ML17202H360

Forwards Safety Evaluation Re Procedures Generation Package for Plants

ML17202H360
Person / Time
Site:	Dresden
Issue date:	03/15/1990
From:	Siegel B Office of Nuclear Reactor Regulation
To:	Kovach T COMMONWEALTH EDISON CO.
References
TAC-44297, TAC-44298, NUDOCS 9003200249
Download: ML17202H360 (19)

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• Docket Nos. 50-237 and 50-249 NRC & Local PDRs LLuther PDIII-2 r/f JZwo l inski BSiegel EJordan Plant File Thomas J. Kovach Nuclear Licensing Manager Commonwealth Edison Company-Suite 300 OPUS ~Jest II I 1400 OPUS Place Downers Grove, Illinois 60515

Dear Mr. Kovach:

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SUBJECT:

SAFETY EVALUATION FOR THE DRESDEN NUCLEAR POWER STATION UNITS 2 AND 3 PROCEDURES GENERATION PACKAGE (TAC NOS. 44297 AND 44298)

The staff has completed its review of your Procedures Generation Package (PGP) for the Dresden plants submitted in a letter dated October 30, 1984 and supplemented by a letter dated December 16, 1985.

The enclosed safety evaluation discusses programmatic improvements which will enhance your ability to develop and maintain consistently high quality Emergency Operating Procedures (EOPs).

The majority of the findings are related to the writer's guide.

The staff concludes that your PGP needs to be reviewed to address these pr-ogrammatic improvements.

For items you deem inappropriate, no longer applicable, or unnecessary for inclusion in your PGP, you should develop and maintain documented justification in an auditable form.

During the period of May 31, 1988 through June 8, 1988, a team of NRC inspectors audited your Emergency Operating Procedures. The staff recommends you consider both the enclosed discussion and the results of the EOP inspection as stated in Inspection Report Numbers 50-237/88-12 and 50-249/88-14 and utilize them as appropriate in the next major revision to your PGP and EOPs.

The staff recognizes that your PGP and EOPs may have been revised since the submittals, and requests that you maintain records of all revisions to your PGP and EOPs in an auditable form.

No further submittals are required.

This safety evaluation closes out the staff's review of this issue.

Sincerely, in.

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Byron L. Siegel, Project Manager Project Directorate III-2 ii i:'i:iu I I :11-:*r*~Q 1

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Enclosure:

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UNITED STATES NUCLEAR REGULATORY COMMISSION Docket Nos. 50-237 and 50-249 Thomas J. Kovach Nuclear Licensing Manager WASHINGTON, D. C. 20555 Ma*rch 15, 1990 Commonwealth Edison Company-Suite 300 OPUS West II I 1400 OPUS Place Downers Grove, Illinois 60515

SUBJECT:

SAFETY EVALUATION FOR THE DRESDEN NUCLEAR.POWER STATION UNITS 2 AND 3 PROCEDURE*s GENERATION PACKAGE (TAC NOS. 44297 AND 4~298).

.The staff has completed its review of your Proc_edures Generation Package (PGP) for the Dresden plants submitted in a letter dated -October 30, 1984 and supplemented by a letter dated December 16, 1985.

The enclosed safety evaluation discusses programmatic improvements which will enhance your ability to develop and maintain consistently high quality Emergency Operating Procedures (EOPs).

The majority of the findi_ngs are related to the writer's.

guide.* The staff concludes* that ~our PGP*needs to be reviewed to address these programmatic improvements.

For items you deem inappropriate, no l_onger applicable, or unnecessary for inclusion in your PGP, you should develop and maintain documented justification in an auditable form.

During the period of May' 31, 1988 through June 8, 1988, a team of NRC inspectors audited your Emergency Operating Procedures.

The staff *recommends you consider both the enclosed discussion and the results of* the EOP inspection as stated in Inspection Report Numbers 50-237/88-12 and 50-249/88-14 and utilize them as appropriate in the next major revisi9n to your PGP and EOPs.

The s.taff recognizes -that your PGP and EOPs may have been revised since the submittals, and requests~that you maintain records-of all revisions to,your PGP and EOPs in an auditable form.

No further submittals are ~equired.

This safety eva1uation closes_ out the staff's :review of this issue.

Enclosure:

As stated cc w/enclosure:

See next page

~:*4t

-s/r~n L. Siegel, Project Manager

• Project Directorate III-2 Division of Reactor Projects - III, IV, V and Special Projects Office of Nuclear Reactor Regulation

Mr. Thomas J. Kovach Commonwealth Edison Company cc:

Michael I. Miller, Esq.

Sidley and Austin One First National Plaza Chicago, Illinois 60690 Mr. J. Eenigenburg Plant Superintendent Dresden Nuclear Power Station Rural Route #1 Morris, Illinois 60450 U. S. Nuclear Regulatory Commission Resident Inspector~ Office Dresden Station Rural Route #1

• Morris, Illinois 60450 Chairman Board of Supervisors of Grundy County Grundy County Courthouse.

Morris, Illinois 60450 Regional Administrator Nuclear Regulatory Commission, Region III 799 RooseveJt Road, Bldg. #4 Glen Ellyn, Illinois 60137 I 11 i noi s Department of Nuclear Safety Office of Nuclear Facility Safety 1035 Outer Park Drive

• Springfield, Illinois 62704 Dresden Nuclear Power Stati-0n Units 2 and 3

.. * :J

. *'l SAFETY EVALUATION REGARDING THE PROCEDURES GENERATION PACKAGE FOR pRESDEN NUCLEAR POWER S.TATION UNITS 2 AND 3 ENCLOSURE

1.

INTRODUCTION Following the Three Mile Island (TMI) accident, the Office of Nuclear Reactor Re9ulat;on developed the wTMI Action Plan (NUREG-0660 and NURE~-0737) whi_ch required licensees o*f operating reactors to reanalyze transients and accid~nts and to upgrade emergency operating procedures

• (EOPs) (Item I.C.l). The plan also required the NRC staff to develop a long-term plan that integrated and expanded efforts 1n the writing, reviewing, and monitoring of plan procedure (Item I.C.9). NUREG-0899, "Guidelines for the Preparation of Emergency: Operating Procedures, 11 represents the NRC staff's long.;.tenn program for upgrading EOPs, and

• descri_bes' the use of a "Procedures Gen~ration Package" (PGP) to prepare EOPs.- Submittal of the PGP *w~s made a requirement by Generic Letter

. 82-33, "Supplement 1 to NUREG--0737 - Requirements for Emergency Response Capability." The generic letter requires each licensee to* submit to the

• NRC a PGP which includes:

(fl (ii)*

( i 11)

(iv}

Plant-specific techn~cal guidelines A writer's guide

• A descript;or1 of the progr.am to.. be used for ~he validation of EOPs *.

• A descripti~n bf*~he _tr~ining program*for.ihe ~pgraded **

EOPs

• This report describes the review of the Commonwealth Edison response to the generic letter related to development and ~mplementation of EOPs (Section 7 _of Generic letter 82-33) for the Dresden Nuclear Power Station Units 2 and~3 (Dres~en).

. Our rev few was conducted to deter.mine the adequacy of the Commonwea 1th

• Edison program for preparing and implementing upgr~ded EOPs for Dresden

• This review was based on NUREG-0800 (formerly-NUREG-75/087)~ Subsection 13.5.2, Standard Review Plan for the Review of Safety AnalysiS Reports*

• for Nuclear Pow~"'. Plants.* Section 2 of this report briefly discusses the Commonwea 1th Edison submitta 1, the NRC staff review, and the acceptability of the submittal. Section 3 contains the conclusions of this review.

As indicated in t~e following secti.ons, our review determined th~t.the procedure g~neratibn program for Dtesd~n has se~eral items that must be satisfactorily addressed before th.e PGP is acceptable *. Commonwealth Edison should address these items in a.revision to the PGP, or provide justification for why such revisions are not necessary. This revision and/or justification need not be submitted, but should be retained for

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subsequent review by the NRC staff. The revision of the PGP, and subsequently of the fOPs, should not impact the schedule for the use of the EOPs.

The revision should be made in accordance with the Dresden administrative procedures and 10 CFR 50.59.

EVALUATION AND FINDINGS In a letter dated October 30, 1984 from B. Rybak {Commonwealth Edison) to Harold R. Denton {NRC), Commonwealth Edison submitted its PGP for Dresden.

The PGP contained_ the following sections and attachments:

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• Dresden-Specific Emergency Procedures Guidelines Dresden Emergency Writer's Guide Description of the Emergency Procedures Verification and Validation Programs Description of the Training Program.

The NRC staff conducted a review of the Dresden PGP, and identified its findings in a Draft.Safety Evaluat;on Report {OSER) which was forwarded to Commonwealth Edison in a letter dated July 31,. 1985 from J. A *

. ZwoHnski to D. L. Farrar. Corrmonwealth Edison provi'ded responses to the OSER Hems in a letter from J. L. Wojnarowski to J. A. Zwolinski dated December 16, 1985 and included a revision to the PGP that incor~orated cha~ges to address the identified items. The NRC staff ~eview of the revised Dresden PGP, including the response to the OSER items, is

'documented in the following subsections. The verification and validation program comments are combined irl one subs*ectfon.

A.

Plant;..Speciffc. Techni_cal Guidelines {P-STG)

Because sta.ff evaluation of Revision 4 cJf the generic technical guidelines is now complete, the P-STG program description should be revised to conform with Revision 4 of the General Electric Boiling Water Reactor Owner's Group (BWROG) Emergency Procedure Guidelines

.(EPGs). Safety significant.deviations from the BWROG Emergency Procedures Guidelines should be documented, justified, and archived for future reference.

B.

Writer's Guide The writer's guide was* reviewed to determine ;fit described acceptable methods for accomplishing the objectives stat~d in

. NUREG-0899.

The _purpose of the writer's guide is to provide administrative and technical guidance on the proper writing techniques during the prep*ration and subsequent revision of the

. *Dresden Emergency Operating Procedures (DEOPs).

The DEOPs consist of

_separately bQund procedures, each with a simplified flowchart at the back. Dresden lists six categories of DEOPs:

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Reactor Control (DEOP 100 Series)

• Primary Containment Control (DEOP 200 Series)

Secondary Containment/Radioactive Release Control (DEOP 300 Series).

Contingency Procedures (DEOP 400 Series)

Support Procedures (DEOP 500 Series)

General Precautions (DEOP 010)

Our review*of the Dresden writer's guide identified the following concerns:

1.

.OSER Item.2.B.2: Section 4.4.3, page 14, states that *where possible, an action step or a note should be completed.on the page where it began.* *Jhis statement should be revised to require that action steps and notes be complete on one page.

Furthermore, Section 4.4 pertains to the DEOP review* and.

revision process.* Because writers should be awa*re of all g~idance when they begin writing procedures, the wri'ter's guide should be modified to ensure that writers are aware of the guidance -in Section 4.4* when they begin writing procedures.

2.

OSER Item 2.B.5:. The guidance added in Sectitin 4.4.4, page 14, 1s not sufficient to guide writers in producing consistently formatted DEOPs.

Writers need *specific iiiformation to produce consistently formatted procedures.

The writer's guide should include requirements* for margins, line *spacing, and *type or pitch size for text, flowcharts, tables.* and graphs. The exa~ples p~ovided should be consistent with the text.

• 3.

OSER Item.2.8~6:

T~e concern C?f. this,item is not the level of.

detail included-in the steps. 'No matter what level of detail*

• . is used.i.n DEOPs, different types of action steps exist, and procedure writers need guidance to produce consistently formatted steps. rhe writer's guide should define the follo~ing types of action steps, describe how. they should be formatted, and provide examples consistent with the tex~:

a.

Steps used to verifi accomplishment of objectives.

b...steps that must be repeatediy performed.

The writer*' s guide should discuss conditions o~ intervals determining repetition, and what type of reminder will be used to ensure that the steps are.repeated at the correct times or intervals *..

c *. Steps fQr which several alternatives are equally correct *.

The writer's guide should contain a co111J1itment to present one alternative, should discuss conditions under which

• other alternatives will be presented, and provide instructions for fo.rmatting mult.iple alternatives.

d. *

• St~ps perfo.nned concurrently w~t.h other steps.

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OSER Item 2.B.7: Examples alone do not provide adequate guidance to ensure that DEOPs will be consistently formatted.

In addition to providing examples, the writer's guide should describe the system of step numbering to be used in DEOPs.

• 5.

OSER Item 2.B.8: Placekeeping aids can assist operators in keeping track of their positions within a procedure. The use of "special binders" described in Section 2.3, page 5, helps solve some placekeeping problems, but it does not adequately ensure that placekeeping d;fficulties will be overcome.

Operators may have to refer to different pages within a single procedure, and they will therefore still need to flip through procedure pages. Additionally, while the special binders may help prevent an operatQr from losing his page, it is not clear.

how they will assist an operator in keeping track of his place on the page. Therefore, the writer's guide should be expanded to describe a placekeeping aid that operators use at the

• indhidua l step level.

6.

OSER,Item 2.B.9: Section 3.0 does not provide adequate*

~uidance for writing action steps.

So that prbcedure writers can create DEOPs that the consistent a_nd readily understood by operators, the writer's guide should be revised to address the*

following.

a.

Adverbs 11 rapidly 11 or 11slowly" (used in Section 3.1.6, page

10) a~e vague, do not des~ribe specifit actions, and should be included in a list of words to avoid.

Alternately, these words can be used if they *are appropriately qualified-(e.g., cooldown rapidly, bu~ less than 100°F/hr.).

b.

Sections 3~4.3 and 3.4.5, page 12, discuss words which the procedure preparers should avoid using.

In addition to being described in the text, these words should be included in a reference list of words to avoid using.

c.

• Section 3.4.3 instructs procedure writers to define words that may be understood in more than one way.

The use with more than one meaning could lead to operator confusion.

This section should be revised to st~te that*~mbiguous terms will be avoided in EOPs.

Such terms should be included in a list of words to avoid.

d.

Section 3.4.iO, page 13, states that common words and their definitions are provided in Attachment 3, (page 21). Section 3~5.1, page 13~ provides a list of 12 action verbs, of which only two ("initiate" and 11confirm 11 ) are -

included in Attachment 3. Additionally, examples in the text and in Attachments 1 and 2 include other action verbs

• such as "execute" and "terminate" that are not included in. Attachment 3 should be expanded to present 4

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an inclusive list of acceptable terms and Section 3.4.10 should state that only those terms will be used in DEOPs.

Only those action terms included in Attachment 3 should be included in examples in the writer's guide.

Section 3.0 should be revised to state that all sentences will be complete and will be short. Short, complete*

sentences are more precise than sentence fragments and are more easily understood than fragments or long sentences.

Section 3.0 should be revised to state that instruction steps will be written as directives, in the.imperative

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7.

OSER Item 2.B.10: In addition to the or.iginal concern expressed in OSER Item 2.B.10, revisions of and additions to the writer's guide have introduced new concerns. regarding* logic terms..

. a.

The term *butn is used.as a logic term in Attachment 2, Section B.1, page 19. *eut" is not corrunonly used as a logic term and should not be used as a logic term in DEOPs.

b.

To ensure that logic terms are used consistently and clearly used, Section 3.2, page 1r. should be expanded to include a Jist of all the words that will. b* used*as logic terms, to provide a definition and an example of each.

term, and to state that no other terms will be used as*

logic terms.

c..

THEN is use.d to join actions rather.than to introduce the consequent action in*an IF THEN.statement in Attachment 1, page 18, Step C-6.d.(1) *. Actions which are embeded in this way create several problems:

embedded actions may be overlooked and not performed, they may be confused with logic *statements, and they are difficult to. v.erify with check-offs.

In this particular case, ~n operator could easily overlook the first action, *cLOSE the charging water valve 2(3)-0301-25,n because he would ~xpect the action instruction to follow the term THEN.

The

• instructions for the use of THEN, to be added to Section 3.2, should state that.THEN will not be used to run actions together. Attachment 1 should be revised accordingly.

d.

se*ction 3.2.3, page.11, states that.10g1c terms will be emphasized using location, capitalization, and underlining. However, the use of these tech~iques in examples in the writer's guide is inconsistent. For example, in Attachment 1, page 18, a blank line is inserted between the contingency and the action in the first IF THEN statement (in the exit condition), but this 5

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blank line is not included in other IF THEN statements

• The Jog;c term THEN fs usually underlined, but ft is not underlined in Section 3.2.7, page 11.

To ensure consistency in the formatting of log;c *statements, Section 3.2.3 should describe exactly how location, capitalization, and under-lining will be used to emphasize logic terms, and examples fn the writer's guide should be consistent with the description.

In Attachment 1, page 18, Step C-6.6.{l), the conjunction 11and" fs formatted as the logic term AND.

If the

- difference between the conjunctions 11and 11 and 11or 11 and, the logic terms AND and OR is unclear, operators could mistake a conjunction for _a logic term.

To ensure that conjunctions are formatted in a manner that f s clearly different from logic terms, Section 3.2 should specify the formatting of conjunctions so they will not.be confused with logic terms and examples should be consistent with the text.

8.

• osER Item 2.B.11: The changes ~ade *in Section 2.7 do not adequately address the concerns regarding referencing. During the execution of EOPs ft is often necessary to refer operators to other procedures or* sections of a procedure. Such referencing and branching can cause errors and unnecessary delays.

a.

Section 2~7, page 9, states that references.will be indicated by the verbs 11enter" and "execute.

11 However, in

• Attachments 1 and 2 the following ter.ms are.used to*

. indicate referencin9:

"Perform" (Step C.2, page 20) and "per" (Step C-6.d(l J~ page 18). The forma~ for reference statements should be precisely described in Section 2.7 and all examples should adhere to that format.

b.

When referencing to another procedure, a step number should always be included in the reference to ensure that operators know where to start in the referenced procedure. Section 2.7, page. 9~ should be revised to specify that step numbers are required or to specify that referenced procedure will be used in their entirety~

c *. The referencing examples A and B, in Section,2.7.2, page 9, are* confusing.

Example A states, "THEN execute DEOP.

400-2 (Emergency RPV Depressurization) concurrently with this procedure AND proceed to Step 12.~.* There are three sources of ambiguity in this sentence,. which.. lead to six

• possible interpretations of the sentence.

First~ it is unclear whether step. 12.c is part of DEOP 400-2 or part of th~ procedure the operator fs currently using. Second, 1t is unclear whether the operator is to begin at the

• . beginning of the procedure and 11proceed 11 thro~gh the procedure, executing steps, until Step 12.c fs reached, or ff he is to "proceed to Step 12.c" and then begin executing 6'

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the procedure. Third, if the statement indicates that the operator ;s to execute the procedure from* the beginn;ng to Step 12.c, then ft is not clear whether he is to stop executing steps.before or after executing the actions in Step 12.c. In example B, the title of the procedure should be move.d next to the numbered term it refers to; that is, *oEOP 100 (Reactor Control) Step 11.* Section 2.7 should be changed to specify referencing.f~rmats that are clear, unambiguous, and easily understood. Additionally, to ensure that writers correctly interpret the examples, the format instructions *should be,described in the text-as

. we 1 fas demonstrated by examp.les.

9.

OSER Item 2.B.12: rhe changes made in Section 2.3.and 2.5 do not adequately address the concerns regarding organization and forma~. Consistent, well-organized, and well-labelled-EOPs increase the ease with which operators understood and use procedures.

. a.

Section 2.3, pages 5-6, should be expanded to state that each procedure ~ill have a cover page, ~nd that the.

following __ fnformatfon will b~ included on the cover page:

procedure: ident1ffcat1on (t~tle and number); the revfsfon

_ number; the revision date; the total number of pages*;

'.review and approval signatures; the unit designation; and

• the facility designation.

An example, consistent with the.

text, should be provided.

b. *_.Section. 2.3, page 5, states that an a index sha 11 identify...

each OEOP by number and title, u_ but does *not de_s_cr:ibe the desired format of the index.

Se~tion 2.3 should provide guidance for coristructing indexes.

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c.

Secti.on 2.3, page 5~-should'specify that eac_h pro*cedure

• will include a stat~ment as to the scope of that procedure

, so tha~ operators can be sure they are using the proper

'procedure.

d.

Section 2.5, pages 6-.7, should be revhed to address the.

. fo1low1ng* concerns regar.d-ing figures and tables *

. 1) Section 2.5 should address th~ crite~ia which will determine.the use and content of graphs and tables.

2) Section 2.5.should b~ expanded to state that graphs

• .. and tables w111 be titled and numbered* uniquely so that graphs and tables are easy for operators to find and identify..

• 3) Section 2.5.3, page 7., should. be expanded to state

• that units of measure io graphs and tables will be consistent with control room labels and with the text of procedures *.

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4} Section 2.5 should be supplemented with examples of a graph and a table that are consistent with the text.

The revision of the writer's guide introduced new concerns. The following comments (B.10 through B.12) address passages of the writer's guide that were added or significantly modified.

10. Section 2.2, page 5, states that DEOP 500 procedures use various types of single col,umn formats which comply with the controls of Dresden Administrative PrQcedure (OAP) 9~2, nProcedures Preparation.* The format controls should be 1~cluded in the writer's guide.

11.' Section 2.6.5 states that cautions may be placed ori the left hand pages of procedur~s. Cautions placed on the facing (left hand) page could be missed by operators. So that operators are ware of all information in a caution before performing the steps to which the caution applies, cautions should always be

.placed directly before the first step to whfch they apply, as stated fn Section,2.6.2, page 8. Section 2.6.5 should be removed from the writer's guide.

12.

The flowchart in Attachment 1, page 16, contains several

• usability problems *. Using,this flowchart for guidance in designing DEOP flowcharts could lead to flowcharts that are hard to read and confusing. The writer's guide should be modified as follows:

a.

The entire text of the sample flowchart is capitalized.

If all ~ords are capitalized, then capit~lization cannot be used for emphasis.

Furthermore, text written in all capitals is more. difficult to* read than mixed case.

• The writer's guide should state, and this example should be revised to show, that capitalization in flowcharts *w111 conform to the rules established for DEOPs *.

b.

Sectiori.2.0, pages 4-9, does not addr~ss ~autions and

.notes in flowcharts. Cautions and notes should always precede the steps to which they apply.

The writer's guide should be revised to indicate that cautions and notes will be placed on the flow path before flowchart steps to which they apply.

c.

The writer's guide does not.destr1be how cautions should be formatted in flowcharts.

To ensure that cautions are

,.always identified, the writer's guide should be expanded to describe a technique for formatting cautions in flowcharts that ensures that they will be easily identified and *not confused with flowchart steps.

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d.

Because the text 1n flow'charts can be read more easily if it.is double-spaced, the writer's guide should state that the text in flowcharts will be double-spaced.

e.. The sample flowchart contains two different symbols used to enclose text. Consistent use of symbols will enable operators to understand flowcharts more easily. The writer's guide should include a Hst of all" symbols to be used in flowcharts, along with their definitions.

f.

The sample flowcharts contains a step for which there is no exit option. For the step acontinue torus temperat~re control, a there are two arrows leading to the step, but there is no way to proceed from the step. The writer's guide should be expand~d to describe how the logical movement through a flowchar~s should be structured, and this structure should not allow.an operator to reach a step from which he *cannot exit.

• The sample flowchart should be modified to reflect this concern. The list of flowchart symbols that should be added to the writer's guide should include a symbol used to indicate flowchart exit ~oints.

g.

The sample flowchart contains nothing to indicate an entry point.

The entry point into a flowchart should be clearly identified so that operators enter the flow path.at the -

correct point. The list of symbols that should be added to the writer's guide should*. include a sy'mtfol used to indicate flowchart entry points." The writer~s guide should specify a means of indicating the entry point into a flowchart and the entry point should be so indicated in th.e sample flowchart.

h.

One step in the sample flowchart is not enclosed in a symbol: :"Continue torus temperature control." *secause*

the different symbols *in flowcharts convey information about the t~xt within them, all flowchart steps should be enclosed in symbols.

The writer's guide should state that all flowchart steps.are to be enclosed in symbols, and_ the

. :sample flowchart should. be revised accordingly..

i.

In the sample flowchart, text extends outside of symbol boundaries, making both the symbols and the text less.

legible~. Because of problems such as these, hand-drafted flowcharts are more difficult to read. The.writer's guide should state that all text in flowcharts should be fully contained within the flowchart symbols. This guidance

.should not be met by reducing type s1ze to an illegible -

size *of by making symbols s.o large that the flowcharts become crowded and hard to read. Therefore, the writer's guide should state requirements for symbol size, type size,*.

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and s_pac1ng between flowchart elements to ensure flowchart legibility. Consideration should be given to the way the flowcharts will be presented and the distance from which they will be read.

j.

The sample flowchart contains a flowpath that moves from bottom-to-top (the YES flowpath entering the step "Continue torus temperature control"). The flowchart could be designed in a manner that omitted this upward movement without changing the logical structure of the flowchart. Flowcharts are more easily read by operators if, as much as is possible, all flowpaths move either from top-to-bottom or from left-to-right. The writer's guide should contain instructions to ensure top-to~bottom and left-to-right consistency in flowcharts.

The sample

• flowchart should be modified accordingly.

• k.

Iri the sample flowchart, YES f~owpaths e~it from the left hand corners, the bottoms, and th~ ri~ht hand corners of decision symbols.

NO flowpaths exit from the bottoms and from the right hand corners of decision symbols.

Flowcharts should be constructed so that all YES flowpaths exit decision symbols from one specific corner, and so

• that all NO flowpaths exit decision symbols from one other specific corner. This consistency in flowchart design reduces the opportunities for error when operators select a path out of a decision step. The writer's guide should state from which corner of the decis.ion symbol each type

- of flowpath will ~xit. The example flo~chart should be changed accordingly.

l.

• The sample. flowchart contains a flowpath that changes direction unnecessarily (the YES flowpath entering the step

• continue torus temperature control"). The flowchart could be designed in a manner that omitted this turn in the flowpath without changing the log1ca 1 structure of.th.e flowchart.

Any angle in a line undermines the integrity of the line and makes the line harder to follow. The writer's guide should be expanded to include instructions that ensure that ~nnecessary changes of direction will not be made in flowpath lines.

m.

Some of the flowchart steps in the example flowchart.

. include step numbers and some of the flowchart steps do no

.contain step numbers.

The absence of numbers from some

. flowchart steps raises two concerns:

(1) it is n~t clear when *step numbers should be included iri flowchart steps and when they should be omitted from flowchart steps, and (2) if those flowchart steps that do not contain step numbers do not correspond to written procedure steps, then

. it appears that the flowchart does not accurately summarize the written procedure.

The writer' guide should be.

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expanded to state that each flowchart step should contain a step number that reflects the relationship of that flowchart step to the written procedure. The sample flowchart should be revised accordingly.

The sample flowchart contains flow lines that run parallel to each other. If several flow path 11nes run parallel to*

each other, operators may have difficulty following the correct line. The wr;ter's guide should indicate a means by which operators wi 11 be ab le to differentiate between such lines (e.g. sufficient spacing between the lines, different line patterns).

The use of sentence fragments in the sample flowchart makes.it difficult to interpret some of the flowchart statements. For example, one step states, "Emergency RPV

• depressurization required execute DEOP 400-2 concurrently."

.This statement has two possible meanings: {l} "Emergency RPV depressurization is required.

Exe~ute DEOP 400-2 concurrently,... or ( 2) IF emergency RPV depressurization is required THEN execute DEOP 400-2 concurrently.* Because incomplete sentences such as this one can be difficult for operators to understand, the writer's guide should state, and the sample flowchart should be revised to show, that

• complete sentences are requ.ired in flowcharts.

Several steps in the sample flowchart refer to FIG 2-8, which fs not included in the.iriter's guide. The writer's guide contains no guidance for*integrated figures an~

tables with flowcharts.

So that writers have complete

.. information to writer procedures, the writer's guide should discuss the placement of figures and tables with respect to flowcharts.

13. 'cautions provide operators with critical information concerning specific steps or sequences of steps in DEOPs.

Secti9n 2.6, pages.7-8, should be revised in regard to the following topics:

a. *The revised caution statements in Section 2.6, page 7, and in Attachment 1, page 17, contain action steps. Cautions should ~escribe a hazardous condition which can cause

.injury or equipment damage, and should describe the.

consequences of the hazardous condition. Section 2.6.4, page, 8 should state that caution statements will not contain action steps and the examples on pages 7 and 17 should be revised accordingly.

11

• b.

To ensure that cautions are properly written, Section 2.6 should include a definition of cautions.

c.

To ensure that operators easily understand cautions and notes, Section 2.6 shou.ld be revised to state that capitalization will be used for the heading CAUTION or NOTE, but wf 11 not be used to pres~nt the information fn the text of the caution or note.

d.

To ensure that operators can easily understand cautions and notes, Section 2.6 should be revised to state that only one topic will be included in each caution or note.

14. Because of the delays and errors that can result when referencing f s used, referencing should be minimized. Section 2.7, pages 8-9, should include a commitment to minimize the use of referencing. Section 2.7 should also discuss* the criteria to be.used when deciding ff the necessary steps should be included in the text of the procedure or if referencing should be employed. See NUREG-0899, Section *s.2.2, for additional information.

15. Acronyms and abbreviations used in EOPs should be understood easily and used consistently by both procedure preparers and.

operators. So that EOPs can be clearly understood, the writer's guide should be revised in the following manner.

a.

Section 3.4.11, page 13, *should be revised to state that

. each ~bbrevi~t1on and acronym will have only one meaning.

b.

Section 3.4.11 should be revised to state that each meaning will hav~ *only one abbreviation or acronym.

c.

Abbreviations for simple expressions, such as CLO for cold, increase the complexity of procedures. Section 3.4.11, page 13, should be revised to state that abbreviations and acronyms for simple expressions will not be *used, unless they are part of an engraved name.

d.

Examples in the writer's guide.use abbreviations that are not included in Attachment 4, such as uBkr" (Section 2.3, page 6)

"Aux. Elect." and uturb. Bldgu {Section 3.1.4, page 10,, and "Tech. Spec." {Attachment 1, page 15). Only those abbreviations and acronyms included f n an approved list of abbreviations should be used in the DEOPs and in examples in the writer's guide. Section 3.4.11; page 13, should be revised to state that only terms included.in

'Attachment 4 wi 11 be used 1n DEOPs, and Attachment 4 should be expanded to include all necessary abbreviations and acronyms.* Examples in the writer's guide should be changed to include only those abbreviations and acronyms included in Attachment 4.

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16. The correct use of punctuation can significantly increase the understandability of procedures.

The writer's guide does not address punctuation; Section 3.0,page 10-13, should be revised to state that standard American English punctuation will be used consistently, and all examples in the writer's guide should_ be consistent with this. gui~ance.

17.

As stated in Section 3.5, page 13, *capitalization should.be used sparingly because it dec.reases readabi 11ty if app lfed to entire bodies of text. Capitalization should also be used

• sparingly because the overuse of capitalization decreases the effectiveness of capitalization as an emphasis technique.

Additionally, inconsistent use of capitalization can lead to

• operator confusion. For these reasons, the use of capitalization should be precisely defined.

The guidance

. provided in Section 3.5 that 11capital1zat1on can be used to emphasize individuals words or short phrasesu could lead to overuse and inconsistent use of *Capita 11zation in DEOPs *. This use of capitalization should. be deleted from Section 3.5, and Section 3.5 should be revised to state that the use of capitaliiation should be limited to the uses listed in that

• section. Examples in the. writer's guide should. conform to this guida~ce.

~.

18 *. Section 3.3.4~ page 12, *states that aacceptance values should be specified in such a way that addition and subtraction by the user is avoided if possible.a Section 3.3.4~should-b~ revised to state the need to avoid calculations more strongly, and shbuld indicate how operator~ ~ill be assisted in ~aking calculations (by such aids.as forms or decision tables) if calculations are unavoidable. Examples consistent with the

.*text should be pr~vided.

ihe *adequate resolution of the above items will ensure that the Dresden writer*~ guide will accomplish the objectives stated in NUREG-08~~ and.th~t it will provide adequate guidance for

• • translating the technical guidelines into EOPs that will be usable, accurate, complete, readable, conv~nient to use, and acceptable to control room operators..

C.

Verification a~d Validation Program The description of the verification and validation program *was reviewed.to determine if it described acceptable methods for accomp1ishing the objectives stated in *NUREG-0899.

• The verificati~n program determines that consistency has *been maintained between:the 13

wr1t~r's guide, EPGs, and the DEOPs by evaluating each DEOP for written correctness and t.echnical accuracy. The validation program determines that the control room operators can manage emergency conditions in the plant using the OEOPs by evaluating each DEOP for usability and operational correctness. Our review of the Dresden verification and validation program description identified the following concerns:

1.

OSER Item 2.C.1: The verification program s~ould include a specific description of the method by which the verification and validation process accounts for differences between Units 2.

and 3.

2.

OSER Item 2.C.2: Neither the rev1sed verification and validation program desiription nor Attachrrent 2, pages 2~10, discusses the selection of team members in the verification.

. and validation process. -The types of personnel including

• engineers, operations personnel, and human factors experts, and the criteria for selecting these team members should be specif1~d.

3.

OSER Item 2.C.3: Neither the revised verification and

• validation program description nor Attachment 2, pages 2-5, through 2-10, discusses the roles and responsib111t1es of human factors experts in the verification and validation proce~s.

The roles and responsibilities of personnel, including engfheers, operations personnel, and hum*n factors experts, should be specified.

4.a. Sectie>n 3.1 of the validation an.d verification program should be ~xpanded to include a descri~tion of the criteria that will.

be used to.select the scenarios to oe run during the validation and ver1ficat1on process. The criteria should be developed on the bo.sis of what.. is needed to validate the procedures and should ensure that single,* sequ~nt1al, and concurrent -failures are 1ncluded *.

b. A review of the capabilitf~s and the limitations of the simulator will then identify what can _be validated on the simulator. For the parts of the EOPs* that cannot be validated on the simulator, t~e criteria.for selecting any additional

. validation that may' be needed and the methods to be used, such as a contro 1 room walk-through or a mock-up walk-through,. should

• be described. *

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5.

Section 3.1 states that *the validation process will be

• documented by use of a form and any discrepancies will be recorded and resolved accordingly." Section 3.1 should describe the plan, and the forms used in the plan, to correct and revise DEOPs as a result of the validation process.

6.

Section 6.0 states that *all revisions to DEOPs will be

._evaluated to determine if the verification and validation process.must be applied to the revision." Section 6.0 should include the criteria that will be used for determining whether it 1s necessary to revalidate and reverify changes that result from the V+V process.

7.

Section 3.1 should.indicate that the EOPs will be exerci~ed, during simulator exercises or control room walk-throughs, with the minimum control room staff size required by the facility Technical Specif~cations.

8.

Section 3.1 should include a description of the plan by which*

adequacy of control room instrumentation and controls will be determined, and a description of the plan by which correspondence between EOPs and control room instrumentation and controls will be determi~ed.

With adequate resolution of the above items, the Dresden verification and validation program should.accomplish the object1v*e.s stated in NUREG-0899 and should provide assurance. that the EOPs adequately incorporate the-guidance of the writer's guide and the technical g~idelines and will guid~ the operator in mit1gating emergency conditions...

D.

Training Program The description of the operator training program on the Dresden upgraded EOPs was reviewed to determine if it described acceptable methods fo~ accomplishing the objectives stated in NUREG-0899.

The D~esden training program is expected to assure, as a minimum, that*

all licensed personnel have a working knowledge and under~tanding of the DEOPs.

The program describes a sh phase course consisting of*

50 classroom hours ~nd 18 simulator. training hours.

As a resui~ of our ~eview of the revised PGP, the NRC staff has the following* comments.

1.

The training program description should be expanded to indicate _

• that. a 11 EOPs wi 11 be exerc1 sed by a 11 operators on the simul~tor or, for those areas not ~onducive t~ simulator training,* 1n control room walk-throughs.

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2.

The training program description should indicate the use of a wide variety of scenarios, including simultanious and sequential failures, to fully exercise the EOPs on the simulator and in control room walk-throughs, thus exposing the operators to a wide variety of EOP uses.

3.

CONCLUSIONS The staff concludes that the PGP submitted by Conunonwealth Edison Company for Dresden Units 2 and 3 in a letter to the NRC, dated October 30, 1984, and as supplemented in a letter dated December 16, 1988, should be reviewed to a*ddres s the programmatic improvements out 1 i ned in Section 2 of this

• report. A PGP revision should not be submit~ed to the NRC. *For items.the licensee deems inappropriate, no longer applicable, or unnecessary for.

inclusion in its PGP, it should develop and maintain documented justifi-cation in an a~ditable form.

All revisions to the PGP should be reflected in plaht EOPs within a reasonable period of time, ~.g., the next planned*

revision of the EOPs.

Principle Reviewer:

G.W. Lapinsky Dated:

• Ma r c h 1 5, 1 9 9 0 16