ML030770638

Temporary Change Review & Approval, OM 4.3.2, Eop/Aop Verification/Validation Process

ML030770638
Person / Time
Site:	Point Beach
Issue date:	09/25/2002
From:	Vandenbosch T Nuclear Management Co
To:	Office of Nuclear Reactor Regulation
References
FOIA/PA-2003-0094, TCN 2002-0616 OM 4.3.2, Rev 3
Download: ML030770638 (33)

Text

Nuclear Power Business Unit g *.'

TEMPORARY CHANGE REVIEW AND APPROVAL 7

Note: Refer to NP 1.2.3, Temporary Procedure Changes, for requirements.

Page 1 of 3

I - INITIATION Doc Number OM 4.3.2 Current Rev 3 Unit PB0 Temp Change No. TCN 2002-0616 Document Title EOP/AOP VERIFICATIONIVALIDATION PROCESS Existing Effective Temporary Changes NONE Brief Description INCORPORATE FEEDBACK OPS 2002-01364, 2002-01416 (Identify specific changes on Form PBF-0026c, Document Review and Approval Continuation, and include with the package) 0 Initiate PBF-0026h and include with the change.

Other documents required to be effective concurrently with the temporary change:

NONE Changes pre-screened according to NP 5.1.8?

El NO 0 YES (Provide docunmntation according to NP 5.1.8)

Screening completed according to NP 5.1.8?

0 NA El YES (Attach copy)

Safety Evaluation Required? 0 NO E] YES (aryfs a revision my be pr*cmsed or finsl revitei and aprov-ls shall be obtaiaed beforc implementing)

Determine if the change ctrnstitutes a Change Of Intent to the procedure by evaluating the following questions.

(If any answers are YES, a revision maybe processed or final reviews and approvals shall be obtained before implementing)

Will the proposed change:

YES NO

1. Require a change to, affect or invalidate a requirement, commitment, evaluation or description in the Current or ISFSI Licensing Basis (as defined in NP 5.1.8 and NP 5.1.7)?

El 0

C

2.

a.Cuse an increase inrmagnitude, significance orimpact such that it zhould be prccessnd as E revision?

Imp

3.

Delete or modify a prerequisite, initial condition, precaution, limitation or other steps that could have safety significance or affect the procedure's margin of safety?

4. Delete QC hold points, Independent Verification or Concurrent Check steps without the related step(s) that require the performance also being deleted?

5. Change Tech Spec or other regulatory acceptance criteria other than for re-baselining El Z

purposes?

6. Require a change to the procedure Purpose or change the proceclsiflca

?

El 0

Initiated By (printisign)

T VANDENBOSCH I

tDate 09/25/2002 H - INITIAL APPROVAL This change is correct and complete, can be performed as written does not adversely affect personnel or nuclear safety, or Plant operatin* cndi en'doe Group Supervisor (printsign)

1. t Date

"(Cannot be the Initiator)

This change does not adversely affect Plant operating conditions. (Safety Related procedures o ly)

Senior Reactor Operator (print/sign)

J:7. ?.n-1-5c4

=

_*"t Date (Cannot be the Initiator or Group Supervisor)

III - PROCEDURE OWNER REVIEW 0 Permanent El One-time Use El Expiration'Date, Event or Condition:

El Hold change until procedure completed (final review and approval still required within 14 days of initial approval) 09 QR/MSS Review NOT Required (Admin/NNSR only)

El QR Review Regu-wed E] MS§ iwRequcsR0 4

(Ref.r.N.PAA.)

Procedure Owner (print/sign) 7 1jt"

-t*/

Aa.,.-

Date This Chanee and sutmortinsfreauirements correctly completed and nrocess6d.

IV - FINAL REVIEW AND APPROVAL (Must be comoleted within 14 days of Initial anorovall

)(The Initiator. OR and Anoroval Authority shall be Indenendent from each otherl OR/MSS (print/sign)

/.) j

/A Date Indicates 50.59/72.4 applicability assessed, anyA1'ecessary screenings/evaluations-ormed, determination made as to whether additional cross-disciplinasy review required, and if required, performed.

MSS Meeting No.

osr

/.

Avproval Authority (vrint/sin)

/

/

Date V - REVISION INFORMATION FOR PERMANENT CHANGES Post Typing Review (print/sign)

I Date Indicates temporary change(s) incorporated exactly as approved and no other changes made to document.

eivD

1.

Incorporated into Revision Number

______Effective Date PBF-0026e

References:

NP 1.23 Revision 13 01/16/02

Point Beach Nuclear Plant DOCUMENT REVIEW AND APPROVAL CONTINUATION Doc Number OM 4.3.2 Revision 3

Unit PB0 Title EOP/AOP VERIFICATION/VALIDATION PROCESS Temporary Change Number 2002-0616 Description of Changes:

Step

• Change/Reason 4.2.4 Changed (should) to (shall)./ Corrected terminology 4.2.12 Changed [should) to (shall) and changed (major) to (technical). / Corrected terminology.

Added (Probabilistic Risk Assessment). I PRA knowledge is important in the development of technically correct procedures that maintain plant safety.

Other Comments L

Note: Recording of Step Number(s) is not required for multiple occurrences of identical information or when not beneficial to reviewers.

PBF-0026c Revision 6 04/l1/01

References:

NP 1.1.3. NP 1.2.3 Page 2

of 3

Point Beach Nuclear Plant TEMPORARY CHANGE-AFFECTED MANUAL LOCATION Page 3

of 3

Procedure Number OM 4.3.2 Revision 3

Unit PBO Title EOP/AOP VERIFICATION/VALIDATION PROCESS Temporary Change Number TCN 2002-0616 I - IMMEDIATELY AFTER INITIAL APPROVAL ON PBF-0026e (Non-Intent changes)

(after Final Approval if change of intent involved)

This procedure change has been processed as follows: (Manual/Location)

Date Performed EL Copy included in work package for field implementation. (WO No.

)

[1 Copy filed in Control Room temp change binder (Operations only).

IX!

Original change package provided to to obtain Procedure Owner Review (e-&, Owner review may be coordinated by In-Group OA I1, Procedure Writer, Procedure Supervisor, etc.).

El,_

Performed By (print and sign)

Date

.. - PROCEDIJRE OWNER REVIEW ON PBF-0026e S(nmay be performed by OA II, Procedure Writer, etc.)

This procedure change has been processed as follows: (Manual/Location)

Date Performed

[]

Copy sent to Document Control Distribution Lead for Master File.

(Not required for one-time use change) 0-Copy filed in Group satellite file. (Not required for one-time use changes.)

El Copy filed in Group one-time use file.

Original Temp Change provided to to obtain Final Approvals (e.g., final approval may be coordinated by In-Group OA II, Procedure Writer, Procedure Supervisor, etc.)

El Pe Performed By (print and sign)

/Date_____

PBF-0026h Revision 5 06/13/01

-I-

Reference:

NP 1.2-3

Point Beach Nuclear Plant 10 CFR 50.59/72.48 APPLICABILITY FORM Page 1 Brief Activity Title OM 4.3.2, EOPIAOP VERIFICATION/VALIDATION PROCESS or

Description:

This form is required to be completed and attached to the applicable activity change forms to document all or portions of an activity that are covered by another regulation other than 10 CFR 50.59 and 10 CFR 72.48 (pre-screening criteria 2). See NP 5.1.8, 10 CFR 50.59/72.48 Applicability, Screening and Evaluation (New Rule).

NOTE: Guidance for searching the FSAR, Technical Specifications, Regulatory Commitments (CLB Commitment Database) and other licensing basis documents can be found in NP 5.1.8, Attachment G.

NOTE: Although 10 CFR 50.59 and 72.48 may not be applicable to the processes listed below, change activities conducted under these processes may require changes to the FSAR. If so, initiate FSAR Regulatory or Plant Process YES NO

1.

Does the activity require a change to the Facility Operating License, License Conditions or Technical Specifications? (If the answer is YES, process the applicable changes per EU 19 NP 5.2.7, License Amendment Request Preparation, Review and Approval.)

2.

NOTE: The Quality Assurance Plan is described in FSAR Section 1.4.

Does the activity require a change to the Quality Assurance Program? If the answer is U

YES, process the applicable changes per NP 11.1.3, QA Program Revisions.

3.

NOTE: Implementation of Security Plan changes that require physical changes to the plant, or changes to operator access to the plant require a screening.

NOTE: Security is described in FSAR Section 12.7.

Does the activity require a change to the PBNP Security Plan, a safeguards contingency U

plan, or security training and qualification plan? If the answer is YES, assess the acceptability of the change per 10 CFR 50.54(p) using Security procedures.

4.

NOTE: The Emergency Plan is described in FSAR Section 12.6.

Does the activity require a change to the Emergency Plan? If the answer is YES, process the applicable changes per NP 1.8.1, Emergency Preparedness Procedures.

5.

NOTE: The Radiation Protection Program is described in FSAR Section 11.4.

Does the activity require a change to the PBNP Radiation Protection Program described U

0 in NP 4.2.9, Radiation Protection, OR is the activity within the scope of NP 4.2.9 and 10 CFR 20, Standards for Protection Against Radiation?

6.

NOTE: Changes to the plant or method of evaluation that result in re-analysis of the FSAR loss-of-coolant accident (LOCA) analysis require a screening.

Does the activity require a change to the FSAR LOCA analysis results subject to 10 CFR 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light-U Water Nuclear Power Reactors? If the answer is YES, process the applicable changes per NP 5.2.12, 10 CFR 50.46 Reporting Requirements, and NP 5.2.6 FSAR Revisions.

7.

NOTE:

Regulatory commitments are found in the CLB Commitment Database.

Does the activity involve a change to a Regulatory Commitment ? If the answer is YES, Ul E

process the applicable changes per NP 5.1.7, Regulatory Commitment Changes.

8.

Does the activity involve a change to the Environmental Manual (EM), Radiological Effluent Control Program Manual (RECM), Offsite Dose Calculation Manual (ODCM),

or Process Control Program (PCP), AND does NOT involve changes in use of explosive Ul E

gases in waste treatment systems? If the answer is YES, document the applicable changes per the requirements of TS 15.7.8.7.B {ITS 5.5.1}.

I_

I PBF-1515a Revision 0 10/24/01 Reference NP 5.1 8

Point Beach Nuclear Plant 10 CFR 50.59/72.48 APPLICABILITY FORM Page 2 Regulatory or Plant Process YES NO NOTE: For purposes of determining 10 CFR 50.59 / 72.48 applicability, the determination of an administrative procedure below takes precedence over definitions or classifications in other plant procedures or guidelines.

9.

Does the activity require a change to an administrative procedure or controlled document ONLY?

0 El ALL of the following statements shall be true for the procedure or controlled document to be considered administrative.

a. DOES NOT direct how plant structures, systems, or components are operated, maintained, tested or repaired either specifically QR generically.

b. DOES NOT specify acceptance criteria or operating limits for plant structures, systems, or components.

- c.

)OtS NOT aptacifyjfns, n awriai hefnicals, ubniemits,-etc: lo ue usCu ii pilaai structures, systems, or components.

d. DOES NOT specify compensatory action(s) to address plant structures, systems, or components out of service, or to address non-conforming conditions.

e. DOES NOT affect operator access to operating areas of the plant.

10 CFR 50.59172.48 APPLICABILITY CONCLUSION PBF-1515a Revision 0 10/24/01

Reference:

NP 5 1.8

.

NOTE: If ANY portion of the activity is NOT controlled by one or more of the processes above, further 10 CFR 50.59 / 72.48 review is required L.e., portions not covered by the above processes shall be prescreened to other criteria or screened).

AL.L aspects of the activity are controlled by one or more of the processes above, therefore NO YES NO additional 10 CFR 50.59 and 72.48 review is required.

0 LI If the above question is answered NO. briefly describe the portions of the activity NOT covered by one or more of the above processes:

Performed By T VANDENBOSCH Date 09/25/2002 Name (Print) ig&nature Reviewed By C

'S )-

/

/

/

zf

)

Date - ?/

'40 1

Name (Print)

Signature

OM 4.3.2 EOP/AOP vrATION/ v A,_)AT-iON PROCESS DOCNUMENT TYPE:

REVISION:

EFFECTIVE DATE:

APPROVAL AUTHORITY:

PROCEDURE OWNER (title):

OWNER GROUP:

Administrative 3

September 16,2002 Department Manager Group Head Operations

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS 1.0 PURPOSE The purpose of this procedure is to establish the requirements for the verification and validation processes for the Emergency Operating Procedures (EOP) and Abnormal Operating Procedures (AOP).

The verification and validation processes are applicable to procedures designated with EOP, ECA, SEP, CSP, ST, and AOP.

2.0 DISCUSSION

• 2.!

Verification of EOPs and AOPs is the process of independently checking that the procedures are technically-correct, anydilictffs ff6-ihec6respiondiffiERG/AR' guidance are justified, that the procedures are compatible with plant hardware, and that the procedures adhere to the guidance in OM 4.3.1, AOP and EOP Writers' Guide.

2.2 Validation of EOPs and AOPs is the process of exercising procedures to ensure that they are usable, that the language and level of information is appropriate, and that the procedures will function as intended. The validation requirements of this procedure are not applicable to revisions made for the correction of typographical errors.

2.3 The matrix in Attachment D was developed based on initiating events with a frequency of.

core damage greater than 1E-6 and an initiating event frequency of greater that IE-3. The selected scenarios were then compared to the procedures that the operator would most likely use to prevent core damage. It is expected that procedure validation would 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.

2.4 EOPs, AOPs, and supporting documentation are revised for the following reasons:

0 Plant design changes Operator comments or change requests Industry or plant operating experience 0

ERG or ARG revisions Corrective action program Tech Spec changes Revisions to'other related program instructions INFORMATION USE Page 2 of 28

POINT BEACH NUCLEAR PLANT OM 4:3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERTFICATION/VALIDAT]ON PROCESS 2.5 EOP revisions associated with design changes, Tech Spec changes, or other related procedure changes should hormally be implemented concurrently with the change. EOP revisions required to correct technical deficiencies in the EOPs shall be completed in a timely manner.

2.6 Operator requalification training on EOPs provides a means of periodically verifying the technical adequacy of emergency procedures. Operators and training personnel are responsible for ensuring that problems or discrepancies discovered in EOPs during training are documented. Proposed enhancements and suggestions for improvement of the EOPs should also be encouraged.

2.7 Temporary changes to the EOPs and AOPs will be processed and controlled by NP 1.2.3,

.Temporary Procedure Changes. These changes are usually limited to emergent technical changes!anWd do f-qtiiifee'rifiertionor vaiidatipu pcr this pr:c'-d,ý.,

3.0 RESPONSIBILIT/ES 3.1 Manager's Supervisory Staff (MSS)

The MSS shall have the responsibility of reviewing and approving'revisions to the EOPs and AOPs.

3.2 Operations Manager The Operations Manager shall have the overall responsibility for the EOP Verification and Validation processes.

The Operations Manager shall designate the personnel who will comprise the Verification Team.

3.3 EOP Writer The EOP writer shall determine the need for revision of the EOP supporting documents and develop revisions for those documents as necessary.

3.4 Nuclear Engineering Nuclear Engineering should coordinate the necessary changes if a revision to the EOPSTPT is required.

3.5 Reactor Enaineerine Reactor Engineering should initiate revisions to the Safety Parameter Display System (SPDS) if revision to CSP-ST.0, Critical Safety Function Status Trees, are required.

These revisions shall not be implemented until approval of the CSP-ST.0 revision.

INFORMATION USE Page 3 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 OE TNSeptember 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS 4.0 PROCEDURE 4.1 General 4.1.1 The Emergency Response Guideline (ERG) or Abnormal Response Guideline (ARG) documents shall be reviewed to evaluate the intent of the corresponding ERG/ARG steps and whether the proposed change constitutes a deviation from the WOG guidelines.

4.1.2 The applicab*le EOP Deviation Document shall be reviewed to ensure that previous commitments are properly evaluated and to assess the justification for the present version of the step.

..4..3

.ro

- l te l

o' -contai d in other em ergen.

y pr3 : i-z l.

be evaluated for potential impact.

4.1.4 When setpoints are involved, the EOP Setpoint Document (EOPSTPT) shall be reviewed to ensure that setpoints are correctly implemented and to determine if revision of the EOPSTPT is required.

4.1.5 Review the applicable portions of OM 4.3.1, AOP and EOP Writers' Guide, to ensure compliance with the writers guide.

4.1.6 All safety related deviations from the WOG guidelines shall be documented and justified in the associated Deviation Document.

4.2 Verification Process NOTE;:- Technical changes involve any of the following:

0 Changing the method of performing a step or the sequential order of steps Changing the intent of any step, note, or caution Adding, deleting, or changing numerical values, limits, bands, or setpoints a

Changing instrumentation or controls used in the procedure 0

Changing entry/exit conditions or symptoms 0

Addition or deletion of steps, notes, cautions, graphs, tables, etc.

a Any change which deviates from the WOG guidelines 4.2.1 Technical changes to EOPs should be verified by a multi-discipline team (at least three members) to maximize effectiveness of the verification process.

Non-technical (editorial) changes to EOPs and changes to AOPs may be verified by a single individual provided that the individual is a licensed operator and a qualified reviewer.

INFORMATION USE Pag~e 4 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS 4.2.2 Technical changes to EOPs and changes to AOPs should be evaluated using Attachment A, Technical Evaluation Guidelines. Changes to Critical Safety Function Status Trees should be evaluated using Attachment B, Status Tree Evaluation Guidelines.

4.2.3 To ensure an independent verification process, personnel who have been involved in the development of the procedures(s) being verified should not be selected as verifier or appointed to the Verification Team.

4.2.4 The Verification Team members shall consist of, as a minimum, a Chairman, C) a licensed operator (SRO or RO), and a Training representative. Other C

C members shall be selected based on the type of change(s) being made to the I4 procedure. For technical changes, a member of the PRA Group shall review the..........

ch' ages butidoes'i't h~i t6be a part ofthcerifitira nccti....

4.2.5 The Verification Team members shall be listed on PBF-2102a, EOP Verification Team Meeting Form.

4.2.6 Verification Team members should obtain source documents as necessary, such as WOG guidelines, Deviation Documents, and Background Documents.

Other documents such as Tech Specs, FSAR, and other supporting procedures may also be applicable.

4.2.7 Review applicable portion(s) of the revised procedure. Depending upon the scope of the revision, it may be necessary to review the entire procedure and other interfacing procedures to adequately verify the revision. If step numbering or sequencing is affected by the revision, then the entire procedure shall be verified for internal step number referencing.

NOTE:

Minor discrepancies may be resolved by the Verification Team without the use of PBF-2102b, EOP Verification Discrepancy Form.

4.2.8 Identify and document discrepancies on PBF-2102b, EOP Verification Discrepancy Form.

4.2.9 A safety evaluation, in addition to the screening review, should be prepared for changes which involve new deviations from the WOG guidelines.

INFORMATION USE Page 5 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16,2002 EOP/AOP VERIFICATIONIVALIDATION PROCESS NOTE:

The required reviews contained in the following steps may be performed concurrently with the verification process if the appropriate personnel are part of the verification team. If performed separately, the review should be identified as a Cross-Discipline Review. The Operations procedure writer is responsible for ensuring that assigned reviewers understand the scope of the review required.

4.2.10 Engineering shall review EOP/AOP revisions which involve any of the following:

a. New deviations from WOG guidelines or changes in the method or scope of deviations from the ERG or ARG.

b3. Addition, dele-tion, or changes in stonso e~ituae

c. Changes to status trees or other changes affecting SPDS displays.

d. Additions or changes to actions outside the control room which could impact radiation dose estimates.

e. Changes in instrumentation used in EOPs which could affect compliance with Reg Guide 1.97, Post Accident Monitoring Instrumentation.

f. Proposed revisions to AOPs that affect Technical Specifications surveillance requirements.

S4.2.11 Reactor Engineering should review proposed revisions to EOPs or AOPs C) which may affect Reactivity Management.

C I 4.2.12 The PRA Group shall review any proposed technical revisions to EOPs or Z

AOPs.

4.2.13 Organizations other than Operations (such as Chemistry, Radiation Protection, or Maintenance) should review proposed revisions to EOPs and AOPs which affect actions by the affected organization.

4.3 Resolution of Verification Discrepancies 4.ý.1 Verification discrepancies are documented using PBF-2102b, EOP Verification Discrepancy Form, so that future revisions will not undo corrections or improvements made as a result of the verification process.

4.3.2 The Validation Chairperson shall assign personnel (preferably those responsible for writing the procedures) to prepare a resolution for each discrepancy.

INFORMATION USE Page 6 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS 4.3.3 The personnel assigned to resolve the discrepancy shall:

a. Propose a resolution to correct the discrepancy on PBF-2102b, EOP Verification Discrepancy Form.

b. Obtain concurrence from the Verification Chairperson, as applicable.

c. If the Verification Chairperson does not concur with the resolution, coordinate efforts to assess and resolve the discrepancy.

d. Document the final resolution on PBF-2102b, EOP Verification Discrepancy Form.

"4.3.4 I~ffe todipehii lot bewsoivzd btween-t~c Fersorne!s'igvA 'o resolve the discrepancy and the Verification Chairperson, then the Verification Chairperson shall recommend a corrective action and obtain approval from the Operations Manager or designee.

4.3.5 After resolution of the discrepancy has been determined, the Verification

• Chairperson shall:

a. Ensure the procedure is changed to incorporate the resolution of the discrepancy.

b. Determine the scope of any additional verification required.

c. Document completion of the additional verification.

d. Determine if additional training is required and, if so, notify the Training Department.

INFORMATION USE Pagge 7 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS 4.4 Validation Process 4.4.1 The validation method shall be selected using the following guidance:

a. The simulator method is preferred and should be used, when practical, because this method:

a More accurately demonstrates operator response to a specific scenario.

0 Effectively identifies discrepancies between instructions and Control Room hardware.

Effectilyeid-en-tifi-es 'discrepancies... between"instructions and*'thie operators execution of them.

b. The walkthrough method should be used when:

Use of the simulator method is impractical due to modeling constraints or other limitations.

In combination with the simulator method when the simulator method is partially impractical.

When the revision affects action taken outside the Control Room.

For changes which do not warrant simulator validation due to the nature or scope of the change.

NOTE:

The walkthrough method is more effective than a table-top discussion in ensuring that the instructions contain the necessary level of detail arid are compatible with plant hardware and personnel.

c. The table-top method should be used only when the simulator and walkthrough methods cannot be used effectively OR for minor editorial or technical revisions which do not involve plant hardware and do not warrant simulator or walkthrough validation.

INFORMATION USE Page 8 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATIONIVALIDATION PROCESS 4.4.2 The Validation Team Leader shall be designated based upon the scope of the validation and the validation method(s) to be used. The Validation Team Leader should possess expertise in as many of the following areas as possible:

a. Supervisory skills

b. Plant Operations

c. Operations Training

d. Technical Bases

e. Development of EOP/AOPs 4.4.3 The Validation Team members requirements should be based on the following:

a. Technical changes to an EOP should be validated by a multi-disciplined team consisting of at least three members. Revisions to AOPs and minor changes to EOPs do not require a multi-disciplined team nor do they require a minimum of three team members.

b. The Validation Team should collectively be knowledgeable in the following areas:

0 Plant Operations 0

Training/Simulator Instruction Technical Bases Development of EOP/AOPs

°1 Probabilistic Risk Assessment C14

c. At least one member of the Validation Team shall be a licensed operator.

The operations personnel used as the operating crew for the validation scenarios may be included as part of the Validation Team.

d. At least one member of the Validation Team shall be a simulator instructor (N/A for walkthrough or tabletop validation methods).

e. The Validation Team members shall be listed on PBF-2103a, EOP Validation Form.

INFORMATION USE Page 9 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS 4.4.4 The Validation Team Leader shall review the PBF-2102a, EOP Verification Team Meeting Form and any PBF-2102b, EOP Verification Discrepancy Form(s) to determine the validation methods to be used and identify significant changes incorporated into the new procedure revision.

4A.5 The Validation Team Leader shall outline one or more scenarios encompassing the identified changes in the procedure. Select plant failures that will initiate the desire response, considering the following:

a. Use both single and multiple failures where practical.

b. Use concurrent and sequential failures where practical.

c... "...

.lJedii "ffiilurd§ kfie6mpi ictical."

d. If the simulator is to be used, select simulator malfunctions that closely model the selected failures.

4.4.6 Each validation scenario shall be docimented using on PBF-2103b, EOP Validation Scenario Form.

4.5 Simulator Validation Method 4.5.1 The Procedure Writer or Validation Team Leader should prepare for simulator validation as follows:

a. Schedule licensed operators and a simulator instructor to participate in the simulator validation. Operators selected should be representative of the iraining level expected of all operators.

b. Arrange for the needed resources to support the validation such as simulator time, copies of procedures and relate instructions, and copies of the scenarios to be covered.

c. Review the purpose and objective of the validation with the operator(s) involved. Include a discussion of the procedure revision.

d. Brief the operators on how the validation will be conducted.

e. Evaluate any known simulator characteristics which are different from the actual plant responses for impact on the validation.

INFORMATION USE Page 10 of,28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS

f. Prior to beginning the scenario, the Validation Team will discuss any differences between units that may come into play during execution of the scenario. The Validation Team Leader should ensure that the operators are aware of these differences and what effect they have on execution of the steps to be validated.

4.5.2 Conduct of the Simulator Method.

a. The operators will use the procedures in response to the scenario enacted on the simulator. The procedure writer may be present but should not interfere or provide guidance during the scenario.

b. The Validation Team will assess the procedures by noting any problems or deviations durnng the siatlato

c. At the conclusion of each simulator run, the Validation Team will conduct a debriefing as follows:

Evaluate the instruction using Attachment C, Validation Guidelines and document all discrepancies on PBF-2103c, EOP Validation Discrepancy Form.

0 Allow operators to present any problems or discrepancies that they identified during the simulator run. Document all discrepancies identified.

Discuss any deviations noted during the simulator run to identify discrepancies in the procedures.

d. Any portions of the procedure or other procedures impacted by the revision which cannot be validated on the simulator should be validated separately using the walkthrough or tabletop methods.

INFORMATION USE Page I11 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS 4.6 Walkthrough Validation Method 4.6.1 The Procedure Writer or Validation Team Leader should prepare for walkthrough validation as follows:

a. Schedule personnel to participate in the walkthrough. Individuals selected should be representative of the training level expected of all similarly qualified personnel.

b. Arrange for the needed resources to support the validation such as copies of procedures and relate instructions, and copies of the scenarios to be covered, and related technical documentation.

c. Review the purpose and objective of the validation with the personnel involved. Include a discussion of the procedure revision.

d. Brief the personnel on how the validation will be conducted.

e. Prior to beginning the walkthrough, the Validation Team will discuss any differences between units that may come into play during execution of the walkthrough. The Validation Team Leader should.ensure that the personnel are aware of these differences and what effect they have on execution of the steps to be validated.

4.6.2 Conduct of the Walkthrough Validation

a. Walkthrough validatidn should be performed at the in-plant location(s) where the procedure would be performed.

b. If the procedure being validated is written for either unit, then a walkthrough should be performed on both units.

c. The Validation Team Leader will use the scenario to direct the walkthrough by first providing the plant initial conditions and then providing appropriate cues while the personnel walk through each procedure step.

INFORMATION USE

. Page 12 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/ViALIDATION PROCESS

d. The personnel will use the procedures in accordance with the scenario and walk through or talk through actions they would take in response to each instruction step. Personnel should:

Describe actions they are taking.

0 Identify information sources used to take actions.

0 Identify controls used to carry out actions expected system response(s), how response(s) are verified, and action(s) to be taken if response(s) did not occur.

e. At any time during the walkthrough, personnel may stop to identify any problems-or discrepancies ini the procedurcs. -.Vidation Tear-member.

may ask questions during the validation.

f. The Validation Team will assess the procedures by noting any performance problems during the walkthrough.

g. At the conclusion of each walkthrough, the Validation Team will conduct a debriefing as follows:

Evaluate the instruction using Attachment C, Validation Guidelines.

Review comments made during the walkthrough and document all discrepancies identified.

Discuss any performance deviations to identify discrepancies in the procedures which resulted in the deviation.

INFORMATION USE Page 13 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATIONIVALIDATION PROCESS 4.7 Table-Top Validation Method 4.7.1 The Procedure Writer or Validation Team Leader should prepare for table-top validation as follows:

a. Schedule personnel to participate in the validation. Individuals selected should be representative of the training level expected of all similarly qualified personnel.

b. Arrange for the needed resources to support the validation such. as copies of procedures and relate instructions, and the scenarios to be covered.

c. Review the purpose and objective of the validation with the personnel

..inv..olved. "..i......d.......

i V6f ih proce'dffxe' revis-ici.

d. Brief the personnel on how the validation will be conducted.

e. Prior to beginning the scenario, the Validation Team will discuss any differences between units that may come into play during execution of the scenario. The Validation Team should ensure that the personnel are aware of these differences and what effect they have on execution of the steps to be validated.

4.7.2 Conduct of the Table-Top

a. The Validation Team Leader will use the scenario to direct the table-top discussion by first providing the plant initial conditions and then providing appropriate cues while the performer discusses each procedure step.

b. The personnel will use the procedures in accordance with the scenario, discussing the actions taken in response to each instruction step while identifying any problems or discrepaficies in the procedure(s).

c. During the table-top, the Validation Team will discuss and evaluate the instructions against Attachment C, Validation Guidelines. All discrepancies from the checklist or from individual comments will be documented on an on PBF-2103c, EOP Validation Discrepancy Form.

d. The Validation Team will assess the procedures by noting any performance problems during the walkthrough.

e. At the conclusion of the table-top discussion, the Validation Team will discuss any deviations to identify discrepancies in the procedures which resulted in the deviation and document all discrepancies on PBF-2103c, EOP Validation Discrepancy Form.

INFORMATION USE Page 14 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALDATION PROCESS NOTE:

EOP/AOP changes to resolve verification/validation discrepancies may require repeating portions of the verification and/or validation process.

4.8 Resolution of Validation Discrepancies 4.8.1 Validation discrepancies are documented using form PBF-2103c, EOP Validation Discrepancy Form, so that future revisions will not undo corrections or improvements made as a result of the validation process.

4.8.2 The Verification Team Leader shall assign personnel (preferably those responsible for writing the procedures) to prepare a resolution for each discrepancy.

4.8.3 Discrepancies nvb'lving Plan't repnse frOfi, iruiatr validation shall be evaluated to deterrfiine if they were caused or aggravated by simulator modeling deficiencies.

4.8.4 The personnel assigned to resolve the discrepancy shall:

a. Propose a resolution to correct the discrepancy on PBF-2103c, EOP Validation Discrepancy Form.

b. Obtain concurrence from the Validation Team Leader, as applicable.

c. If the Validation Team Leader does not concur with the resolution, coordinate efforts to assess and resolve the discrepancy.

d. Document the final resolution on PBF-2103c, EOP Validation Discrepancy Form.

4.8.5 If the discrepancy cannot be resolved between the personnel assigned to resolve the discrepancy and the Validation Team Leader, then the Validation Team Leader shall recommend a corrective action and obtain approval from the Operations Manager or designee.

INFORMATION USE Page 15 of 28

PONT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS 4.8.6 After resolution of the discrepancy has been determined, the Validation Team Leader shall:

a. Ensure the procedure is changed to incorporate the resolution of the discrepancy.

b. Determine the scope of any additional validation required.

c. Document completion of the additional validation.

d. Determine if additional training is required and, if so, notify the Training Department.

4.9

'Final Approval of EOP/AOP Revisions NOTE:

Temporary changes to the EOPs and AOPs can be approved via NP 1.2.3, Temporary Procedure Changes.

4.9.1 Following completion of the verification and validation process, including resolution of all discrepancies, final approval is obtained.

4.9.2 MSS review and approval is required for technical revisions to the EOPs. If the bdsis and step deviation documents are affected by the change, the revised background document should be submitted with the EOP for MSS review.

4.9.3 All EOP/AOPs and background documents shall be approved by the Operations Manager or his designee.

INFORMATION USE Page 16 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16,2002 EOP/AOP VERIFICATION/VALIDATION PROCESS

5.0 REFERENCES

5.1 NUREG 0899, Guidelines for the Preparation of Emergency Operating Procedures 5.2 NRC Generic Letter 82-33, Supplement 1 to NUREG-0737 - Requirements for Emergency Response Capability 5.3 C. W. Fay letter to H. R. Denton, "Response to Generic Letter No. 82-33...

"April 15, 1983.

5.4 OM 4.3.1, AOP and EOP Writers' Guide 5.5.,estinghouse Owners' Group (WOG), Emergency Response Guidelines (ERGs) 5.6 Westinghouse Owners' Group (WOG), Abnormal Response Guidelines (ARGs) 5.7 PBF-2102a, EOP Verification Team Meeting Form 5.8 PBF-2102b, EOP Verification Discrepancy Form 5.9 Institute of Nuclear Pomfer Operations (INPO) Guidelines, Emergency Operating Procedures Verification Guidelines,83-004, March 1983 5.10 PBF-2103a, EOP Validation Form 5.11 PBF-2103b;EOP Validation Scenario Form 5.12 PBF-2103c, EOP Validation Discrepancy Form 6.0 BASES NONE INFORMATION USE Page 17 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATIONNALIDATION PROCESS ATTACHMENT A TECHNICAL EVALUATION GUIDELINE Page ] of 3 1.0 (EOP)

Are entry conditions consistent with those listed in the Owner's Group guidelines or are deviations justified in the basis and deviation documents (AOPISEP)

Are entry conditions logical. (reflective of the expected conditions leading to performance of the instruction). Are the entry conditions observable.

2.0 (EOP)

Is the sequence of steps consistent with that in the Owner's Group Guidelines or are deviations Thdeq-ue f3~j st i fi te alh i

si siiri and ti6'n 66biii (AOP/SEP)

Are the steps sequenced logically. Does the sequence follow good operations principles.

3.0 (EOP)

Are all steps consistent with the intent of those in the Owner's Group Guidelines or are deviations adequately justified in the basis and deviation documents.

(AOP/SEP)

Is the intent of each step understandable. Does the step provide adequate detail.

"4.0 (EOP)

Have all applicable Owner's Group Guideline steps been incorporated into the procedure or are deviations adequately justified in the basis and deviation documents.

(AOP/SEP)

Are the steps necessary instructions provided to the user.

5.0 (EOP)

Are differences from the Owner's Group Guidelines consistent with the intent of the Owner's Group Guidelines.

6.0 (EOP).

Is documentation adequate to explain the intent of complex steps.

(AOP/SEP)

Is documentation adequate to explain the intent of complex steps.

7.0 (EOP)

Is all Owner's Group Guidelines "bracketed" information, pertinent to the plant design, incorporated.

(AOP/SEP)

Is applicable plant design and components clearly addressed by the instruction.

INFORMATION USE Page 18 of 28"

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS ATTACHMENT A TECHNICAL EVALUATION GUIDELINE Page 2 of 3 8.0 (EOP)

Have all references to systems or components in the Owner's Group Guidelines that are applicable to the plant design been included.

(AOP/SEP)

Are all references to system, component and plant design clear and correct.

9.0 (EOP)

Are required computations, specified in the procedure. consistent with Owner's Group Guidelines

............... or deviations aqdequately justified within source documents.

(AOP/SEP)

Are all required computations specified in the procedure. Has adequate guidance been given and is space available for working and recording computations.

10.0 (EOP)

Are the cautions and notes, as specified in the procedure, consistent with the Owner's Group Guidelines or are deviations adequately justified in the basis and deviation documents.

(AOP/SEP)

Are cautions and notes specified in the instruction clear and concise. Do they provide adequate information to convey the message.

11.0 (EOP)

Are the contingency actions in the procedure consistent with those specified in the Owner's Group Guidelines or are deviations adequately justified in the basis and deviation documents.

(AOP/SEP)

If specified/used, are contingency actions clear and.easily understood. Do they provide adequate detail for implementation.

12.0 (EOP)

Is there a conflict between the foldout page requirements and the action steps of the procedure.

(AOP/SEP)

Is there any conflict between steps and required actions.

13.0 (EOP)

Are the itequired steps to be performed consistent with the plant design.

(AOP/SEP)

Are the steps consistent with plant design.

14.0 (EOP)

Are the quantitative ranges as specified in the procedure consistent with the plant design.

(AOP/SEP)

Are the quantitative ranges as specified in the procedure consistent with the plant design.

INFORMATION USE Page 19 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS ATTACHMENT A TECHNICAL EVALUATION GUIDELINE Page 3 of 3 15.0 (EOP)

Are the limits, as specified in the procedure consistent with those specified in the Owner's Group Guidelines or are deviations adequately justified in the basis and deviation documents.

(AOP/SEP)

Are limits clearly specified.

16.0 (EOP)

Are the charts, tables, and curves presented in the procedure consistent with the Owner's Group

_Guidelines or are deviations adequately justified in the basis and deviation documents.

(AOP/SEP)

Are the charts, tables, and curves consistent with the information provided in source documents.

17.0 (EOP)

Do parameter values, numerical values, and setpoints in the procedure correspond with the parameter values, numerical values, and setpoints specified in Setpoints Document.

(AOP/SEP)

Do parameter values, numerical values, and setpoints in the procedure correspond with the parameter values, numerical values, and setpoints specified in supporting technical documentation.

18.0 (EOP)

If the revision involves a change to a setpoint, have all the procedures affected been revised.

Verify against the list of affected procedures contained in the setpoints document.

19.0 (EOP)

If the revision affects a "standard" step, have all of the procedures affected been revised. Verify against the list of affected procedures contained in the standard step document.

INFORMATION USE Page 20 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS ATTACHMENT B STATUS TREE EVALUATION GUIDELINE Page 1 of 3 1.0 WRITERS' GUIDE CONVENTIONS 1.1 Procedure Title 1.1.1 Is the title 10 words or less.

1.1.2 Are the important words placed at or near the beginning of the title.

1.2 Identification Information 1.2.1 Does the procedure number include the required information:

a. Instruction type

b. Instruction number

.2.0 STATUS TREE FORMAT 2.1 Page Format 2.1.1 Does the Status Tree clearly show the transitions.

2.2 Symbol Coding 2.2.1 Are the symbols used correctly.

2.2.2 Are arrows positioned correctly.

2.3 Function Flow and Branching 2.3.1 Does the flow path move from left-to-right.

2.3.2 Is sufficient spacing allowed between flow paths.

t 2.3.3 Are the number of arrowheads sufficient to indicate flow.

2.3.4 Does the flow path go down for each favorable response.

INFORMATION USE Pag~e 21 of 28

POINT BEACH NUCLEAR PLANT OPERATIONS MANUAL EOP/AOP VERIFICATION/VALIDATION PROCESS OM 4.3.2 Revision 3 September 16, 2002 ATTACHMENT B STATUS TREE EVALUATION GUIDELINE Page 2 of 3 3.0 READABILITY 3.1 Text 3.1.1 Is the text in black type against a light background.

3.1.2 Is the text readable at arms length under degraded lighting conditions.

3.1.3 Is the typeface legible and consistent.

3.1.4 Is spacing between letters and words adequate.

3.1.5 Is the correct line spacing used.

4.0 WRITING STYLE 4.1 Step Construction 4.1.1 Does each step contain only one statement.

4.1.2

'Are the statements simple and precise.

4.1.3 Are double negatives avoided.

4.1.4 Are terms used consistently within and among status trees.

4.1.5 Does each decision step clearly indicate a yes or no answer.

5.0

• MECHANICS OF STYLE 5.1 Spelling 5.1.1 Is the spelling correct.

5.2 Abbreviations and Acronyms 5.2.1 Are abbreviations and acronyms used consistently.

5.2.2 Are abbreviations used in accordance with the Writers' Guide.

PINFORMATION USE Page 22 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16,2002 EOP/AOP VERIFICATION/VALIDATION PROCtSS ATTACHMENT B STATUS TREE EVALUATION GUIDELINE Page 3 of 3 5.3 Curves and Tables 5.3.1 Are the curves and tables legible, consistent with the instructions, and usable.

5.3.2 Are the safe and unsafe regions of curves labeled.

5.4 Hyphenation 5.4.1 Are hyphens used correctly.

5.4.2 Is hyphening at the end of a line avoided.

P oINFORMATION USE Page 23 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16,2002 EOPIAOP VERIFICATION/VALIDATION PROCESS ATTACHMENT C VALIDATION GUIDELINES Page 1 of 4 1.0 USABILITY 1.1 Level of Detail 1.1.1 Are the introductory sections of the instruction sufficient.

1.1.2 Is there sufficient information to perform the specified actions at each step.

1.1.3 Are the alternatives adequately described at each decision step.

1.1.4 Are labeling, abbreviations, and nomenclature as provided in the instruction sufficient to enable the operator to find the needed equipment.

1.1.5 Does the instruction have all information or instructions needed to manage the emergency condition.

1.1.6 Are the actions sufficient to correct the condition.

1.1.7 Are the titles and numbers sufficiently descriptive to enable the operator to find appropriate instructions.

1.2 Understandability 1.2.1 Is the instruction's typeface easy to read.

1.2.2 Are the figures and tables easy to read with accuracy.

1.2.3-Can the values on figures and charts be easily determined.

1.2.4 Are the cautions and note statements readily understandable.

1.2.5 Are the individual instruction steps readily understandable.

1.2.k Were the step sequences understood.

INFORMATION USE Pagle 24 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS ATTACHMENT C VALIDATION GUIDELINES Page 2 of 4 2.0 OPERATIONAL CORRECTNESS 2.1 Plant Compatibility 2.1.1 Can the actions specified in the procedure be performed in the designate sequence.

2.1.2 If alternate success paths exist, does the procedure use the best method to

-accomplish the task.,

2.1.3 Can the information from the plant instrumentation be obtained, as specified, by the instructions.

2.1.4 Are the available Control Room instrumentation and annunciators adequate for the Operator to"recognize the entry or prerequisite conditions.

2.1.5 Are the instructions entry or prerequisite conditions appropriate for the plant symptoms displayed to the operator.

2.1.6 Is all the equipment required to accomplish the task specified in the instruction.

2.1.7 Do the plant resources agree with the instruction.

2.1.8 Are the instrument readings and tolerances stated in the instruction consistent with the instrument values displayed on the instruments.

2.1.9 Is the instruction physically compatible with the work situation (e.g., too bulky to hold, binding would not allow them to lie flat in the work space, no place to lay the instruction down to use).

2.1.10 Are the instrument readings and tolerances specified by the instruction for remotely located instruments accurate.

2.1.11 Can plant parameters be maintained within limits or bands specified in the procedure.

INFORMATION USE Page 25 of 28

POINT BEACH NUCLEAR PLANT OM 4.3.2 OPERATIONS MANUAL Revision 3 September 16, 2002 EOPIAOP VERIFICATION/VALIDATION PROCESS ATTACHMENT C VALIDATION GUIDELINES Page 3 of 4 2.2 INFORMATION USE Operator Compatibility 2.2.1 If time intervals are specified, can the instruction action steps be performed on the plant within or at the designated time intervals.

2.2.2 Will environmental conditions permit completing the required actions.

2.2.3 If concurrent or sequential steps are required by more than one individual, can the required *ictinns be coordinated

-dequte!y.

2.2.4 Can personnel follow the designated action step sequences.

2.2.5 Can a particular step, set of steps, or other information be readily located when required.

2.2.6 Can instruction branches be entered at the correct point.

2.2.7 Are place keeping aids utilized as required by the user's guide.

2.2.8 Are instruction exit points adequately specified.

2.2.9 Are the procedures compatible with the operating shift manning.

2.2.10 If steps and instructions are verified with signoffs, are provisions adequate.

2.2.11 Do Operators interfere with each other physically.

2.2.12 Is there adequate Radiation Protection support and/or provisions to make the required entries into contaminated areas.

2.2.13 Does plant staffing support procedure requirements.

2.2.14 Is the procedure adequate to allow properly trained personnel to complete the t

task without errors.

Pag~e 26 of 28

POINT BEACH NUCLEAR PLANT OPERATIONS MANUAL EOP/AOP VERIFICATION/VALIDATION PROCESS ATTACHMENT C VALIDATION GUIDELINES Page 4 of 4 2.3 Additional Guidelines for Validation of Local Operator Actions 2.3.1 Can the Operator easily locate the component from a combination of the information in the procedure and operator training/knowledge.

2.3.2 Is the component clearly identified by name and/or number.

2.3.3 Is the component easily accessible.

2.3.4 Are special tools needed to operate the component.

2.3.5 Is the environment at the component location suitable to allow the operator to perform desired actions.

2.3.6 Do the local actions require more than one operator.

2.3.7 Are communications available from the remote location.

2.3.8 Is the Operator performing the local actions familiar with the procedure and does he/she understand the objective and/or consequences of his/her actions.

2.3.9 Are the local actions required to be performed in a specific time period. If so, can the actions be completed within this time period.

INFORMATION USE Page 27 of 28 OM 4.3.2 Revision 3 September 16, 2002

POINT BEACH NUCLEAR PLANT OPERATIONS MANUAL OM 4.3.2 Revision 3 September 16, 2002 EOP/AOP VERIFICATION/VALIDATION PROCESS ATTACHMENT D PRA CORE DAMAGE RISK MATRIX Page 1 of I PINFORMATION USE Page 2.8 of 28