Text

Compilation of AFW Corrective Actions, Taken in Response to Potential Common Mode Failure Due to a Loss of Station Air and Operator Actions, Volume 2 of 4 (Provided by Licensee in Response to a Question from Ken O'Brien, Usnrc), State Chang
	ML030640203
Person / Time
Site:	Point Beach
Issue date:	02/06/2003
From:	; Nuclear Management Co
To:	; Office of Nuclear Reactor Regulation
References
	FOIA/PA-2003-0094
	Download: ML030640203 (137)
	v • d • e

Page 1 ot 4 Nuclear Management Company STATE CHANGE HISTORY V, Review & Quality Check Assign Work Complete Approval Approved Initiate Work Assign Conduct Work 9/20/2002 9/18/2002 2/5/2002 2/6/2002 1.32 47 9.49 37 AM PM 7.02.19 AM 3.35.35 PM Owner Owner Owner TERRY by TERRY by DUANE PBNP CAP Owner by TOM DUANE by RICHARD DUANE VANDENBOSCH VANDENBOSCH SCHOON Admin FLESSNER SHELEY SCHOON SCHOON SECTION 1

- - - .' r-.'. *-

Activity Request Id: CA003697 Corrective Action Submit Date: 2/5/2002 PM 3:35"35 Activity Type:

Site/Unit: Point Beach - Common Activity Requested: Review EOPs and AOPs containing high-risk human error events against human error reduction methods used in the PRA model and revise where appropriate to achieve significant CDF risk reduction.

See UPDATE section TPS N Initiator: FLESSNER, 0 CATPR: RICHARD fR PO PB Operations Initiator Department: EX Engineering Responsible Group Code:

PBZ Processes PB DUANE SCHOON Activity Supervisor:

Responsible Department: Plant Activity Performer: TERRY VANDENBOSCH SECTION. 2 f l t,, . .= **=.=* .n~ * * * * * **' ' == * **

t *r 3 Due Date: 10/4/2002 Priority:

Y Management Exception From PI?:

" Mode Change Restraint: (None) N 0 Licensing Review?:

""QANuclear Oversight?: N 0 NRC Commitment Date:

NRC Commitment?: N SECTION 3 Activity Completed: 1/18/2002 12:52PM - LARRY PETERSON:

R Due date extended as requested and approved by F. Cayia in prior update. Retruned to flessner for completion.

1/18/2002 12.54PM - LARRY PETERSON:

Reassigned to R. Flessner for completion following extension 2/22/2002 12.14PM - MARK RINZEL:

This item has been exempted from performance indicators by the Plant Manager via e-mail dated 2/21/2002. The item has been updated to reflect this exemption in section two.

8/21/2002 9.22.43 AM - TERRY VANDENBOSCH:

I I (... 9/20/2002 https://nmc.ttrackonline.comntmtrack/tmtrack.dll?IssuePage&TabeId= I 000&Recordld=

Nuclear Management Company Page 2 of 4 Two groups of 1 SRO and 2 COs are scheduled to meet with the PRA group on the simulator to perform a review of the EOPs. This is scheduled for the week of 8/19/02.

9/18/2002 7:02:19 AM - TERRY VANDENBOSCH:

Comments from 8/21/02 simulator observations

1. Step 15 of EOP-0, The Simulator and actual Control Room have different operator aids (rad monitor index). The difference extents the time in the Simulator to perform this step. The extended time blurs the training in this step and the steps that follow. There is a negligible impact on PRA HRA assumptions

2. The reading of the foldout to the operators after the immediate actions extends the time by about 4 minutes Most of the actions are covered later in the procedure This was repeated at the start of each procedure which starts to adds up over several procedures. Thesecould be addressed differently.

3 EOP-1.4, step 1 provides condition to stop RHR pumps, which are the same conditions for the kick-out from EOP-1.3 to EOP-1.4. Step 3 b directs operator to check RHR flow, a condition that should not exist. The RNO provides the same conditions again without clear direction on what to do or go if the condition does not exist. In general, if you answer yes to step 3.b, you are in the wrong procedure. If you are in the right procedure, you can never answer yes to 3.b because if you entered at >200 psig RCS pressure, you stop the RHR pumps. If you enter at <200 psig and < 450 gpm, you most likely will still be <450 gpm. This is confusing to the operator. There is a negligible impact on PRA HRA assumptions.

4. EOP-1.4, attachment A performance and actions of step 14.b overlap in time. Attachment A takes 10-15 minutes to complete. Step 14.b is performed by the same operator and is requested about 5 minutes after attachment A is complete.

5 EOP-1.4, step 19 Note and step 19 are confusing to the operators. The note provides guidance to maintain maximum RHR flow, but <2200 gpm. Substep b directs throttling RHR flow to < 2200 gpm. RCS pressure is not addressed and is a major factor with RHR flow.

Operators speculated that if the ACS pressure eventually dropped that they could reach runout conditions In order to achieve a throttled condition that would not runout the RHR pumps, the operators placed the valves in the 20% throttled position. There is a negligible impact on PRA HRA assumptions.

6. EOP-1.4, step 1 note and step 28 note caused operator confusion. Ifyou are monitoring for information only, you don't implement CSPs. Note for step 1 directs operators to monitor for information only in this procedure and then not to implement before step 27. Note for step 28 says to implement if >34% RWST level. The intent is that CSPs are not implemented if steps 1-27 are not complete or if RWST is <34%. The intent needs to be clearer in the first note.

There is a negligible impact on PRA HRA assumptions.

7. CSP-H.1, step 11, Operators became confused when SI occurred after 11.a but before 11.c. The actuation after the reset prevented the reset of the feedwater isolation. This may have some impact on the Human Error Probability.

8 The stroke time for the Containment Air Isolation Valve is 4 minutes. The time to open this valve delayed initiation of feed and bleed in CSP H.1. The re-establishment of Containment Instrument Air needs to be started earlier in the procedure. The timing of the valve allows for the operator to keep aware of the valve status The procedure should recommend this practice. There is a minor impact on PRA HRA assumptions

9. AOP-5B, step 27 directs the operator to perform several checklists, very few of these required any real action. The required actions need to be identified and prioritized to aid the operator. HEP-IA--AOP5B-74 may be slightly improved by simplifying the procedure.

10. AOP-9A needs to provide a wider scope of actions to address the effect on other system, such as Instrument Air. The procedure really only addresses a service water leak and/or rupture. A blockage could lead to flooding concern arose and a loss of Instrument Air occurred. The operators were left with little effective guidance to deal with the event.

Operators considered opening heat exchanger drains to increase cooling flow, but this is not contained in the procedure. Flooding of the RHR pumps is expected to occur when relief valves for the SW system open in the Aux Building if both SW discharge valves are closed or blockage occurs in the system. The effect on plant risk is not quantified, but it is greater than negligible. This item is the most important of the items listed https://nmc.ttrackonline.comltmtrackltmtrack.dll?IssuePage&Tableld=1000&Recordld= l (... 9/20/2002

Nuclear Management Company Page 3 of 4 Actions completed/recommendations" Item 1: Simulator operator aid has been changed to match the control room.

Item 2: The foldout page items apply throughout the applicable procedure The operators need to be aware of these items when entering the applicable procedure. The guidance contained in OM 3.7 is consistent to the ERG users guide. No action required.

Item 3. The procedure steps are correct as written. It is possible that between the time the operator transitioned from EOP 1.3 to EOP 1.4 RCS pressure could have lowered to less than 200 psi. The transition out of EOP 1.3 has two critena to be met, RCS pressure greater than 200 psi and RHR flow less than 450 gpm. Once the transition is made to EOP 1.4 the operator is to remain in this procedure and is not dependent on RCS pressure. When the operator gets to step 3 b. it could be possible the RHR pumps are still running In this case he would stop the "B" train and align the "A' train for recirc. No further action is required.

Item 4: The sequence is correct. If the operator while performing Attachment A would extend past the time of request to perform step 14 b., the operator is to stop Attachment A perform Step 14 b then continue with Attachment A. No further action is required.

Item 5: Based on calculations the RHR pumps will not runout when in this alignment. 2200 gpm limitation was chosen because it is the last point on the RHR pump operating curve and ensures the pump is operating well within its design. When pressure drops in the RCS the operators should be adjusting flow to maintain less than 2200 gpm No further action is required.

Item 6: The intent is to perform steps 1-27 without delay and if RWST level is > 34% the CSPs should be implemented until RWST level is <34% A procedure feedback has been issued to evaluate the wording of the notes. This is an enhancement to the procedure.

Feedback numbers OPS 2002-01340 and 2002-01341.

Item 7: The scenario given was a reactor trip without SI with a loss of all feed. The timing of the operators was such that they just performed step 11 a. and 11 b. when an SI occurred.

The operators took appropriate actions to reset SI by repeating steps 11 a.. A procedure feedback has been issued to evaluate whether or not we need to enhance the step as in EOP

3. This is an enhancement to the procedure. Feedback numbers OPS 2002-01342 and 2002-01343.

Item 8: Reestablishing air cannot be done until after SI is reset This occurs at step 32 however there is a foldout page item directing the operators to step 27 when the feed and bleed is to occur. When talking to the operators they waited for the step to be complete. This should not be the case. Once the action is commences there is not a need to wait for full opening of the valve. No further action should be required.

Item 9: AOP-5B is designed for any plant condition. The operator will have to reed the table and determine the applicability for plant conditions. No further action required.

Item 10: AOP-9B was not designed to address return blockage Engineering will need to evaluate plant response since this failure is beyond plant design. This will be a long term project to develop the applicable AOP. CAP029344 was written to track this issue No further action required.

This CAP should be closed since the procedure feedbacks are enhancements to the procedures. A CAP has been issued to track the service water concerns.

9/19/2002 6:04:42 AM - TERRY VANDENBOSCH:

The wrong CAP was referenced for the AOP-9A, service water concerns The CAP referenced should be CAP029404.

9/20/2002 9 49.37 AM - DUANE SCHOON" Closed.

SECTION 4 https://nmc.ttrackonline.com/tmtrackltmtrack.dli ?IssuePage&Tableld=! 000&Recordld=l (... 9/20/2002

Page 4 of 4 Nuclear Management Company (None) Licensing Supervisor: (None)

QA Supervisor:

SECTION 5 Q Project: CAP Activities & Actions

) State: Quality Check ) Active/Inactive: Active Daughter Q Owner: PBNP CAP Admin AR Type:

2/6/2002 0 Submitter: RICHARD FLESSNER Assigned Date:

DUANE SCHOON 0 Last Modified Date: 9/20/2002 9.49.37 AM 0 Last Modifier:

DUANE SCHOON 0 Last State Change Date: 9/20/2002 9.49.37 AM 0 Last State Changer:

" Close Date:

" One Line

Description:

Probabilistic Risk Assessment PRA For Auxiliary Feedwater System AFW NUTRK ID: CR 01-3595 Child Number: 1

References:

CR 01-22781RCE 01-069LGOOD CATCH out Update: Action out a ACE that is being classified as a ROOT CAUSE. Due dates and priority set ACE 314. C6ntact the author of ACE 314 for any clarification. TPS by ACTIVITY COMPLETED is old information from the ACE that was cloned into this action responsible ACE individual -- Disregard.

Import Memo Field:

PBNP CAP Admin Site: Point Beach CAP Admin:

OLDACTIONNUM:

Cartridge and Frame:

NOTES/COMMENTS 8.04:32 AM)

Management exception from performance indicators by DENNIS HETTICK (2/28/2002 This excetion was granted by plant manager. e mail attached.

ATTACHMENTS AND PARENT/CHILD LINKS

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Page I of 2 Nuclear Management Company STATE CHANGE HISTORY Initiate AR Pre-Screen

/18/2002 5 28 56 PM Owner (None) by RICK WOOD 'i; SECTION 1 Activity Request Id: CAP029404 CAP 9/18/2002 5.28 56 PM Submit Date:

Activity Type:

AOP-9A has little guidance for sytem blockage

@ One Line

Description:

9/18/2002 5:28:56 PM - RICK WOOD:

0 Detailed

Description:

in the simulator to look for improvement Operations and PRA evaluated a number of scenarios One scenario involved a full in response to CA003697".

in the area of human error probability System Malfunction was Water blockage of service water discharge. AOP-9A Service was not fully considered for of Service Water discharge referenced, but the complete blockage service water leak and/or rupture.

a this procedure. The procedure really only addresses of Service Water System are potential consequences Internal Flood or Loss of Instrument Air to deal with the simulated guidance blockage. The operators were left with little effective increase cooling flow, but heat exchanger drains to scenario. Operators considered opening this is not contained in the procedure.

high-risk human error events against human

CA003697 Review EOPs and AOPs containing model and revise where appropriate to achieve error reduction methods used in the PRA significant CDF risk reduction.

WOOD, RICK tý3 Initiator Department: EPP PB PRA Engineering Z Programs Initiator: ,

9/18/2002 4:48.35 PM Date/Time of Occurrence:

Date/Time of Discovery: 9118/2002 4:48:35 PM Point Beach - Common Site/Unit:

Identified By: Site-identified (None)

(None) Equipment Type (1st):

Equipment # (1st): (None)

(None) Equipment Type (2nd):

Equipment # (2nd): (None)

(None) Equipment Type (3rd):

Equipment # (3rd):

9/18/2002 5:28:56 PM - RICK WOOD:

Why did this occur?: but other failure modes are not included.

Procedure considered pump failure and pipe rupture, Immediate Action Taken:

9/18/2002 5:28:56 PM - RICK WOOD:

Recommendations: needs to be understood and factored

1. The effect of full SW flow blockage on plant systems into the PRA model.

changes or design changes should be

2. If vulnerabilities are identified, then procedure considered.

N @SRO Review Required?: Y

@Notify Me During Eval?:

(None)

System:

SECTION 2 Operability Status: (None) "oCompensatory Actions:

Basis for Operability: N

" Unplanned TSAC Entry:

OPR Completed?: N N

0 External Notification:

9/18/2002 https://nmc.ttrackonline.com/tmtrack/tmtrack.dll?issuePage&Tableld= I000&Recordld=26(...

Nuclear Management Company Page 2 of 2 SECTION 3 Screened?: N " Significance Level: (None)

Potential MRFF?: N INPO OE Reqd?: N N " Licensing Review?: N D QA/Nuclear Oversight?:

Good Catch/Well Doc'd?: NA SECTION 4 Inappropriate Action:

Process: (None) Activity: (None)

(None) Human Perf Fail Mode: (None)

Human Error Type:

(None) Process Fail Mode: (None)

Equip Failure Mode:

(None) 0 Group Causing Prob: (None)

Org/Mgt Failure Mode:

Hot Buttons: (None)

SECTION 5 CAP Admin: PBNP CAP Admin Prescreener: (None) 0 Project: Corrective Action Process (CAP) ..

AR Pre-Screen 0 Active/Inactive: Active 4 State:

RICK WOOD 0 Owner: (None)

" Submitter:

Parent " Last Modified Date: 9/18/2002 5:28:56 PM AR Type:

RICK WOOD " Last State Change Date: 9/18/2002 5:28:56 PM

" Last Modifier:

D Last State Changer: RICK WOOD 0 Close Date:

NUTRK ID:

of Children: 0

References:

Update:

Prescreen Comments:

Import Memo Field:

OLDACTIONNUM:

Cartridge and Frame:

1 https://nmc.ttrackonline.com/tmtrack/tmtrack.dll?IssuePage&TableId= 1000&Recordld=26 ... 9/18/2002

Nuclear Management Company Page i ot 2 STATE CHANGE HISTORY Work Review &

Initiate Assign Work Assign Conduct Complete Approved Quality Check Work Approval 5/22/2002 2/5/2002 512212002 5/22/2002 3 30 27 PM 2 03 31 PM 2 02 25 PM 2.02 45 PM Owner PBNP by RICHARD Owner RICK by RICK Owner RICK Owner RICK by RICK WOOD by RICK WOOD CAP Admin FLESSNER WOOD WOOD WOOD WOOD Complete and Close Done 6/11/2002 6 57 50 AM by MARYBETH Owner (None)

ARNOLD SECTION 1

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- - t , Activity Request Id: CA003696 Activity Type: Corrective Action Submit Date: 2/5/2002 3:30.27 PM Site/Unit: Point Beach Common Activity Requested: Formally provide Operations and Training with a description of the human error reduction methods used in evaluating operator actions in the PRA model.

4DCATPR: N Initiator: FLESSNER, RICHARD EX Engineering Responsible Group Code: EPP Engineering Initiator Department:

Processes PB Programs PRA PB Activity Supervisor: RICK WOOD Responsible Department: Engineering Activity Performer: RICK WOOD SECTION 2 Priority: 3 Due Date: 6/5/2002 Management Exception From PI?: N Mode Change Restraint: (None)

SLicensing Review?: N 0 QA/Nuclear Oversight?: N NRC Commitment?: N 4 NRC Commitment Date:

SECTION 3 Activity Completed: 1/18/2002 12:52PM - LARRY PETERSON:

Due date extended as requested and approved by F. Cayia in prior update. Retruned to R.

flessner for completion.

1/18/2002 12.54PM - LARRY PETERSON:

Reassigned to R. Flessner for completion following extension.

5/22/2002 2 01.52 PM - RICK WOOD.

Memo NPM 2002-0267 was sent to T. Vandenbosch and J. Fouse documenting those items which contribute to the success and failure of Human Interactions in the PRA model. These factors are spelled out in this memo and can be looked at with respect to the way the procedures are written and trained on.

6/11/2002 6"57.50 AM - MARYBETH ARNOLD:

https://nmc.ttrackonline.comltmtrackltmtrack.dll?IssuePage&Tableld= 1000&Recordld=l l(... 9/18/2002

Nuclear Management Company Page 2 ol 2 Memo NPM 2002-0267 dated 05/21/02 was verified in EDMS and issued to Operations and Training personnel CLOSED.

SECTION 4

.- 1 -. 1 1-1--, 1-.

OA Supervisor: (None) Licensing Supervisor: (None)

SECTION 5 0 Project: CAP Activities &

Actions ,i o State: Done " Active/Inactive: Inactive o Owner: (None) AR Type: Daughter

" Submitter: RICHARD Assigned Date: 5/22/2002 FLESSNER f.*

" Last Modified Date: 6/1112002 6:57.50 " Last Modifier: MARYBETH ARNOLD AM 0 Last State Changer: MARYBETH ARNOLD

" Last State Change Date: 6/11/2002 6:57:50 AM "OClose Date: 6/11/2002 6:57:50 AM "0One Line

Description:

Probabilistic Risk Assessment PRA For Auxiliary Feedwater System AFW NUTRK ID: CR 01-3595 Child Number: 1

References:

CR 01-2278 RCE 01-069 GOOD CATCH NPM 2002-0267 Update:

Import Memo Field:

CAP Admin: PBNP CAP Admin Site: Point Beach OLDACTIONNUM:

Cartridge and Frame:

ATTACHMENTS AND PARENT/CHILD LINKS

,e ! £ ACE000314 Probabilistic Risk Assessment PRA For Auxiliary Feedwater System AFW e **-CAP001415 Probabilistic Risk Assessment PRA For Auxiliary Feedwater System AFW https://nmc.ttrackonl ine.comltmtrackltmtrack.dll?lssuePage&Tableld= 1000&Recordld=l f... 9/18/2002

INTERNAL

.MC CORRESPONDENCE Commntried 10 Auclce Encdlcncce~

NPM 2002-0267 To: Terry Vandenbosch, Jimmy Fouse From: R. P. Wood Date: May 21, 2002

Subject:

CA003696 AFW PRA Root Cause Corrective Action Copy To: File Root cause evaluation RCE 01-069 Increased CDF in AFW PRA Model Due to ProceduralInadequaciesRelated to Loss of Instrument Air identified that human error factors used in assessing error probabilities have not been compared to Abnormal or Emergency Operating procedures, the writers' guide for these procedures, and training materials. CA003696 from this root cause evaluation requires the PRA group to formally provide Operations and Training with a description of the human error reduction methods used in evaluating operator actions in the PRA model A little history on human factors in Emergency Response Guidelines: A Supplemental SER on the Revision I ERGS was issued by the NRC on July 7, 1986 which stated for the first time that the NRC review of the ERGS was one of technical adequacy and not human factors adequacy. Subsequently, several utilities reported that NRC audits of their EOP programs resulted in many human factors comments with several having generic implications. The subcommittee evaluated this situation and recommended that the WOG interact with the NRC to clarify and resolve the generic concerns.

In June 1989, the WOG participated in NUMARC workshops in Washington, D.C., and Denver, Colorado that discussed the industry-wide EOP implementation concerns of the NRC. At the NUMARC workshop, members of the NRC Human Factors Branch approached the WOG representatives concerning the ERG human factors issue tabled since early 1987 by the WOG.

On November 16, 1989, members of the Operations Subcommittee met with the NRC to scope out a program for human factoring ERGS, which would result in the issuance of Revision 2 at the end of 1991. This separate program (which was not part of the 1990 ERG Maintenance Program) was not funded by the WOG at the February, 1990 General Session. In other words, the WOG and NRC identified this as a concern, but a review of Emergency Response Guideline with a focus on generic human factors concerns has not been performed by these organizations.

The Kewaunee and Point Beach PRA group uses a computer program developed by EPRI called the HRA Calculator version 1 to determine human error probabilities for specific operator action. The HRA Calculator is designed to step PRA analysts through the tasks needed to develop and document Human Failure Events and Human Error Probabilities in a Human Reliability Analysis. The HRA Calculator operates on a Basic Event basis and uses EPRI's SHARP framework (Systematic Human Action Reliability Procedure (SHARP), 1984, NP-3583) The current version of the HRA Calculator employs EPRI's CBDTM (An Approach to the Analysis of Operator Actions in Probabilistic Risk Assessment, 1992, EPRI-TR-100259) for cognitive modeling and THERP (Handbook of Human Reliability Analysis With Emphasis on Nuclear Power Plant Applications, A.D. Swain and H E. Guttman, 1983, NUREG/CR-1278) for the execution modeling For the most recent PRA update, the PRA group at Point Beach has developed and documented probabilities for 5 different human actions. There are 116 different HEPs that exist in the PRA model. The list of these actions is appended to this memo. Quantification of the Human Error Probability (HEP) is accomplished using this tool. The method is described in a course on human reliability analysis presented by Scientech. The material from this course is available from the PRA group if Operations or Training is interested in the details of this analysis. The essential elements of the analysis involve determining the errors due to cognitively nmstaking the action and those due to improperly executing the action BEST COPY AVAILABLE

NPM 2002-0267 Page 2 The cognitive errors are divided into eight factors, four focused on a failure of the plant information-Operator interface, and four focused on a failure of the procedure-crew interface. The cognitive part of the human error probability (HEP) is denoted as pc. Specific elements to be reviewed by Operations and Training are as follows:

1. Availability of Information 1.1. Warning in Procedure - If the normally displayed information is expected to be unreliable, is a warning or a note directing alternate information sources provided in the procedure?

1.2. Training on Indicators - Has the crew received training in interpreting or obtaining the required information under conditions similar to those prevailing in this scenario?

2 Data not attended to 2.1. Alarmed vs Not Alarmed - Is the critical value of the cue signaled by an annunciator?

3. Data Misread or Miscommunicated 3.1. Formal Communications - Is a communications protocol used where the person transmitting a value always identifies with what parameter the value is associated?

4. Information Misleading 4.1. All cues as stated - Are cue states or parameter values as stated in the procedure?

4.2. Warning of differences - Does the procedure itself warn that a cue may not be as expected or provide instructions if the cue is not as stated?

4.3. Specific Training - Has simulator training provided a similar cue configuration and emphasized the correct interpretation of the procedure in the face of the degraded cue state?

cue 4.4 General Training - Have the operators received training that should allow them to recognize that the information is not correct for the given circumstances?

5. Relevant Step in Procedure Missed 5.1. Obvious vs. Hidden - Is the relevant instruction a separate stand alone step or is it "hidden" in a note or caution, on the back of a page, or buried in one of several statement in a paragraph?

5.2. Single vs. Multiple - Is the procedure reader using more than one procedure?

5.3. Graphically distinct - Is the step more conspicuous than other steps?

5.4. Placekeeping aids - Are placekeeping aids used by all crews.

6. Misinterpret Instruction 6.1. Standard Unambiguous wording- Does the step include unfamiliar nomenclature?

6.2. Training on Step - Has the crew received training on the correct interpretation of this step?

7. Error in interpreting Logic 7.1. NOT statement - Does the step contain the word "not?"

7.2. AND or OR statement - Does the step contain diagnostic logic where more than one condition is combined to determine the outcome?

ORed 7.3. Both AND and OR-Does the step contain a complex logic involving a combination of ANDed and terms?

7.4. Practiced Scenarios - Has the crew practiced this step in the simulator?

8. Deliberate Violation 8.1. Belief in Adequacy of Instruction-Does the crew have confidence in the effectiveness of the procedure for dealing with the current situation? If the crew does, then there is no reason for believeing the step would be deliberately violated.

8.2. Adverse Consequences if Comply - A crew must have a strong motivation for violating a procedure.

The approach is applied to major decision steps such as transfers to another procedure, or the decision to initiate some the process It is not applied to steps that are purely directions to perform a specific task; these are considered as part of execution.

(HEP)

Errors in execution are determined using the THERP tables The execution part of the human error probability to each Operator Action modeled in the Plant Response Trees.

is denoted as pe. It is estimated by applying THERP to identify the critical steps (i.e., those essential to completion The approach is essentially to review each procedure of the task(s)) and whether any potential recovery mechanisms (such as verification of flow or valve position, are present in alternative steps accomplishing the same action, revisitation of the step due to a procedure 'loop', etc.)

recovery mechanisms the procedure and would be read in accordance with the procedure usage guidelines. Such

NPM 2002-0267 Pae 3 account for the fact that failure to perform a procedure step may preclude success in a subsequent step, which results in a search for the cause of the previous failure. The methodology has 27 different tables, but we use four. Tables 7 and 8 list the values for errors of omission and should be of particular interest to the procedure writers. Table 7 is the estimated probabilities of errors of omission per item of instruction when use of written procedures is specified. The table is divided into procedures with and without check offs and with long or short lists. Using procedures with check off steps that have fewer than 10 items in a list has the best probability of success. Table 8 is less frequently needed'and is the estimated probabilities of errors in recalling oral instruction items not written down. Table 12 is the estimated probabilities of errors of commission in operating manual controls. Table 13 is the estimated probabilities for selection errors for locally operated valve. I've included both of these tables so that Operations and Training can be sensitive to those areas that have a higher potential for error.

NPM 2002-0267 Page 4 Appendix A Quantified and Documented Human Error Probabilities for Point Beach

1. AF--HEP-STARTXXX Brief Description - This HEP calculates the probability to fail to manually start an AFW pump after its associated auto-start fails Associated Basic Events - AF--HEP-START1TD, AF--HEP-START2TD, AF--HEP-START-MD, AF--HEP-START12T

2. AF--HEP-TDAFISOL Brief Description - This HEP calculates the probability to fail to isolate a faulted steam generator, which would allow the TDAFW pump to inject into the intact steam generator.

Associated Basic Event - AF--HEP-TDAFISOL

3. AF--HEP-RECIRCXX Brief Description - This HEP calculates the probability to manually control the AFW pump mini-flow valve with a loss of IA to the valve.

Associated Basic Events - AF-HEP-RECIRC-1, AF-HEP-RECIRC-2, AF--HEP-RECIRC-A, AF-HEP-RECIRC-B

4. AF--HEP-MDP-FLOW Brief Description - This HEP calculates the probability to manually control the MDAFW pump discharge flow control valve with a loss of IA to the valve.

Associated Basic Events - AF-HEP-MDP-FLOW

5. AF--HEP-CST-LOW Brief Description - This HEP calculates the probability to supply back-up to the AFW pumps on CST low level. This HEP is broken into multiple parts to take into account the various dependencies that may exist.

Associated Basic Events - AF-HEP-CST-LOW-, AF--HEP-CST-SWTD, AF--HEP-CST-SWMD, AF--HEP-CST-FW--, AF--HEP-CST-SW-

S 7 NPM 2002-0267 Page 5 HEPs in the Point Beach PRA Model PARM ID: 125-HEP--D04-D28 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-04 TO D-28 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 001 BY TUE JUN 12 17:45:44 2001 WHY: JPM PARM ID: 125-HEP--D04-D40 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-04 TO D-40 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 09:27:34 2001 WHY: CSG PARM ID: 125-HEP--D40-D28 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-40 TO D-28 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP--D49-D51 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-49 TO D-51 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP--D49-D52 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-49 TO D-52 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP--D49-D53 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-49 TO D-53 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP--D50-D51 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-50 TO D-51 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP--D50-D52 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-50 TO D-52 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP--D50-D53 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM D-50 TO D-53 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001

1 ?1 NPM 2002-0267 Page 6 PARM ID: 125-HEP-IB32D302 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS IB-32 TO D-302 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-IB49D301 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS IB-49 TO D-301 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-2B39D301 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS 2B-39 TO D-301 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-2B42D302 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS 2B-42 TO D-302 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-BSI-D302 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS B-81 TO D-302 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-D05--D01 DESCRIPTION: OPERATOR FAILS TO ALIGN BATTERY D-05 TO BUS D-01 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Thu Sep 20 13:27:04 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-D06--D02 DESCRIPTION: OPERATOR FAILS TO ALIGN BATTERY D-06 TO BUS D-02 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Thu Sep 20 13:27:15 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-DI05-D03 DESCRIPTION: OPERATOR FAILS TO ALIGN BATTERY D-105TO BUS D-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-DIOG-D04 DESCRIPTION: OPERATOR FAILS TO ALIGN BATTERY D-106TO BUS D-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 20:38:45 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-D14-D40 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS D-14 TO BUS D-40

NTPM 2002-0267 Page 7 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-D28-D40 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS D-28 TO BUS D-40 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-D305-DO1 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS D-305 TO BUS D-01 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Mon Jun 18 16:19:32 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-D305-D02 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS D-305 TO BUS D-02 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.OOOE-003 MODFD: Mon Jun 18 16:19:36 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-D305-D03 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS D-305 TO BUS D-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.OOOE-003 MODFD: Mon Jun 18 16:19:41 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-D305-D04 DESCRIPTION: OPERATOR FAILS TO ALIGN BUS D-305 TO BUS D-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Mon Jun 18 16:19:45 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 125-HEP-EOP10-08 DESCRIPTION: NO BATTERY CHARGER AFTER UV + POWER RECOVERY DISTRIBUTION: Lognormal Mean Failure Prob.: 4.200E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 138-HEP-H21-CLSE DESCRIPTION: FAILURE OF OPERATORTO CLOSE BKR H52-21ONTO BUS H-02 DISTRIBUTION: Lognormal Mean Failure Prob.: 5.500E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 138-HEP-H31-CLSE DESCRIPTION: FAILURE OF OPERATORTO CLOSE BKR H52-31ONTO BUS H-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 5.300E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 138-HEP-STARTGO5 DESCRIPTION: OPERATOR FAILS TO START GAS TURBINE G-05 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.300E-001 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001

I. I NPM 2002-0267 Page 8 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-IA032A03 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 1A-03 TO 2A-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-1A042A04 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM IA-04 TO 2A-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-1X041A03 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 1A-04 TO 2A-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-IX041A04 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 1X-04 TO IA-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-2A031A03 DESCRIPTION:.OPERATOR FAILS TO TRANSFER PWR FROM 2A-03 TO 1A-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.OOOE-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-2A041A04 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2A-04 TO 1A-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.OOOE-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-2X042A03 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2X-04 TO 2A-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-2X042A04 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2X-04 TO 2A-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.OOOE-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-GO1-1A05 DESCRIPTION: OPERATOR FAILS TO ALIGN G-01 TO lA-05UI ECA-0.0 STEP 9 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001

NPM 2002-0267 Page 9 PARM ID: 416-HEP-G02-1A05 DESCRIPTION: OPERATOR FAILS TO ALIGN G-02 TO 1A-05U1 ECA-0.0 STEP 10 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-G03-1A06 DESCRIPTION: OPERATOR FAILS TO ALIGN G-03 TO IA-06U1 ECA-0.0 STEP 12 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 416-HEP-G04-1A06 DESCRIPTION: OPERATOR FAILS TO ALIGN G-04 TO 1A-06U1 ECA-0.0 STEP 13 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-1A051B03 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM IA-05 TO 1B-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-1A061B04 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM IA-06 TO IB-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-IB031B04 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 1B-03 TO IB-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-1B041B03 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM IB-04 TO 1B-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2A012B01 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2A-01 TO 2B-01 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.OOOE-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2A022B02 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2A-02 TO 2B-02 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2A052B03 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2A-05 TO 2B-03

NPM 2002-0267 Page 10 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.OOOE-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2A062B04 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2A-06 TO 2B-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2B012B43 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2B-01 TO 2B-43 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2B022B43 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2B-02 TO 2B-43 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2B032B01 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2B-03 TO 2B-01 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2B032B04 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2B-03 TO 2B-04 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2B042B02 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2B-04 TO 2B-02 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: 480-HEP-2B042B03 DESCRIPTION: OPERATOR FAILS TO TRANSFER PWR FROM 2B-04 TO 2B-03 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-003 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-CST-FW-l DESCRIPTION: FIRE WATER TO CST DISTRIBUTION: Lognormal Mean Failure Prob.: 1.100E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:12 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-CST-LOW DESCRIPTION: FAILURE OF OPERATORTO RESPOND TO LOW CST LEVEL ALARM DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-004 MODFD: Fri Aug 17 16:23:55 2001 BY SUN JUN 10 11:31:12 2001

I NPM 2002-0267 Page 11 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-CST-SWMD DESCRIPTION: SERVICE WATER TO THE MOTOR-DRIVEN PUMP DISTRIBUTION: Lognormal Mean Failure Prob.: 1.500E-002 MODFD: Wed Jun 13 19:10:40 2001 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-CST-SWTD DESCRIPTION: SERVICE WATER TO THE TURBINE-DRIVEN PUMP DISTRIBUTION: Lognormal Mean Failure Prob.: 9.200E-003 MODFD: Wed Jun 13 19:10:40 20 01 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-MDP-FLOW DESCRIPTION: FAIL TO MANUALLY CONTROL MDAFW AFTER A LOSS OF IA DISTRIBUTION: Lognormal Mean Failure Prob.: 4.400E-002 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-MINI-GAG DESCRIPTION: FAILURE TO GAG MINI RECIRC VALVE >1HR INTO EVENT DISTRIBUTION: Lognormal Mean Failure Prob.: 3.400E-003 MODFD: Tue May 07 09:22:31 2002 BY JPM WHY:

PARM ID: AF--HEP-RECIRC-1 DESCRIPTION:.FAIL TO MANUALLY CONTROL RECIRC ON TDP IP-29 DISTRIBUTION: Lognormal Mean Failure Prob.: 2.500E-002 MODFD: Tue May 07 10:24:38 2002 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-RECIRC-2 DESCRIPTION: FAIL TO MANUALLY CONTROL RECIRC ON TDP 2P-29 DISTRIBUTION: Lognormal Mean Failure Prob.: 2.500E-002 MODFD: Tue May 07 10:24:42 2002 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-RECIRC-A DESCRIPTION: FAIL TO MANUALLY CC)NTROL RECIRC ON MDP P-38A DISTRIBUTION: Lognormal Mean Failure Prob.: 2.500E-002 MODFD: Tue May 07 10:24:46 2002 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-RECIRC-B P-38B DESCRIPTION: FAIL TO MANUALLY C()NTROL RECIRC ON MDP DISTRIBUTION: Lognormal Mean Failure Prob.: 2.500E-002 MODFD: Tue May 07 10:24:51 2002 BY JPM WHY: REV 5/7/2002 PARM ID: AF--HEP-RECIRC4F DESCRIPTION: MEX EVENT FAIL TO MANUALLY CONTROL 4 AFW PUMPS DISTRIBUTION: Lognormal Mean Failure Prob.: 5.060E-003 Median: 0.OOOE+000 Error Factor: 5.OOOE+000 MODFD: Tue May 07 09:21:53 2002 BY JPM WHY:

NPM 2002-0267 Page 12 PARM ID: AF--HEP-START-MD DESCRIPTION: FAIL TO MANUALLY START MDP AFTER AUTO FAILS DISTRIBUTION: Lognormal Mean Failure Prob.: 1.640E-003 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-START1TD DESCRIPTION: FAIL TO MANUALLY START TDP IP-29 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.640E-003 2001 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:13 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-START2TD DESCRIPTION: FAIL TO MANUALLY START TDP 2P-29 Mean Failure Prob.: 1.640E-003 DISTRIBUTION: Lognormal BY SUN JUN 10 11:31:13 2001 MODFD: Wed Jun 13 19:10:41 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: AF--HEP-TDAFISOL TDAFW PUMP FROM RUPTURED SG DESCRIPTION: FAILURE TO ISOLATE Mean Failure Prob.: 5.750E-003 DISTRIBUTION: Lognormal BY SUN JUN 10 11:31:13 2001 MODFD: Wed Jun 13 19:10:41 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP--SI--SD--DRN FROM SHUTDOWN OOS FOR FEED DESCRIPTION: FAIL TO RESTORE SI Mean Failure Prob.: 1.000E÷000 DISTRIBUTION: Lognormal BY SUN JUN 10 11:31:13 2001 MODFD: Wed Jun 13 19:10:41 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-120-INVBACKU 1ANUALLY ALIGN 1-43/Y-01 TO DY-OA DESCRIPTION: OPERATOR FAILS TO Mean Failure Prob.: 2.200E-002 DISTRIBUTION: Lognormal BY SUN JUN 10 11:31:13 2001 MODFD: Wed Jun 13 19:10:41 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-416-ECA00--5 START DG MANUALLY DESCRIPTION: OPERATOR FAILS TO Mean Failure Prob.: 1.800E-003 DISTRIBUTION: Lognormal BY SUN JUN 10 11:31:13 2001 MODFD: Wed Jun 13 19:10:41 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-480-AOP1OC-5 TO B08 PER AOP1OC-6 DESCRIPTION: FAIL TO WIRE IPIIA Mean Failure Prob.: 5.000E-001 DISTRIBUTION: Lognormal BY SUN JUN 10 11:31:13 2001 MODFD: Wed Jun 13 19:10:41 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-480-AOPIOC-6

6.1 DESCRIPTION

FAIL TO ALIGN TO B08 / B09 PER AOP 0.0 STEP Mean Failure Prob.: 1.000E-001 DISTRIBUTION: Lognormal 2001 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:13 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-CCI-AOP9B-73

NPM 2002-0267 Page 13 DESCRIPTION: OPERATOR FAILS TO ALIGN UNIT 2 CCW PUMPS TO UNIT DISTRIBUTION: Lognormal Mean Failure Prob.: 6.500E-002 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-CCW-AOP9B-74 DESCRIPTION: OPERATOR FAILS TO ISOLATE CCW RUPTURE DISTRIBUTION: Lognormal Mean Failure Prob.: 7.OOOE-002 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-CCW-EOP13-03 DESCRIPTION: OPERATOR FAILS TO START CCW PUMPS DISTRIBUTION: Lognormal Mean Failure Prob.: 1.200E-004 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:13 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-CCW-OI-71-42 DESCRIPTION: OPERATOR FAILS TO ALIGN STANDBY HEAT EXCHANGER DISTRIBUTION: Lognormal Mean Failure Prob.: 4.OOOE-002 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-CV--AOP6E-62 DESCRIPTION: OPERATOR FAILS TO EMERG BORATE FROM CHRG.

DISTRIBUTION: Lognormal Mean Failure Prob.: 4.100E-002 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-CV--ECA01-4B DESCRIPTION: OPERATPR FAILS TO START CHARGING PUMPS DISTRIBUTION: Lognormal Mean Failure Prob.: 2.300E-003 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-CV--EOP-0-49 DESCRIPTION: HEP - CHG PUMP OPER. FOR SEALING FLOW #NAME?

DISTRIBUTION: Lognormal Mean Failure Prob.: 4.100E-003 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-ECA-EOP31-32 DESCRIPTION: OPERATPR FAILS TO COOL DOWN AND DEPRESSURIZE DISTRIBUTION: Lognormal Mean Failure Prob.: 7.700E-003 MODFD: Wed Jun 13 19:10:41 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-ECAOO-U2-09 DESCRIPTION: OPERATOR FAILS TO ALIGN G-02 TO 2A-05U2 ECA-0.0 STEP 9 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-003 MODFD: Wed Feb 20 07:33:50 2002 BY JPM WHY:

PARM ID: HEP-ECAOO-U2-10 DESCRIPTION: OPERATOR FAILS TO ALIGN G-01 TO 2A-05U2 ECA-0.0 STEP 10 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-003

NTPM 2002-0267 Page 14 MODFD: Wed Feb 20 07:34:07 2002 BY JPM WHY:

PARM ID: HEP-ECA0O-U2-12 DESCRIPTION: OPERATOR FAILS TO ALIGN G-04 TO 2A-06U2 ECA-0.0 STEP 12 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-003 MODFD: Wed Feb 20 07:34:16 2002 BY JPM WHY:

PARM ID: HEP-ECA0O-U2-13 DESCRIPTION: OPERATOR FAILS TO ALIGN G-03 TO 2A-06U2 ECA-0.0 STEP 13 DISTRIBUTION: Lognormal Mean Failure Prob.: 3.900E-003 MODFD: Wed Feb 20 07:34:32 2002 BY JPM WHY:

PARM ID: HEP-ECC-ECAOO-21 DESCRIPTION: OPERATOR FAILS TO DEPRESSURIZE SGS TO 250 PSI DISTRIBUTION: Lognormal Mean Failure Prob.: 5.000E-001 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-ESF-EOP-0-04 DESCRIPTION: OPERATOR FAILS TO MANUALLY INITIATE SI DISTRIBUTION: Lognormal Mean Failure Prob.: 3.250E-003 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-FP--FUEL-OIL DESCRIPTION: OPERATOR FAILS TO SUPPLY FUEL OIL TO FIREPUMP DISTRIBUTION: Lognormal Mean Failure Prob.: 3.500E-002 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-HHR-EOP13-23 DESCRIPTION: OPERATOR FAILS TO ALIGN FOR HHR DISTRIBUTION: Lognormal Mean Failure Prob.: 1.250E-002 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-IA--AOP5B-74 DESCRIPTION: OPERATOR FAILS TO ISOLATE IA HEADER RUPTURE DISTRIBUTION: Lognormal Mean Failure Prob.: 2.000E-002 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-IA--FO-04748 DESCRIPTION: OPERATOR FAILS TO REOPEN 3047 OR 3048 DISTRIBUTION: Lognormal Mean Failure Prob.: 1.OOOE-003 MODFD: Thu Jun 14 10:18:03 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-IA--FO-START DESCRIPTION: OPERATOR FAILS TO RESTART IA OR SA DISTRIBUTION: Lognormal Mean Failure Prob.: 6.900E-004 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001

NPM 2002-0267 Page 15 PARM ID: HEP-IA--RE-01207 DESCRIPTION: OPERATOR FAILS TO RESTORE IA-1207 AFTER T/M DISTRIBUTION: Lognormal Mean Failure Prob.: 5.000E-003 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-IA--RE-01210 DESCRIPTION: OPERATOR FAILS TO RESTORE IA-1210 AFTER T/M DISTRIBUTION: Lognormal Mean Failure Prob.: 5.000E-003 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-MFW-CSPHl-06 DESCRIPTION: OPERATOR FAILS TO ALIGN MFW AFTER SI SIGNAL DISTRIBUTION: Lognormal Mean Failure Prob.: 5.000E-002 MODFD: Wed Jun 13 19:10:42 2001 BY SUN*JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-MFW-CSPH1-XX DESCRIPTION: OPERATOR FAILS TO OPEN MOV SW-2880 AFTER SI DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E-001 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-MFW-EOP01-06 DESCRIPTION: OPERATOR FAILS TO ALIGN MAIN FEED WATER TO SGS DISTRIBUTION: Lognormal Mean Failure Prob.: 2.300E-003 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-MS--EOP-3-02 DESCRIPTION: OPERATOR FAILS TO DIAGNOSE SGTR EVENT DISTRIBUTION: Lognormal Mean Failure Prob.: 4.750E-003 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:14 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-OCC-EOP01-04 DESCRIPTION: OPERATOR FAILS TO CONTROL CHARGING / LETDOWN DISTRIBUTION: Lognormal Mean Failure Prob.: 1.500E-002 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-ODA-EOP12-05 DESCRIPTION: FAILURE TO COOLDOWNAND DEPRESSURIZE AFTER SLOCA DISTRIBUTION: Lognormal Mean Failure Prob.: 2.700E-003 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-ODB-CSPCI-14 DESCRIPTION: OPERATOR FAILS TO DEPRESS. TO USE LPSI AFTER SLOCA DISTRIBUTION: Lognormal Mean Failure Prob.: 1.050E-002 MODFD. Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-ODC-EOP-3-21

NPM 2002-0267 Page 16 DESCRIPTION: OPERATOR FAILS TO DEPRESS. INTACT SG AFTER SGTR DISTRIBUTION: Lognormal Mean Failure Prob.: 2.000E-002 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-ODD-CSPCI-14 DESCRIPTION: OPERATOR FAILS TO DEPRESS. TO USE LPSI AFTER MLOCA DISTRIBUTION: Lognormal Mean Failure Prob.: 1.200E-002 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-RC--EOP-1-05 DESCRIPTION: FAILURE TO ISOLATE PORV WITH BLOCK VALVE DISTRIBUTION: Lognormal Mean Failure Prob.: 5.600E-003 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-RCS-CSPHl-12 DESCRIPTION: OPERATOR FAILS TO ESTABLISH FEED AND BLEED (NO SI)

DISTRIBUTION: Lognormal Mean Failure Prob.: 2.360E-002 MODFD: Wed Jun 13 19:10:42 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-RCS-CSPHl-13 DESCRIPTION: OPERATOR FAILS TO ESTABLISH FEED AND BLEED (WITH SI)

DISTRIBUTION: Lognormal Mean Failure Prob.: 2.050E-002 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-RHR-EOP13-23 DESCRIPTION: OPERATOR FAILS TO ALIGN FOR LHR DISTRIBUTION: Lognormal Mean Failure Prob.: 2.450E-002 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-RP--AOP9B-63 DESCRIPTION: OPERATOR FAILS TO MANUALLY TRIP RX (TCC/TSW)

DISTRIBUTION: Lognormal Mean Failure Prob.: 1.100E-004 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-RP--CSPS1-01 DESCRIPTION: FAILURE TO SCRAM RXVIA OPENING MG SET BKR DISTRIBUTION: Lognormal Mean Failure Prob.: 5.700E-003 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-RP--EOP-0-01 DESCRIPTION: OPERATOR FAILS TO MANUALLY TRIP REACTOR DISTRIBUTION: Lognormal Mean Failure Prob.: 8.300E-004 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-SI-ACC-AISOL DESCRIPTION: OPERATOR FAILS TO ISOLATE ACCUMULATOR DISTRIBUTION: Lognormal Mean Failure Prob.: 1.700E-001

NPM 2002-0267 Page 17 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-SW--AOP9A-63 DESCRIPTION: OPERATOR FAILS TO ISOLATE SW HEADER RUPTURE DISTRIBUTION: Lognormal Mean Failure Prob.: 5.200E-002 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-SW--EOP-0-9A DESCRIPTION: OPERATOR FAILS TO ISOLATE NON-ESSEN SW LOADS DISTRIBUTION: Lognormal Mean Failure Prob.: 1.800E-002 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:15 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: HEP-SWI-AOP9A-61 DESCRIPTION: OPERATOR FAILS TO START STANDBY SW PUMPS DISTRIBUTION: Lognormal Mean Failure Prob.: 2.370E-005 MODFD: Wed Jun 13 19:10:43 2001 BY SUN JUN 10 11:31:16 2001 WHY: SUN JUN 10 09:27:34 2001 PARM ID: OP--HEP--DGFOXFR DESCRIPTION: OPERATORS FAIL TO ALIGN VLVES FOR FUEL OIL X-TIES DISTRIBUTION: Lognormal Mean Failure Prob.: 1.000E+000 MODFD: Thu Jun 14 11:32:09 2001 BY JPM WHY:

"NpM2002-0267 Page 18 THERP Tables ATTACHED

T20-7 is one of the most frequently used tables. in theiHRA Handbook because so

-.many routine tasks.involve the use of writtedp.-ro'e~dures." If-the procedures are

-poorly written (which-isb 6ften the 'case'); and-especially if there-are-several atti6n iims per numbered step or paragraph7;'EOMs will, be Jrelatively'frequent.

KM must be evaluated separately, using-other tables.

In the table, "items of instruction" refers to statements that include .(usually) some type of information presented to an operator.-(the S in the S-O-R paxradigm, i.e., Box A in the basic human performance-model on p 1-21), some degree '(often minimal) of operator processing of the information (the 0 in S-O-R, or Box C in the figure on p 1-21), and some type of required response (The'R in S-O-R, or Box E in thi figure on p 1-21). The least error-likely instructions have only one S-O-R per numbered step.

- ... . 7*---------- ---. --- ... -------

7 ,Table .20-7 Estimated,, pro babi-tiesi.of*_j rrorýg6bission.-peritem of instruction.1when ;use Iof .writensipo.oedure tiss., specified,

(._from.Tabl&'15-3

Item2 Omission of item:. HEP EF rl When procedures with checkoff provisions are correctly used':

S(1) Short list, :<10 items .001 3 i j) - (2) Long list, >10 items .003 3

ýen rocedures without checkoff provisions are used, or when available checkoff vr rectl s .d ..

S(3) Short list, KI0 items /;, " .003 3 g-o3

.)

(4) Long list, >10 items 113.01 3 I.3E-0-.

When written procedures are available 7,.65 (5) and should be used but are not used' .5

§.o OŽ%

'The estimates for each-item (or perceptual unit) presume zero .dependence among the items (or units) and must be modified by using the dependence model when a non-zero level of dependence is assumed.

"The term "item" for this column is the usual designator for tabled entriles and does not refer to an item of instruction in a procedure.

3Correct use of checkoff provisions is assumed for items in which written entries such as numerical values are required of the user.

'Table 20-6 lists the estimated probabilities of incorrect use of checkoff provisions and of non-use of available written procedures.

'If the task is judged to be 'second nature" or "skill-of-the-craft," use the lower uncertainty bound for .05, i.e., use .01 (EF - 5).

The written instruction model in T20-7 makes an artificial division of procedures into short and long lists. Obviously, there is nothing magical ab6ut the 10 items that serve as the dividing line between a short and a long list. As more data are obtained, this model can be revised to allow more than two points -to represent

. the length of a list of items.

~-- - Z 0 0 Z

).

- (.co3-OI) 11-4

- I

- ( j.c...

J- - -- - ,.1***

I.-'

-- *-. - - *-. *-,...--.------ *'1

remembered increases. In the table, "detailec which each task or activity is mentioned by AF7757, AF7756, and AF7759." "General oral of detail,*e.g., "Open the blocking valv T 2cb-5 is the concept of a perceptual unit is importan oral instructions, the analyst may judge that

-THE__ I* *-TorZ W1-co the general oral instruction is equivalent important to note the last foo note in the t Table 20-8 Estimated probabilities ol on items not wri T~&14 f-A. 1 E-/

y fHEPs as A uction of number of Number of Oral Instruction Itr S r[F] to recall em "N." order I

i HTi -hcsee nL-_* T22r'tp r- is item 3 (a) (b) (c)

HEP - - - EF HEP -' - - E, HEP - - - EF Oral instructions are detailed:

(1) - - - 1' .001 - - 3 .001 3 .001 - - 3 (2) - - - 2 .003 - - 3 .004 3 .006 - - 3 e4 (3) - - - 3 .01 - - 3 .02 5 .03 - - 5 (4) - - - 4 .03 - - - 5 .04 5 .1 - - 5 (5) - - - 5 - 5 .2 5 .4 - - - 5 Oral instructions are general:

(6) - - - 1' .001 3 .001 3 .001 3 (7) 2 .006 3 .007 3 .01 3 (B) 3 .02 5 .03 5 .6 5 (9) -- 4 .06 5 .09 5 .2 5 (10) -- 5 .2 - 5 .3 5 .7 5

'It is assumed that if more than five oral instruction items or perceptual units are to be remembered, the recipient will write them down. If oral instructions are written down, use Table 20-5 for errors in preparation of written instructions and Table 20-7 for errors in their use.

'The first column of HEPs (a) is for individual oral instruction items, e.g., the second entry, .003 (item 2a), is the Pr[F] to recall the second of two items, given that one item was recalled, and order is not important. The HEPs is the other columns for two or more oral instruction items -are joint HEPs, e.g., the

.004 in the second column of HEPs is the PrfF] to recall both of two items to be remembered, when order is not important. The .006 in the third column of HEPs is the P4[F] to recall both of 'two items to be remembered in the order of performance specified. For all columns, the EFs are taken from Table 20-20, as explained in Ch 15.

'The term "item' for this column is the usual designator for tabled entries and does not refer to an oral instruction item.

"The Pr[F]s in rows I and 6 are the same as the Pr[F) to initiate the task.

)

11-6

V20-12 applies zo all kinds of manual controls, including switches in a control room that are used to govern the position 'of -otor-operated valves: (MOVs),.air-'

operated vaives (AOVs), and pneumatic-operatedv;'afv(es that are locat~d elsewhere in a plant. As stated in the discussion of'T20-9-(selection HEPs for displays),

it is speculative to predict which particular incorrect control will be selected, given that the correct one was not selected. For some operations, initial "incorrectmovement of a switch or other control is not important. The importance of this error is obviously situation-specific.

Item 1A was mistakenly left out of the HRA Handbook. Original 'item 8 in the HRA Handbook version of this table was cumbersome to apply, and in the present table, items BA-C replace it.- No changes were made to the HEPs or EFs.

X M Table 20-12 .Estimated procbabilities of Orrors of Commiaiis,

.in ,ocliqating Einal ntrols".Uram Table 13-3) - /

Item Potential Errvors __

(1) Inadvertent activation of a control - See tarn. Ch. 13 (lA)' Select wrong control whom it is dissimilar to adjacent controls Neiglile Select wrong control on a panel fro an array of similar-appearing controlz:'

(2) identified by labels only .003 3 (3) arranged in well-delineeted functioanal groups ( CoQ A. 3 . q3 -t.

(4) which are part of a well-defined mimic layout .0005 Turn multi-osaition rotary control in wrong direction 10 I (for rotary switches with only two positions. 5ee items BA-C):

(5) when there is no violation of populational stereotype .0005

-- S *05 (6) when design violates a strong populational stereotype

qd operating conditions are normal (7) when design violates a strong populational Stereotype .5

operation is under high stress Turn a two-poeition switch in wrong direction o1 leave it in the wrong setting':

(BA) when there is no violation of populational stereotype .0001

.01 (BB) when design violates a strong populational stereotype ajd operating conditions are normal D L (SC) when design violates a strong populational stereotype .1

&& operation is under high stress (9) Sat a culti-position rotary control to an incorrect setting .001 (for rotary switches with only two positions, see item aA-C)

.003 (10) Failure to complete change of state of a component U switch 3

=ust be'held until change is completed Select wrong circuit breaker in a group of circuit breakers':

(11) densely grouped and identified by labels only .005 3 35 (12) in which the PSF' are more favorable (see Ch. 13 in ERA Handbook) .003 3 3.*)- U-2 (13) Improperly mate a connector (this includes failures to beat connectors Completely ~O&~ 3 t4 failure to test locking features of connectors for proper engagemunt) 01P 1

'These E H do not include errors in deciding which controls to activate.

'Ite 1A is a new addition to this table; it in not in NWLE/CR-127B.

'If controls or circuit breakers are to be restored and tagged, adjust the tabled Es according to Table 20-15 .

"Items HA-C replace It=. 8 in this table in HURV;L/-1278; no change in EEs or Us.

"This 17 is a function of the clarity with 'ticb indicator position can be determined: designs of control knobs and their position indication. vary greatly. For plant-specitic analyses, an El of 3 may be used.

11-15

- - - -*t* *.. - .*--:

Veo.ve restoration errors occur frequently in all kinds of plants. T20-7 and T20-8 are used for estimating probabilities of EOMs. T20-13 below is used for selection errors, and T20-14, which follows, is used for other types of ECOMs.

. T20-13 lists some HEPs in increasing value according to soime important PSFs. Note that there is a factor of 10 difference between the smallest HEP and -the largest.

For any given application, choose the descriptive statement that most closely fits.

Table 20-13 Estimated HEPs for s-'er"ection- errors fqr_g 3 oca-a i-ted7 alve3s(from Table 14-1)

Item Potential Errors HEP EF Making an error of selection in changing or restoring a locally-operated valve when the valve to be manipulated is:

(1) Clearly and unambiguously labeled, set apart from valves .001 3 t.3E-Ca that are similar in AU of tbpollow* g: size and shap, state, and presence of tags -V%*)

(2) Clearly and unambiguously labeled, part of a group of .003 3 two or more valves that ard similar in o of the following: size and shape, state, or presence of tags (3) lUnclearly or ambiguously labeled, set apart from valves .005 3 that are similar in AU of the following: size and shape, state, and presence of tags S(4) Unclearly or ambiguously labeled, part of a group of .008 3 two or more valves that are similar in 9= of the following: size and shape, state, or presence of tags (5) Unclearly or ambiguously labeled, part of a group of .01 3 1.3&-0C-e two or more valves that are similar in aU2 of the following: size and shape, state, and presence of tags 1"Unless otherwise specified, Level 2 tagging is presumed. If other levels of tagging are assessed, adjust the tabled HEPs according to Table 20-15.

4i&t 4QQ

)

11-20

Table No .m Text I Mean I EF IMedian Notes Noe 20-7 Estimated probabilities of errors of omission per item of instruction when use of written procedure is specified 1 (from Table 15-3) 1 Omission of item when procedures with checkoff provisions are correctly used. 1.3E-3 3 0.0010 2,5 Short list, <= 10 items.

2 Omission of item when procedures with checkoff provisions are correctly used. 3.8E-3 3 0 0030 2,5 Long list, > 10 items.

3 Omission of item when procedures without checkoff provisions are used, or when 3.8E-3 3 0.0030 3,5 available checkoff provisions are incorrectly used. Short list, <= 10 items.

4 Omission of item when procedures without checkoff provisions are used, or when 1.3E-2 3 0.0100 3,5 available checkoff provisions are incorrectly used. Long list, > 10 items.

5 Omission of item when written procedures are available and should be used but 8.OE-2 5 0.0500 3,4,5 are not used.

20-8 Estimated probabilities of errors of omission - Added for Wisconsin Electric la 1.3E-3 2a 3.8E-3 2b 5.OE-3 2c 7.5E-3 3b 3.2E-2 4 1.3E-3 20-9 Estimated probabilities of errors In selecting unannunclated displays (or annunciated displays no longer annunciating) for quantitative or qualitative readings (from Table 11-21 1 Selection of wrong display when it is dissimilar to adjacent displays. neg. neg. neg. 6,7 2 Selection of wrong display from similar-appearing displays when they are on a 1.4E-3 10 0.0005 6 panel with clearly drawn mimic lines that include the displays.

3 Selection of wrong display from similar-appearing displays that are part of well- 1.3E-3 3 0.0010 6 delineated functional groups on a panel.

Page 1

Table No r r

,mi Text THFR 1 P1 P' Mean EF Median Notes 4 Selection of wrong display from an array of similar-appearing displays identified by 3.8E-3 3 0.0030 6 labels only.

20-10 Estimated HEPs for errors of commission in reading and recording quantitative Information from unannunciated displays (from Table 11-3) 1 Display or task - Analog meter 3.8E-3 3 0.0030 8 2 Display or task - Digital readout (<=4 digits) 1.3E-3 3 0.0010 8 3 Display or task - Chart recorder 7.5E-3 3 0.0060 8 4 Display or task - Printing'recorder with large number of parameters 8.OE-2 5 0.0500 8 5 Display or task - Graphs 1.3E-2 3 0.0100 8 6 Display or task - Values from Indicator lamps that are used as quantitative 1.3E-3 3 0.0010 8 displays 7 Display or task - Recognize that an instrument being read is jammed, if there are 1.6E-1 5 0.1000 8 no indicators to alert the user 8 Display or task - Recording task: Number of digits or letters to be recorded <=3 neg. neg. neg. 8,9 9 Display or task - Recording task: Number of digits or letters to be recorded >3 1.3E-3 3 0.001/ 8,9 symbol 10 Display or task - Simple arithmetic calculations with or without the use of a 1.3E-2 3 0.0100 8 calculator 11 Display or task - Detect out-of-range arithmetic calculations 8.OE-2 5 0.0500 8 09/18/2002 Page 2

Table No jm Text THEr ý.RI PR Mean EF Median Notes 20-11 Estimated HEPs for errors of commission in check-reading displays (from Table 11-4) 10 1 Display or task: Digital indicators (these must be read - there is no true check- 1.3E-3 3 0.0010 reading function for digital display) 09/18/2002 Page 3

Table No. .im Text TW=P- .L: ( Mean EF I Median Notes 2 Display or task: Analog meters with easily seen limit marks 1.3E-3 3 0.0010 3 Display or task: Analog meters with difficult-to-see limit marks, e.g., scribe lines 2.5E-3 3 0.0020 4 Display or task: Analog meters without limit marks 3.8E-3 3 0.0030 5 Display or task: Analog-type chart recorders with limit marks 2.5E-3 3 0.0020 6 Display or task: Analog-type chart recorders without limit marks 7.5E-3 3 0.0060 7 Display or task: Confirming a status change on a status lamp neg. neg. neg. 11,12 8 Display or task: Misinterpreting the indication on the indicator lamp neg. neg. neg. 12 20-12 Estimated probabilities of errors of commission In operating manual 13 controls (from Table 13-3) 1 Inadvertent activation of a control 1.3E-3 for Ch. 13 See Text la Select wrong control when it is dissimilar to adjacent controls 0.OE+0 neg neg. 14 neg.

2 Select wrong control on a panel from an array of similar-appearing controls 3.8E-3 3 0.0030 15 identified by labels only Select wrong control on a panel from an array of similar-appearing controls 1.3E-3 3 0.0010 15 arranged in well-delineated functional groups 09/18/2002 Page 4

Table No. .m Text THEPr. .pI F:_ Mean EF Median Notes 4 Select wrong control on a panel from an array of similar-appearing controls which 1.4E-3 10 0.0005 15 are part of a well-defined mimic layout 5 Turn multi-position rotary control in wrong direction when there is no violation of 1.4E-3 10 0.0005 populational stereotype (for rotary switches with only two positions, see items 8A 8C) 6 Turn multi-position rotary control in wrong direction when design violates a strong 8.OE-2 5 0.0500 populational stereotype and operating conditions are normal (for rotary switches with only two positions, see items 8A-8C) 7 Turn multi-position rotary control in wrong direction when design violates a strong 8.OE-1 5 0.5000 populational stereotype and operation is under high stress (for rotary switches with only two positions, see items 8A-8C) 8a Turn a two-position switch in wrong direction or leave It in the wrong setting when 2.7E-4 10 0.0001 16 Ithere is no violation of populational stereotype 8b Turn a two-position switch in wrong direction or leave it in the wrong setting when 1.6E-2 5 0.0100 16 design violates a strong populational stereotype and operating conditions are normal 8c Turn a two-position switch in wrong direction or leave It in the wrong setting when 1.6E-1 5 0.1000 16 design violates a strong populational stereotype and operation Is under high stress 9 Set a multi-position rotary control to an incorrect setting (for rotary switches with 2.7E-3 10 0.0010 17 only two positions, see items 8A-C) 10 Failure to complete change of state of a component if switch must be held until 3.8E-3 3 0 0030 change is completed 11 Select wrong circuit breaker in a group of circuit breakers densely grouped and 6.3E-3 3 0.0050 15 identified by labels only 12 Select wrong circuit breaker in a group of circuit breakers in which the PSFs are 3.8E-3 3 0.0030 15 more favorable (see Ch. 13 in HRA Handbook) 13 Improperly mate a connector (this includes failures to seat connectors completely 1.3E-2 3 0.0100 and failure to test locking features of connectors for proper engagement) 20-13 Estimated HEPs for selection errors for locally-operated valves (from Table 14-1) 18 1 Making an error of selection in changing or restoring a locally-operated valve 1.3E-3 3 0.0010 when the valve to be manipulated is clearly and unambiguously labeled, set apart from valves that are similar in all of the following; size, shape, state, and presence of tags.

09/18/2002 Page 5

rw L 0 ;w Text Text TWDI. API F Mean EF Median Notes 2 Making an error of selection in changing or restoring a locally-operated valve 3.8E-3 3 0.0030 when the valve to be manipulated is clearly and unambiguously labeled, part of a group of two or more valves that are similar in one of the following: size and shape, state, or presence of tags.

3 Making an error of selection in changing or restoring a locally-operated valve 6.3E-3 3 0.0050 when the valve to be manipulated is unclearly or ambiguously labeled, set apart from valves that are similar in all of the following; size, shape, state, and presence of tags.

4 Making an error of selection in changing or restoring a locally-operated valve 1.OE-2 3 0.0080 when the valve to be manipulated is unclearly or ambiguously labeled, part of a group of two or more valves that are similar in one of the following: size and shape, state, or presence of tags.

5 Making an error of selection in changing or restoring a locally-operated valve 1.3E-2 3 00100 when the valve to be manipulated is unclearly or ambiguously labeled, part of a group of two or more valves that are similar in all of the following: size and shape, state, and presence of tags.

20-16 Modifications of estimated HEPs for the effects of stress and experience levels (from Table 18-1)

Modifiers for Nominal HEPs 19 Stress Level (Task Load) Skilled (a) Novice (b) 20 1 Very low stress (very low task load) 2 2

_______ 2 Optimum stress (optimum task load): Step-by-step 1 ___ 1 21 3 Optimum stress (optimum task load): Dynamic 1 2 21 4 Moderately high stress (heavy task load): Step-by-step 2 4 21 5 Moderately high stress (heavy task load): Dynamic 5 10 21 6 Extremely high stress (threat stress): Step-by-step 5 10 21 7 Extremely high stress (threat stress): Dynamic or diagnosis 0.25 5 0.50 21,22 Note for item 7: These are actual HEPs to use with dynamic tasks or diagnosis; they are NOT modifiers.

20-17 Equations for conditional probabilities of success and failure on Task "N", given success or failure on previous Task "N-1", for different levels of dependence (from Table 10-2)

Failure Equations:

Level of Dependence: ZD Pr[F.N.IF"N.¶.IZD] = N Eqn #: (10-14)

Level of Dependence: LD Pr[F-N.IF.N.1.ILD] = (1 + 19N)/20 Eqn #: (10-15)

Level of Dependence- MD Pr[F-N-IF-N."I-MD] = (1 + 6N)/7 Eqn ft: (10-16) 09/18/2002 Page 6

Table No -1

m Text Mean FF M*_dimn Nnf*,*

Level of Dependence: HD Pr[F.N-IF.N.l.IHD] = (1 + N)/2 Eqn #: (10-17)

Level of Dependence: CD Pr[F-N.IF-N.rl.CD] = 1.0 Eqn #: (10-18) 20-20 General guidelines for estimating uncertainty bounds for estimated HEPs (from Table 7-2) 23 Task consists of performance of step-by-step procedure conducted under routine 24,26 circumstances (e g., a test, maintenance, or calibration task); stress level is optimal:

SI Estimated HEP < 0.001 10 25 2 Estimated HEP 0.001 to 0.01 3 25 3 Estimated HEP > 0.01 5 25 Task consists of performance of step-by-step procedure but carried out In 24,26 nonroutine circumstances such as those involving a potential turbine/reactor trip; stress level is moderately high:

4 Estimated HEP < 0.001 10 25 5 Estimated HEP > 0.001 5 25 Task consists of relatively dynamic interplay between operator and system 24,26 indications, under routine conditions, e.g., increasing or reducing power; stress level is optimal 6 Estimated HEP < 0.001 10 25 7 Estimated HEP > 0.001 5 25 8 Task consists of relatively dynamic interplay between operator and system 10 24,25,26 indications, but carried out in nonroutine circumstances; stress level is moderately high 9 Any task performed under extremely high stress conditions, e.g., large LOCA; 5 24,25,27 conditions with status of ESFs not perfectly clear; or conditions where initial operator responses proven inadquate so severe time pressure felt (see Ch 7 for EF=5 rationale).

20-22 Estimated probabilities that a checker will fall to detect errors made by others (from Table 19-11) 28 1 Checking routine tasks, checker using written materials (includes over-the- 1.6E-1 5 0.1000 shoulder inspections, verifying position of locally-operated valves, switches, circuit breakers, connectors, etc, and checking written lists, tags, or procedures for accuracy) 2 Same as above, but without written materials 3.2E-1 5 0.2000

-3 Special short-term, one-of-a-kind checking with alerting factors 8.OE-2 5 0.0500 4 Checking that involves active participation, such as making special 1.6E-2 5 0.0100 measurements 09/18/2002 Page 7

Table No. .mT Text TH49=PF- . ALRI 9=_Q Mean EF Median Notes Given that the position of a locally-operated valve is checked (item 1 or 2 above),

noticing that it is not completely opened or closed (for "hands-on verification" of valve position, use lower bounds for the percentage of people estimated to carry out this administrative control procedure):

5 Position indicator only 1.6E-1 5 0.1000 29 6 Rising stem with or without a position indicator 8.OE-1 5 0.5000 29,30 7 Neither of position indicator nor a rising stem 1.OE+0 5 0.9000 29 8 Checking by reader/checker of the task performer in a two-person team, or 8.0E-1 5 0.5000 checking by a second checker, routine task (no credit for more than 2 checkers)

Checking the status of equipment if that status affects ones safety when 1.6E-3 5 0.0010

_performing the checking task I 1__

20-23 The Annunciator Response Model: estimated HEPs for multiple annunciators alarming closely in time (from 31, 32 Table 11-13)

Number Pr[F1] for each annunciator (ANN) for completely dependent set of ANNs, successively addressed by the operator ANNs 1 2 3 4 5 6 7 8 9 10 Pr[Fa 33 (a) (b) (c) (d) (e) (f) (g) (h) (I) (1) (k) 1 1 .0001 1.OE-4 2 2 .0001 .001 6.OE-4 3 3 .0001 .001 .002 1.OE-3 4 4 .0001 .001 .002 .004 2.OE-3 5 5 .0001 .001 .002 .004 .008 3.OE-3 6 6 .0001 .001 .002 .004 .008 .016 5.OE-3 7 7 .0001 .001 .002 .004 .008 .016 .032 9.OE-3 8 8 .0001 .001 .002 .004 .008 .016 .032 .064 2.OE-2 9 9 .0001 .001 .002 .004 .008 .016 .032 .064 .13 3.OE-2 10 10 .0001 .001 .002 .004 .008 .016 .032 .064 .13 .25 5.OE-2 11 11-15 Pr[F] for each additional ANN beyond 10 = 0.25 1.OE-1 "12 16-20 Pr[Fj] for each additional ANN beyond 10 = 0.25 1.5E-1 13 21-40 Pr[Fd for each additional ANN beyond 10 = 0.25 2.OE-1 14 >40 Pr[Fi for each additional ANN beyond 10 = 0 25 2.5E-1 09/18/2002 Page 8

I

.. ote No. IABLER Note MERE 1 The estimates for each item (or perceptual unit) presume zero dependence among the items (or units) and must be modified by using the dependence model when a non-zero level of dependence is assumed.

2 Correct use of checkoff provisions is assumed for items in which written entries such as numerical values are required of the user.

3 Table 20-6 lists the estimated probabilities of incorrect use of checkoff provisions and of non-use of available written procedures.

4 If the task is judged to be "second nature" or "skill-of-the-craft," use the lower uncertainty bound for 0.05, i.e., use 0.01 (EF=5).

5 Divide by 3 based on Swan's (pg. 15-3 to 15-15) adjustments to HEPs at nuclear power plants with response/non-response procedure type.

6 The listed HEPs are independent of recovery factors. In some cases, the content of the quantitative or qualitative indication from an Incorrect display may provide immediate feedback of the selection error and the total error can be assessed as neg.

7 This assumes the operator knows the characteristics of the display for which he or she is searching.

8 Multiply HEPs by 10 for reading quantitative values under a high level of stress if the design violates a strong populational stereotype, e.g., a horizontal analog meter in which values increase from right to left, or in which the scale is non linear.

9 In this case, "letters" refer to those that convey no meaning. Groups of letters such as MOV (Motor-Operated Valve) do convey meaning to NPP operators, and the recording HEP is considered to be negligible.

10 "Check-reading" means reference to a display merely to see if the indication is within allowable limits, no quantitative reading is taken. The check-reading may be done from memory or a written checklist may be used.

09/18/2002 Page 9

.ote No. I Note TI-I I:: 1:71 A.RI~ I=Q*

at No I.INoeIW~

L---:I -* :--

The HEPs apply to displays that are checked Individually for some specific purpose, such as a scheduled requirement, or in response to some developing situation involving that display.

11 If the operator must hold a switch in a spring-loaded position until a status lamp lights, use HEP - .003 (EF=3), from Table 20-12, item 10.

12 For levels of stress higher than optimal, use 0.001 (EF=3).

13 These ECOM HEPs do not include errors in deciding which controls to activate.

14 Item IA is a new addition to this table; it is not in NUREG/CR-1 278.

15 If controls or circuit breakers are to be restored and tagged, adjust the tabled HEPs according to Table 20-15.

16 Items 8A-C replace item 8 in this table in NUREG/CR-1278; no change In HEPs or EFs.

17 This EF is a function of the clarity with which indicator position can be determined; designs of control knobs and their position indications vary greatly. For plant-specific analyses, an EF of 3 may be used.

18 Unless otherwise specified, Level 2 tagging is presumed. If other levels of tagging are assessed, adjust the tabled HEPs according to Table 20-15.

19 The nominal HEPs are those in the data tables in Part III and in Ch. 20 of the HRA Handbook. Error factors (EFs) are listed in Table 20-20.

20 A skilled person in one with at least 6 months' experience in the tasks being assessed. A novice is one with less than 6 months' experience. In NPPs both levels have the required licensing or certificates.

21 Step-by-step tasks are routine, procedurally guided tasks, such as carrying out written calibration procedures. Dynamic tasks require a higher degree of man machine interaction, such as decision-making, keeping track of several functions, controlling several functions, or any combination of these. These requirements are the basis of the distinction between step-by-step and dynamic tasks, which are often involved in responding to an abnormal event.

09/18/2002 Page 10

.nte_ Nn. ] Note Til=Dr. ' AQI I:Q t*i No I Not. _-=_ =. === =

22 Diagnosis may be carried out under varying degrees of stress, ranging from optimum to extremely high (threat stress). For threat stress, the HEP of 0.25 is used to estimate ones performance. Ordinarily, more than one person will be involved.in such tasks. Tables 20-1 and 20-3 list joint HEPs based on the number of control room personnel presumed to be involved in the initial diagnosis of an abnormal event. For subsequent diagnosis tasks, use the dependence models.

09/18/2002 Page 11

.1

.,ote No. I Note THER1= - ABI ES 23 The estimates in this table apply to experienced personnel. The performance of novices is discussed in Chapter 18. See Appendix A to calculate the UCBs for Pr[FT], the total-failure term of an HRA event tree.

24 For UCBs for HEPs based on the dependence model, see Table 20-21.

25 The highest upper bound is 1.0.

26 See Table 20-16 for definitions of step-by-step and dynamic procedures.

27 An error factor (EF) of 5 is assigned for the extremely high stress conditions because the upper uncertainty bound is truncated at 1.0, and it is considered desirable to have a more conservative (i.e., higher) lower UCB for such tasks.

28 This table applies to cases during normal operating conditions in which a person is directed to check the work performed by others either as the work Is being performed or after its completion.

29 A position indicator incorporates a scale that indicates the position of the valve relative to a fully opened or fully closed position. A rising stem qualifies as a position indicator if there is a scale associated with it.

30 This change is based on the conservative assumption that the checker will just look at the rising stem even when there Is a position Indicator.

31 The HEPs are for the failure to initiate some kind of intended corrective action as required. The action carried out may be correct or incorrect and is analyzed using other tables. The HEPs already include the effects of stress and should not be increased in consideration of stress effects.

An EF of 10 is assigned to each Pr[Fj] or the mean of Pr[F1 ] in column k.

Based on computer simulation, use of an EF of 10 for the mean yields approximately correct upper bounds for the 95th percentile. The corresponding lower bounds are too high; they are roughly equivalent to 20th percentile rather than the usual 5th-percentile bounds on a log-normal distribution. Thus, use of an EF of 10 for the mean Pr[F1 ] values provides a conservative estimate since the lower bounds are high.

09/18/2002 Page 12

.4ote No. I Note TWCOIL AMI:1 C--C 32aote No. I"Closely in time" refers to cases in which two or more annunciators alarm Note III.

TLZIDL AI within several seconds or with a time period such that the operator perceives them as a group of signals to which he must selectively respond.

33 The values in column k represent the expected Pr[F]s to Initiate action in response to a randomly selected ANN (or completely dependent set of ANNs) in a group of ANNs competing for the operator's attention. It is the arithmetic mean of the Pr[FF]s in a row, with an upper limit of 0.25. The mean Pr[Fj values assume that all of the ANNs (or completely dependent sets of ANNs) are equal in terms of the probability of being noticed. See page 11-52, paragraph 2, in the HRA Handbook ifthis assumption does not hold.

09/18/2002 Page 13

Page 1 of 3

' Nuclear Management Company STATE CHANGE HISTORY Quality Check Assign Initiate Work Assign Conduct Work L Review & Approved 6/29/2002 2/512002 3 39:44 2/6/2002 1:36 53 PM Work Complete Approval 6/27/2002 6 41:33 AM r-* 2.55:16 PM Owner PM by TERRY Owner DUANE by DUANE by Owner by TOM Owner TERRY PBNP SCHOON SCHOON RICHARD SHELEY VANDENBOSCH VANDENBOSCH CAP DUANE FLESSNER SCHOON j7 Admin Review &

SL Approval Complete Done L Conduct Work Work Complete 9/16/2002 Update Assign Work Assign and Close 7/3/2002 9/5/2002 7.08 42 9/5/2002 4.15"48 12 44:37 3.32:21 AM PM PM PM Owner DUANE Owner TERRY by TERRY Owner Owner by JULIE by TOM SHELEY VANDENBOSCH VANDENBOSCH DUANE by JULIE SCHOON (None) KREIL SCHOON KREIL Quality Check Approved 9/17/2002 10.53:24 AM Owner PBNP by DUANE SCHOON CAP Adi SECTION 1 Activity Request Id: CA003698 Corrective Action Submit Date: 2/5/2002 3:39:44 PM Activity Type:

Site/Unit: Point Beach - Common Activity Requested: Revise OM 4.3.1, AOP and EOP Writers' Guide, to incorporate human error reduction methods used in the PRA model that can significantly reduce CDF nsk.

SEE UPDATE TPS N Initiator: FLESSNER, SCATPR: RICHARD f PO PB Operations EX Engineering Responsible Group Code:

Initiator Department: PBZ Processes PB DUANE SCHOON Activity Supervisor:

Responsible Department: Plant Activity Performer: TERRY VANDENBOSCH SECTION 2 Due Date: 10/4/2002 Priority: 3 Y

Management Exception From Pl?:

Mode Change Restraint: (None) https://nmc.ttrackonline.comltmtrack/tmtrack.dll ?IssuePage&Tableld= 1000&Recordld= 11 (... 9/18/2002

Nuclear Management Company Page 2 of 3 Q QA/Nuclear Oversight?: N " Licensing Review?: N NRC Commitment?: N " NRC Commitment Date:

SECTION 3 Activity Completed: 1/18/2002 12:52PM - LARRY PETERSON Due date extended as requested and approved by F. Cayia in prior update. Retruned to R.

flessner for completion.

1/18/2002 12:54PM - LARRY PETERSON:

Reassigned to R. Flessner for completion following extension.

2122/2002 12:15PM - MARK RINZEL:

This item has been exempted from performance indicators by the Plant Manager via e-mail dated 2/21/2002. The item has been updated in section two to reflect this exemption 6/27/2002 6:41:33 AM - TERRY VANDENBOSCH:

OM 4.3.1 revision 4 was revised and issued on 6/6/02 incorporating the guidance for PRA.

6/29/2002 2.55:16 PM - DUANE SCHOON:

Closed.

7/3/2002 3:32:21 PM - JULIE KREIL:

OM 4.3.1 Rev 4 was issued 62/6/02. CA003697 is assigned to PO group to review/revise EOPs and AOPs. CLOSED CA003698.

9/5/2002 7:08:42 AM - JULIE KREIL:

This item is being re-opened per discussion of R. Flessner and T. Vandenbosch.

Determination is that the OM issuance of 6/6/02 did not fully include human error reduction methods used in the PRA model that can significantly reduce CDF risk.

9/16/2002 12:44:37 PM - TERRY VANDENBOSCH:

Revision 5 to OM 4.3.1 was issued on 9/16/02 which included discussion step 2.6 and attachment I, PRA CONSIDERATIONS, which discusses guidelines or techniques that are known to increase the chance of success in performing a procedure.

This item can be closed.

9117/2002 10:53.24 AM - DUANE SCHOON:

Closed.

SECTION 4 QA Supervisor: (None) Licensing Supervisor: (None)

SECTION 5 SProject: CAP Activities & Actions SState: Quality Check SActive/Inactive: Active AR Type: Daughter 0 Owner: PBNP CAP Admin Assigned Date: 9/5/2002 0 Submitter: RICHARD FLESSNER 0 Last Modified Date: 9/17/2002 10.53.24 AM 0 Last Modifier: DUANE SCHOON DUANE SCHOON 0 Last State Change Date: 9/17/2002 10:53:24 AM 0 Last State Changer:

https://nmc.ttrackonline.com/tmtrack/tmtrack.dll?IssuePage&TableId= 1000&Recordld= I I ...9/18/2002

Nuclear Management Company Page 3 of 3 0 Close Date:

4) One Line

Description:

Probabilistic Risk Assessment PRA For Auxiliary Feedwater System AFW NUTRK ID: CR 01-3595 Child Number: 1

References:

CR 01-2278 RCE 01-069 GOOD CATCH OM 4.3 1 Update: Action out a ACE that is being classified as a ROOT CAUSE. Due dates and prionty set out ACE 314. Contact the author of ACE 314 for any clarification. TPS ACTIVITY COMPLETED is old information from the ACE that was cloned into this action by responsible ACE individual -- Disregard.

Import Memo Field:

CAP Admin: PBNP CAP Admin Site: Point Beach OLDACTIONNUM:

Cartridge and Frame:

NOTES/COMMENTS Management exception from performance indicators by DENNIS HETTICK (2/28/2002 8:06:43 AM) approved by the plant manager. email is attached ATTACHMENTS AND PARENT/CHILD LINKS

&'/* 0 ACE000314: Probabilistic Risk Assessment PRA For Auxiliary Feedwater System AFW 0' WE CAP001415" Probabilistic Risk Assessment PRA For Auxiliary Feedwater System AFW FW Request for Performance Indicator Exception for tTRACK actions.rtf (6255 bytes) https://nmc.ttrackonline.comltmtrack/tmtrack.dll?IssuePage&Tableld=1000&Recordld=l R... 9/18/2002

OM 4.3.1 AOP AND EOP WRITERS' GUIDE DOCUMENT TYPE: Administrative REVISION: 5 EFFECTIVE DATE: September 16, 2002 APPROVAL AUTHORITY: Department Manager PROCEDURE OWNER (title): Group Head OWNER GROUP: Operations

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE TABLE OF CONTENTS SECTION TITLE PAGE 1.0 PURPOSE ...................................................................................................................... 4 2.0 DISCUSSION ........................................................................................................ 4 3.0 RESPONSIBILITIES ................................................................................................ 5 4.0 CONTENT OF M AJOR SECTION S ........................................................................ 6 4.1 Em ergency Operating Procedure Identification ......................................................... 6 4.2 Revision Identification .............................................................................................. 7 4.3 Page Identification and Numbering ............................................................................ 7 4.4 Cover Page ............................................................................................................ 7 4.5 Procedure Section ....................................................................................................... 8 4.6 A ttachm ents .................................................................................................................... 8 4.7 Foldout Pages ........................................................................................................ 9 4.8 Status Trees ................................................................................................................... 10 5.0 FORMAT AND STYLE REQUIREMENTS ........................................................... 10 5.1 Step Length and Content ............................................................................................ 10 5.2 D ual Column Form at ................................................................................................. 12 5.3 Use of Logic Term s ................................................................................................... 13 5.4 U se of Cautions and Notes ....................................................................................... 16 5.5 Calculations ................................................................................................................... 18 5.6 Use of Underlining ................................................................................................... 18 5.7 Transitions to Other Procedures or Steps .................................................................. 18 5.8 Branching to Other Docum ents ................................................................................ 19 5.9 Referencing ................................................................................................................... 20 5.10 Com ponent Identification .......................................................................................... 21 5.11 Standard Steps, Cautions, and Notes ......................................................................... 22 5.12 Level of D etail .......................................................................................................... 23 5.13 High Level Steps ....................................................................................................... 24 5.14 Substeps ......................................................................................................................... 25 Page 2 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE TABLE OF CONTENTS SECTION TITLE PAGE 6.0 MECHANICS OF STYLE ....................................................................................... 26 6.1 Spelling .......................................................................................................................... 26 6.2 Punctuation .................................................................................................................... 26 6.3 C apitalization ................................................................................................................ 28 6.4 Vocabulary .................................................................................................................... 28 6.5 Numerical Values ..................................................................................................... 30 6.6 Abbreviations, Letter Symbols and Acronyms ........................................................ 31 6.7 E nd ................................................................................................................................ 31 6.8 Normal and Adverse Containment Setpoints ........................................................... 32 6.9 Supporting Documentation ....................................................................................... 32 6.10 Use of Oversized Pages ........................................................................................... 36 6.11 Use of Reduced Pages .............................................................................................. 36 6.12 R eproduction ................................................................................................................. 36

7.0 REFERENCES

......................................................................................................... 37 8.0 B A SE S .......................................................................................................................... 37 ATTACHMENT A, DEFINITIONS OF KEY WORDS AND PHRASES ...................................... 38 ATTACHMENT B, ABBREVIATIONS, ACRONYMS, AND SYMBOLS ................................. 41 ATTACHMENT C, SYMPTOM OR ENTRY CONDITION EXAMPLES ................................... 42 ATTACHMENT D, EXAMPLES OF STEP CONSTRUCTION, DUAL COLUMN PROCEDURES ................................................................................................ 43 ATTACHMENT E, STATUS TREE PRIORITY IDENTIFICATION SYMBOLS ........................ 47 ATTACHMENT F, SAMPLE FORMAT ....................................................................................... 48 ATTACHMENT G, SINGLE COLUMN AOP FORMAT ............................................................. 49 ATTACHMENT H, PRA CORE DAMAGE RISK MATRIX ......................................................... 75 ATTACHMENT I, PRA CONSIDERATIONS ............................................................. 76 Page 3 of 77 INFORMATION USE

V POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 1.0 PURPOSE 1.1 This procedure establishes the administrative and technical guidance used in the development and maintenance of Abnormal Operating Procedures (AOPs) and Emergency Operating Procedures (EOPs).

1.2 This procedure is used to develop the EOP set that is derived from the Westinghouse Owner's Group Emergency Response Guideline Program.

1.3 The requirements of this procedure shall be implemented as follows:

1.3.1 New procedures initiated on, or after, the effective date of this procedure shall comply with these requirements. New procedures that have NOT completed technical review on, or before, the effective date of this procedure shall comply with these requirements.

1.3.2 Total rewrite revisions initiated on, or after, the effective date of this procedure shall comply with these requirements. Total rewrite revisions that have NOT completed technical review before the effective date of this procedure shall comply with these requirements.

1.3.3 Existing procedures in effect on the effective date of this procedure are exempt from these requirements until a total rewrite revision is initiated.

1.3.4 Exceptions to the format and content requirements of this document shall be approved in writing by the Operations Manager.

2.0 DISCUSSION 2.1 The following guidance is to be applied consistently for the emergency operating procedure set. The emergency operating procedure set includes those procedures identified with the designators EOP, ECA, CSP, and SEP.

2.2 Point Beach Nuclear Plant Procedures Writers' Guide should be followed whenever possible to provide plant consistency for procedures, however, explicit exceptions will be listed in this document. Differences are generally caused by the special application of the procedures requiring quick responses. Other differences are due to differences in word processing software.

2.3 Some AOPs will be written in a Single Column format due to the nature of the procedure.

Refer to ATTACHMENT G, Single Column AOP Format, for these requirements.

2.4 This writers' guide should be used in conjunction with the EOP procedure change checklist PBF-2004. A checklist should be completed for each permanent EOP revision.

The checklist is structured to follow this writers' guide. It also checks items which have been identified as problems during previous EOP issues.

Page 4 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 2.5 The matrix in H, PRA CORE DAMAGE RISK MATRIX, was developed based on initiating events with a frequency of core damage greater than 1E-6 and an initiating event frequency of greater that 1E-3. The selected scenarios were then compared to the procedures that the operator would most likely use to prevent core damage. Procedure validation should consider those scenarios where an X is marked. This matrix is risk based only and should not be used as the sole consideration for determining scenarios for procedural validation.

2.6 When revising or developing a new emergency procedure the writer should refer to ATTACHMENT I, PRA CONSIDERATIONS. The way a procedure is written can play an important role in the probability of successfully implementing human actions that are required to mitigate plant transients and accidents. Human Reliability Analysis (HRA) is the method that Probabilistic Risk Assessment used to evaluate the chances of success or failure to correctly perform a human action. There are two primary types of human errors that can be made that could lead to failure to successfully perform an action. Errors of Commission errors involve performing the wrong action even though the correct information is understood. These types of errors include selection of wrong unit / wrong train valves or putting a control in the incorrect position. These types of errors are typically reduced through good labeling and training. Another type of error is the error of Omission. These types of errors typically involve misinterpreting or completely missing procedure steps. Well written procedures can reduce the chance of these types of errors.

3.0 RESPONSIBILITIES 3.1 Operations Manager 3.1.1 Ensures that a technical basis is maintained for the EOPs using background documents and setpoint databases.

3.1.2 Determines when to incorporate subsequent revisions to generic technical guidelines into appropriate plant-specific procedures.

3.2 EOP Coordinator 3.2.1 Ensures the procedures are technically accurate and written to the standards established in this writers' guide.

3.2.2 Determines when the procedures will be upgraded to the requirements of this writers' guide.

3.2.3 Determines when to incorporate subsequent revisions to plant-specific technical information into appropriate procedures.

3.3 Procedure Writer 3.3.1 Researches reference sources.

Page 5 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 3.3.2 Verifies the accuracy of information.

3.3.3 Revises any applicable procedure backgound documentation which supports the procedure development.

3.3.4 Confirms the usability of new or revised program descriptions, procedures, and instructions.

3.3.5 Ensures procedures and instructions comply with the requirements of this procedure when developing or revising these documents.

4.0 CONTENT OF MAJOR SECTIONS 4.1 Emergency Operating Procedure Identification Each plant procedure shall be uniquely identified. This identification permits easy administration of the procedure preparation, review, revision and distribution process.

4.1.1 Each emergency operating procedure that is derived from the Westinghouse Owners Group Optimal Recovery Guidelines will be identified with the designator EOP followed by a sequential number.

Example: EOP-0, EOP-l.1 4.1.2 Each emergency operating procedure that is derived from the Westinghouse Owners Group Emergency Contingency Action will be identified with the designator ECA consistent with the generic procedures.

Example: ECA-0.0 4.1.3 Each related emergency operating procedure that is derived from the Westinghouse Owners Group Functional Restoration Guideline shall be identified with the designator CSP to represent Critical Safety Procedure followed by an alphanumeric symbol that is consistent with the generic numbering scheme for function restoration guidelines.

Example: CSP-P.1, CSP-H.4 4.1.4 Each procedure is identified using its designator and number and a descriptive title that is consistent with the respective generic guidance ERG. It is acceptable to change the generic title in the plant specific procedure to incorporate plant terminology or to better describe the scope of the procedure.

Such a change will be justified in the deviation document for that procedure.

4.1.5 Each status tree is derived from the Westinghouse Owners Group Status Trees and will be identified with the designator ST followed by a sequential number.

Page 6 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE 4.2 Revision Identification 4.2.1 The word DRAFT shall be used in the title block to designate a procedure that has not received Manager's Supervisory Staff approval.

4.2.2 The descriptor REVISION 0 shall be used in the title block to designate the original issuance of each procedure.

4.2.3 The REVISION followed by the next sequential number shall be used in the title block to identify revisions to each procedure for changes made subsequent to the implementation of the original plant procedures.

4.2.4 To identify revision to the text of a procedure, a change bar located in the left side of the changed text will be used. Total rewrite revisions will not utilize revision change bars.

4.3 Page Identification and Numbering 4.3.1 The header printed on every page will be in accordance with Point Beach Nuclear Plant Procedures Writers' Guide. In addition, CSPs will have the color designators within the title block on every page to represent the priority of the critical safety procedure status tree paths that are entry conditions to the CSP.

4.3.2 The page number will appear in the header of the page along with the total number of pages in the procedure. The last page of each procedure will additionally be identified by the word END following the last instruction step.

In addition to the procedure page count, attachments and figures will also provide a section page number and total section page count under the section number. The section number is located under the heading block.

4.4 Cover Paae 4.4.1 The cover page will be in single column format. Each cover sheet will contain three sections in addition to the procedure title and title block. The first will be titled PURPOSE and will briefly describe what the procedure is intended to do for the operator. It will include the applicability of the procedure.

Page 7 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE 4.4.2 The second section is a summary of those symptoms which require entry into the procedure. This section will be titled SYMPTOMS OR ENTRY CONDITIONS. Certain procedures can be entered primarily based on symptoms; for these procedures a symptom summary is sufficient. Some other procedures can only be entered by transitions from previous procedures and a summary of the entry conditions (and EOP procedure step) should be provided. Due to the complexity of the EOP set, the step number referenced by the SYMPTOMS OR ENTRY CONDITIONS may not be correct, however, the referenced procedure is current. For critical safety procedures, the conditions that were present to satisfy the path on the status tree should be included in the SYMPTOMS OR ENTRY CONDITIONS. This is done to provide the operator with a quick reference to verify the correct procedure is being used. This description is not meant to duplicate the monitoring function of the status trees. Because of this, every branch of the status tree does not need to be described in this section. This information should be presented in a manner that is most useful for the procedure user.

4.4.3 The third section is a list of REFERENCES for that procedure.

4.5 Procedure Section

.This section will contain the operator actions and contingency desired. A step-by-step procedure directs the operator to perform necessary actions required by the intent of the procedure. The left-hand column is for action/expected response and the right-hand column is for response not obtained. Attachment F provides a sample of this two-column format.

4.6 Attachments Attachments, figures, and tables may be attached to the procedure to provide additional information. Attachments may be used to simplify transitioning within a procedure if a series of actions may be required in more than one place within the same procedure.

4.6.1 Attachment Pages

a. Attachments shall be designated by sequential capital letters.

b. Attachments are identified with the following header centered immediately below the page header block:

EXAMPLE ATTACHMENT A (Page 1 of 2)

TITLE Page 8 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE

c. The last page of each attachment should have the word -END- centered on the page, below the last line of text to indicate the end of the attachment.

4.6.2 Figure Pages

a. Figures shall be designated by sequential Arabic numbers.

b. Figure pages located at the end of the document are identified with the following header centered immediately below the page header block:

EXAMPLE FIGURE 1 TITLE

c. Related figures may be shown on the same page under a single title.

Figures identified with a separate title should be shown on a separate page.

d. Graphical information or pictures may also be presented as figures at the end of the document as a figure page.

e. The independent variable on all graphs should be plotted on the horizontal axis.

f. Figure numbers or titles may be used within the text of a document but are not required. If they are used, all figures within the document should be numbered.

4.6.3 Tables

a. Tables may be used within the text or attachments of a document to clearly present information.

b. Table numbers or titles may be used but are not required. If they are used, all tables within the document should be numbered.

c. There should not be a vacant cell in the table. If no entry is necessary, "NA" or "- -" should be entered to indicate not applicable.

4.7 Foldout Pages 4.7.1 Each foldout page, when provided, shall be identified by the heading FOLDOUT PAGE FOR followed by the applicable procedure and unit number, centered at the top of the page within the page border.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 4.7.2 Starting with the procedure page where the first step of the procedure is located, foldout pages shall be printed on the back of each procedure page.

4.8 Status Trees 4.8.1 Refer to Attachment E for status tree priority identification symbols.

4.8.2 The descriptive title for each Critical Safety Function Status Tree shall consist of the term "ST-X" followed by the noun name for the applicable critical safety function. The letter X shall be replaced with the numerical order of priority for that particular safety function where one is the highest priority.

4.8.3 Critical safety function status trees will be presented in the block version. The trees are represented horizontally along the page. Color coding and line pattern coding shall be used from each branch point to its terminus. All text should be at least as legible (type size and spacing) as the instruction steps in the procedures.

4.8.4 Changes to status trees shall be upgraded on the PPCS screens.

5.0 FORMAT AND STYLE REQUIREMENTS 5.1 Step Length and Content 5.1.1 Steps should be written in short and precise language.

5.1.2 The writer should consider that persons using the procedure may have a different background or skill level than the writer. Generally procedures should be written so that a fully qualified person can perform the procedure.

5.1.3 Each step should begin with an action verb except when location information is provided.

5.1.4 If multiple tasks are required to perform a step, the high level step should describe the purpose of the entire step and the multiple tasks should be presented as individual substeps.

5.1.5 Individual steps should be limited to a single action or no more than three closely related actions.

5.1.6 Limits should be expressed quantitatively whenever possible. An example of limits which cannot be expressed quantitatively are the cooldown limits specified by a curve.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE 5.1.7 Each action step shall be wholly contained on a page when step content allows.

For large steps it may be necessary to continue a step from one page to the next. When a step must be continued to the next page, include the following words centered at the bottom of the initial page and left justified at the top of the subsequent page to clearly show that the step is continued:

Example:

(Step 27. continued on next page)

Step 27. (continued from previous page) 5.1.8 The following guidelines should be followed when applying to sequencing of steps within the document:

a. Technical necessity should be the overriding consideration for step sequencing.

b. Physical layout and organization of equipment should be considered so that optimal movement and monitoring are achieved.

c. Steps should be structured to minimize the movement of personnel around the Control Room or the plant during performance of the procedure.

d. Steps should be structured to avoid unintentional duplication of tasks.

e. All numbered steps should be assumed to be performed in sequence unless stated otherwise in a preceding note.

5.1.9 Expected results of routine tasks need not be stated.

5.1.10 When considered beneficial for proper understanding and performance, provide the system response time associated with performance of the instruction.

5.1.11 When system response dictates a time frame within which the instruction must be accomplished, prescribe such time frame. Avoid using time to initiate operator actions. Operator actions should be related to plant parameters.

5.1.12 When additional confirmation of system response is considered necessary, prescribe the backup readings to be taken.

5.1.13 Definitions of key words and phrases used in procedures are listed in Attachment A, Definitions of Key Words and Phrases.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13. 2002 GUIDE AOP AND EOP WRITERS' 5.1.14 Items that are unique to the procedures are listed in Attachment B, Abbreviations, Acronyms, and Symbols. These items are used to help in keeping procedures concise.

5.1.15 When used in statements other than logic statements, "not" shall stand for the negative of the proceeding group of words.

5.1.16 All procedures shall end with a transition to another procedure, or with direction to consult with appropriate plant management for guidance.

5.1.17 Procedures shall be structured so that they can be executed by the minimum shift staffing and Control Room staffing required by Technical Specifications.

5.2 Dual Column Format 5.2.1 Steps and substeps may be written as imperative sentences in the following format: (Refer to Attachment D for examples of step construction and Attachment F for a sample format)

a. Action verb, procedure user action, or plant parameter; a hyphen and expected response in all capital letters.

b. The action verb used in a step should apply to all subsequent substeps and may be deleted from those steps.

5.2.2 The left-hand column, titled Action/Expected Response, contains directions for the operator and the expected plant response. The following rules apply to the left-hand column:

a. Each step shall begin with a high level action step which presents primary, sequential tasks to be performed in response to the specific emergency or off-normal operating condition.

b. Each high level action step should be written in all initial capital letters and bold font.

c. Periods should not be placed at the end of left-hand column steps, however, a colon should be placed at the end of any step which has substeps.

d. Left-hand column tasks shall be presented in the desired sequence unless otherwise specified.

e. If the left-hand column action cannot be performed, or the expected response is not obtained, the right-hand column contains contingency guidance.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.2.3 The right-hand column, titled Response Not Obtained, provides contingency actions which are to be taken in the event a stated condition or task in the left-hand column does not represent or achieve the expected response. The following rules apply to the right-hand column:

a. Right-hand column contingency actions are designated consistent with the left-hand column substeps to which they apply.

b. A contingency action which applies to a high level step is not numbered and starts on the same line as the related high level step.

c. Contingency actions provided for any high level step or substep which has subordinate substeps shall apply to all of the subordinate substeps.

d. If the right-hand column contains multiple contingency actions which cannot be described by a simple sentence, the phrase "Perform the following:" should be used as the introductory statement, and the required tasks shall be presented as substeps.

e. If a right-hand column action must be completed prior to continuing, that requirement shall appear explicitly stated in the procedure using the words "DO NOT CONTINUE" followed by the condition(s) which must be satisfied prior to continuing.

f. After completing applicable contingency actions in the right-hand column, the procedure user proceeds to the next high level step or substep in the left-hand column unless directed otherwise.

g. If a contingency action is not provided in the right-hand column or the contingency action cannot be performed, the procedure user proceeds to the next high level step or substep in the left-hand column.

5.3 Use of Logic Terms 5.3.1 The logic terms AND, OR, IF, IF ...NOT, WHEN...THEN, and IF...THEN are often necessary to precisely describe a set of conditions or sequence of actions.

5.3.2 When logic terms are used, they should be in all capital letters and underlined so that all conditions are clear to the document user.

5.3.3 Procedures written in dual column format equate to the logic "IF the expected conditions in the left-hand column are NOT satisfied, THEN perform the contingency action in the right-hand column" The logic terms should not be repeated in the right-hand column. However, logic terms may be used to introduce a secondary contingency in the right-hand column.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE So that contingencies are only contained in the right-hand column, the use of logic terms IF and IF.. .NOT should not be used in the left-hand column.

5.3.4 When steps are contingent upon certain conditions or combinations of conditions, the step should be formatted in accordance with one of the following examples:

EXAMPLES

" IF condition A, THEN perform action.

" IF condition A is NOT satisfied, THEN perform different action.

" WHEN condition A, THEN perform action.

5.3.5 Use of the logic term IF...NOT should be limited to those cases where the document user must respond to the second of two possible conditions. The logic term IF should be used to specify the first condition, as shown in the above example.

5.3.6 The logic term THEN should always follow a condition, not an action. This ensures only one action exists for each step.

EXAMPLES

" Ensure spray addition tank level has been lowered by at least 12%, THEN stop containment spray (Unacceptable)

" WHEN spray addition tank level has been lowered by at least 12%, THEN stop containment spray. (Acceptable) 5.3.7 Action steps should be performed in sequence so that a conjunction such as "and" is not required between steps. However, in the case of combinations of conditions within a single step, the logic term AND should be placed between the description of each condition.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.3.8 In order to simplify a long sequence of conditions, the logic term AND should not be used to join more than three conditions. If more than three conditions need to be joined, a list format should be used.

EXAMPLES IF all of the following conditions are met, THEN perform action.

"* Condition A

"* Condition B

"* Condition C

"* Condition D

"* Condition E 5.3.9 When used for connecting actions in a step, the word "and" need not be emphasized.

5.3.10 The logic term OR should be used between alternative conditions. It should be used in the inclusive sense, meaning that any one or all of the conditions may be present.

5.3.11 The word "or" (not a logic term) should be used between alternative actions.

It should be used in the exclusive sense, meaning that only one action is to be performed.

5.3.12 Presenting alternative actions without stating priorities should be minimized.

Priorities should be established for each action where possible.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.3.13 The use of logic terms AND and OR within the same step should be worded so as to avoid confusion or ambiguity, as shown in the following example.

EXAMPLE IF condition A AND condition B OR condition C occurs, THEN go to Step X.

This example can have two possible meanings and should be worded instead as either one of the following:

Meaning Number 1:

"oIF both condition A AND condition B occur, THEN go to Step X.

OR "oIF condition C occurs, THEN go to Step X.

Meaning Number 2:

"oIF both condition A AND condition B occur, THEN go to Step X.

OR "oIF both condition A AND condition C occur, THEN go to Step X.

5.3.14 Conditional statements in notes and cautions should follow all requirements for logic terms with the following exceptions:

a. They should be written in lower case with no underline.

b. The logic term THEN should not be used.

EXAMPLES

" IF condition A AND condition B, THEN result. (Unacceptable in notes and cautions)

" If condition A and condition B, result. (Acceptable in notes and cautions) 5.4 Use of Cautions and Notes 5.4.1 Non-action information should be presented as either a note or caution.

5.4.2 A caution is used to present information regarding potential hazards to personnel or equipment associated with the subsequent step(s).

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.4.3 A note is used to present advisory or administrative information necessary to support performance of the subsequent step(s).

5.4.4 Notes or cautions shall appear immediately before the step to which they apply.

5.4.5 Notes and cautions should appear within the page border, extending across the entire page, inside distinct boxes in bold font. The word NOTE or CAUTION, in all capital letters, bolded and underlined, should be centered at the top of the box.

NOTE This is a note.

5.4.6 Notes may be grouped together with each individual note identified with a closed bullet (.).

5.4.7 Cautions may be grouped together with each individual caution identified with a closed bullet (°).

5.4.8 Cautions shall precede notes when they appear together unless the note contains information which clarifies the caution.

5.4.9 Notes and cautions and the first applicable step shall not be split between pages.

5.4.10 Notes and cautions themselves shall not be split between pages.

5.4.11 The following guidelines apply to the wording in notes and cautions:

a. Each document should provide enough information to accomplish the purpose of the document without relying on information contained in notes or cautions.

b. Notes and cautions should be declarative statements of fact and not commands or action statements unless they are advising on actions to be taken in the event of changing plant conditions.

c. Notes and cautions which are repeated in different documents should have standardized wording whenever possible.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.5 Calculations 5.5.1 Mathematical calculations should be avoided in procedures. If a value has to be determined in order to perform a procedural step, a chart or graph should be used whenever possible.

5.5.2 Actions which require calculations should have space provided within the document for recording all steps of the calculation.

5.6 Use of Underlining Underlining will be used for emphasis of logic terms and to designate transitions.

5.7 Transitions to Other Procedures or Steps 5.7.1 Examples of transition from several procedures for the same or different reasons are listed in Attachment C, Symptom or Entry Condition Examples.

5.7.2 Transitioning is defined as leaving the procedure at the current step and resuming actions in another procedure or step within the current procedure.

5.7.3 Since transitioning is likely to lead to errors in implementation by interrupting the flow of guidance, documents should be written to minimize the use of transitions. For example, if short sections of other procedures are required, those sections may be copied into the procedure instead of transitioning to the other procedure.

5.7.4 Transitions to other procedures do not contain an automatic return feature. If it is desired to return to the procedure which caused the transition, words such as "return to procedure and step in effect" must appear in the procedure being transitioned from.

5.7.5 A transition is identified by underlining the transition.

5.7.6 Steps which create a transition to another document should be formatted in accordance with the following example:

EXAMPLE Transitions to another document:

o Go to EOP-0.1, REACTOR TRIP RESPONSE.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.7.7 Transitions to an earlier or a later step in the current document or to an attachment in the current document should be formatted in accordance with the following example:

EXAMPLE Transitions within the current document:

"* Go to.StepI.

"* Return to Step 2

"* Go to ATTACHMENT A.

5.7.8 Transitions to steps within the current document which are preceded by a caution or note should be formatted in accordance with the following example:

EXAMPLE Transitions to steps in the current document with preceding notes or cautions:

" IF conditions are NOT satisfied, THEN OBSERVE NOTE PRIOR TO STEP 1 and return to Step 1.

" IF conditions are NOT satisfied, THEN OBSERVE CAUTION PRIOR TO STEP 10 and go to Step 10.

5.8 Branching to Other Documents 5.8.1 Branching is defined as the concurrent performance of two or more documents. Branching can also apply to the use of attachments to the main document.

5.8.2 Each document should contain all the guidance necessary to perform the course of action. Therefore, the writer should limit the use of branching whenever possible.

5.8.3 Branching should be used for the following situations:

a. When a complex or time consuming operation is required which could delay performance of the main document.

b. When more than three local operator actions are necessary which do not require close supervision by the performer of the main document.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE

c. When it is desired to delegate supervision of a particular task sequence to another individual.

5.8.4 Steps which create a branch should contain the following information in the order shown:

a. A brief description of the actions to be accomplished in the document being branched to.

b. The term "per."

c. The document number and title in all capital letters. When branching to an attachment within the current document, it is only necessary to specify the attachment designator in all capital letters.

d. When branching to an attachment in another document, the appropriate attachment designator at which to enter the other document should be included following the document title.

e. The words "while continuing with this procedure (instruction)" should be placed at the end of the sentence to emphasize the need for concurrent performance.

EXAMPLES

1. Check Emergency Diesels ANY RUNNING UNLOADED

a. Stop any unloaded diesel per OP 1 A, EMERGENCY DIESEL GENERATOR 5.9 Referencing 5.9.1 Referencing is defined as the use of other documents or sources of information to perform the current step. Referencing also applies to obtaining guidance from plant management or plant engineering staff.

5.9.2 Referencing is usually made to figures or other sources of information that are too lengthy to be provided in the step.

5.9.3 Referencing to a document is designated by the term "refer to" followed by the document designator.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE I 5.9.4 Referencing to a person for guidance is designated by the terms "as determined by" or "as directed by" followed by the title.

EXAMPLES o Refer to ATTACHMENT A for list of valves receiving containment isolation signal.

o Adjust RMS high alarm setpoint to clear alarm as directed by TSC.

5.10 Component Identification 5.10.1 The preferred method for identifying equipment in procedures is to use the name and number of the equipment (Word Paraphrasing Method).

EXAMPLES "o Emergency Diesel Generator GO0 "o Letdown Containment Isolation Valve CV-371 5.10.2 When two or more equipment numbers can be associated with the same equipment name, the equipment numbers should be listed below the equipment name.

EXAMPLE

1. Shut Letdown Orifice Isolation Valves

"* CV-200A

"* CV-200B

"* CV-200C 5.10.3 When a list of equipment is included in a procedure, the equipment number followed by a comma and-the equipment name should be listed.

EXAMPLE

1. Locally ensure the following valves open:

2SF-820B, RWST to P-33 refueling water circulating pump valve

"* 1SF-820, RWST to P-33 refueling water circulating pump valve Page 21 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE 5.10.4 In some cases it may be desired to identify the component exactly as it appears on the component label (Verbatim Method).

a. This method should be used when Control Room annunciator legends are provided in documents.

b. This method should be used when component nameplate identification is provided as part of an equipment lineup checklist which is intended to be read by the document user performing the equipment manipulation.

c. This method should be used when other identification methods have resulted in confusion.

5.10.5 When only a generic reference to a component is being made, the equipment number is not needed (Common Usage Method).

EXAMPLES

"* Start one emergency diesel generator

"* Identify all open containment isolation valves 5.11 Standard Steps, Cautions, and Notes Standard steps, cautions, and notes are blocks of text that are the same in more than one place in the emergency operating procedures. When a standard text block is changed, then it shall be reviewed for change in all other locations. This ensures a consistent method for completing actions steps and helps prevent operator error. When making a change to a standard text block, care must be taken to ensure the new text is applicable for all locations and does not conflict with the basis for each location.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.12 Level of Detail Too much detail in emergency operating procedures should be avoided in the interest of being able to effectively execute the instructions in a timely manner. The level of detail required is the detail that a newly trained and licensed operator would desire during an emergency condition.

To assist in determining the level of detail for emergency operating procedures, the following general rules apply.

5.12.1 Actions may unintentionally be performed incorrectly or omitted if a procedure lacks needed information. On the other hand, excessive detail can result in the procedure being time consuming or in steps being missed due to the user scanning over the procedure. To determine the appropriate level of detail the following factors should be considered:

a. User knowledge and skills (skill of the craft)

b. Complexity of task

c. Task frequency

d. Past experience in implementing the procedure 5.12.2 Recommended action verbs are as follows:

a. Use "start/stop/pullout" for power-driven rotating equipment.

b. Use "open/shut/throttle" for valves.

c. Use "trip/close/lockout/pullout" for electrical breakers.

5.12.3 Standard practices for observing abnormal results need not be prescribed within procedural steps. For example, observations of noise, vibration, erratic flow, or discharge pressure need not be specified by steps that start pumps.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.13 High Level Steps Procedure steps will be numbered and substeps indented as follows:

1 High Level Step

a. First Level Substep

1) Second Level Substep a) Third Level Substep High level steps are printed in bold print with each word capitalized. These are the numbered steps.

5.13.1 Continuous Action Step

a. Continuous Action steps are used to provide guidance which applies throughout the remainder of the procedure.

b. Continuous action steps are steps which are identified by an asterisk "*"

box around the step text.

c. WHEN, THEN continuous action logic statements do not need to be enclosed in an asterisk box. When the condition is met, the action is performed. Until the condition is met, the operator is expected to continue with procedure.

5.13.2 Immediate Action Steps

a. Immediate actions steps are high level steps which can be identified by a circle around the sequential step number.

b. Immediate action steps shall be identified by a note prior to the first action step which states "Steps X through Y are immediate action steps."

c. Immediate action steps shall be used for operation of controls or confirmation of automatic actions that are required to stop the degradation of conditions and mitigate their consequences.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 5.14 Substeps Substeps are usually lettered sequentially accordingly to desired order of performance. If the order of importance is not important, then the substeps will not be designated by a letter, but will be preceded by an open or closed bullet. Use of the third level of indentation should be minimized.

5.14.1 Sequential Sequential substeps are preceded by a small letter or number. These items are expected to be followed in the order presented.

5.14.2 Equally Acceptable Substeps

a. Equally acceptable substeps are those for which any of several alternative steps or sequence of steps may be equally correct.

b. Equally acceptable substeps should be separated by the logical term OR.

c. Equally acceptable substeps should be indexed with open bullets instead of numbers and letters to indicate that not all substeps need to be performed.

5.14.3 Closed Bullet Substeps Closed bullet substeps do not require any specific order. A closed bullet further indicates that all of the items must be used to satisfy the high level step.

5.14.4 Equipment Lists

a. Equipment lists provide the equipment designation. Each item is preceded by a closed or open bullet.

b. Closed bullet equipment lists indicate all the listed items must be used.

c. Open bullet equipment lists indicate any or all of the items is used.

5.14.5 Continuous Action Substeps Continuous action substeps are designated with the asterisk "*"box.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13. 2002 AOP AND EOP WRITERS' GUIDE 6.0 MECHANICS OF STYLE 6.1 Spelling Spelling should be consistent with modern usage. When a choice of spelling is offered by a dictionary, the first spelling should be used.

6.2 Punctuation Punctuation should be used only as necessary to aid reading and prevent misunderstanding. Word order should be selected to require a minimum of punctuation.

When extensive punctuation is necessary for clarity, the sentence should be rewritten and possibly made into several sentences. Punctuation should be in accordance with the following rules.

6.2.1 BRACKETS, [],should only be used to indicate adverse containment setpoints.

6.2.2 COLON should be used to indicate that a series of related substeps or a list is to follow.

6.2.3 COMMA should be used:

a. Prior to the logical term THEN

b. To separate items in a series

c. Prior to the conjunction in a series

d. To separate five or more digits in a numeral EXAMPLES o IF conditions satisfied, THEN take action.

o Unlock, rack in, and close the following breakers:

6.2.4 HYPHENATION of words should be minimized while meeting the following guidelines:

a. Hyphenated component identifiers and document numbers should be kept on the same line of text.

b. Written compound numbers from twenty-one to ninety-nine should be hyphenated.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE

c. Written fractions, such as one-half, should be hyphenated.

d. Compound words with "self," such as self-contained, should be hyphenated.

e. Compound words which would result in misleading or awkward combinations of consonants, such as bell-like, should be hyphenated.

f. Compound words which could be confused with another word, such as re-cover versus recover or pre-position versus preposition, should be hyphenated.

g. A letter which is linked to a noun, such as x-ray or O-ring, should be hyphenated.

h. Chemical elements and their atomic weights, such as Boron-10 or U-232, should be hyphenated.

6.2.5 PARENTHESES, (), may be used to set off explanatory or supplementary information.

a. Action steps should not be included within parentheses.

b. May be used to denote the plurality of a noun name or equipment.

c. Documents should be written to avoid the use of parentheses.

6.2.6 PERIOD is used at the end of complete sentences in the RNO column and for indicating the decimal place in numbers.

6.2.7 QUOTATION MARK may be used to set off unique titles or examples contained within the text of a document.

Quotation marks should not be used for program description, procedure, or instruction titles.

6.2.8 SEMICOLON should not be used because they encourage long sentences.

6.2.9 SLANT may be used to:

a. Form fractions

b. Indicate alternate positions on a single switch

c. Form acronyms such as S/G for steam generator Page 27 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13. 2002 AOP AND EOP WRITERS'GUIDE 6.3 Capitalization 6.3.1 Capitalization should be used consistently in documents to avoid confusion.

If used too often or inappropriately, capitalization can hamper reading speed and comprehension.

6.3.2 The following words normally have an initial capital letter:

a. The first word in a sentence

b. The first word in steps and substeps

c. The first word in a list

d. Words such as Step, Section, and Number when followed by a designating numeral or letter.

6.3.3 Capitalization of only the important words should be used for the following:

a. Proper nouns such as an organization's name

b. Official personnel or staff titles 6.4 Vocabular' 6.4.1 Certain terms have unique meanings as listed below:

a. Manual or manually - an action performed by the document user at the location of document performance.

b. Local or locally - an action performed by a document user at a location other than the Control Room.

EXAMPLES o "Manually shut valve" means to operate Control Room switch(s) to close the valve. If the valve cannot be closed from the Control Room, then dispatch an operator to locally close the valve.

o "Locally shut valve" means to directly manipulate the hand wheel, air supply, or other equipment to close the valve.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 GUIDE AOP AND EOP WRITERS'

c. Operable - indicates that a system, subsystem, train, component, or device is capable of performing its specified function(s), and when all necessary attendant instrumentation, controls, electrical power, cooling water, seal water, lubrication, or other auxiliary equipment are also capable of performing their related support function(s).

d. Operating - indicates that a system, subsystem, train, component, or device is in operation and is performing its specified function(s). Auxiliary equipment required to perform its specified function(s) may or may not be capable of performing their related support function(s).

e. Available - indicates that a system, subsystem, train, component, or device is capable of performing its specified function(s) even though required auxiliary equipment may or may not be capable of performing their related support function(s).

6.4.2 Words such as "approximately," "rapidly," and "slowly" should not be used unless clarification is provided.

6.4.3 The terms "increase," "decrease," "increasing," and "decreasing" shall not be used. In order to avoid possible confusion, these terms should be replaced with other terms that convey the same intent, such as "rising," "lowering,"

"trending higher," or "trending lower."

6.4.4 The following rules apply to inequalities:

a. Inequalities should be expressed as words rather than symbols.

b. The terms "greater than" and "less than" should be used instead of "above" or "below," unless they could cause confusion. Then the terms "higher than" and "lower than" should be used.

EXAMPLES "o The phrase "maintain level greater than three feet below the reactor vessel flange" could mean to keep level at least three feet below the flange or it could mean that level should not be lower than three feet below the flange. (Unacceptable)

"o The phrase "maintain level higher than three feet below the reactor vessel flange" means keep level above the negative three foot setpoint. (Acceptable)

"o The phrase "maintain level lower than three feet below the reactor vessel flange" means keep level below the negative three foot setpoint. (Acceptable)

Page 29 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE 6.4.5 Although excessive use of symbols can be confusing, certain symbols are widely recognized and can be effective in increasing reading speed.

a. The terms differential pressure and delta P may be written as AP.

b. The terms differential temperature and delta T may be written as AT.

c. The terms degrees Fahrenheit and degrees Centigrade may be written as

F and 'C respectively.

d. The word percent may be written as % when used following a number.

e. Mathematical symbols in equations may be used.

f. Greek letters and other symbols used to express engineering units may be used.

6.5 Numerical Values 6.5.1 Use of Roman Numerals should be avoided whenever possible.

6.5.2 All numerical values should be consistent with scale and range that can be read on the instrumentation to be used. This is typically one-half the smallest division on the instrumentation being used.

6.5.3 The number of significant digits presented should be equal to the reading precision of the document user.

6.5.4 Decimal functions should be written with at least one digit to the left of the decimal point.

6.5.5 Numbers written in exponential form should be written as shown in the following example.

EXAMPLES

6.4 x 10-6 (preferred) o 6.4 E-6 (acceptable)

Page 30 of 77 PINFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 6.5.6 Acceptance values should be stated in such a way that any addition and subtraction operations are avoided. This is done by stating acceptance values as limits.

EXAMPLES ACCEPTABLE UNACCEPTABLE maintain pressure between maintain pressure at 250 + 5%

238 psig and 262 psig torque to between 22 ft-lbs and 26 ft-lbs torque to 24 + 2 ft-lbs 6.5.7 Engineering units should always be specified when presenting numerical values for process parameters. They shall be the same as those used on the instrumentation displays.

6.5.8 Numerical values and associated engineering units should be kept on the same line of text.

6.6 Abbreviations, Letter Symbols and Acronyms 6.6.1 When using abbreviations and acronyms, it is important to determine who the user of the procedure is. In some cases it may be acceptable to use abbreviations and acronyms without definition. In other cases it may need to be defined to ensure the user knows its meaning.

6.6.2 When an abbreviation or acronym needs to be defined, it should be done by writing out the term and placing the abbreviation or acronym in parentheses after the term. Refer to Attachment B for a listing of abbreviations.

6.7 End To designate the end of each procedure or multiple page attachment, the word -END- will be placed below the last line of text centered on the page.

Page 31 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE 6.8 Normal and Adverse Containment Setpoints 6.8.1 Procedures which address severe accident conditions are written such that, in many steps, the procedure user determines an appropriate action to be taken based upon process parameter values. In order to minimize the instrument uncertainty required when normal containment conditions exist, two separate set points may be provided in the step.

6.8.2 In those instances where both the normal and adverse values are given, the first process value is the abnormal containment value and shall be enclosed in brackets. The normal value shall be listed second.

EXAMPLE

a. Check PZR Level - GREATER THAN [34%] 10%

VAdverse Normal containment value containment value 6.8.3 When only one process parameter value is given, brackets are not required and the value presented shall apply for both normal and adverse containment conditions.

6.9 Supporting Documentation 6.9.1 Setpoint Documentation for EOPs

a. Procedures based on the Westinghouse Owner's Group Emergency Response Guidelines (ERGs) shall have a description of the conversion of ERG footnotes into plant specific set points contained within a Setpoint Document.

b. A clear description of how each setpoint within EOP procedures is derived shall also be contained in a Setpoint Document.

c. The format of Setpoint Document(s) should be established and approved by the Operations Manager.

d. Setpoint Document(s) may be maintained either electronically in a database or as a hard copy document.-_

6.9.2 Background Document Requirements for EOPs and Selected AOPs

a. A Background Document shall be written and maintained for all EOPs and selected AOPs. Background Documents for other documents may be produced on an as-needed basis as determined by the Responsible Manger.

b. Background Documents provide explanatory and other background information regarding the content of its associated document.

Page 32 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE

c. The purpose of the Background Document is to serve as a reference source for document users, training personnel, and personnel initiating document changes.

d. Each Background Document shall be numbered with the background document designator "BG-" followed by the same alpha-numeric designator as its associated document.

EXAMPLE Document Number/Title Background Document Number/Title EOP E-0, REACTOR TRIP OR BG-EOP E-0, REACTOR TRIP OR SAFETY INJECTION SAFETY INJECTION

e. When a revision to a document is made, appropriate modifications to the Background Document shall also be made.

f. The revision number of the Background Document need not match the revision number of the associated document.

g. Revisions to a Background Document which do not involve changes to the made.

associated document may be

"* Such changes shall be approved by the Responsible Manager of the associated document.

"* In this situation the revision number of the associated document is not changed.

h. The step, caution, or note text is provided word for word as found in the issued PBNP procedure for easy cross reference to the procedure.

Page 33 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE 6.9.3 Deviation Document Requirements (EOP Network)

a. Deviation Documents for procedures based on Westinghouse Owner's Group generic guidelines are intended to serve as a reference source and technical justification for all deviations in wording, content, and step sequence between the generic guideline and the plant specific procedure.

b. Step Deviations shall be provided which describe the differences between the generic guideline steps and the plant specific steps including justification for these differences.

"* Step deviations shall be explained for all wording changes, step sequence changes, and any additions or deletions of steps, substeps, notes, or cautions.

" A deviation consists of two parts; the deviation portion which describes the difference between the PBNP step and the WOG step, and justification which provides the reason for the deviation.

"* When the difference in an abbreviation or acronym used in the plant specific procedure versus that used in the generic guideline is slight and easily understood, a deviation description is not required.

c. When a revision to a document is made, appropriate modifications to the Deviation Document shall also be made.

d. The revision number of the Deviation Document need not match the revision number of the associated document.

e. Revisions to a Deviation Document which do not involve changes to the associated document may be made.

Such changes shall be approved by the Responsible Manager of the associated document.

6 In this situation the revision number of the associated document is not changed.

6.9.4 Background Document Content for EOPs and Selected AOPs

a. The format of Background Document(s) should be established and approved by the Responsible Manager of the associated document.

b. Each Background Document shall contain a Cover Page which identifies the associated document, document title, revision number, and approval date.

Page 34 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE

c. Each Background Document shall contain a brief basis for performing the document actions.

"* This may be done in a section or step-by-step manner.

"* Additional explanatory and background information, as deemed necessary and appropriate by the document writer, may also be included.

"* This information may provide explanation of symptoms or entry conditions or document steps that are not readily apparent.

"* This information should also include explanations of critical step sequences that are not readily apparent and/or consequences of changing or not following the sequence.

d. Explanatory information may be provided, but is not required in Background Documents, for the Purpose and Symptoms Or Entry Conditions sections.

e. Background information for any document figures or attachments may be documented as if the figure or attachment were a single step. A more detailed discussion of these document elements may be provided if desired.

f. Each Background Document for procedures which contain a Foldout Page shall provide step documentation for each Foldout Page item.

g. Each Background Document for procedures based on Westinghouse Owner's Group generic guidelines shall contain the following additional information:

"* Source document identification shall be provided which indicates the generic guideline(s) used as the basis for the associated procedure including any appropriate revision number.

"* Step Documentation shall be provided which provides a cross-reference between the generic guideline steps and the plant specific procedure steps.

Page 35 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE 6.10 Use of Oversized Paees Oversized pages should be avoided whenever possible.

6.11 Use of Reduced Pages Reduced pages should be avoided whenever possible. Final size of reduced pages should be standard page size. Reduced pages should be readable.

6.12 Reproduction Reproduction of procedures, including figures and tables, shall be of a quality equal to that of the originals.

Page 36 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE

7.0 REFERENCES

7.1 Westinghouse Owners Group Low Pressure ERGs, Volume I to II.

7.2 NUREG/CR-2005, Checklists for Evaluating Emergency Procures used in Nuclear Power Plants.

7.3 FSAR Section 12.4, Written Procedures.

7.4 Westinghouse Owners Group, Writer's Guide for Emergency Response Guidelines, Revision 1, up through and including Revision 1C.

7.5 Point Beach Nuclear Plant Procedures Writers' Guide.

7.6 NUREG-0899, Guidelines for the Preparation of Emergency Operating Procedures.

7.7 NUREG-1358, Lessons Learned from the Special Inspection Program for Emergency Operating Procedures.

7.8 NUREG-1358, Supplement 1, Lessons Learned from the Special Inspection Program for Emergency Operating Procedures.

7.9 WCAP 10204, Emergency Response Guidelines Validation Program.

7.10 WCAP 10599, Emergency Response Guidelines Validation Program Final Report.

7.11 Westinghouse Owners Group (WOG) Emergency Response Guidelines.

7.12 Westinghouse Owners Group Emergency Response Guidelines, Executive Volume.

8.0 BASES NONE Page 37 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT A (Page 1 of 3)

DEFINITIONS OF KEY WORDS AND PHRASES AVAILABLE Indicates that a system, subsystem, train, component, or device is capable of performing its specified function(s) even though required auxiliary equipment may or may not be capable of performing their related support function(s).

CHECK Observe a system or parameter to determine its present condition. When "Check" is used there will always be criteria included (possible in a subsequent substep) to be used in the evaluation. The word "Check" alone does not imply that any action is to be taken beyond observing the condition.

Example: Check if SI is Actuated DO NOT CONTINUE The procedure user should not continue in this procedure until the desired condition that follows is obtained. If another procedure is being done concurrently, it does not have to be halted but the operator should be cautious to avoid taking any actions that this statement is attempting to avoid.

Example: Do not proceed to next step until RCS pressure is reduced to 1200 psig.

ENSURE The word "Ensure" is used to confirm that an expected desirable condition exists. If the condition does NOT exist, the appropriate contingency, either stated or implied, is to establish the expected condition.

FAULTED (NON-FAULTED)

"Faulted" refers to a steam generator with an uncontrolled secondary system release.

Example: Identify Faulted Steam Generator Page 38 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE ATTACHMENT A (Page 2 of 3)

DEFINITIONS OF KEY WORDS AND PHRASES GO TO (RETURN TO)

This phrase tells the procedure user to leave the procedure at this point and continue executing procedure steps beginning with the step number in this statement. The user will sometimes be instructed to go to an earlier step in the procedure (i.e., "Return to") or a later step in the procedure (i.e., "Go to")

or another procedure altogether. Whenever the user leaves a procedure, prior to the end, a shoe lace should be inserted as a page marker. Often the procedure that the user is transferred to will have an instruction to "return to the procedure in effect." This page marker will allow the user to continue the original procedure where it was left off.

INTACT "Intact" specifically refers to a steam generator that is neither faulted nor ruptured. This means the steam generator does not have a secondary depressurization or tube rupture. Often if neither steam generator is intact, one of them will have to be considered intact to complete necessary actions in the procedure. This is also described in the appropriate procedure.

Example: "Depressurize Intact Steam Generator to 250 psig Intact can also be used more generally to describe a pressure boundary that is not relieving.

LOCALLY This word is used to remind the procedure user that the action that follows cannot be executed from the Control Room.

MANUALLY This word is used to remind the procedure user that the action that follows can be done from the control room.

OPERATE This word is used to allow the operator to manipulate a particular control or cycle equipment in order to establish or maintain a definite criteria.

RUPTURED (NON-RUPTURED)

"Ruptured" refers to a steam generator with a ruptured tube.

Page 39 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT A (Page 3 of 3)

DEFINITIONS OF KEY WORDS AND PHRASES PER This word is used to present a reference procedure identifier that is to be used in satisfying the step.

This is used when there are additional concerns that have to be addressed beyond the information that can be put in the procedure. The user is expected to obtain the referenced procedure and satisfy the directives of this procedure while performing the procedure step.

VERIFY "Verify" is used to confirm that an expected desirable condition exists. The desirable condition shall be defined in succeeding substeps. If the condition does NOT exist, the contingency stated in the RNO column shall be followed.

Example:

9 Verify SI Flow Not Required:

a. Check RCS subcooling based on a. Manually start SI pumps as core exit thermocouples - GREATER necessary to restore RCS THAN [80°F] 35°F subcooling and go to EOP-1 UNIT 1, LOSS OF REACTOR OR SECONDARY COOLANT "o 1P-15A, train A "o 1P-15B, train B

b. Check PZR level - GREATER b. Perform the following:

THAN [34%] 10%

1) Control charging flow as necessary maintain PZR level.

2) IF PZR level can NOT be maintained, THEN manually start SI pumps as necessary to restore PZR level and go to EOP-1, LOSS OF REACTOR OR SECONDARY COOLANT "o1P- 15A, train A "o P- 15B, train B Page 40 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE ATTACHMENT B (Page 1 of 1)

ABBREVIATIONS, ACRONYMS, AND SYMBOLS AC Alternating Current AFW Auxiliary feedwater AOV Air Operated Valve BAST Boric Acid Storage Tank CC Component Cooling CST Condensate storage tank CVCS Chemical & volume control system DC Direct Current El. Elevation EDG Emergency Diesel Generator EH Electrohydraulic FCV Flow Control Valve HCV Hand-control valve (used as a valve identifier)

HP High Pressure I&C Instrumentation & Control LP Low Pressure MCC Motor Control Center MOV Motor Operated Valve MSIV Main Steam Isolation Valve PORV Power Operated Relief Valve PPCS Plant process computer system PRT Pressurizer Relief Tank PZR Pressurizer RCP Reactor Coolant Pump RCS Reactor coolant system reg Regulating RHR Residual heat removal system RMS Radiation monitoring system RTD Resistant Temperature Device RVLIS Reactor Vessel Level Indication System RWST Refueling water storage tank SFP Spent Fuel Pool S/G Steam Generator SGTR Steam generator tube rupture SI Safety injection SL Turbine Stop Valve Left SR Turbine Stop Valve Right SUR Startup rate SW Service water AT Delta temperature TSC Technical Support Center VCT Volume control tank Page 41 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT C (Page 1 of 1)

SYMPTOM OR ENTRY CONDITION EXAMPLES TRANSITION FROM SEVERAL PROCEDURES FOR DIFFERENT REASONS B. SYMPTOMS OR ENTRY CONDITIONS

1. This procedure is entered from the following procedure when it has been determined that a natural circulation cooldown is required:

EOP-0.1, UNIT 1, REACTOR TRIP RESPONSE, Step 33

2. This procedure is entered from the following procedure after plant conditions have been stabilized following restoration of AC emergency power:

ECA-0.1, UNIT 1, LOSS OF ALL AC POWER RECOVERY WITHOUT SI REQUIRED, Step 25

3. This procedure is entered from the following procedure if a natural circulation cooldown is in progress:

CSP-I.3 UNIT 1, RESPONSE TO VOIDS IN REACTOR VESSEL, Step 2 TRANSITION FROM SEVERAL PROCEDURES FOR THE SAME REASON B. SYMPTOMS OR ENTRY CONDITIONS

1. This procedure is entered from the following procedures if SI actuates:

o EOP-0.2 UNIT 1, NATURAL CIRCULATION COOLDOWN, Step 1 o EOP-0.3 UNIT 1, NATURAL CIRCULATION COOLDOWN WITH STEAM VOID IN VESSEL (WITH RVLIS), Step 1 o EOP-0.4 UNIT 1, NATURAL CIRCULATION COOLDOWN WITH STEAM VOID IN VESSEL (WITHOUT RVLIS), Step 1 Page 42 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT D (Page 1 of 4)

EXAMPLES OF STEP CONSTRUCTION, DUAL COLUMN PROCEDURES ACTION STEP

13. Energize PZR Heaters As Necessary To Saturate PZR Water At Ruptured S/G Pressure olT-lA olT-lB olT-1C olT-1D olT-1E CONCURRENT STEPS

10. Dispatch Operator To Locally Close Breaker 1A52-02

11. Dispatch Operator To Locally Close Breaker 1A52-15 Page 43 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT D (Page 2 of 4)

EXAMPLES OF STEP CONSTRUCTION, DUAL COLUMN CONTINUOUS ACTION STEP

7 Stabilize S/G Levels: *

a. Check S/G levels - GREATER a. Perform the following: *

THAN [51%] 29% *

1) Maintain total feed flow *

greater than 200 gpm until S/G *

level greater than [51%] 29% *

in at least one S/G. *

2) IF total feed flow NOT greater *

than 200 gpm, THEN verify *

valve alignment and start *

pumps as necessary to *

establish total feed flow *

greater than 200 gpm. *

b. Control feed flow to maintain SIG b. IF level in intact S/G continues *

levels between [51%] 29% and 65% to rise, THEN stop feed flow to *

that S/G.

DIAGNOSTIC STEP 17 Check If Diesels Should Be Stopped:

a. Check 4160 Vac safeguards buses a. Restore offsite power to 4160 Vac ENERGIZED BY OFFSITE POWER safeguards buses

1A-05, train A

1A-06, train B

b. Stop all unloaded EDGs:

"o For G-01 OR G-02 use OP-11 A, EMERGENCY DIESEL GENERATOR "o For G-03 OR G-04 use OP- I1B, EMERGENCY DIESEL GENERATOR Page 44 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE ATTACHMENT D (Page 3 of 4)

EXAMPLES OF STEP CONSTRUCTION, DUAL COLUMN EOUALLY ACCEPTABLE SUB STEPS 55 Go To Appropriate Post-Steam Generator Tube Rupture Cooldown Procedure:

o Go to EOP-3.1 UNIT 1, POST-STEAM GENERATOR TUBE RUPTURE COOLDOWN USING BACKFILL OR o Go to EOP-3.2 UNIT 1, POST-STEAM GENERATOR TUBE RUPTURE COOLDOWN USING BLOWDOWN OR o Go to EOP-3.3 UNIT 1, POST-STEAM GENERATOR TUBE RUPTURE COOLDOWN USING STEAM DUMP RECURRENT STEP

17. Check Surge Tank Level Repeat Steps 13 through 16 STABLE every 5 to 10 minutes until surge tank level is stable.

Continue with Step 18.

Page 45 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' OUIDE ATTACHMENT D (Page 4 of 4)

EXAMPLES OF STEP CONSTRUCTION, DUAL COLUMN TIME-DEPENDENT STEP d) WHEN containment spray has has been actuated for greater than two minutes, THEN ensure at least one spray additive eductor suction valve open "o2SI-836A, train A "o2SI-836B, train B VERIFICATION STEP

25. Verify Service Water System

a. Ensure service water header a. Manually start pump(s) and align pressure - GREATER THAN OR valves as necessary to establish EQUAL TO 40 PSIG service water header pressure greater than or equal to 40 psig.

Page 46 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT E (Page 1 of 1)

STATUS TREE PRIORITY IDENTIFICATION SYMBOLS COLOR LINE PATTERN TERMINUS STATUS/RESPONSE CODE CODE The critical safety function is under extreme challenge and immediate Red Ooperator action is required.

The critical safety function is under Orange un Orang[ *

[r severe challenge and prompt operator 4:1][][][

action is required.

The critical safety function condition is

( off-normal and operator action may be Yellow taken but is not required.

Green The critical safety function is satisfied G0 and no operator action is required.

Page 47 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE ATTACHMENT F (Page 1 of 1)

SAMPLE FORMAT POINT BEACH NUCLEAR PLANT CSP-S.2 UNIT 1 YELLOW EMERGENCY OPERATING PROCEDURES MAJOR Revision DRAFT 4/8/99 RESPONSE TO LOSS OF CORE SHUTDOWN Page 2 of 3 SON/EECTED RESPONSE RESPONSE NOT OBTAINE NOTE Foldout page shall be monitored throughout this procedure.

Check Intermediate Range-Flux LESS- Perform the following:

THAN l.5xl0"° AMPS

a. If flux trending lower. TEEN

"*IN-35. train A perform the following:

"* IN-36. train B

1) Monitor flux.

2) WHEN flux less than l.5xl0"10 amps. TREK go to Step 2. Continue with procedure and sten in effect.

b. R flux NOT trending lower AND undercompensation is suspected.

THE go to Ste2 2.

c. IF flux FMT trending lower AND intermediate range channels are NOT undercompensated. THEN borate RCS until flux is less than l.5XlO2 sups.

4 2 Verify Source Range Channels Operating:

a. Check source range detectors - a. Depress both intermediate range BOTH ENERGIZED permissive defeat push-buttons.

- 1N-31. train A

- 1N-32. train B

b. Transfer both pens of NR-45 recorder -to source range scale 3 Check Source Range Channels Startup Borate RCS until source range Rate - ZERO OR NEGATIVE - startup rate is negative or zero.

"* IN-31. train A

"*1N-32. train B CONTINUOUS USE Page 48 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT G (Page 1 of 26)

SINGLE COLUMN AOP FORMAT 1.0 SINGLE COLUMN AOP FORMAT 1.1 Required Sections For Single Column AOPs 1.0 PURPOSE 2.0 DISCUSSION 3.0 SYMPTOMS 4.0 INITIAL RESPONSE - AUTOMATIC 5.0 INITIAL RESPONSE - MANUAL 6.0 SUBSEQUENT ACTIONS FIGURES ATTACHMENTS 1.2 Page Header format 1.2.1 The header printed on every page will be in accordance with Point Beach Nuclear Plant Procedures Writers' Guide. The following information shall appear within the header.

a. POINT BEACH NUCLEAR PLANT.

b. Manual type.

c. Leave one empty row between the manual and the title. The title should be on the bottom line of the header.

(see example below)

d. Title.

e. Unit number (if applicable).

f. Document number.

g. Classification.

Page 49 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT G (Page 2 of 26)

SINGLE COLUMN AOP FORMAT

h. Revision number.

i. The word DRAFT shall be used in the title block to designate a procedure that has not received Manager's Supervisory Staff approval.

j. Current date (do NOT use a date code).

1.2.2 The descriptor REVISION 0 shall be used in the title block to designate the original issuance of each procedure.

1.2.3 The following are examples of how some headers appear in documents:

POINT BEACH NUCLEAR PLANT AOP X.XX ABNORMAL OPERATING PROCEDURE CLASSIFICATION Revision XX DRAFT TITLE Month, Day, Year UNIT X TOTAL REWRITE POINT BEACH NUCLEAR PLANT AOP XX ABNORMAL OPERATING PROCEDURE CLASSIFICATION Revision XX DRAFT TITLE Month, Day, Year 1.3 Page Footer format NOTE: All footers are in Times New Roman 12PT.

1.3.1 The footer printed on every page will be in accordance with Point Beach Nuclear Plant Procedures Writers' Guide. The following information shall appear within the footer.

a. Page number.

b. Total number of pages in the procedure.

Page 50 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT G (Page 3 of 26)

SINGLE COLUMN AOP FORMAT 1.3.2 In addition to the procedure page count, attachments will also provide a section page number and total attachment page count under the attachment title. The attachment title is located under the header block.

1.4 Revision Identification 1.4.1 To identify revision to the text of a procedure, a change bar located in the left side of the changed text will be used.

1.4.2 Total rewrite revisions will not utilize revision change bars.

1.5 Attachments 1.5.1 Attachments, figures, and tables may be attached to the procedure to provide additional information. Attachments may be used to simplify transitioning within a procedure if a series of actions may be required in more than one place within the same procedure.

1.5.2 Attachment Pages

a. Attachments shall be designated by sequential capital letters.

b. Attachments are identified with the following header centered immediately below the page header block.

Page 51 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS' GUIDE ATTACHMENT G (Page 4 of 26)

SINGLE COLUMN AOP FORMAT Figure Pages 1.5.3

a. Figures shall be designated by sequential Arabic numbers.

b. Figure pages located at the end of the document are identified with the following header centered immediately below the page header block.

EXAMPLE FIGURE 1 TITLE

c. Related figures may be shown on the same page under a single title.

Figures identified with a separate title should be shown on a separate page.

d. Graphical information or pictures may also be presented as figures at the end of the document as a figure page.

e. The independent variable on all graphs should be plotted on the horizontal axis.

f. Figure numbers or titles may be used within the text of a document but are not required. If they are used, all figures within the document should be numbered.

1.5.4 Tables

a. Tables may be used within the text or attachments of a document to clearly present information.

b. Table numbers or titles may be used but are not required. If they are used, all tables within the document should be numbered.

c. There should not be a vacant cell in the table. If no entry is necessary, "NA" or "- -" should be entered to indicate not applicable.

Page 52 of 77 INFORMATION USE

POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE ATTACHMENT G (Page 5 of 26)

SINGLE COLUMN AOP FORMAT 2.0 FORMAT AND STYLE REQUIREMENTS 2.1 Step Length and Content 2.1.1 Steps should be written in short and precise language.

2.1.2 The writer should consider that persons using the procedure may have a different background or skill level than the writer. Generally procedures should be written so that a fully qualified person can perform the procedure.

2.1.3 Individual steps should be limited to a single action or no more than three closely related actions.

2.1.4 Limits should be expressed quantitatively whenever possible. An example of limits which cannot be expressed quantitatively are the cooldown limits specified by a curve.

"2.1.5 The following guidelines should be followed when applying to sequencing of steps within the document:

2.1.6 Technical necessity should be the overriding consideration for step sequencing.

2.1.7 Physical layout and organization of equipment should be considered so that optimal movement and monitoring are achieved.

2.1.8 Steps should be structured to minimize the movement of personnel around the Control Room or the plant during performance of the procedure.

2.1.9 Steps should be structured to avoid unintentional duplication of tasks.

2.1.10 All numbered steps should be assumed to be performed in sequence unless stated otherwise in a preceding note.

2.1.11 Expected results of routine tasks need not be stated.

2.1.12 When considered beneficial for proper understanding and performance, provide the system response time associated with performance of the instruction.

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POINT BEACH NUCLEAR PLANT OM 4.3.1 OPERATIONS MANUAL Revision 5 September 13, 2002 AOP AND EOP WRITERS'GUIDE ATTACHMENT G (Page 6 of 26)

SINGLE COLUMN AOP FORMAT 2.1.13 When system response dictates a time frame within which the instruction must be accomplished, prescribe such time frame. Avoid using time to initiate operator actions. Operator actions should be related to plant parameters.

2.1.14 When additional confirmation of system response is considered necessary, prescribe the backup readings to be taken.

2.1.15 Definitions of key words and phrases used in procedures are listed in Attachment A, Definitions of Key Words and Phrases.

2.1.16 Items that are unique to the procedures are listed in Attachment B, Abbreviations, Acronyms, and Symbols. These items are used to help in keeping procedures concise.

2.1.17 When used in statements other than logic statements, "not" shall stand for the negative of the proceeding group of words.

2.1.18 Procedures shall be structured so that they can be executed by the minimum shift staffing and Control Room staffing required by Technical Specifications.

2.2 Use of Logic Terms 2.2.1 The logic terms AND, OR, IF, IF ...NOT, WHEN...THEN, and IF...THEN are often necessary to precisely describe a set of conditions or sequence of actions.

2.2.2 When logic terms are used, they should be in all capital letters and underlined so that all conditions are clear to the document user.

2.2.3 When steps are contingent upon certain conditions or combinations of conditions, the step should be formatted in accordance with one of the following examples:

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SINGLE COLUMN AOP FORMAT 2.2.4 Use of the logic term IF...NOT should be limited to those cases where the document user must respond to the second of two possible conditions. The logic term IF should be used to specify the first condition, as shown in the above example.

2.2.5 The logic term THEN should always follow a condition, not an action. This ensures only one action exists for each step.

EXAMPLES Ensure spray addit ion tank level has been lowered by at least 12%, THEN stop containment spray (Unacceptable)

WHEN spray addi tion tank level has been lowered by at least 12%, THEN stop containment spray. (Acceptable) 2.2.6 Action steps should be performed in sequence so that a conjunction such as "and" is not required between steps. However, in the case of combinations of conditions within a single step, the logic term AND should be placed between the description of each condition.

2.2.7 In order to simplify a long sequence of conditions, the logic term AND should not be used to join more than three conditions. If more than three conditions need to be joined, a list format should be used.

EXAMPLES IF all of the following conditions are met, THEN perform action.

"* Condition A

"* Condition B

"* Condition C

"* Condition D

Condition E Page 55 of 77 INFORMATION USE

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SINGLE COLUMN AOP FORMAT 2.2.8 When used for connecting actions in a step, the word "and" need not be emphasized.

2.2.9 The logic term OR should be used between alternative conditions. It should be used in the inclusive sense, meaning that any one or all of the conditions may be present.

2.2.10 The word "or" (not a logic term) should be used between alternative actions.

It should be used in the exclusive sense, meaning that only one action is to be performed.

2.2.11 Presenting alternative actions without stating priorities should be minimized.

Priorities should be established for each action where possible.

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SINGLE COLUMN AOP FORMAT 2.2.12 The use of logic terms AND and OR within the same step should be worded so as to avoid confusion or ambiguity, as shown in the following example.

EXAMPLE IF condition A AND condition B OR condition C occurs, THEN go to Step X.

This example can have two possible meanings and should be worded instead as either one of the following:

Meaning Number 1:

"oIF both condition A AND condition B occur, THEN go to Step X.

OR "oIF condition C occurs, THEN go to Step X.

Meaning Number 2:

"oIF both condition A AND condition B occur, THEN go to Step X.

OR "oIF both condition A AND condition C occur, THEN go to Step X.

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SINGLE COLUMN AOP FORMAT 2.2.13 Conditional statements in notes and cautions should follow all requirements for logic terms with the following exceptions:

a. They should be written in lower case with no underline.

b. The logic term THEN should not be used.

EXAMPLES

" IF condition A AND condition B, THEN result. (Unacceptable in notes and cautions)

"* If condition A and condition B, result. (Acceptable in notes and cautions) 2.3 Use of Cautions and Notes 2.3.1 Non-action information should be presented as either a note or caution.

2.3.2 A caution is used to present information regarding potential hazards to personnel or equipment associated with the subsequent step(s).

2.3.3 A note is used to present advisory or administrative information necessary to support performance of the subsequent step(s).

2.3.4 Notes or cautions shall appear immediately before the step to which they apply.

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SINGLE COLUMN AOP FORMAT 2.3.5 Cautions should appear within the page border, extending across the appropriate page width, inside a distinct box and in bold font. The word CAUTION in all capital letters, bolded and underlined, should be centered at the top of the box.

CAUTION This is the CAUTION format.

2.3.6 The appropriate page width is defined as the same width as the step to which the CAUTION applies.

2.3.7 Notes should appear within the page border, extending across the appropriate page width and in bold font. The word NOTE in all capital letters and bolded should be at the beginning of the line.

NOTE: This is the NOTE format.

2.3.8 The appropriate page width is defined as the same width as the step to which the NOTE applies.

2.3.9 Notes may be grouped together with each individual note identified with a closed bullet (e).

2.3.10 Cautions may be grouped together with each individual caution identified with a closed bullet (o).

2.3.11 Cautions shall precede notes when they appear together unless the note contains information which clarifies the caution.

2.3.12 Notes and cautions and the first applicable step shall not be split between pages.

2.3.13 Notes and cautions themselves shall not be split between pages.

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SINGLE COLUMN AOP FORMAT 2.3.14 The following guidelines apply to the wording in notes and cautions:

a. Each document should provide enough information to accomplish the purpose of the document without relying on information contained in notes or cautions.

b. Notes and cautions should be declarative statements of fact and not commands or action statements unless they are advising on actions to be taken in the event of changing plant conditions.

c. Notes and cautions which are repeated in different documents should have standardized wording whenever possible.

2.4 Use of Underlining 2.4.1 Underlining will be used for emphasis of logic terms and to designate transitions.

2.5 Transitions to Other Procedures or Steps 2.5.1 Examples of transition from several procedures for the same or different reasons are listed in Attachment C, Symptom or Entry Condition Examples.

2.5.2 Transitioning is defined as leaving the procedure at the current step and resuming actions in another procedure or step within the current procedure.

2.5.3 Since transitioning is likely to lead to errors in implementation by interrupting the flow of guidance, documents should be written to minimize the use of transitions. For example, if short sections of other procedures are required, those sections may be copied into the procedure instead of transitioning to the other procedure.

2.5.4 Transitions to other procedures do not contain an automatic return feature. If it is desired to return to the procedure which caused the transition, words such as "return to procedure and step in effect" must appear in the procedure being transitioned from.

2.5.5 A transition is identified by underlining the transition.

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SINGLE COLUMN AOP FORMAT 2.5.6 Steps which create a transition to another document should be formatted in accordance with the following example:

EXAMPLE Transitions to another document:

o Go to EOP-0.1. REACTOR TRIP RESPONSE.

2.5.7 Transitions to an earlier or a later step in the current document or to an attachment in the current document should be formatted in accordance with the following example:

EXAMPLE Transitions within the current document:

"* Go to Step 10.

"* Return to Step 2

"* Go to ATTACHMENT A.

2.5.8 Transitions to steps within the current document which are preceded by a caution or note should be formatted in accordance with the following example:

EXAMPLE Transitions to steps in the current document with preceding notes or cautions:

" IF conditions are NOT satisfied, THEN OBSERVE NOTE PRIOR TO STEP 1 and return to Step 1.

"* IF conditions are NOT satisfied, THEN OBSERVE CAUTION PRIOR TO STEP 10 and go to Step 10.

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SINGLE COLUMN AOP FORMAT 2.6 Branching to Other Documents 2.6.1 Branching is defined as the concurrent performance of two or more documents. Branching can also apply to the use of attachments to the main document.

2.6.2 Each document should contain all the guidance necessary to perform the course of action. Therefore, the writer should limit the use of branching whenever possible.

2.6.3 Branching should be used for the following situations:

a. When a complex or time consuming operation is required which could delay performance of the main document.

b. When more than three local operator actions are necessary which do not require close supervision by the performer of the main document.

c. When it is desired to delegate supervision of a particular task sequence to another individual.

2.6.4 Steps which create a branch should contain the following information in the order shown:

a. A brief description of the actions to be accomplished in the document being branched to.

b. The term "per."

c. The document number and title in all capital letters. When branching to an attachment within the current document, it is only necessary to specify the attachment designator in all capital letters.

d. When branching to an attachment in another document, the appropriate attachment designator at which to enter the other document should be included following the document title.

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SINGLE COLUMN AOP FORMAT

e. The words "while continuing with this procedure (instruction)" should be placed at the end of the sentence to emphasize the need for concurrent performance.

EXAMPLES

1. Check Emergency Diesels ANY RUNNING UNLOADED

a. Stop any unloaded diesel per OP 11 A, EMERGENCY DIESEL GENERATOR 2.7 Referencing 2.7.1 Referencing is defined as the use of other documents or sources of information to perform the current step. Referencing also applies to obtaining guidance from plant management or plant engineering staff.

2.7.2 Referencing is usually made to figures or other sources of information that are too lengthy to be provided in the step.

2.7.3 Referencing to a document is designated by the term "refer to" followed by the document designator.

2.7.4 Referencing to a person for guidance is designated by the terms "as determined by" or "as directed by" followed by the title.

EXAMPLES "o Refer to ATTACHMENT A for list of valves receiving containment isolation signal.

"o Adjust RMS high alarm setpoint to clear alarm as directed by TSC.

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SINGLE COLUMN AOP FORMAT 2.8 Component Identification 2.8.1 The preferred method for identifying equipment in procedures is to use the name and number of the equipment.

(Word Paraphrasing Method)

EXAMPLES "o Emergency Diesel Generator G01 "o Letdown Containment Isolation Valve CV-371 2.8.2 When two or more equipment numbers can be associated with the same equipment name, the equipment numbers should be listed below the equipment name.

EXAMPLE

1. Shut Letdown Orifice Isolation Valves

CV-200A

CV-200B

CV-200C 2.8.3 When a list of equipment is included in a procedure, the equipment number followed by a comma and the equipment name should be listed.

EXAMPLE

1. Locally ensure the following valves open:

2SF-820B, RWST to P-33 refueling water circulating pump valve

"* lSF-820, RWST to P-33 refueling water circulating pump valve Page 64of 77 INFORMATION USE

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SINGLE COLUMN AOP FORMAT 2.8.4 In some cases it may be desired to identify the component exactly as it appears on the component label.

(Verbatim Method)

a. This method should be used when Control Room annunciator legends are provided in documents.

b. This method should be used when component nameplate identification is provided as part of an equipment lineup checklist which is intended to be read by the document user performing the equipment manipulation.

c. This method should be used when other identification methods have resulted in confusion.

EXAMPLE

EDG GO1 2.8.5 When only a generic reference to a component is being made, the equipment number is not needed.

(Common Usage Method)

EXAMPLES Start one emergency diesel generator Identify all open containment isolation valves Page 65 of 77 INFORMATION USE

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SINGLE COLUMN AOP FORMAT 2.9 Level of Detail Too much detail in abnormal operating procedures should be avoided in the interest of being able to effectively execute the instructions in a timely manner. The level of detail required is the detail that a newly trained and licensed operator would desire during an abnormal condition.

To assist in determining the level of detail for abnormal operating procedures, the following general rules apply.

2.9.1 Actions may unintentionally be performed incorrectly or omitted if a procedure lacks needed information. On the other hand, excessive detail can result in the procedure being time consuming or in steps being missed due to the user scanning over the procedure. To determine the appropriate level of detail the following factors should be considered:

a. User knowledge and skills (skill of the craft).

b. Complexity of task.

c. Task frequency.

d. Past experience in implementing the procedure.

2.9.2 Recommended action verbs are as follows:

a. Use "start/stop/pullout" for power-driven rotating equipment.

b. Use "open/shut/throttle" for valves.

c. Use "trip/close/lockout/pullout" for electrical breakers.

2.9.3 Standard practices for observing abnormal results need not be prescribed within procedural steps. For example, observations of noise, vibration, erratic flow, or discharge pressure need not be specified by steps that start pumps.

2.9.4 Procedure steps will be numbered and substeps indented as follows:

1.0 Section Title 1.1 High Level Step 1.1.1 First Level Substep

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SINGLE COLUMN AOP FORMAT 3.0 MECHANICS OF STYLE 3.1 Spelling Spelling should be consistent with modern usage. When a choice of spelling is offered by a dictionary, the first spelling should be used.

3.2 Punctuation Punctuation should be used only as necessary to aid reading and prevent misunderstanding. Word order should be selected to require a minimum of punctuation.

When extensive punctuation is necessary for clarity, the sentence should be rewritten and possibly made into several sentences. Punctuation should be in accordance with the following rules.

3.2.1 COLON should be used to indicate that a series of related substeps or a list is to follow.

3.2.2 COMMA should be used:

a. Prior to the logical term THEN.

b. To separate items in a series.

c. Prior to the conjunction in a series.

d. To separate five or more digits in a numeral.

EXAMPLES o IF conditions satisfied, THEN take action.

o Unlock, rack in, and close the following breakers:

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SINGLE COLUMN AOP FORMAT 3.2.3 HYPHENATION of words should be minimized while meeting the following guidelines: