IR 05000456/1989011

Safety Insp Repts 50-456/89-11 & 50-457/89-11 on 890508-24. No Violations Noted.Major Areas Inspected:Verify That Util Emergency Operating Procedures Technically Correct & Usable

ML20245B722
Person / Time
Site:	Braidwood
Issue date:	06/16/1989
From:	Hasse R, Hopkins J, Phillips M, Sears J, Vansickle G, Wilfred G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20245B720	List: IR 05000456/1989011 ML20245B719
References
50-456-89-11, 50-457-89-11, NUDOCS 8906260037
Download: ML20245B722 (16)

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'U.S. NUCLEAR REGULATORY COMMISSION :

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[, REGION II '

Repo'rts No. 50-456/89011(DRS); 50-457/89011(DRS)-

Docket.Nos. 50-456; 50-457 Licenses.No. NPF-72; NPF-77

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Licensee: Commonwealth Edison' Compan Post:0ffice; Box 767 Chicago,-IL 60690-g - Facil'1ty? Name: .Braidwood Nuclear Power Station, Units.1 and 2

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Inspection At: - Braceville, IL 60407

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-Inspection Conducted: May 8-24, 1989

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' Inspectors A e ader 6[/8[ff

}J.' Hopkins'.Cl & /6 L e 2 7 Date k.6. h

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G. VanSickle .

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Date-ear , Consu a (COMAX) ([//!/f

. f . Wilfred, Consultant G

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Date Approved By: .P ps, Chief 6 6// 7-Operational Programs Section Date

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Inspection Summary ,

Inspection on May 8-24, 1989 (Reports No. 50-456/89011(DRS); 50-457/89011(DRS))

Areas Inspected: Special announced safety inspection to-verify that the Braidwood Emergency Operating Procedures (EOPs) are technically correct and usable. The inspection was conducted in accordance with TI 2515/92 (SIMS No.-HF'4.1).

Results: ~No violations were identified, The licensee showed strengths'in

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adherence to the accident mitigation strategy presented in the owners group Emergency Response Guideline Some programmatic weakness was identified in the~ area of E0P verification and validatio i 8906260037 890619 PDR ADOCK 05000456 / l

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DETAILS 4

1.' Persons Contacted l l

Commonwealth Edison Company (CECO) 1

• R. Querio,. Station Manager

• E. Carroll, Regulatory Assurance

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• L. Bush, Regulatory Assurance

• P. Holland, Regulatory Assurance

• R.-Kyrouac,-Quality Assurance Superintendent

• M. Trusheim, Operations

• Pontius, Operations Staff

• C. Bearden, Operations Staff

• S. Merrell, Operations Staff (Byron)

• W. McGee, Training Supervisor

• M. Gorski, Nuclear Safety j

• G. Masters, Assistant Superintendent, Operations '

• D. O'Brien, Technical Superintendent J. Chozinicki, Shift Engineer U.S. Nuclear Regulatory Commission (UdNRC)

• G. Wright, Chief, Operations Branch, Region III T. Tongue, Senior Resident Inspector T. Taylor, Resident Inspector Other licensee personnel were contacted / interviewed during the inspectio * Denotes those personnel attending the exit interview on May 24, 198 . Emergency Operating Procedures Background Emergency Operating Procedures (E0Ps) have undergone significant changes due to the 1979 accident at the Three Mile Island (TMI)

facilit The post-TMI procedures are symptom-oriented rather than event-oriented. Symptom-oriented E0Ps provide the operator guidance on how to verify t eh adequacy of critical safety functions and how to restore and maint ain these functions when they are degrade Symptom-oriented E0is are written in a manner that the operator need not diagnose an event to maintain the plant in a safe shutdown condition for all accidents that are within the scope of the E0P The purpose of this inspection was to verify that the Braidwood E0Ps are technically correct; prepared in accordance with the writer's guide; that their specified actions can be accomplished using existing equipment, controls, and instrumentation; and that the available procedures have the usability necessary to provide the operator with an effective operating too _ _ _ _ _ _ -

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( Inspection'Me'thodology-

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The inspection consisted of a desk top review of 22 Optimal Recovery V Procedures and 17 Function Restoration Procedures; an in plant walkdown of local'actionsEspecified in 11 Recovery Procedures and-two Abnormal. Procedures; exercising.five scenarios on the plant'

simulator which used 16 procedures;.and a human' factors review of_the procedures, plant walkdowns, and simulator exercises. In

' addition, 12 users and developers of the E0Ps were interviewe 'A detailed listing of these activities is given in Appendix ' Inspection Results

.The following paragraphs provide a general discussion of the results of the' inspection. A detailed history of observations and coacerns is given in Appendix (1) Desktop Review The-desktop review consisted of a detailed comparison of the E0Ps to the owners group (WOG), Emergency Response Guidelines (ERGS). !Where deviations from the ERGS occurred, the documented justification for these deviations was reviewe Also,.a large sample of setpoints used in the E0Ps was compared to the' plant specific setpoint document. The background portion of.the ERGS was referenced extensively to assure the Braidwood E0Ps were consistent with the accident mitigatio strategy developed by the WO The inspectors concluded that the Braidwood E0Ps were adequate to mitigate accidents within the scope of the ERGS. A-strength was noted in the adherence of the Braidwood E0Ps to the ERGS except where plant' differences from the reference plant dictated deviations. In these cases, the WOG strategy wa generally maintaine A number of minor concerns were identified during this review.-

These concerns are detailed in Appendix 8. Typical of these concerns were:

• Inconsistent component location information for local actions;

• action statements appearing in " cautions" and " notes;"

• minor technical and reference errors or omission The licensee committed to address these concerns as specified in Appendix B. Completion of these actions'will be tracked under open item (456/89011-01 457/89011-01).

One weakness was identified with the documentation of deviations from the ERGS. While deviations were generally documented, the justifications for these deviations were

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sometimes very crypti Discussions with developers of the E0Ps determined that the deviations were justified in these cases; however, the inspectors were concerned-that it could be difficult for future developers of the E0Ps to interpret the justification (2) Plant Walkdowns The inspectors walked through the local actions specified in selected E0Ps and off-normal procedures. These walkdowns were conducted with licensed and non-licensed operators who would normally perform these tasks. The objective of these walkdowns was to determine if these actions could be performed in a timely manner with a minimum potential for erro As part of this effort', the inspectors also assessed the accessibility of equipment requiring local action with respect to the post-accident radiation level described in Appendix E of the FSAR. In general, location operation was accessible and could be operated with a minimum of operator inconvenienc The inspectors did identify several minor concerns which are detailed in Appendix B. The only generic problem involved labellin While valves were accurately labelled, the tags were generally small and could not be read from any distanc This could delay accessing the right valve in some instance !

Also, in at least one case, the location of individual breaker switches inside a panel was described on a list enclosed in a plastic envelope attached to the panel door. This ceald lead to a delay in identifying the proper breaker or even an error in identification. The licensee had a labelling improvement program in progress; however, priority was being given to labelling of instrument and control equipment. The licensee agreed to accelerate the schedule for valves and electrical gear used in the E0P Only two valve accessibility problems were identified. One of these was corrected during the inspection (this involved N2 bottles hindering access to the steam generator PORVs). The other case involved reactor coolant system loop to residual heat pump suction isolation valves. These valves are located in containment and two of them are 15 to 25 feet above ground level. While accessible by climbing over piping in the area, a dedicated ladder or platform would be more appropriate. The licensee agreed to correct this situatio During these walkdowns, the inspectors noted that procedures for equipment operation were not available at the equipment location. The licensee stated that this was a conscious policy decision prcmpted by the difficulty in assuring that local procedures were the current revision. Procedures for local operation must be obtained from the shift engineer's offic The licensee felt that any delay in local operations would !

be minimal since operators performing local operations are l

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' typically dispatched from the shift engineer's offic The-inspectors considered this a potential weakness from the ,

standpoint of. emergency operations; however, the need for i procedure control was acknowledge !

The inspectors identified no accessibility problems due to post-accident radiation levels; however, the inspectors were concerned that operation specific assessments were not part of the verification / validation program. This is discussed further j in Paragraph 2.c.(4).

(3) Simulator Exercises Five scenarios using 16 E0Ps were conducted on the Byron /Braidwood simulator to verify that the E0Ps provide the operator with an effective operating tool to place the plant in a safe shutdown condition for accidents and transients that are within the scope of the E0Ps. The scenarios were run with two different operating crews from the Byron station using the Byron E0Ps. Since Byron and Braidwood are sister plants and the licensee makes a concerted effort to keep their E0Ps identical, the use of the Byron crews and E0Pr was considered an acceptable surrogate for evaluating the Braidwood E0P The E0P procedures proved to be technically correct and could be accomplished using the existing equipment, controls, and instrumentation. Several recommended procedure enhancements indicated by these exercises were provided to the license (4) Verification and Validation (V&V)

A review of the Braidwood V&V program consisted of (1) review of verification and validation documentation, (2) comparison of WOG 1A verification and validation documentation against current E0Ps and (3) an interview with the procedure writer ;

concerning the V&V progra ;

One area of concern was the lack of use of inplant walkdowns as a validation methodology, even though this method is one of the four described in the validation pla Review of the V&V documentation indicated that no E0P validations for Rev. 1 WOG 1A had been accomplished by the walkdown methodolog Simulator, tabletop, and "by reference" were the methodologies used. While the licensee stated that all E0Ps were walked down for Byron Unit 1 (Braidwood Sister Plant) in early 1985, subsequent use of the walkdow methodology would have identified some of the problew found during this inspection (e.g. , valve accessibility problem in containment - see Appendix B).

A second concern was the failure to include off-normal procedures (OAs) in the V&V progra Several problems identified during the inspector's walkdowns could have been identified by a licensee walkdown of these procedures

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-(e.g., lack of extender handles for local; operation of steam

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p generator PORVs -see= Appendix'B). Also, during interviews',-

operators expressed less confidence in the OAs than the EOPs-(see Paragraph d).

The final concern in this are was the' failure to' explicitly

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i address post-accident equipment accessibility due to radiation levels as-a part of-the V&V' effort for-local actions. While the study presented in Appendix.E:of the FSAR indicated ~no:

immediate' access. problems, useful information could be gained

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from explicH-consideration for' specific local actions. This l

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could include limited " stay". times in some areas or the-potential'need'to rotate operators'in areas requiring extended stay time Licensee resolution of these concerns will be tracked as an

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.open item (456/89011-.03 457/89011-03).

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d. ' Human Factors Evaluation A human. factors evaluation.of the E0Ps'for Braidwood' Units 1 and 2 was conducted to ensure that the E0Ps: (1) are consistent'with'the Breidwood Abnormal / Emergency Operating Procedure Writer's Guide-Resision 5; (2) could.be physically performed;'and (3) could be correctly performed by the staf The human factors evaluation consisted of a desk-top review of selected E0Ps, E0P walkdowns in both plant and control room, observation of simulator exercises, and interviews of selected users, developers, and trainers of-the Braidwood E0P (1) Desk-Top Review A desktop review was conducted of the writers guide, verification program documentation, validation program documentation and a sample of E0P. Concerns identified

.during this desktop review include the following:

• Per NUREG-0899 guidance,' cautions and notes should not contain actions. The Braidwood writers guide gives contradictory guidance on the incorporation of actions in cautions and notes. Sections VI, G, 1.b, 7) and 8) on page 36 and VI, G.2., 7) and 8) on page 37 of the writers guide; state that " caution / notes shall not direct actions" (step 7) and " caution may use a conditional action statement format . . " (step 8). Numerous examples of

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actions contained in cautions and notes were found during the desktop revie * A review of a large sample of E0Ps indicated that equipment / component location / identification information for control room and local actions was inconsisten Discussions with E0P developers indicated the philosophy f pertaining to this issue-is the use of common terminology and heavy reliance on operator training / knowledg _ _ _ _ _ _

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g o Discussions with operating personnel revealed that

': though they are confident they could locate all reference'd

. equipment, considering the high stress of an event they would like to.-see this information.as part' of the E0P The licensee committed to address'these issues as detailed

'in Appendix B..~ Action statements in: notes and~ cautions will be corrected for those that are plant specifi Those taken directly from the ERGS will be. referred to the WO Location information will be provided for

, .all. valves. . Inclusion of other equipment locations will follow current philosoph (2).Walkdowns-Walkdowns were conducted in both the control room and the L plant.' . Operators assisting in plant walkdowns demonstrated

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excellent knowledge of the plant and were able to simulate

, implementation of the E0Ps. The location of E0Ps within the control room was clear and easily accessible. Control room-lighting and'noi.se levels were' adequate for implementation of the E0P Control room layout did not appear to potentiall interfere with efficient execution of actions called for in the E0Ps. .In general, local actions were successfull accomplished, with tools present, equipment labeled and accessible, and emergency lighting provided (exceptions noted below). The following concerns were identified:

o Procedures were not available locally for remote action Licensee philosophy dictates that procedures can be obtained either at the control. room or the remote shutdown panel. ; Licensee concern here is' for control

_of documentation. The inspectors concern is to have procedures available without unnecessary time delay * Individual sheets of control room and remote shutdown panel E0Ps were contained within transparent plastic sleeves for use with a grease pencil as a peacekeeping aid. It'was observed that these sheets can slide within the sleeve causing blurring / smearing of the tex * All inspection team members noted difficulty in reading labels. The current Braidwood station labeling scheme uses stamped metal tags (raised alphanumerics) that are wired to the particular component. Though this scheme ,

provides durability and longevity, there are significant l human factors problems associated. The basic problem is illegibility due to type size and lack'of contras The labels cannot be read from more than a few feet awa Under emergency conditions, provisions should be made for rapid, easy identification. Also noted was the fact that for some remote actions operators had difficulty locating a specific component in an area of many component This suggests the use of some sort of operator aid to direct

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the operator to the emergency related components in that area (i.e., arrows pointing the way). In determining the types and locations of such operator aids, consideration should be given to the vantage point of the operator as he would be executing.the emergency procedur The licensee has a program to upgrade the entire plant to high visibility equipment labeling. However, the fact that it may be up to three years before valves are provided

'with this new labeling is' a safety concern. The licensee agreed to expedite high visibility labeling for all components that are safety / emergency relate (3) Simulator Exercises One day of the inspection was dedica.ed to observation of simulator exercises. The human factors team member observed scenarios 1, 2, and 3 out of the 5 scheduled for the day. The comments that follow therefore pertain to only the first three scenario In general, it was noted that staffing levels were adequate, the roles and responsibilities of the crew were clearly defined, a team approach was utilized, and the operators were able to carry out their assigned task Peacekeeping and the physical act of transitioning to other procedures was accomplished with no difficulty. Two specific problems are noted below:

• BwEP-1, Step 2, illustrates a potential problem that is generic to all Westinghouse procedure The problem arises in the use of wording that will result in a "yes" answer and thus keep the operator in the Action / Expected Results column. This step reads " check if no steam generator pressure is decreasing in an uncontrolled j manner," rather than " check if steam generator pressure ;

is stable or increasing." During the performance of this !

scenario, operators made a mistake at this step. Whether or not this was a result of a misinterpretation of control board information or something induced by the wording of the procedure was not clear; however, less convoluted wording would enhance understandabilit * In BwCA-0.0, step 23 RNO 4) the direction provided is not specific enough. Following the scenario, the operator told the inspectors he was not sure where to go when the diesel was restored. The caution on page 7 should appear in the loop from step 23 back to step 1 (4) Interviews I During the inspection, 12 Braidwood staff members were interviewed. The interviewees consisted of three senior reactor operators, three reactor operators, two equipment

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i operators,.two equipment attendants, one procedure developer / ]

writer, and one training specialis In general, the E0P users '

had a very positive attitude toward the E0Ps and supported I their use. They were unanimously of the opinion that in the i case of an event they would bring the plant to safe and stable conditions. The interviewees did c.xpress a number of common concerns. These concerns were also identified by the inspection team. Following is a list of the most commonly  ;

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reported concerns:

• Operators expressed concern that on the backshift with a two unit trip, manpower for local actions would be tigh Operator confidence would be bolstered by 1 or 2 additional equipment operator (BwCA-0.0 was cited as an example.)

• Operators expressed the opinion that during the stress of an event it would be desirable to have equipment location /

designation for ALL control room and locally operated equipment incorporated as part of the E0Ps (see 2.d.(1) desktop review comments).

• Equipment operators and equipment attendants expressed the following concerns with regard to their E0P training:

• They desire to have more consistent / regular coverage of E0P Some of the operators interviewed could not recall the last time E0Ps were covered as part of their regular trainin * The operators expressed the opinion that a greater portion of their training should be devoted to locations of ECCS equipmen * The operators expressed desire for some exposure to the simulator, if not hands on at least in an observing rol (It should be noted that the E0s and EAs do not use the E0Ps directly.)

• In general all SR0s and R0s were highly confident in the E0P They expressed their view that they were well written, logically laid out, easily followed, and under event conditions would wor However, a number of operators expressed concerns for the BWOAs (off-normal procedures). It was their collective opinion that this set of procedures have not been as highly scrutinized as the E0Ps. Specific OAs cited were:

• Bw0A RCP-1, Reactor Coolant Pump Seal Failure poorly laid out, branching problem !

• Bw0A PRI-8 Essential Service Water Malfunctio * Bw0A ELEC-1, Loss of DC Bu _ - _ _ _ _-. _ _

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Training _and Qualification Effectiveness A review of the Braidwood training program was conducted to ensure that adequate training'in the use and bases of the E0Ps was occurring. This portion of the inspection consisted of a review of the training program description included as part of the PGP, review of lesson plans, and interview with the training department superviso The training supervisor stated that total estimated time devoted solely to E0P training during initial operator training is four weeks. The training staff philosophy is " verbatim compliance" with the E0Ps, thus ensuring total operator familiarity with the procedure Retraining consisted of quarterly periods of instruction lasting 16 days. During this period, 13 days consisted of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> simulator /4 hours classroom. Review of weak areas and procedure changes are covere Stud-ts are evaluated daily by the instructor and also the cross crew method by which peers review fellow student simulator performance. The Training Department keeps individual student records of which procedures have been trained and the date of training, to ensure eventual coverage of all E0Ps. Total time devoted to E0P retraining is 3 to 4 days per quarte Training on E0P revisions is conducted by training department instructors sent to the Braidwood station for onshift training. This ensures total and timely exposure for all operators on procedure revisions. Once the procedures have been approved and issued, the training department updates the appropriate lesson plans. Operator training on revisions also can take the form of required readin ~If the training department discovers a technical deficiency or other problem in a procedure it can initiate the change process by completing an Operations Revision Request Form (BWAP 340-4Tl). This form goes to the Procedure Coordinator who evaluates the request and ensures proper disposition. The Procedure Coordinator does provide feedback to the training department regarding disposition of the particular revision reques Training department responsibility in the V&V process includes scheduling of the simulator and providing instructors to run the simulator and observe / provide insight gained from their experiences with particular procedures. Typically 1-2 weeks per year are set aside for using the simulator for V& In general, all Braidwood staff involved with the preparation of use of the E0Ps appeared well trained and qualifie . Quality Verification Effectiveness The inspectors reviewed two licensee conducted audits of the Braidwood ;

E0Ps. The first audit (QAA 6-88-54/QAA 20-88-56) was conducted in November 1988 and the second (QAA 20-89-47) in May 1989. No previous audits of the E0Ps had been conducted. The licensee stated that the November 1988 audit was prompted by a violation issued to another ;

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0; licensee facility,for failure to conduct audits of their E0P The Noveniber:1988 audit reviewed BWEP-3 against the ERGS including the background. document. Several minor errors and discrepancies were identified. These' findings have been close The audit conducted from April'28 through.May 5, 1989 used a small break

.LOCA as a' scenario and covered all E0Ps and off-normal procedures that would be used'in such an event. Other areas were also' covered where interviews conducted during the audit indicated problems might' exis .The findings of this audit paralleled, and in some cases were identical-i t

to those of the NRC inspectio The. inspectors' concluded that, while tardy in initiation, the audits being conducted were effective in identifying problems with the E0P , .0 pen Items Open. items are matters which have been discussed.with the licensee which will be reviewed further by the inspectors or which involve some actions on the part of the NRC or licensee or both. The open items dicciosed during this. inspection are detailed in Appendix B and referenced-throughout the body of the repor . Exit Interview

'The inspectors met with licensee representatives (denoted-in Paragraph 1)

on May 24, 198 The inspectors summarized the purpose, scope, and findings of-the inspection and the likely informational content of the inspection report. The licensee acknowledged thisiinformation and did not identify any proprietary information, g

Attachments:

Appendix A Appendix B i

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APPENDIX'A ~

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Description of' Inspection-Activities  ;

Emergency Operating Procedure .o

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. . 1 s (1)(2)(3)- BWEP-0 Reactor: Trip;or. Safety Injection-K .-

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- (1)(2)(3)L- BWEP-1 Loss of' Reactor or'. Secondary Coolant

.(3) BWEP-2 . Faulted Steam.. Generator Isolatio ~(2)(3). BWEP-3 Steam. Generator Tube Rupture'

.; BWES- Rediagnosis

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_( 3) . BWES- Reactor Trip Response g

BWES-0.2: Natural. Circulation Cooldown BWES- Natural Circulation Cooldown with Steam Void in Vessel (with RVLIS)-

BWES- Natural Circulation Cooldown with Steam Void in Vessel (without RVLIS).

.BWES- SI Termination-

.I BWES- Post LOCA Cooldown and

~Depressurization

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-(3) BWES- Transfer to Cold Leg Recirculation (2) BWES- Transfer to Hot Leg Recirculation BWES- Post-SGTR Cooldown Using Blowdown BWES- Post-SGTR Cooldown Using Blowdow BWES- Post-SGTR Cooldown Using Steam Dump

.- (2)(3) BWCA- Loss of All AC Power BWCA- Loss of All AC Power Recovery Without S1 Required

.(3) BWCA- Loss of All AC Power With 61 Required-i

(2)(3) BWCA- Loss of Emergency Coolant

.. Recirculation

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7 BWCA- LOCA=0utside' Containment b

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BWC -2.1- Uncontrolled Depressurization of L- LAll Steam Generators

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- (2)(3). BWCA- SGTR With' Loss of Reactor-Coolant-Subcooled Recover Desired-

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,. , (3) -BWCA- SGTR WithLLoss of Reactor-R Coolant-Saturated. Recovery Desired'-

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.BWCA- SGTR Without Pressurizer Pressur Control

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, - (3) BWFR- Response to Nuclear' Power; Generation /ATWS-BWFR- Response to' Loss of Core' Shutdown (1)(2)' BWFR- Response to Inadequate Core Cooling (3): BWFR- Response to Degraded Care Cooling-

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BWFR- Response to Saturated Core.'C'ooling l(3) BWFR- Response..to Loss of Secondary Heat'

h- Sink-BWFR- Response to Steam Generator Overpressure-BWFR- Response to Steam' Generator High Level.-

BWFR- Response to Loss of Normal Steam Release Capabilities

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BWFR- Response to Steam Generator Low Level

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BWFR- Response to. Imminent Pressurized Thermal Shock Condition

BWFR- Response to Anticipated Pressurized Thermal Shock Condition

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BWFR-Z.,1 Response to High Containment Pressure BWFR- Response to Containment Flooding BFFR- Rosponse to High Containment Radiation Level 2 Appendix ' I .'..'

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BWFR- Response to High Pressurizer Level BWFR- Response to Low Pressurizer Level BWFR- Response to Voids in Reactor Vessel Operating and Off-Normal Procedures (1) BWOP MS-6 Local Manual Operation of the Steam Generator Power Operated Relief Valves (1) BWOA SEC-5 Screen House (1) BWOA PRI-5 Control Room Evacuation (1) All procedures with these exceptions were reviewed during the desktop review described in Paragraph 2.c.(1).

(2) Local actions described in these procedures were walked down as described in Paragraph 2.c.(2).

(3) These procedures were exercised during the simulator scenarios described in Paragraph 2.c.(3).

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APPENDIX Detailed Inspection Findings

. ' Procedure Revision - Open Item (456/89011-01; 457/89011-01)

The licensee committed to implement the following procedure revisions: l All E0Ps - Provide valve number, functional title, and location (level and grid number) for all valves specified in local operation .BWEP-2, Step 4.c - correct valve numbers for steam generator PORV BWEP-2, Step 4.e - make open and closed bullets consistent between A/EP and RNO column BWEP-3, Step 3.d(2) - change " isolated intact SGs" to "unisolated intact SGs" in the RNO colum 'BWCA-2.1, Steps 11.6, 27, and 39 - include explicit instructions

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for initiating normal pressurizer spra BWCA-2.1, Step 15 - change "SI pumps" to "ECCS pumps" in RNO column BWCA-3.1, Step 25.9 - delete the requirement for 50 F subcooling as a prerequisite for isolating SI accumulators (50*F subcooling not consistent with the ERG). BWCA-3.1, Step 25.a - first sentence of RN0 column should direct operator to Step 25.c instead of.2 BWCA-0.0, Step 12 - change identification of ruptured SG "by sampling" to "by radiation survey." BWCA-0.1 - include actions in Attachment B in body of procedur I BWCA-0.0, Step 19 - correct penetration number for chilled water return isolation valve (or correct penetration label). BWCA-1.1, Step 26 - evaluate need to correct RVLIS reading for l number of RCPs runnin ! BWFR-P.1, Step 3.a - make pressurizer pressure for closing PORVs consistent with set point document (reseat vs litt pressure). BWFR-P.1, Step 6 - insert caution from ERG en loss of offsite power after resetting S BWFR-I.2 - add step 3.b of ERG on establishing instrument air to containmen _____

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" BWEP-3, step 9.f - add RNO to locally open-fire protection

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containment isolation valve r.' BWEP-3, step 17.b~'- add RNO to direct operator to BWCA- s.. .AM E0Ps - Remove action statements from plant specific " cautions" l and " notes".and include as procedure' steps (to extent. practicable) R or " facing page aids."

- BWOP-0G-10 -' ' add reference to the. key needed to open the panel.

L BWOA-PR-5,' Attachment E, step 1 - add reference to key nEeded to g access panel in step . 'Fie'ld Actions - Open Item (456/89011-02; 457/89011-02)

The licensee committed to resolve the following field concerns:

a.' Provide high. visibility labelling for'all valves and electrical equipment used in the E0Ps and referenced procedure b.- Provide hand pump extenders for steam generator PORV local operators-and specify provisions'for storing and retrieving the c .' Provide easier access for RCS loop to RH pump suction isolation valves 2RH8701B and 2RH8702 d .' Add open/close direction indication on valve AF 005F and others in this are . Concerns to be A'ddressed by Written Response from Licensee - Open Item (456/89011-03; 457/89011-03)

The following are concerns identified by the inspectors for which resolution was not obtained during the inspection (due primarily to the need for Braidwood Station consultation with Byron Station on a unified approach to. resolution). Failure to include off-normal and other E0P referenced procedures in the V&V progra Failure to continue to use walkdown methodology in the V&V progra BWFR-H.2, step 8 states: " Consider using SG blowdown . . . ."

The step should be changed to direct actio BWFR-H.1, step 2.a.(2) states: " Consider the following steps . . . ." The language should be changed to direct actio Failure to explicitly consider post-accident radiation levels '

in the V&V of local operation Appendix B

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