

d.

Step 3 notes:

Same as Step I cautions above, c.

Step 6c:

This step converted an action into expected response format contrary to writer's guide requirements.

,

'

f.

Step 7:

Same as' Step 1 above.

P

'

g.

Sten 7b RNO: -Same as Step 2 above.

-

h.

Step 8 caution:

This caution included logic terminology

!

structured contrary to writer's guide requirements.

,

1.

Step 8:

Same as Step 1 above.

I

j.

Step 11 caution 1:

Same as Step 1 cautions-above.

!

k.

Step 12:

Same as Step 1 above.

1.

Step 12b:

This step included expected responses using logic terminology contrary to writer's guide requirements.

'

m.

Step 12 RN0:

Same as-Step 2 above.

[

n.

Step 14b:

This step included a valve number struc tured.-

contrary to writer's guide requirements.

g

[

o.

Step 14a RNO:

Same as Step 2 above.

,.

.p.

Step 16g:

This step included valve numbers structured-lL contrary to writer's guide requirements.

9,.

q.

Step 17a:

Same as Step 12b above, 3y

,

r.

Step 18a: This step was not a distinct action from step 18b

but rather ~ indicates the equipment to use to accomplish step i

b 18b.

s.

Step 19 note:

This note was a continuous action step contrary to writer's guide requirements, t.'

Step 19:

Same as Step 1 above, w

u.

Step 19b:

Same as Step 1 above.

,

.I

!

b

. [-

y

,

.

h

{

Appendix C

'

11-

-

v.

Step'20-Same as Step 1 above.

,

w.

Step 20a RNO:

This step contained two transitions structured contrary to writer's guide requirements.

x.

. Step 20b RNO:

This' step contained local. actions structured

.

. contrary to writer's guide requirements.

y.

Step 21:

Same as Step 1 above.

z.

Itap 21a:

This step included use of the term "-OR " contrary to wr/+er's guide requirements.

'

aa.

Step 25 note:

This note was an action step. contrary to writer's guide requirements, ab.

Step 25a:

Same as Step 2 above, ac.

Step 25h-j:

Because this step-was split between two pages,.

substeps on the second pages were missing a first level : step number.

ad.

Step 25j:

This step contained valve numbers structured contrary to writer's guide requirements.

ae.

Step 27a RN0:

This step included an acronym inconsistent

.with those shown in the writer's guide approved list.

af.. Step 28:

Same as Step 1 above, ag.

Step.28a RN0:

Same as Step 2 above.

Y ah.

Step 28b RNO:

This step was a local action structured contrary to writer's guide requirements, ai.

Step 29:

Same as Step 1 above, aj.

Step 29a: 'Same as Step 21a above.

..a k.

Step 31 note:.Same as Step'21 note above.

al.

Step 32a:

Same as Step 1 above.

am.

Attachment B step 5:

Same as Step 1 above.

'

an.

Attachment B step 8:

Same as Step 'l above.

5.

ECA-1.2 LOCA outside containment No comments.

6.

ECA-2.1 Uncontrolled depressurization of steam generator

,.

p

'

..

.-

.

Appendix C-

No comments.

-

7.

ECA-3.1-SGTR with loss of reactor coolant:

subcooled recovery i

desired a.

Step-I caution: This caution, contrary to the writer's guide, containe'd action steps.

b.

Step.3a RNO:

This step used an action verb not permitted by the writer's guide-.

c.

Step 5: Same as Step 3a RNO above, f

'

s d.

Step 6 caution: Same as Step 1 caution above.

!

!

e.

Step 7d3:- This step contained an acronym not permitted by-the writer's guide, f.

Step :9 caution:

Same as. step 1 caution above.

In addition,

I this caution did not state the available alternate source of water for AFW..

g.

Step 10 note:- Same as Step 1 caution above, h.

Step 16 caution:

Same'as Step 1 caution above, i.

Step 16 note:

Same as' Step 1 caution above.

J.

Step 17 note:

Same as Step I caution above.

k~

Step 23 caution:

Same as Step 1 caution above.

1.

Step 23 note:

Same as. Step 1 caution above, m.

Step 28a RN0: _Same as Step 3a RNO above, n.

Step 29:.Same as step 7d3 above.

Contrary to the writer's guide, this step had a period after Aux.

'l o.

Step 34 caution:

Same as Step 1 caution above.

p.

Step 36 note:

Same as Step 1 caution above.

8.

ECA-3.2 SGTR with loss of reactor coolant-saturated recovery desired a.

Step 1 caution: A conditional action statement was included in this caution contrary to the writer's guide, b.

Step 2 caution:

Same as Step 1 caution above, c.

Step 5 note:

Same as Step 1 caution abov,'o

.

n e-

..

i'*

.

4 a..

i

.

' Appendix C

d.

Step 8: The multiple action steps were structured contrary

"

to the writer's guide. Also, action verbs were not used and capitalization rules were not followed, contrary; to the

'

writer's guide, e.

Step 9: The multiple action steps were. structured contrary i'

to the writer's guide:

Also, action verbs were not used,

'

contrary to the writer's guide.

f..

Step 9b RN0; Transition terminology was contrary to the writer's guide.

.g.

Step 10: The multiple action steps lacked action verbs,

,

contrary to the writer's guide.

+

h.

Step 11:

Same as Step 10 above.

,,

1.

Step 11c RNO:

Same as Step 9b RNO above.

,

It

'j.

Step 11d'RNO:

Capitalization was contrary to the writer's

.,C guide.

'

'

k.

Step 12: 'Same as Step 10 above, w

- 1.

Step-12c RN0:

Same as Step 9b RNO above.

[

m.

Step 12.c RNO:

Same as Step 11d-RNO above.

I n.

Step 13:

Same as Step 10 above,

o.

Step 13b RN0:

Same as Step 9b RNO above.

p.

Step 13c RN0:

Same as Step 11d RNO above.

q.

Step 17a:

Same as Step 10 above.

• r.

Caution above step 18:

A contitional action statement was

-

,

X included in.this caution contrary to the writer's guide.

!

s.

Step 21:

Same as Step 9 above.

t.

Step 21a RN0:

Transition terminology was contrary to the

,

writer's guide, p"

u.

Step 25a: An action verb was not.used, contrary to the

"

writer's' guide, v.

Step 25 note:

itis note applies to an AER in step 26 which was on tM next page, ccatrar.y to the writer's guide, w.

Step 26b:

The action verb " verify" was used contrary to the writer's guide.

o

>

'

"{

F',

'

u..

<

,,q,

fa.

.

I

.

Appendix C

e x.

Step 26a RNO:

'

~

Same as Step 21a.RNO above.

.

j y.

. Step 30 note-Contrary to the-writer's guide, this note

!

contained a conditional action statement, i

.

-

l 9.

ECA-3.3. SGTR without pressurizer pressure contrei-i

,No comments.

!

q

'V.

FRP comments i

l '.

.FR-C-1 Response to inadequate core cool'ng

'

]j

.

No comments.

2.

FR-C.2 Response.to degraded core cooling

,

q

'

a.

Step.1-caution: ' Contrary to the writer's guide, this caution contained an action statement.

b.

Steps 2b, c, and d RNO:

These steps contained typographical-errors,=.in that they were not aligned with step 2a RNO.

i

~

i c.

Step - 9a RNO:

This step contained a typgraphical error:

'2/ instead of 27.

3.

FR-C.3 Response to saturated core cooling

.St'p :1-caution:

Contrary to' the writer's guide, this step a.

e contained actions steps.

.

S' ep 2a RNO:

Contrary - to the writer's ' guide, this step used b.-

t an action verb not permitted.

,

c.

Step 2b RNO:

Same as Step 2a RNO above.

d.

. Step 2c RN0: Same as Step 2a.RNO above.

I o-s 4.

FR-H.1. Response to loss of secondary.' heat. sink

$

No coments..

,

5.

FR-H.2 Response to steam generator overpressure

'l a.

Step 4 caution:

Contrary to the writer's guide, this step contained action steps.

'

'

"~

b.

Step 6 caution:

Same as Step 4 caution above.

c.

Step 8:

.The abbreviations used in this step were not consistent with other abbreviations used in the rest of the procedure, in that it used S/G ARV(s) instead of S/G ARVs.

id.

,

f":

e

-

i; ce lI.

'

$

Appendix C

['

6.

FR-H.3 Response to steam generator high level v3

a..

Step I caution:

Contrary to the writer's guide, this caution contained action steps.

j b.

Step 8:

Contrary to. t'he writer's guide, this - step used an action verb not permitted.

7.

FR-H.4 Response to loss of normal steam release capabilities

,

,

t No comments.

',

'9.

FR-H.S Response to steam generator low level

-!

<

j a.

Step 2:

The multiple action steps were structured contrary

!

to the writer's guide.

' t i

b.

' Step 2a RNO: Transition terminology was contrary to the writer's guide.

!

,

c.

' Step 5:

The AER was structured contrary to the writer's

'

3-guide.

.

i

,

10.

FR-I.1 Response to nigh pressurizer level

'

I a.

Step 3 note:

Contrary to the writer's evWe, this note j

contained conditional action statemen*

b.

Step 3:

The multiple action steps wec structured contrary

~

to the writer's guide.

,

a c.

. Step 5: Same as Step 3 above.

]

d.

Step Sc2: The action verb " verify" was used contrary to the U

writer's guide.

,

4w

.

-f e,

-Step 6:

The multiple action steps were structured contrary to the writer's guide.

l

,

o.

f.

Step 6a RN0:

This conditional action statement-was structured contrary to the writer's guide.

4.,. a.

g.

Step 7: Same as Step Sc2 above.

l q

M.

11.

FR-I.2 Response to low pressurizer level

f m

+

t No comments.

12.

FR-I.3 Response to voids in reactor vessel y

a.

Step 1 caution: Contrary to the writer's guide, this caution contained action steps.

A I'.

G Q ;,

"

...

Md,

@n"f

}

<>p

'

t Appendix C

• sL b.

Step 2 note-Contrary to the writer's guide, this note l

contained action steps.

t c.

Step 2b2 RNO:

This step used an action verb not permitted-by

<

.'

the writer's guide.

,..

d.

Step 3 RNO:

Same as Step 2b2 RNO above.

-

e.

Step.6a:

This step contained an acronym. not permitted by the

'

writer's guide.

,

.

a V

f.

Step 6c:

Same as Step 6a above.

'

b

g.

Step 9 caution:

Same as Step 1 caution above.

.

h.

Step 9 note: Same as Step 2 note above.

1.

Step 9 RNO:

Same as Step 2b2 RNO above.

J J.

Step 13 caution:

Same as Step 1 caution above.

,

i k.

Step.16a:

Same as--Step 2b2 RNO above.

• -

1.

Step 16b:

Same as Step 2b2 RNO above.

,

Li m.

Step 18:

Same as Step 2b2 RNO above.

n.

Step 19 caution:

Same as Step 1 caution above.

,

w i

y o.

Attachment E, step lb:

This step used a symbol that was not

.

'

understood by operators.

y p.

Attachment E, step 3b:

Same as Step 6a above.

,

q.

Attachment E, step 4a:

Same as attachment E Step lb above, h

' '

.

13.

FR-P.1. Response to imminent pressurized thermal shock condition v

,

a.

Step 1. caution:

This caution was a conditional action step

structured contrary to writer's guide requirements.

b.

Step lel RNO:

This step used an acronym inconsistent with

,,W that shown in.-the writer's guide list.

s.

t Y" i c.

Step le2-3 RN0:

Step 1 RNO was split between two pages,

. leaving these substeps without first and second level step <

numbers.

'

d.

Step le3 RNO:

This step was a conditional action step structured contrary to writer's guide requirements.

[D e.

' Sten 2a-b RNO:

These steps were local actions structured

~~~

contrary to writer's guide requirements.

. +.

$

I I

.

• p

..

\\

..

l

Appendix C

'

e..

Step 3 caution:

Same as Step 1 caution.

f.

Step 3:

This step used logic terminology in a manner a

contrary to the writer's guide requirements.

(

g.

Step 3b and 3d RNO:

.These steps each included-two

'

transitions structured contrary to writer's guide

,'

requirements.

[

,

h.

Step 4:.This step used logic terminology incons'. stent with

'

,

writer.'s guide requirements and included an expectad response r

structured inconsistent with writer's guide requirements, i.

Step 5:

Same as-Step 3 above, q

J.

Step 6 caution:

Same as Step 1 caution above.

k.

Step 8a: RNO:.This step included a transition structured

!

contrary -to writer's guide requirements.

1.

Step 10 caution:

The second sentence in this caution was a conditional action step contrary to writer's guide

. requirements.

m.

Step 10 note:

Same as Step 1 caution above.

n.

Step 13 RNO:

The second conditional action step included a

~!

transition and a continuous action structured contrary to

,

writer's guide. requirements.

'

.

o.

Step 15a RNO:

This step. included. logic terminology used j

contrary to writer's guide requirements.

Q p.

Step 15b:

This step was a continuous action step structured contrary to writer's guide requirements and included the term

"-0R " structured contrary to writer's guide requirements, i

q.

Step 17 RNO:

Same as Step 8a RNO above.

[a s

r.

Step 18 note: 'Same as Step 1 caution above.

,

s.

Step 19 caution:

Same as Step 1 caution above, t.

Step 23:

Same as Step 3 above.

.g u.

Steps 23b1 and 23b3:

These steps were continuous action steps structured contrary to writer's guide requirements,

'

v.

Steps 23bl and 23b2:

These steps were written in the negative contrary to writer's guide requirements.

.

14.

FR-P.2.

Response to anticipated pressurized thermal shock condition

-

.

ne.

,

t

'

Appendix'C

a.

Step 3: This step contained a typographical error:

an extra word " rate" '

b.

Figure 1:

This graph was not titled " Figure 1",. but was referred to as " Figure 1" in step 4a2.

,

w.

Step 23b5:

Same as Step 8a RNO above.

,

15.

FR-S.1 Response to nuclear power generation /ATWT

,

a.

Step 3:

This step used logic terminology contrary to l

writer's guide requirements,

-

b.

Step 4:

This step used the term "-0R " contrary to writer's guide requirements.

c.

Step Sa:

This step included. a transition structured contrary to writer's guide requirements.

d.

Step.5b1:

This step was a continuous action step structured

,

contrary < to writer's guide requirements.

e.

Step 6 note 2: This note used logic terminology contrary to writer's guide requirements, f.

Step 9 cautions 1 and 2:

These cautions included actions contrary to writer's guide requirements, g.

Step 9c RNO:

This step included acronyms inconsistent with those in the writer's guide list.

h.

Step 10 RNO:

This step. included a continuous : action step structured contrary to writer's guide requirements.

16.

FR-S.2 Response to loss of core shutdown

a.

Step 1 RN0:

Transition terminology was contrary to the writer's guide, b.

Step la:

The action verb " verify" was used contrary to the

'riter's guide.

'

,

c.

Step-Ic:

Contrary to the writer's guide, this action step lacked an action verb.

d.

Step 3 caution:

The conditional action statement included in this caution was contrary to the writer's guide.

.

17.

FR-Z 1 Response to high containment pressure a.

Step 11 cautions:

Contrary to the writer's guide, these cautions contained action statements.

.

~

.

.

.-

'G-

..

it--

$':

' Appendix C 19:

'

L 18.

FR-Z.2 Response to containment flooding a.

Step 2: Usage of action verbs for multiple action steps was contrary to the writer's guide.

19, FR-Z.3 Response to high containment radiation level

,

No comments.

'7 VI.

CSFST comments

-

No comments.

b" ' ",

VII. A0P comments y

1.

A0P-001 Primary system instrumentation malfunction

'N-No comments.

L_'

.

2.

A0P-002 Nuclear instrumentation system malfunction

. /'

N.

a.

Steps A4d and A4e:

These steps included logic terminology and commas used contrary to writer's guide requirements, I

b.

Step A6:

This step was a conditional action step structured 4'

-contrary to writer's guide requirements.

c.

Step.B5 caution:

This caution was an action step contrary. to

'

writer's guide requirements.

t n

d.

Step B7:

Same as Step A6 above, d

e.

Step B8:

This step was structured passively, contrary to Lyr writer's guide requirements, f

"

>

f.

Step C5:

This step included logic terminology used contrary to writer's-guide requirements, g.

Step C7:

Same as Step C5 above.

,.

h.

Step C10:

Same as Step B8 above.

.1.

Step C11:

Same as Step A6 above.

.

P 3.

.A0P-003 Rod control system malfunction No comments.

4.

A0P-004 Reactor coolant leakage

o

'

j".

'

a.

Step A7 caution:

Contra ry to the writer's guide, this

'

caution contained action steps.

.? *

r

,

n

.

c{c j=; s

'

g yu_-

E.7-F,

-

t

-

,

,

.m

.c

'

.

r

,

t't ;

.

-4 Appendix C~

b.

Stcp All note:

Contrary-to the writer's guide, this note-contained ac'iion steps.

"

c.

Step B1 note:

Same as Step All note above,

'

d Step B15 note:

Same as Step All note above.

e.

Step B16 note:

Same as Step All note above.

f.

Step B24 RN0:

Same as Step All note above.

g.

Step B31: This step used capitalization incorrectly.

o 5.

A0P-005 Partial loss of flow No comments.

.6.

A0P-007 Chemical & volume control system malfunction

!No comments.

7._

A0P-009 Steam generator tube leak a.

Step 3:

This step used an action verb 'not found in1 the

<

writer's guide approved list.

I b.

Step 4:

This step used logic ~ terminology in a manner contrary to the writer's guide.

The fifth bullet included-an

. action structured in a manner inconsistent-with the writer's-guide.

.c.

Step 5_ note:

This note was a conditional action step contrary to writer's guide requirements.

d.

Step 5:

This step used-logic terminology i r.

a manner inconsistent with H.e writer's guide, e.

Step 6 note and caution:.These were action steps contrary to writer's guide requirements.

f.

Step 9:

This step included a transition structured and located contrary to writer's guide. requirements, g.

Step 10 notes:

Same as step 6 note and caution.

h.

Step 10. This step included a transition structured contrary to writer's guide requirements.

i.

Step 11 RNO:

Same as Step 5 above.

J.

Step 12 notes:

Same as Step 6 note and caution above.

k.

Step 12:

Same as Step 10 above.

,

-

,

,

y

-

..

-

Appendix C_

1 1.

Step 13 note:

Same as Stet 6 note and caution above, j

l m.-

Step.13:

This. step contgins a continuous action step-

!

structured contrary to writer's guide requir'ements,

n 8.

A0P-012 Turbine runback i

No comments.

t

.

9.

A0P-016 Condensate & feedwater, malfunction No comments.

10. A0P-19 Loss of residual heat removal a.

Step Al RN0:

This step was incorrectly numbered, as it was supposed to be step Ala RNO.

Also, the step contained no

nigh level statement but had only three bulleted substeps under a blank space.in place of a high level statement.

b.

Step A2 RNO: This step contained no high level statement but had only two bullet ad substeps under a blank space in place

,of a high level statement, c.

Step A5 RN0:

This step contained three lettered alternate means of depressurizing the RCS. The word "or" was not used between the three alternato means.

d.

Step A6 RN0:

This step contained no high level statement but had six lettered substeps.

e.

Step A5:

This step contained a logic statement that was contrary to the writer's guide and was also confusing:

if, then, and then, or and then.

Licensed. operators could net determine -if the step was directing them to transit bn to step A6 or step A9.

11. A0P-020 Loss of component cooling water No comments.

7.

12. A0P-0P.1 Loss of nuclear service cooling water system-a.

Step 4:

This step used an action verb not permitted by the writer's guide.

l 13. A0P-022 Loss of auxiliary component cooling water No comments,

14. A0p-023 Loss of turbine plant cooling water systems a.

No comments

p,

-

p 1'

.c.

-Q Appendix C~

.

15. A0P-028 Loss of jnstrument air a..

Step 1 Note:

This note contained informa' tion that described -

conditions that could result in equipment damage.

This is d

not in accordance with the writer's guide.

l b.

Step A4:

This step _ used an action verb not permitted by the writer's guide.

l c.

Step B10 RN0:

This step contained valve position I

.

designations that were not permitted by the writer's guide.

16. A0P-031 Loss of class 1E electrical system No comments.

17. A0P-032 Loss of 120V AC instrument power a.

Step Al RNO:

This step included a transition structured contrary to writer's guide requirements.

b.

Step A4:

Same as step Al RNO above.

-

c.

Step A5:~

step was a continuous action step structured This contrary to writer's guide requirements, d.

Step AS:

This step used logic -terminology in a manner contrary: 'to writer's guide requirements and included a transition structured contrary to writer's'

guide requirements, j

e.

Step A9:

This step included - an acronym - inconsi stent with those found on the approved writer's. guide list,

-

f.

Step A13:

Same as Step Al RNO above.

g.

-Steps A14,-A15 and A16: Same as Step Al RNO above, h.-

Steps B2, B3, 84 and B5:

Same as Step Al RNO above.

'

i.

Step C4: Same as Step Al RNO above.

j.

Step-C5:

Same as Step A5 above.

k.

Step C8:

Same as Step Al RNO above.

1.

Step C12 RN0:

Same as Step Al RNO above.

m.

Steps C14, C15 and C16:

Same as Step Al RNO above, n.

Steps D2, 03, D4 and 05:

Same as Step Al RNO above.

o.

Steps El RNO, ES, E6 and E7:

Same as Step Al RNO abov.

'

r

_

.

Q'

Appendix C-

-

p.

Steps F1 RNO, FS, F6 and F7:

Same as Step Al RNO above.

q.

Step G1:

This step is structured contrary to writer's guide requirements for logic steps.

i r.

Steps G4, G5, G6 and G7:

Same as Step Al RNO above.

s.

-Step H4:

Same as Step G1 above.

l

. -

t.

Steps H7, H8, H9, Il and 12:

Same as Step Al RNO above.

i

'

g

_

Same as Step G1 above, u.

Step J1:

v.

. Steps J5, J6, J7, J8, K1, K2, L1 and L3: Same as Step Al RNO above,

.

w.

Step L4:

Same as Step G1 above,

!

x, Steps:M1, M2, N3, N6. 02, 03, P1 and P2: Same as Step Al RNO above.

'

y-Step N2:

Same as Step G1 above.

z.

-Step N4:

This step used the action term "ver.ify" in a manner contrary to that -defined in the writer's guide.

18.

A0P-036 Seismic event

'

No comments.

,

VIII Attachments 1..

Recovery of RCP seal injection a.

Steps _ 4, _5 and 6:

These steps are local actions structured contr3ry to the manner defined in the writer's guide.

2.-

Establish charging without instrument air a.

Steps Al and A2:

These steps required operators to verify the position of one of two vaives listed with bullets, but failed to include the word "or" between the bulleted valves, b.

Steps B1 and 82:

Same as Steps Al and A2 above.

.

..

.1

]

,rw:

'

v

,

,

,

-,

.

.

.

APPENDIX D NOMENCLATURE I

This apr.endix contains basic plant nomenclature observations.

For example, instancos where writer's guide application to the E0P would cau'se the reader to expect in exact nomenclature match with component nomenclature, yet there was

,

no match.

It also includes instances where a complete match was neither i

.

required nor found and the mismatch or lack of label was sufficient to cause I

concern. The licensee agreed in each case to evaluate the problem and make the l

appropritte ' changes.

These items will be reviewed during a future NRC'

!

inspection.

STEP /PG E0P NOMENCLATURE COMPONENT NOMENCLATURE l

h Procedure ES-1.1

12.e RNO CONT SPRAY ADDITIVE TANK U1: CNMT SPRAY ADD TANK DISCH MANUAL OUTLET < ISO ISOL.T0 EDUCTOR 1 & 2 U2: CNMT SPRAY ADDITIVE OUTLET TO EDUCTORS AC, 1 CVCS SEALS RCP SEAL INJ SEAL INJ ISOLATION.

SUPPLY CNMT 150 ACCW return ACCW THERMAL BARRIER RTN VLV AC, 5 CVCS SEALS RCP SEAL INJ SEAL INJ ISOLATION SUPPLY CNMT ISO AC, 7 ACCW return ACCW THERMAL BARRIER RTN.VLV AD, 2e RCP STNDPIPE LO LEVEL RCP STANDPIPE LO LEVEL AD, 2f RCP STNDPIPE HI LEVEL RCP STANDPIPE HI LEVEL AD, 2h RCP N0 2 SEAL LKOFF HI FLOW RCP NO 2 LK0F HI FLOW AD, 2k ACCW RCP THERM BARRIER HX ACCW RCP THRM BARRIER HX H.'

HI FLOW FLOW AD, 21 ACCW RCP THERM BARRIER HI ACCW RCP THRM BARRIER HX HI PRESS FLOW AD, 6a RCP LOW FLOW RCP LOW FLOW ALERT AD, 6b RCP SHAFT VIBRATION RCP SHAFT VIBRATION ALERT AD, 6c RCP FRAME VIBRATION RCP FRAME VIBRATION ALERT

V:r y b

l[

'

,

y q;'

.n

p[,

sAppendix-0 2,

-

,

.

uu ' w

' :w

- Procedure ECA-2,1 No Comments

.

Procedure F-0.2

No Comments

>

i Procedure F-0.3 I

No Comments l

>

Procedure FR-H 4 No Comments

'

Procedure A0P-1.0

n C.

MOVI-8000A(B) INTERLOCK PRZR PRESS L0 PORV BLOCK

=

ACTUATED

'

Procedure AOP-3.0 B3 IN-HOLD-0VT SWITCH R0D MOTION SWITCH Procedure FR-C.I.

.AA/13-CCP Combined Mini-Flow A&B Common Mini-Flow

' Isolation

'

AA/13~

Bypass Charging Supply-Safety Grade Charging To Regen-Isolation Heat Exchanger

AA/13 Normal Charging-Supply Charging To RCS Isolation

,

Isolation q

AA/13 CCP Discharge Cross-connect CCP Discharge Header Cross-connect AA/13 BIT Outlet Isolation BIT Discharge Outlet Isolation n

.AB/14 Combined SI Pump Suction RWST To SI Pumps

,

w

~AB/14 si Fwnp A Suction From RWST SI Pump A Suction Isolation

.p:

<

AB/14 SI Pump To CCP Suction Cross SI Pump-A Suction cross

,

Connect connect To CCP Suction

,

Header

..

AB/14 Combined SI Pump Mini-Flow SIS Pumps Common Mini Flow Iso Viv

>'

AB/14'

Combined SI Pump Cold Leg Cold Leg INJ From SIS Isolation w

4

.' Y, L '

i.

.

7-

,

' -

g, y,

' -

. t. ;

g,,.-

l (,,,

LAppendix 0

'

+

Procedure A0P-22.0

-

t,

-

.

5/3'

RCP Thermal Barrier Outlet RCP Thermal Barrier Return fe Valves Valves

-

'x

"

'18/7 CCP normal miniflow iso'lation CCP J&B Common Mini-Flow

..

18/7-RWST sur.cion valves CCP Suction From RWST

,e j 1-Procedure A0P-12.0

.

No Comments Procedure A0P-16.0

,

,

No Comments'

'n:

Procedure AOP-20-0

< >

y No Comments

?

Procedure A0P-21.0 I

No Comments Procedure ECA-3.3 14c2/4 CCP alternate mini-flow CCP A/B RV To RWST ISO valves

,

y 14b/9 RW3T outlet isolation valves RWST-To CCP A&B Suction

-18bl/12 RCP s_eal return header RCPs seal leakoff IRC/0RC

'

b-1 solation valves isolation Procedure ECA-0.1 3cl/5 Charging line isolation Charging to RCS Isolation valves

.

3cl/5 CCP normal miniflow isolation CCP A&B Common miniflo

-

?

valves isolation valves

!

m y

4b/6 Charging line isolation Charging'to RCS isolation yin'

valves valves

&jr '

4c/6 FV-0121 and HV-0182 FV-121 and HV-182 -

11bl/10 RCP seal return header RCPs seal leakoff ORC /IRC iso j

isolation valves a

ll

g-

-

,

--

-

-

-

.

,

.

K

- ?

,

L

7;.

1

. Appendix D-

.4

,

f H

Procedure ES-0.0

'

No comments Procedure ES-0.3

'

6-Upper Range UP PLEN RV LEVEL (on recorder)

RNO.7d1 N2 supply valve ACCUM N2 ISO VLV-RNO 7d2 accumulator vent valves ACCUM-1 N2' SUPPLY / VENT VLV-RNO 7d3 common vent valves ACCUMUMULATOR VENT-12b CRDM fans-

'CRDM UNIT FAN 12c.

(see 6 above)

!

Procedure ES-0,4 c

No comments

"

!

Procedure ES-1.3 3b RHR hot leg suction valve RHR PMP A UPSTREAM SUCTION t

.FROM HOT LEG-LOOP-1 RHR hot' leg suction valve RHR PMP A' DOWNSTREAM SUCTION

'

.

g,.

FROM HOT LEG-LOOP-1-

'

RHR hot leg suction valve RHR PMP A UPSTREAM SUCTION.

FROM HOT LEG LOOP-4 n

RHR hot leg suction valve-RHR PMP A DOWNSTREAM SUCTION

'

FROM-HOT. LEG LOOP-4

-

i 3cl-SIP RWST suction isolation RWST TO SI PMP ISO VLV-

SIP miniflow isolation SI PMPS MINIFLOW ISO'VLV 3c2 RHR sump suction isolation CNMT' SUMP TO RHR PMP-A SUCTION CNMT SUMP TO RHR PMP-B

SUCTION-3c4.

CCP alternate miniflow:

CCP-A RV TO RWST-ISOLATION isolation CCP-B RV TO RWST ISOLATION

'

-3c5 RHR pump discharge cross-RHR TRAIN A TO HOT. LEG connect isolation'

CROSSOVER ISO RHR pump discharge cross-RHR TRAIN B TO HOT LEG connect isolation CROSSOVER ISO

w

.,

'

.t

,

-

-.;

{

'

v W Appendix D

'

,

J

'

, '

l, 3C6 CCP suction header to SIP SI PMP-A SVCTION-X CONN TO

-

suction head 6r cross-connect CCP SVCTION HEADER

'

.i solation:

(three valves had HV-8924

' identical labels)-

"

%

HV-8807A-i

[

HV-8807B j

u 3d RHR to CCP RHR PMP-A DISCH TO CHG I

i -

PMPS SVCT

'

SIPsuction isolation RHR TO SI PMP-B ISO VLV d

7l

=3e~

RHR pump A sump suction CNMT SUMP TO RHR PMP-A il 3f RHR pump A suction from RWST RWSTTORHRPMP-A3VCTIdN l

3j SIP suction from RWST isolation RWST TD SI PUMPS

,

CS pump 1-CS PUMP A

,

CS pump 2 CS PUMP B i

l Procedure-ECA-0.0 i

3c LV-0459-LV-459

'

3c LV-0460 LV-460 J A:

1AD1-04 1AD104 A

'

' AA -

2AD1-04 2AD104 d

p

AA.

1801-04 18D104 s

o h

AA 2BD1-04'

2BD104

AA 1C01-08 1C0108 m

IU'

AA 2001-08 2CD108 i

AA 1C01-09 1CD109

'

.AA 2001-09 200109

"

r.

,

AA 1D01-04 10D104 AA-2001-04 200104 a

AA 1001-08 1D0108

,

" -

AA 2001-08.

200108 AA 1D01-09 100109

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I

.

L,

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---

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-

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Appendix D'

.

AA 20D1-09 200109

.

'AB (refer. to comment below for AC),

~

AC Noun names did not match any labels. for example:

CNMT PREACCES PURGE SUPPLY CTB NORM PURGE SPLY IRC-ISO VLV-MAIN CNMT PREACCES PURGE SUPPLY.

CTB NORM MIRGE SPLY ORC ISO VLV-MAIN CONTAINMENT. MINI P' URGE SUPPLY CTB. NORM PURGE SPLY IRC ISO VLV-MAIN

Procedure ECA-3.2

14b CCP' Alternate mini-flow CCP-A RV TO RWST ISOLATION

25b2 seal return

. SEAL LEAK 0FF FLOW Procedure FR-5.2 No comments Procedure FR-H.5

'

~

i No comments

!

Procedura FR-Z.2

,

No comments i

!

Procedure FR-I.1 No comments

Procedure F-0 No comments-Procedure F-0.5 E

No comments I

Procedure FR-H.1

."

No Comments Procedure FR-I.2 i

Procedure 13009 (4.6 Emergency Boration)

.i-4.6.2.2'

BORATE BOR

!

4.6.2.3a BA TO BA BLENDER 1-HS-0110A BA TO BLENDER 1-HS-110A 4.6'.2.6 VCT Makeup Selector VCT MAKEUP CONTROL i

'

'

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,

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Appendix D

4. 7. 2 '-

Charging Pump.Suntons from the RWST TO CCP A & B SUCTION Refueling Water Storage

-!

Tarj (RWST)-

-l

'

,

.

,

Procedure 35615-C L

34~

INSIDE CONTAINMENT. ISOLATION RC HOT LEG 1&3 SAMPLE IRC VALVE L

OUTSIDE CONTAINMENT ISOLATION RC HOT LEG 1&3 SAMPLE ORC CHEMICAL DRAIN TANK LIQUID SMPL, RETURN TO WST. HLOUP,

-

-SAMPLE RETURN IS.VLV,

. EMERGENCY SUMP CONTAINMENT CNMT SUMP TO RHR PUMP-B

.

ISOLATION VALVE SUCTION EMERGENCY SUMP CONTAINMENT CNMT SUMP TO RHR PUMP-A ISOLATION' VALVE SUCTION

,

.!

-

ISOLATION VALVE ON SAMPLE FROM CNMT SUMP PASS SAMPLE

'

.

RHR EMERGENCY PUMP

. ISOLATION ORC

_

ISOLATION VALVE ON SAMPLE FROM CNMT SUMP PASS SAMPLE RHR EMERGENCY SUMP ISOLATION - IRC Procedure E-0 1 RNO 2NB08 2NB0801 2NB09 2NB0901 17b-Less than 1625 scale increments at 1500,-1750 17e RHR pump flow indicators RhR PUMP PRESSURE

557 degrees scale increments at 550, 560 AE

'SPDS address ZD9302 Z09304 Procedure FR-S.1

CVCS RMWST SUPPLY HDR RX M/U WTR SUPPLY TO CVCS ISO-

'TO BLENDER and CHG ISO Attachments Establish safety grade letdown

p y,

,

.

.

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c,

.

.

. - -

[ Appendix D

-'

.

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HV-0442A IZI-442A

'

'

HV-0442Bi 1Z1-442B

'

,

.

Valve' lineup for CCP cold leg injection

through the BIT t

1 RWSTLSupply to ECCS Sa'fety Inj RWST Outlet

. Isolation CCP Suction From RWST RWST-CHG-i

.

- CCP Suction from VCT'

VCT Outlet Isolation

-

CCP'To SIPoSuction CHG HDR Cross-connect

,

'

CCP A Mini-Flow Isolation CHG-MNFL

.

Bypass. Charging Supply Safety Grade Charging to-j

Isolation Regen Hx

,

,

Normal-Charging Supply CHG-DISCH

Isolation i

l CCP A Discharge Isolation CHG DISCH

"

"

~ CCP' Discharge. Cross-connect CHG'DISCH I

BIT Outlet Isolation BIT DISCH-

..

Makeup without instrument air available

.1 RMWST TO CCP'A ISO-CVCS CHG RMWST SPLY T0.CCP'A:

'

IS0'

L EMERG BORATE MANUAL ~ ISO CVCS MANUAL EMERGENCY BORATION

l

'

!

1-l Establishing charging without instrument air

.

' 2-1208-U6-152 2-08-S94-C l

Procedure ES-1.2 26b/19)

RCP seal' return. header RCPs Seal Leakoff IRC

,

isolation valves isolation valves l

Procedure ES-1.4-22b/3 SI pump Train A discharge SI Pmp-A to Cold Leg Iso cross-connect valve Viv i

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.

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. Attachment - Valve lineup.'for.RHR. pump

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. cold leg injection:

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Cnmt Sump to-RHR PMP-A a

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L RHR Pump A-Discharge l. Isolation

~RHR:HX. Train-A Outlet-

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l Combined RHR Hot Leg; Injection RHR HL:

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APPENDIX E

!

ABBREVIATIONS

-AER_

Action / expected response l

A0P Abnormal Operating Procedure

!

-AP Administrative Procedure

"{

ARP.

Annunciator Response-Procedure ARV Atmospheric Relief Valve ATWT Anticipated Transient Without Trip

,

B0P Balance of Plant-

-j COPS Cold Overpressure Protection System i

CSF Critical Safety Function

'

CSFST-Critical Safety Function Status Tree E0P-Emergency Operating Procedure ERG Emergency Response Guidelines GPC Georgia Power Company HP High. Pressure HED Human Engineering Deficiency

I&C Instrumentation and Control

'

IFI

. Inspector Followup Item MCB Main Control Board NI-Nuclear Instrumentation PGP Procedures Generation _ Package-l

_

PRB Procedures Review Board

'

PRIP Penetration Room Isolation Panel PSMS Plant System rionitoring System y

PSTG Plant' Specific Technical Guidelines j

PSTG DEV PSTG-Deviation RNO Response Not Obtained-

!

RVLIS

. Reactor Vessel Level Instrumentation System

.

,

SAER Safety Audit and Engineering Review

!

SCM Subcooling Margin

!

SDD Step Deviation Documentation-SER Safety Evaluation Report

.

S/G Steam Generator SGTR Steam Generator Tube Rupture

!

-SI Safety Injection S0P System Operating Procedure SPDS Safety Parameter Display System i

SPE Steam Packing Exhauster

!

SS Shift Supervisor

,

-SUR Startup Rate

'

TSC Technical Support Center-i VEGP Vogtle Electric Generating Plant WOG Westinghouse Owner's Group l